422 



Pentec 



March 2, 1990 



Senate Energy and Natural Resources Committee 

 364 Dhksen Senate Office Building 

 Washington, D.C. 20510 



Attention: Senator Bennett Johnston 



State of Dr. James Brooks, NMFS 

 Fgfrny y 36. 1990 Hey inp ; On Tongass National Forest 



Dear Senator Johnston: 



I have reviewed the statement of Dr. James Brooks that was presented to you on 

 February 26, 1990, at the subcorrrmitiee hearing on the Tongass National Forest The purpose 

 of my review was to evaluate the effectiveness of the NMFS buffer policy for protection of 

 fish habitat and to assess the factual nature of information, which Dr. Brooks states is the 

 basis for this policy. I am a fisheries biologist with expertise in salmorrid ecology and have 

 significant experience concerning the effects of logging on fish habitat (see attached resume). 



Dr. Brooks states "The NMFS policy advocates the use of a minimum 30-meter buffer on 

 each side of all salmon streams a"d their tributaries as a recommended method of curtailing 

 both short-term and long-term de trim ental impacts on fish habitat from timber harvest" 

 (paragraph 2, page 6). He also states "NMFS established the 30-meter minimum because 

 buffers less than 30-meter$ will not adequately maintain fish habitat" (par 2, pg 6). Research 

 by NMFS and others has demonstrated that buffer strips (no cut zones) riparian management 

 zones (selective harvest zone), or both, are effective methods of protecting fish habitat. The 

 size, type, and location of these habitat protection measures are dependent on stream size, 

 channel geomorphic type, and the presence or absence of fish. For example, research has 

 shown that the size of large woody debris (LWD) in streams is inversely related to stream 

 size. The size of timber that should be retained along streams for LWD input can be 

 specified to match the size requirement of the stream. A small stream does not require the 

 largest trees for LWD dependent habitat. Also, smaller streams have less hydraulic capacity 

 to erode their banks than a larger stream, thus channel stability can be maintained by smaller 

 riparian trees and by a narrower strip of riparian timber than required along a larger stream. 



120 West Dayton, Suite A7 • Edmonds, Washington 98020 • Telephone: (206) 775-0602 • Fax: (206) 778-9417 



