423 



Senator Bennett Johnston 

 March 2, 1990 

 Page 2 



Streams which do not have anadromous fish and are tributary to anadromous fish streams do 

 not req uir e riparian retention measures equal to streams with anadromous fish. The objective 

 of riparian management along non-fish streams is to protect water quality for downstream fish 

 hahitat Research indicates that riparian timber retention methods and retention widths 

 necessary to maintain habitat are dependent on the stream in question and that measures other 

 than the NMFS policy can adequately maintain fish habitat 



Dr. Brooks indicated that streams need a continuous supply of LWD and that the level of 

 LWD in a stream will be reduced to 70 percent over 90 years if timber is logged down to the 

 streambanks (par 2, pg 4). Because of this, be states "Stream productivity would also be 

 reduced during the period of regeneration and canopy closure. It is our opinion that, as a 

 consequence, habitat and salmonid abundance would be significantly and irreparably damaged 

 over this period of logging and recovery" (par 1. pg 5). This statement is misleading and 

 untrue, given the current Forest Service riparian management policy and current knowledge. 

 The Forest Service policy requires timber retention for LWD input, thus timber would not 

 be completely cut to the streambank. Stream productivity can either increase or decrease after 

 logging, depending on the degree of canopy opening and physical impacts to the channel. 

 Forest Service guidelines are designed to promote the positive benefits and to prevent the 

 negative consequences. Also, harvest units along a stream are logged on a staggered pattern 

 and at different times to minimize potential negative impacts. Any impact that may occur to 

 fish habitat and salmonid abundance is temporary and will recover. I am not aware of any 

 research mat demonstrates or proposes that impacts from logging are irreparable. Even the 

 eruption of Mount St. Helens, which I investigated, did not cause irreparable damage. Habitat 

 damages can be significant or catastrophic, but not irreparable. The Forest Service policy is 

 designed to prevent logging from having significant or catastrophic impacts on fish habitat. 



Dr. Brooks states "The NOAA policy would provide reliable protection of fish habitat 

 during and after harvest" (par 2, pg 8). This I would agree with, but this or any policy is not 

 a guarantee of habitat protection. Reliability of the NMFS policy is also dependent on 

 application of additional measures needed to prevent catastrophic damages (e.g., landslides). 

 The NMFS policy recognizes this and indicates that buffers wider than 30 meters may be 

 needed in some situations (par 2, pg 6). But this requirement is contradictory to Dr. Brooks 

 statement that "The policy Is relatively simple to apply" (par 2, pg 8). If site specific 



