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Senator Bennett Johnston 

 March 2, 1990 

 Page 3 



information is needed to identify additional protective measures for hazardous areas and to 

 identify the upstream boundaries of the 30-meter zone (see policy exceptions in par 5, pg 7), 

 the NMFS policy is not as simple as it appears. 



Dr. Brooks states "Protection of i m p or t a nt anadromous streams would be far less 

 compromised by lack of expertise, inadequate data," etc. (par 2, pg 8). This as sump tion is 

 just the opposite of what could occur if the NMFS policy is adopted. Catastrophic damages 

 to habitat are more likely to occur if experts are not employed and site specific data are not 

 collected. Management by an interdisciplinary team of trained professionals is essential, 

 regardless of which riparian management prescription is adopted. 



Finally, Dr. Brooks states the NMFS policy would "provide an enforceable standard" and 

 that the policy "should encourage compliance by managers and industry" (par 2, pg 8). If the 

 NMFS policy includes site specific exceptions as indicated above, then quality control checks 

 will require the same level erf detail rnformation required by the Forest Service. If the NMFS 

 policy does not include site specific exceptions, then quality control checks will be easier. 

 Although, the latter may encourage compliance, it may also encourage the taking of timber 

 from areas with hazardous soils unless site specific plans are required and enforced. 



The bottom line is resource management in a multiple-use forest is a complex task and 

 requires trained professionals. The Forest Service recognizes this need and has designed a 

 program to optimize production of all resources without compromising fish habitat and 

 salmonid production. 



Sincerely, 



Pentec Environmental, Inc. 



Donglas J. Martin, PhD. 



DJM/lml 

 Enclosure 

 cc: B. NorcToss 

 D. Finney 



