5 May 1998
Interior Columbia Basin Ecosystem Management Project
112 East Poplar Street
Walla Walla, WA 99362
Dear EIS Team:
The Oregon Chapter of the American Fisheries Society (ORAFS) appreciates the opportunity to comment on the Eastside Draft Environmental Impact Statement of the Interior Columbia Basin Eastside Management Plan. ORAFS is a volunteer organization of professionals in fisheries and aquatic sciences. We have over 500 members in Oregon, representing a diverse mix of scientists in federal, state, and tribal agencies, and in the private sector and higher education. One goal of our Chapter is to promote the application of sound science to resource management decisions. The Oregon Chapter supports effective stewardship and conservation to maintain healthy ecosystems and recover degraded ecosystems for wild fish populations.
We strongly support the need for a scientifically based management plan for the interior Columbia Basin. Such an approach was taken by the drafters of the Interior Columbia Basin Eastside Management Plan (ICBEMP) when they prepared the science assessment to serve as the basis for developing and evaluating the USDA Forest Service and USDI Bureau of Land Management’s (1997) Eastside Draft Environmental Impact Statement (EDEIS). We understand that there will likely be some instances where the policy decisions that are made may not follow directly from the science assessment (e.g., the selection of the alternatives, standards and guidelines). In those cases, inconsistencies between the assessment and the EDEIS need to be clearly identified, the effects on aquatic and other resources analyzed, and a rationale provided for the management direction that spells out the logic and justification for overriding the course of action supported by the scientific information.
After consideration of the relative strengths and weaknesses of the proposed alternatives, we believe the final alternative that would best meet the purpose and need of ICBEMP would be a hybrid of alternatives 6 and 7. The combination of these alternatives would protect existing core areas of strong populations, of intact habitat, and of fringe populations. This combination would also allow active restoration of degraded habitat through adaptive management in a way that would reduce risk and lead to refinement of restoration techniques.
Enclosed is a more comprehensive review that we provide you for consideration during your continuing efforts to formulate a management plan for the eastside Columbia Basin. We commend the whole team for their efforts to date, and we hope it has been and continues to be a rewarding experience for all.
Hal Weeks, Ph.D. Patrick J. Connolly, Ph.D.
President Chair, Aquatic Habitat Committee for the Executive Committee
cc: Steve Kozel, ICBEMP
Danny Lee, Rocky Mt. Research Station,
Jim Sedell, PNW Forest Sciences Lab
Gino Luchetti, President, AFS N.Pacific Chapter
Peter Bisson, President, AFS Western Division.
Paul Brouha, Exec. Dir, AFS