Draft Tier II Analysis of Forest Practices Board's draft rule

Great thank you. My name is my name is Ranie Haas I am

with the Washington State Tree Fruit Association and I am commenting on behalf

of the Tree Fruit Association. So the Washington state tree fruit association

represents the growers, packers, and mark...↓eters of apples, pears, cherries, and

other tree fruits in Washington state.

As a part of the Ag. industry we pride ourselves on being

stewards and maintainers of maintainers of the land. We believe that the

formation and implementation of rules to address this issue must be science-based

and reasonable without developing new thresholds that are unnecessary. The

agricultural industry is currently discussing options to address riparian habitat

and water quality on agricultural lands.

These discussions focus on the forests and fish agreement

as a template for productive conversation and resolution. How the FPB honors

that agreement will either promote or impede cooperation in other sectors. Secondly

the department of Ecology 's proposed rule is being put forward to demand more

restrictions on forest land even though they are meeting their targets. Demanding

higher benchmarks from one party to compensate for inaction in other areas is

not a good precedent. The departments’ proposed rule is a solution in search of

a problem and forcing it through without thought in regard for the agreed upon

process will cast doubt on dependable partnership. This will likely lead to

more conflict and less progress on salmon recovery.

Furthermore we would like to encourage the FPB to push

the pause button on this rule and restore integrity to science-based policy

making thank you for the opportunity to comment we will also be making a

written comments prior to the August 18th deadline.

Thank you.

Hello this is Ken Miller Washington, Farm Forestry Association.

When the governed don't have understanding or buy in they

logically conclude this is simply about bureaucratic power with no connection

to solving any real problems.

No resource, functional ...↓problems, or even alleged in the

NP current NP proposal. I do acknowledge a lot of personal confidence in Chris

Briggs and his appreciate his hand in trying to at least partially correct the

overreach of earlier Tier 2 analysis.

I'm also sympathetic to the Forest practice board member

David Bowen having inherited an issue made much worse than it should have been

by the previous Ecology folks. You must find a way to backtrack if only to

salvage some credibility for DOE.

Tier II language is complicated and bureaucratic but the

issues are simple. The draft NP rule was limited by and now acknowledged to

have been developed under false instructions to the expert panel and the Forest

Practice Board members, exposing DOE and the Forest Practice Board to

malpractice at the minimum without at least a do over.

The CMER science isn't new or unexpected nor

unanticipated in the federal HCP biological opinion where some limited

temporary warming was expected.

DOE was intimately involved in supportive of the 1987 TFW

agreement, through at least the HCP process where everyone at the table was

compromising and as necessary and in overriding public interest in a shared

risk paradigm. The only change appears to be a change of heart by at least the

previous administration at Ecology.

Ecology once had all TFW policy caucuses supporting

efforts to provide more NP shade, a consensus that likely won't survive

hardliner interpretations of Tier II.

The most important question Ecology should be asking is

will alienating or betraying forest and fish partners help or hurt long term

goals to better protect cool water.

The old older and larger small forest land-owners are now

considering the legacy of their forest lands. They are increasingly deciding

they have had it enough with this one-way street purporting to be a

collaborative and balanced goal called forest and fish.

Reject this flawed analysis that is ultimately

counterproductive to the Ecology interests and a betrayal of forest and fish. Thank

you.

Yeah this Ken Miller just a process deal for those of us

that don't do this regularly and even those that do this regularly it would

have been helpful if you'd spelled out the ground rules of the time limits and

that kind of stuff well before the meeting.

Kind of threw me for a loop I had like almost 4 minutes

and had to cut it short and.

Thea:

Would you like to use more time now?

Ken:

No I had to I I scattered that but just for the future

suggestion for the future.

Thank you for the opportunity to comment. Darin Cramer,

Washington Forest Protection Association.

I'd like to highlight a few key technical issues in the

Tier II analysis. First, the analysis misrepresents and omits critical findings

from the CMER hard r...↓ock and soft rock studies while the report emphasizes

better thermal performance for the 100% buffers, it fails to mention that other

buffer treatments often performed similarly. In both studies some of the

coolest post harvest sites have partial buffers and performed similarly to the

reference sites. And more than 90% of temperature observations across all

treatments in both studies were well below the designated use aquatic life

temperature criteria of 16 degrees Celsius.

Second, the method of counting all temperature increases

greater than 0.5 degrees Celsius as equal is highly misleading, failing to

reflect ecological relevance. Additionally, first year post harvest temperature

responses in both studies did not have any relationship with canopy closure,

percent of channel width buffer or total buffer length. This suggests stream

temperature response and NP streams is more complex than with buffer length and

width alone and the analysis does not at all reflect that complexity.

Third, the Tier II analysis draws inappropriate

conclusions about the influence of sites specific variables that were not

directly manipulated in the studies. These studies allow inference about

average treatment effects across very specific conditions not causation from

untested variables.

Fourth, the analysis overreaches by applying study

results to the broader area of landscape, the broader landscape, without

scientific justification.

Both studies were limited in geographic and ecological scope

and findings cannot be generalized to all managed forests in Western

Washington.

2 independent assessments found that less than 2% of

routine harvest activities in Western Washington matched the treatments

implemented in the hard rock study.

Finally, the analysis attempts to predict future

responses using narrative matching of physical features rather than established

predictive tools. For example, there was no consistent relationship between

canopy cover and temperature change above 70% shade. And yet the report

recommends changes to buffer rules based on canopy metrics alone. And the

claims of about downstream benefits and 303d listings are speculative and

unsupported with any data.

In summary the technical components of the Tier II

analysis dropped conclusions not supported by the science it cites. It omits

relevant data, misinterprets scope of inference, and relies on very weak

prediction methods.

We urge the Department of Ecology to abandon this

misguided effort and refocus on finding science based collaborative solutions

for NP streams in Western Washington which balance environmental and economic

benefits.

Thank you again for the opportunity to comment.

I'm Dr. Elaine Oneil executive director of the Washington

Farm Forestry Association, representing small forest landowners across the

state. I'm going to say this thing has been a bit of a boondoggle since the

beginning when Mark Hicks first brought it t...↓o the adaptive management program

somewhere around 2018, 2019. At the time we argued that no measurable change—that

that is the 0.3 degrees centigrade limit—was inconsistent with the forest and

fish 8 CP which specifically allowed for temperature change in NP streams and

it was also likely—unlikely to be biologically significant. But Ecology

persevered.

There was a lot of argument in the adaptive management

program, there were a lot of fighting went going on there were some

grandstanding at the Forest Practices Board and et cetera et cetera and we are

where we are today.

It was only in May that we found out that in fact this

0.3 degrees centigrade limit was in fact just a a goal and not a limit as

Mister Briggs put forth in May. But, we also found out that it was inconsistent

with Tier II water allowances under the Clean Water Act where the limit is the

goal for cold water which is 16 degrees.

So we're going to I'm going to say there's been a

complete inconsistency in how and why this Tier II analysis came into being. That

said we're here now and I want to challenge the veracity and conclusions of the

NP rule cost benefit analysis that you're using in this and in your Tier II

analysis. We're especially concerned about how benefits supposedly accrue to

the state as a whole, but the costs are borne by poverty-stricken census tracts

in our rural counties. This doesn't seem to comport with the HEAL act

requirements at all.

I want to talk a little bit about the cost benefit

analysis using willingness to pay to estimate its benefit. That's a standard

method used in economic analysis and it's used to create a numeric values for

ecosystem services where there is no market so that you can calculate a cost

benefit ratio and figure out if it's better than what it the due benefits

exceed the costs.

Using the NP rule willingness to pay values provided in

that cost benefit analysis and their low-cost estimate shows in fact that cost

exceed benefits not the other way around. Even based on their faulty analysis

using low quality irrelevant data from regions with no similarity to our West

Coast forest.

Better data exists for costs and benefits. Independent

analysis by U dub shows the costs are absolutely astronomical. 200,000 acres

4.1 billion board feet 2.3 billion in immediate loss of asset value 250 million

dollar increase in FREP liabilities and a $90 million reduction in forced

excise tax to counties. A 6 billion dollar economic hit to our rural economy.

I wanna talk about the real costs and benefits. We had an

independent analysis done by U Dub. Much larger costs, 2.3 billion in immediate

lost asset value, plus some of these other numbers that people have talked

about, the 6 billion in economic hit to the rural economies, 5 to 8 billion.

That's twice the upper cost estimate of the cost benefit

analysis that you're relying on. Now we actually have excellent data on payment

for ecosystem services that better represents our forest. That's our Forest Riparian

Easement Program. Over the past 25 years FREP has paid--that's FREP we call

that FREP— has paid for a portion of the timber required to be left standing to

support ecosystem services inherit and buffers on eligible small forest land

owners’ forested lands. The program has dispersed an average of 1.6 million per

year of state appropriated funds and so that accurately represents what our

state citizens are willing to pay for ecosystem services these riparian buffers

provide and we know that because they don't just give it to us, we have to

lobby for it, especially when times are lean so if you take that 204 thousand

acres removed by the rule, if you're harvesting it on a 40-year rotation that

would be 320 bucks an acre, 50 year rotation it's 400 bucks an acre, compare

that to the almost $8900.00 per acre of current timber value. So your real data

shows that your ecosystem service benefit, the value of that it's generating—the

ratio would be about 0.03 or 0.04. In other words 96 to 97% of the purported benefit

is either qualitative or fake. So we have a cost benefit analysis that has so

many problems associated with it, the primary one being that they assert

benefits exceed costs and there's no way that that can be justified or

verified. So I'm going to say giving us overwhelmingly bad cost benefit

analysis ratio, what overriding public interest are we serving by advancing

this rule towards implementation? I think that's a core question that needs to

be answered in this Tier II analysis should you redo it. And I will be

submitting a more detailed comments for the record. Thank you so much.

Thanks, I'm Court Stanley, I'm representing Washington State

Association and Counties. And I was part of I am part of policy that went

through the negotiations on this regulation and just a little bit of background

on it that you know the rock studies t...↓hat when they came out they were good they’re

 BACI studies, they have limitations but

it's good science. And counties along with the rest of the caucuses agreed that

action needed to be taken. So after the NP Work group we entered negotiations

in policy. Counties put out a proposal that was never given any traction. Ecology

was hesitant to accept it. Industry was a bit late getting in their proposal

but was talked about and I don't remember if Westside tribes ever put a

proposal together.

Through negotiations we finally agreed that we would not

reach agreement and it ended up with majority minority prescriptions and

counties decided to side with the minority even though both all caucuses agreed

on scenario 2.

As we all know that the board voted only to bring

majority forward to CR 102. And I think it was based on the NP groups

negotiating team that they were based on the constraint that buffers could not

exceed 0.3 degrees. It was a limit. This kicked out a bunch of several creative

solutions to the problem because of the assumption of water temperature that

weren't tested. And additionally, the costs and benefits for each of the

alternatives were never considered during negotiations. That's a huge flaw. And

after going through training with structured decision making and policy,

economics have to be a part of each alternative before they're brought to

decision makers.

So going forward the counties would propose that we need

to give this back to a group of experts, policy experts, appointed by the Forest

Practices Board through the adaptive management program with guidance from

stream scientists. But we go through with the assumption or with the agreement

the 0.3 degrees is a trigger, not a limit and we balance the impact to rural

communities land-owners with the benefits to fish and water quality.

We have 4 months before the November meeting. In my

wildest dream I think we could accomplish it but we need to start down that

path and we need to continue to go on adaptive management where we pick the

lowest cost alternative to achieve our benefits and monitor them and adapt as

we go forward so thank you.

I'm Jason Williams I'm president of the IMW 130. I have

about 300 members of the woodworker of Warehouser. I'm a 3rd generation logger

myself so I'm still out in the woods.

This would deeply affect all the all my members and their

families, the communiti...↓es and everything else around here. Ecology inflated its

role in the Forest Practice Board process. The board, not Ecology, decided what

rules and purposes for review.

Valuable science based on analysts, based analyst or

dismissed way for the public was able to see, like my RD report. Ecology ignored

laws requiring at least burdensome alternatives and missed alternatives of the anti

deg authority.

The rule could cost the rural Washington up to 8,000,000

over the forest rotation, harming jobs, tax revenue and the working forest. Ecology

ignored smart smarter, less costly options that would still protect water

quality.

The economy analysts failed to account for the impact and

small land-owners as myself, and use inflation assumption to justify and

perform outcome. The entire process is divided or driven by politics, and not

science or law. That's pretty much it, so that's all I have.

Thank you for my time.

I'm Steve Stigar, I'm 3rd generation woodworker. I work

at the warehouse Raymond Sawmill.

There's right at 200 employees there. Warehouser is one

of the largest employers in the Pacific county.

Ecology keeps changing its rules. Its first claim any

stream ...↓warmer warming over 0.3 degrees Celsius violated water quality law, then

allowed warming under its preferred NP buffer rule proposal. Under long

standing law force practice rules already meet Tier 2 through the adaptive

management program, AMP, which was designed to evolve rules based on science.

Now Ecology is claiming that adaptive management program (AMP)

recommendations are new or expanded action that requires a full-blown Tier 2

reviewal, contradicting past practice and law.

AMP shows AMP’s own studies show the existing NP buffers

results in stream temperature similar to the reference sites on in most cases. Ecology

cherry-picked worst case temperature readings while ignoring evidence that

stream temperatures stayed below the legal limit 90% of the time.

Forest Practice Board was steered towards a single

outcome by Ecology. Science based alternatives from the AMP were blocked. Ecology’s

shifting standards, flawed analysis, and dismissive treatment of science and

economic harm have undermined trust and legality.

Yeah this this would be very very detrimental to all the

little communities out there.

But that's all I have and thank you for your time.

Thank you for the opportunity to speak with you today and

provide comments on the tier— Tier II analysis. I agree. I’m a forester with 50

years experience involved in the adaptive management program for the last 25

and I agree with much much of what has...↓ been said today, and will be submitting

written comments as well as public testimony.

Essentially I think the forest practices board should

reject the Ecology’s Tier II analysis and the proposed NP rule, and restart the

process and look more broadly across the landscape instead of the limited study

size that was used for the hard rock and soft rock studies.

Thanks again for the opportunity to comment.

I am Ann Stinson a second-generation small forest

landowner in Lewis County. I'm also the President of the Washington Farm Forestry

Association. As Ken Miller said the Tier II analysis is complex and complicated

so I'm going to tell a simple story.

My br...↓other Steve Stinson had a bumper sticker that

indicated he was a steward of a family forest. One day he was stopped in a

traffic jam on I-5. Someone rolled down their window and yelled ‘what's the

family forest?’ and he yelled back after a brief pause and said ‘a family

forest is a salmon 's best friend’.

And it's true.

A lovingly managed forest is a forest that provides shade,

cool water, habitat, and carbon absorbing biodegradable timber is what we need

to be protecting not harming. Thank you.

Yeah my name is Doug Hooks and I'm speaking on behalf of

WFPA representing forest land owners, managing approximately 4,000,000 acres

across our state. I'm here to express serious concerns about Ecology 's

handling the Tier II antidegradation analysis a...↓nd its role in the proposed NP

forest rule making.

First, Ecology’s interpretation of antideg Tier II

requirements has been inconsistent and appears to shift to support a

predetermined outcome. Tier II applies only to streams that meet water quality

standards with new or expanded actions that measurably change water quality. The

proposed rule is neither new nor expanded according to the definition of WAC

173-201A-020, and should not have been triggered to begin with.

Further Ecology told the adaptive management program the Forest

Practices Board that a 0.3 measurable temperature change was a water quality

violation. Now Ecology admits it's not. This has been problematic in a couple

of ways. First, the hard and soft rock studies were designed to test the

effectiveness of the rules to meet the resource objectives of meeting

designated criteria standards, not antideg and thus the study wasn't designed

to test that level of warming.

Second the NP subgroup of policy was directed to only

provide proposals that prevented warming and greatly limited proposals that

would also meet designated criteria but have a much less significant economic

impact.

Antideg is a standard—is not a standard, it's a policy. It's

even a different WACs than the standards that guides that analysis. The Forest Practice

rules as a water quality control program already meet Tier II requirements

through the adaptive management program. Ecology shifting interpretation of

Tier II lacks legal foundation that undermines the forest and fish process.

Secondly, Ecology has overstepped its legal authority.

RCW 90.4 8.420 subsection one directs Ecology to allow reasonable short term

forest practice impacts yet Ecology impose rigid standards that dismissed

viable alternatives without adequate analysis or public input. The Forest Practices

Board, not Ecology, has the authority to develop rules. Ecology’s overreach

threatens the collaborative structure intended by statute.

Additionally, Ecology has already completed their

analysis to these proposals as noted today and already made their determination.

The Tier II analysis is supposed to be conducted publicly with the development

of proposals and their analysis to be done publicly, which begs the question of

what Ecology will do in response to any comments received today.

Third, the proposed rule imposes massive economic burdens,

an estimated one billion or more lost timber of value and up to 8 billion in

regional impacts and the first harvest rotation without clear evidence of

environmental benefit. The economic analysis by EC is deeply flawed with wide

uncertainty, key emissions and mischaracterized costs and benefits reliance

upon it for the Ecology’s overriding public interest analysis will lead to

extremely inaccurate determination of cost and benefits. This violates the APA,

which requires selection of least burdensome alternative, as noted by type NP Subgroup

of policy there are a number of proposals that will continue to meet designated

water quality, as well as lessen the impact for potential warming that would

have a substantially lower impact.

Ecology’s process lacked transparency, fairness, and

scientific longevity objectivity/ Alternatives that reduce risks were excluded

early. The analysis considered only Ecology’s favorite option in a strong man

100-foot buffer ignoring the APA statutory requirements for full alternatives

analysis.

In conclusion this process is being driven by policy

preference rather than science or law. The current rules already meet or exceed

temperature standards and the vast majority of cases.

Expanding buffers now without clear need or legal

justification imposes massive costs and minimal gain and undermines trust in

science based collaborative rule making and sends a clear message to other land

uses that may be considering the collaborative programmatic approach similar to

program that forestry has.

We understand Ecology—we urge Ecology to abandon this misguided

posture and return to an objective lawful and collaborative approach which

balances environmental and economic benefits.

Thank you.

Thank you for the opportunity. For the record my name is

John Gold.

Your presentation this afternoon was breathtaking. It

sounds so rational, but it reminds me of the aphorism about the forest and the

trees.

I'm a professional forester with Sierria Pacifi...↓c Industries.

Seirra Pacific is a vertically integrated company in the forest sector. We own

over 300,000 acres of forest land in Western Washington, which would be subject

to the proposed rule and our 4 sawmills in Washington rely on the sustainable

harvest of timber from a variety of other private and public lands.

We are strong believers in the resource protections

Washington adopted with the forest and fish law, the HCP which affirms it, and

the adaptive management program which ensures that science is the basis for any

rule changes.

Alas, the proposed NP buffer rule published in the CR-102

and assessed in your draft Tier II analysis does not uphold that commitment. There

are several shortcomings in the rural development and analysis which we believe

need to be addressed.

First, the public record is clear that Ecology directed

the adaptive management program to develop a rule which prevented any

measurable temperature change purportedly because the state water quality

standards mandated that. The Ecology representative to the Forest Practices Board

blocked consideration or analysis of any alternative rule approach.

Yet now, the draft Tier II analysis states the opposite,

that 0.3 degrees is not only allowable but just like the current rule, the

proposed rule will result in temperature increases sometimes in some places. The

correct standard must be articulated and a range of solutions must be developed

and analyzed in a proper analysis.

Second, the rule as written is onerous. It will incur an

enormous societal cost for minimal if any ecological benefit. It strikes the

wrong balance. The context that the current rule results in waters exceeding

the numeric designated use criteria for salmonids is inexplicably missing from

your analysis and must be corrected. The actual impact on beneficial uses must

be considered.

Third, it is unclear why Ecology has determined a Tier II

analysis is required since there is no new action here. The draft analysis

should be revised to explain the new or expanded action.

We will be submitting written comments to supplement this

testimony and I thank you for your time.

Thank you, my name is Cindy Mitchell, the Chief Financial

Officer of the Washington Forest Protection Association. I've been through

decades of rulemakings, timber fish wildlife in the 80s, northern spotted owl

in the 90s, forest and fish in 2000s and n...↓ow the NP rule and accompanying Tier II

analysis. I'm here to tell you how Ecology’s interpretation of the Tier II has

shifted dramatically.

First, in 2003, Ecology stated in its formal response to

comments quote ‘the purpose of Tier 2 ensures that any degradation to water is

better than standards is necessary and in the public interest not to stop all

activities that would lower water quality’ quote. The forest practices rules in

2001 are captured under the general water pollution control program in the

antidegradation program and went through a Tier II analysis as a newer expanded

action at the time.

Second, in a memo written by an Ecology and Water Quality

Program Manager Melissa Gildersleeve on November 1^st 2022 following

an internal antidegradation meeting she's described the majority proposal quote

‘designed to not allow incremental warming up to numeric criteria, we will rely

on the data that shows 75 foot buffers work and allow sending in the outer 25

feet to make it more workable. We do not have science to support this but we

will use it to determine overriding public interest’ quote. It is not clear

whether we will meet the 0.03 measurable allowance we will need to write up

this information on why we did this.

Third, in 2025 Ecology is now treating 0.03 measurable

change as a strict cap excluding alternatives preempting public opinion,

preempting public input, and undermining the process in their own WAC 173-201-A320.

This interpretation stems from a 2018 legal settlement with the Northwest Environmental

Advocates, but when Ecology sought EPA approval for a norm warming limit, EPA

rejected it, affirming that the goal is to protect the numeric criteria of 16

degrees. That standard is being met. You saw Chris Briggs 's presentation over

14 years of adaptive management research shows average post harvest stream

temperature remain at 12.2 degrees in hard rock, 14.8 in soft rock. Further Ecology

uses the photo of a pristine fish stream in the Olympic National Park to

promote a rule that targets small-non fish bearing streams on private land. That

is not just misleading, it erodes public trust.

It's time to follow a colleges own rules and EPA 's and

stop manipulating the process. Thank you.

Sure won't have to be that long I'm super glad that

Bonnie brought that up because.

Sure so my name is Cindy Mitchell, I'm with the

Washington Forest Protection Association. I've been here for more than 30 years

and I've seen rulemakings and I've seen balance processes, which is the goal of

WFPA 's to have balance forest practices I'm super glad Bonnie wrote— brought

up the idea of not harvesting the entire watershed. Because it's a misnomer to

think that what was in the hard rock study replicates reality. In reality you

have land owners that use the NP buffer and there's no fish, the buffers are up

to 200 feet per fish stream so you can be assured that they're not the 75 foot

NP buffer. But they use the boundary to harvest by one side of the stream so

there's constantly trees growing all around the watershed. If there was a case

that 85 or 100% of the watershed was ever harvested like that and it would be a

very rare case, then 100 or 75 foot 100% buffer in other words, not, it would

be it be continuous, would be part of the rule. So I'm glad you brought it up

to clarify that what's in the research is not what's in reality. In fact when

they look through 36,000 actual forest practices applications they could only

find 17 that actually met the criteria. So as my colleague Darren Kramer said

earlier the types of conditions that were in the study occur maybe you know

1.4% of the time and the safety factor is to put a continuous 75-foot buffer on

the streams. Now we just up in Cedro Woolly and I understand those streams go

underground and they're dry for a mile. So they're often underground and

there's no water on the surface. So the idea that we can't have flexibility in

the buffers to manage the upper watershed is just really nonsensical and we do

want to manage our forests because if we don't then well we're looking at smoke

in the sky right now from the Cushman fire, Hama Hama fire, we've got a fire

down in the gorge and those are trees that that have too much brush in them.

So managing our forests is really important and the

forest and fish law which was blessed by the US Fish and Wildlife service, NOAA,

National Oceanic administrative atmospheric administration, Environmental

Protection Agency at the time, and it's a 50 year plan and so aborting that 50

year plan for something that is so not lacks common sense is really that

something to take a look at again. Thank you for the opportunity to testify one

more time.

My comments will be brief. I'm Ed Chadd, I'm a citizen of

Clallam County.

And I just want to point out that every speaker we'd

heard has an economic interest connected with the timber industry with the

exception of the first speaker who's with the True F...↓ruit Association and I find

that to be of interest.

I also believe that one needs to take that into account

when considering all of the comments that we've heard and I'm not saying that

one should discount them but just that that's something that needs to be taken

into account. I do plan to submit some written comments later thank you.

Hello, my name is Bonnie Blessing-Earl. You could call me

a second generation timber worker because my dad had 2 lumber mills in the

1980s and he was fine economically until there was a glut of timber on the

market and until they changed the scaling rul...↓es and a whole bunch of mills went

out of business in the early 80s. I don't know why but it wasn't

environmentally, he kept saying that.

But anyways I appreciate that that Ecology did this Tier II

analysis because I think there's a lot of benefits to keeping at least a 75-foot

buffer. I'm surprised it's that small don't we need more than 75 feet to

protect the microclimate, to protect from stream flow changes? I live in that

area that's just above a salmon bearing stream. And above us it's like they

have this tiny buffer and we have this debris torrent from a rain on snow event

that really like, like can we really harvest that much of a watershed that's

bigger than 30 acres and not have salmon problems downstream? I don't

understand how we can possibly harvest that much of a watershed guys really,

and protect the salmon that's downstream. Our steelhead, they’re going practically

extinct over on the coast. Can you please keep at least a 75 foot buffer? I

also as part of a technician job I found Vandyke salamanders in in riparian

zones of hard rock areas in big logs like 20 meters out from the stream they

really need a moist microclimate down in there. And when it comes to economics

I'm kind of curious because like our it's our— the revenue generated from

hunting and fishing and outdoor recreation is huge and in 2022 9 billion, maybe

during COVID, was spent on hunting, fishing, and wildlife recreation in

Washington generating a ton of money to tax revenues in the general fund.

Shouldn't we protect those opportunities? Elk and deer

and bear do need proximity to like forest and like the large clear cuts with a

tiny buffer really don't protect a lot of our hunting, fishing, and outdoor

recreation opportunities and aesthetics it kills people man, it just. Sorry it

it it's really hard aesthetically for people and then there's fish and

intermittent streams that need these big logs that are in there that come from

300 feet out where's this 75-feet, we need at least 100 feet how can we get

along with just 75 feet? There's a whole lot of reasons to keep at least 75

feet. Thank you very much.