Vegetative Management Impacts and the Platte

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-2- Issue 1 The first issue is the easier one. The FWS has included the following language: "Because new depletions are defined as involving new or expanded uses of water in the basin, hydrologic changes that result solely from restoring land cover to more natural, pre-development conditions will not be considered depletions in the context of this Plan. For example, unless the applicable state depletion plan provides otherwise for comparable non-federal projects, restoration of a site to pre- development wetland conditions will not result in new depletion replacement obligations, except to the extent that the proj ect creates new wetlands where none existed prior to site development, or expands water losses relative to those associated with the original site wetland conditions." There is a real fear that this language could be used in the future to ignore substantial depletions that might occur on National Wildlife Refuges and the Forest Service lands. The Forest Service has assured us that this language was only included to cover the work going on at Rocky Flats, and we have asked that the Federal depletions plan so note that limitation explicitly, so this loophole does not become bigger. The FWS has not yet agreed to this and it may be the subject of future discussions. Issue 2 The Federal depletions plan describes future depletions by the Forest Service in the following manner: This document does not address the impacts, including channel stability, of past and future vegetation management by the U.S. Forest Service (USFS) in the Platte River basin, as this issue is addressed in a separate document (U.S. Forest Service's Vegetation Management Plan", Appendix A). Turning to the U.S. Forest Service Vegetative Management Plan, it is not a plan to address the impacts, but rather is a"list of excuses" (as characterized by Jim Witwer) of why the Forest Service vegetative management plan does not cause depletions, and if the vegetative actions do cause depletions a list of excuses as to why the Forest Service should not be responsible for covering the depletions (they are so small, they are difficult to measure, and they would likely be immeasurable in Nebraska). The Forest Service defends its position in the following manner. They argue that they are not participating in the Program. They argue that they will undergo, and have undergone, Section 7 consultations associated with revisions and updates to their Forest Management Plans. They also argue that there is natural variability of water yield from the forests, tied primarily to precipitation, but tied in part to the fact that as trees grow they use more water. They argue that they should not be responsible for a reduction in the amount of water coming off a forest, because their actions only increase yield (allowing a cut ar initiating a natural fire). The Forest Service Vegetative Management Plan also states: "Models estimating changes in forest size class and water yield from forested lands in the Platte River Basin show a cyclical trend in water yield on a 100 - 150 year cycle (Troendle and Nankervis, 2000, Troendle et. al, 2003). Water yields in the North Platte basin were at their last historic peak in 1860 - 1900. Since approximately 1900, there has been a gradual decline in stream flows in the North Platte basin which are currently at or approaching historic minimums. The magnitude of the change is highly dependant on the data and the modeling Flood Protection • Water Project Planning and Finance • Stream and Lake Protection Water Supply Protection 9 Conservation Planiung