Report on Water Yeild from Forest Management Letter

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Without storage in the immediate vicinity, any water reaching the stream as a result of timber harvest is lost to the system. Troendle 2000, p. 3. Because the water that timber management produces arrives during spring runofF, it will be unusable unless it is captured and stored for later release and use. While there are some reservoirs in the upper North Platte basin, there is no evidence that they are located correctly-or would have space available- to capture water produced during runoff by timber management at the landscape level for later release to the downstream endangered species. The endangered species in Nebraska won't benefit from any water that mi ng t be produced. Even if the water produced from timber harvesting were available below national forest lands-which Troendle states is unlikely-the endangered species living miles downstream on the Platte River in Nebraska will not benefit from that water. This is so due to a combination of state water law factors. Just as a starting point, it is hard to conceive of a way that the Bureau could claim a water right for the produced water. The Bureau would face several obstacles, including the fact that there would be no diversion of this water in Nebraska, and no use in Wyoming. Without a water right, there would be no way for the States of Wyoming and Nebraska to administer the water legitimately within their respective prior appropriations systems. There would thus be no way to require senior water users on the Platte and North Platte Rivers between where the water was produced and the Big Bend reach to forego diverting the water for their decreed uses. As a result, from a purely institutional perspective, it would be virtually impossible to deliver water produced by logging in the Upper North Platte River basin off federal lands, across a state border for hundreds of miles, at the time when needed to b;.nefit the endangered species. (2) The environmental impacts of pursuing this strategy are severe. Unfortunately, Troendle's literature survey includes no review of the large number of studies that report on the environmental impacts, of clear cuts, partial cuts or other timber management. Fortunately, another recent analysis examines many of these studies. Rhodes and Purser 1998. As set out below, studies of timber management activities strongly suggest that the adverse environmental impacts from widespread logging for water would be significant Logging over one million acres of land in an attempt to produce water hundreds of miles downstream is certainly a major federal action in its own right, subject to NEPA; thus the Forest Service would have to analyze the significant environmental impacts associated with this strategy (and consider alternatives with fewer environmental effects). Certainly given that the water produced would almost certainly NOT meet the need for which the project is being undertaken-delivering water to fish-it is unlikely that it could survive NEPA review. This strategy would also need to comply with the Forest Service's responsibilities under FI,PMA and NFMA. Given the strategy's significant adverse environmental effects, it is highly unlikely that the Forest Service could ultimately find that the strategy was consistent with its statutory responsibilities. While the Forest Service does have an obligation to conserve threatened and endangered species under section 7 of the Endangered Species Act,