Laserfiche WebLink
Comments of the Platte River Project on the <br />Platte River Recovery Implementation Program DEIS <br />"The available data suggest that water yields from other national forests in Colorado also <br />have declined." [Lee H. MacDonald and John D. Stednick, Forests and Water: A State- of -the- <br />Art Review for Colorado, p. 40 (MacDonald /Stednick Report) (2003)]. These forests would <br />include the Roosevelt and Pike National Forests, which include lands in the South Platte River <br />basin. The causes of the "overall increase in forest density and/or forest cover in Colorado' are <br />"varied." "[F]ire suppression has clearly played a role, and another likely cause is a reduction in <br />forest harvest for timber, fuel, and other products." [Id. at 36, 38; see also Final Environmental <br />Impact Statement to accompany the 1997 Arapaho and Roosevelt National Forest Revised Land <br />and Resource Management Plan App. A, p. 53 (ARNF Plan FEIS) ( "We believe that the density <br />of forest vegetation has increased throughout this century. The primary cause seems to be from <br />successful fire suppression, rather than from lack of timber harvest. Nevertheless, allowable sale <br />quantities have declined over the near term, from 30 million board feet (MMBF) in the 1984 <br />Plan to 6.7 MMBF in the Revised Forest Plan ")]. <br />"An increase or decrease in the density of the vegetation cover — as indexed by basal area <br />or leaf area — will have a corresponding effect on runoff," so that increased forest density <br />decreases May and June water flows. [MacDonald /Stednick Report, p. 8]. The DEIS describes in <br />detail how the lack of flows during this period harms the species. [DEIS, pp. 2 -7 to 2 -10, 3 -11 to <br />3 -15]. <br />DEIS Chapter 2 (and related sections) do not accurately describe all chief sources of <br />declining historical river flows in the Basin that affect the species, and should be revised <br />accordingly. <br />B. DEIS Chapter 5: Analysis of Cumulative Effects /Preservation of <br />Hydrologic Baseline; Plan for New Federal Depletions on Land <br />Managed by USDA Forest Service. <br />The Governance Committee created pursuant to the Cooperative Agreement "established <br />1997 conditions as the baseline for assessing changes in riverflows and other key resources." <br />[DEIS, p. 1 -19]. In order to achieve recovery program objectives, each state, and the federal <br />government, committed "to track and offset effects of new and expanded (post -July 1, 1997) <br />water related activities that would cause depletions to species and annual pulse flow targets (see <br />the Governance Committee Program Document)." [DEIS, p. 3 -19]. <br />In its analysis of the potential cumulative effects of events occurring outside the Proposed <br />Program, the DEIS notes: "If activities outside the Program were to diminish flows at critical <br />times of the year, flow improvements created by the Program could be undermined." [DEIS, p. 5- <br />271 ]. The DEIS continues: <br />-13- <br />