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Of greater import are the significant water depletions that the Forest Service itself <br />projects will occur during the first Program increment from increased forest density on land it <br />manages. The general requirement to manage new (post -1997) depletions under the Program <br />stems from the 1997 Cooperative Agreement, as amended in 2000. In particular, Milestone W9- <br />EXT of the December 15, 2000 Extension of the Cooperative Agreement provides: <br />W9 -EXT. The FWS will work with the U.S. Forest Service (USFS) and the states <br />to develop a new depletion plan for USFS lands in the Platte River Basin. This <br />will include establishing a baseline against which the impacts, including channel <br />stability, of past and future vegetation management will be measured. By <br />September 1, 2001, the FWS and/or USFS will work with the states to identify <br />what types of water related activities will be covered and the FWS and/or USFS <br />will determine what will be covered by the plan for new depletions. By <br />September 1, 2001, the FWS and/or USFS will conduct an analysis of potential <br />effects the plan may have on pulse flow frequency and magnitude. <br />The Draft Platte River Recovery Implementation Program document, dated December 22, 2003, <br />attached a Federal Depletions Plan that expressly did not address the Forest Service vegetation <br />management impacts as called for in the agreement milestone just quoted. Instead, the Forest <br />Service produced a separate document, to become Appendix A to the Federal Depletions Plan, <br />dated January 8, 2004 and entitled "USDA Forest Service Vegetation Management Plan" (the <br />VM Plan). <br />The VM Plan inadequately addresses the impacts of past and future vegetation <br />management on National Forest lands as called for in the agreement milestone. Such impacts are <br />"new water - related activities" as defined in footnote 3 of the December 22, 2003 Draft Platte <br />River Recovery Implementation Program document prepared for the Governance Committee (see <br />also DEIS at 1 -13 n. 14); they are "new surface water or hydrologically connected groundwater <br />activities including both new projects and expansion of existing projects, both those subject to <br />and not subject to section 7(a)(2) of the ESA, which may affect the quantity or timing of water <br />reaching the associated habitats and which are implemented after July 1, 1997." <br />To include the specific identification and mitigation of these impacts was the clear intent <br />of Milestone W9 -EXT. Instead, the VM Plan simply states: "Vegetation management actions <br />are not depletions, so these activities are not included in the Federal Depletions Plan. Historic <br />(pre 1997) depletions for all consumptive uses of water on National Forest System lands in the <br />Platte River Basin, including activities initiated by the Forest Service and activities initiated by <br />Water yield from 1997 -2001 harvest levels on all Forests in the North Platte basin, when projected <br />into the future, are [sic] expected to only partially offset decreases in streamflow as a result of <br />increased stand density in the next couple decades [citing 2003 Troendle Report]. Vegetation <br />manipulation under most alternatives in the Forest Plan may increase the offset in water yield, but <br />is unlikely to offset the projected decreases in streamflow in the next 30 -50 year period. <br />-15- <br />