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activities or forest fires -4600 acre -feet per year and 922 acre -feet per year, respectively. [2003 <br />Troendle Report, p. 13 -14]. As noted by the consultants, however, such accretions will fail to <br />offset the increasing depletions that will occur as forest density increases on the National Forests <br />during the same period. [2003 Troendle Report Executive Summary]. Moreover, these increases <br />are "substantially below the 37,000 acre -feet of water per year that [the same consultants <br />previously] had estimated could be generated, in the same time frame, by implementing a <br />program to place the nearly one -half million acres of NFS land classified as Suitable for Timber <br />Harvest in the North Platte Basin on a 120 year management rotation." [2003 Troendle Report, p. <br />13]. This latter option is discussed in more detail below; here it suffices to state that, to date, the <br />Forest Service has failed to acknowledge, much less propose mitigation for, the significant <br />additional net water depletions that its own consultants project will occur from its land <br />management activities during the first Program increment, as required by Milestone W9 -EXT. <br />This should be disclosed in the EIS. <br />C. Forest Management as Program Water Supply Alternative. <br />As described elsewhere in these comments, the PRP supports the Proposed Program, <br />including its water action plan. In the event that public comments or other factors should prompt <br />the EIS team to consider reexamining the water elements of the Program or its alternatives, the <br />PRP wishes to identify several issues related to one previously discarded water element, forest <br />management, that may also warrant reexamination. <br />As noted in the Screening Report attached to the DEIS, the EIS investigated the likely <br />results of forest management through an independent analysis headed by an accomplished forest <br />hydrologist formerly with the Forest Service. [DEIS at Attachment -30 (citing 2000 Troendle <br />Report)]. That analysis found: <br />In order for increased runoff from the National Forest to lead to improved Central <br />Platte River flows for the target species, some fraction of the additional flows <br />must be captured and allocated to the Recovery Program. The most likely means <br />for this is capture and storage in a Federally operated reservoir. Due to the <br />number of Federal reservoirs on the North Platte, as well as their relative <br />proximity to the North Platte headwaters, it appears that focusing this study on the <br />North Platte forests is a good test of the viability of this concept .... <br />Water yield from NFS lands on the North Platte is in general quite high because of the <br />high precipitation input. Although the percentage of forest land Suitable for Timber <br />Harvest is less than 50 percent of the total NFS lands, sizable increases in flow appear <br />feasible using the 120 -year rotation and appropriate silvicultural techniques for each <br />forest type with lodgepole pine and spruce -fir being the most prevalent. Simulations <br />indicate that water yield can be increased by 37, 000 acre-feet per year by 2015 with a <br />gradual increase through the rotation to sustainable 50 – 55, 000 acre-feet of water per <br />year. <br />-17- <br />