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<br />Page 7 <br />White River National Forest Management Plan Comments <br />February 18,2000 <br /> <br />to designate a watershed protection area within a five mile radius from their raw water <br />intake. Several municipalities have made these designations which include areas within the <br />WRNF. This correction should be noted. <br /> <br />~ The "Water Quality" section on page 3-41 appears to be a typographical error. The <br />paragraphs in this subsection also appear above in the "Surface Waters" section and on the <br />next page where "Water Quality" is repeated. <br /> <br />~ The "Water Quality" (page 3-41) and the "Environmental Consequences" (page 3-52) <br />sections refer to sedimentation concerns of permitted activities, yet fail to acknowledge the <br />beneficial effects of water storage on downstream turbidity. (Also page 3-63.) And <br />inexplicably, the contribution of Colorado Department of Transportation winter sand and <br />gravel applications warrants only a passing mention in the entire document at page 3-231. <br /> <br />~ The plan commits the WRNF to "factor in state-listed stream segments during planning and <br />implementation of projects to avoid further water quality degradation" on 303( d) listed <br />stream segments. The plan should go further. Many of these segments are listed because <br />of uncontrolled drainage from abandoned mines, many of which are located on NF lands. <br />OtherTMDL limited segments are listed because of sedimentation from highly erodible soils <br />also located within the WRNF. Accordingly, the WRNF should commit in the plan to <br />working with the state and other affected entities to address the causes and TMDL <br />remediation efforts regarding 303(d) listed streams. (A similar commitment is appropriate <br />at page 3-51 under "Future Trends" with respect to erodible lands.) <br /> <br />~ Page 3-51 states, "Water rights held by the Forest will become important in meeting <br />management goals such as maintaining adequate stream-flows for healthy riparian areas and <br />developing recreation sites." What water rights does the USFS own for "maintaining <br />adequate stream-flows"? We are not aware of any such rights. To what is this referring? <br />(Similarly, Appendix J (page J-7) refers to instream water rights held by the Forest Service.) <br /> <br />~ Is the statement on negligible ("not measurably detectable") water yields (page 3-53) from <br />timber harvests consistent with the history and data from Colorado's companion water and <br />timber yield studies at the Fraser Experimental Forest? . <br /> <br />~ The plan states, "the potential for adverse impacts to water resources from vegetation <br />