Marcus Griswold, Water Resources Scientist, San Francisco
Recently, the US Forest Service released a “Directive” which would guide how groundwater is managed by the agency. They are currently accepting comments from the public on that Directive and now is the time to weigh in to ensure public groundwater resources are protected.
In a previous blog, I highlighted the importance of high quality, abundant groundwater from National Forests and the threats it faces. Proper groundwater management on our National Forests would help maintain a clean source of drinking water and a sustainable supply of water to keep forests healthy, wetlands wet, and streams flowing. The Directive is the first comprehensive set of guidance from the Forest Service on groundwater resources – a very important step, in itself. But in order to ensure that National Forests protect and provide clean water into the future, the Directive must be strengthened to improve the proposed framework and properly address growing threats such as energy development. With these improvements, the Forest Service can lead the way in sustainable groundwater management policy.
We applaud the Forest Service for recognizing that there are serious problems with current management of water resources on National Forests and Grasslands and for developing a policy meant to provide consistent management. However, as worded, the Directive could potentially allow for unsustainable use of public groundwater resources. NRDC expects the Forest Service to protect our public waters, as do a number of other conservation groups, as explained in a recent letter we sent to U.S. Department of Agriculture’s Secretary Vilsack and the Forest Service’s Chief Tidwell.
Here’s how we believe the Forest Service can and should improve the Directive. Take a moment to tell the Forest Service to protect your water by strengthening the Groundwater Directive. You can send an email with your comments here by September 3rd.
What can be done to improve the Forest Service’s proposed groundwater policy?
This policy is not just about science and data, but about protecting the drinking water of more than 60 million Americans, as well as fisheries that support our economy, and spring and rivers for recreation. These lands support rural water users and downstream communities, and in the long run reduce the need for new sources of water and the associated costs to treat it. These benefits will only accrue if the Forest Service takes a holistic approach to groundwater management as outlined below.
- Develop a comprehensive groundwater management plan to assess baseline groundwater levels, aquifer characteristics, potentially threatened groundwater dependent ecosystems, and groundwater quality on all National Forest lands.
- Adopt key sustainable groundwater use policies, including a no-net depletion policy, a ban on the use of non-renewable “fossil” groundwater (which takes hundreds or thousands of years to recharge), and restrictions on the use of water in basins where groundwater dependent systems are at risk.
- Develop groundwater standards that ensure 1) sufficient groundwater is discharged to perennial and ephemeral streams and wetlands to support aquatic life and downstream drinking water needs; 2) land disturbance does not impact groundwater recharge areas; and 3) groundwater dependent ecosystems are not impacted by decreasing groundwater quality or quantity.
- Develop a scientifically robust, comprehensive monitoring program that addresses long term impacts, including climate change and drought preparedness.
- Implement mitigation that reaches beyond water volume depletion and includes restoring riparian vegetation, surface water temperature and flows, and water quality that have been adversely affected by groundwater depletion.
Groundwater dependent ecosystems and aquifers should be protected from adverse impacts of mineral extraction and energy development
Minerals and energy development can have substantial impacts on surface and groundwater resources. Just take a look at some of our previous posts on this issue here and here.
The Forest Service is proposing to provide less protection for groundwater resources from mineral and energy development than for any other activity, requiring less detailed assessments and reductions in monitoring and mitigation. On this issue, the Forest Service has it backwards. Mineral and energy development poses some of the greatest risks to aquifers and groundwater dependent resources – extracting large quantities of water for mining and energy development and spewing out chemicals once the process begins.
Public water resources should be protected from these risks. Just as for other activities, the Directive must ensure that the impacts of all mineral and energy development activities on national forests and grasslands are assessed before surface use is approved and that protection and mitigation minimizes the impacts of these activities on groundwater and associated resources and ecosystems.
Forest planning should incorporate principles of sustainable groundwater management
To effectively protect groundwater resources and their associated surface waters, the Forest Service should delineate groundwater protection areas and specific stipulations that will apply for any proposed activity and embed these into the planning process for National Forests. This would ensure that groundwater management is not just an afterthought, but is incorporated into forest management from the outset.
To be successful, the Forest Service needs to ensure adequate funding is allocated to the development of appropriate assessment, monitoring, and mitigation tools and to the actual enforcement of the review process and substantive standards provided in the Directive. The Forest Service must ensure both that policies are enforceable but also enforced.
The Forest Service is one of the first federal agencies to develop an agency-wide policy on groundwater management. We hope to see other agencies follow suit as groundwater sources become an increasingly important source of water. Implementing agency-wide policies can have particularly strong benefits to both educate staff and to help remove interdepartmental silos, and should be sought as a first step, but may not provide the same benefits as regulations.
Please contact the Forest Service to thank them for developing a Groundwater Directive and ask that they strengthen the proposal to ensure public groundwater resources are protected. You can email them here.
