On July 31^st U.S. Forest Service Chief Tom Tidwell announced a 30-day extension in the amount of time the public has to comment on groundwater. The National Ground Water Association has expressed its concerns, stating that the Forest Service currently has limited expertise in groundwater and funding that will require staged implementation and priority setting. The involvement of qualified groundwater professionals is critical when groundwater issues are under consideration.

In his letter Tidwell stated that the proposal does not prohibit any uses, and is not an expansion of authority. However, the NFS could fall under other authority such as the Fish and Wildlife Service or BLM, in which case the Forest Service would have to do as they say. He also stated that the proposal would not impose requirements on private landowners. But, the proposal continually uses the terms “on adjacent lands.” This needs clarification, as “on adjacent lands” seems beyond the scope of the directive.

This Proposal has raised serious concerns over potential conflict with Western water law, and contains many discrepancies that must be addressed by qualified groundwater professionals. In a letter dated 6/24/14 to the U.S. Department of Agriculture, the Congressional Western Caucus raised serious concerns over this new Directive. They stated that it would restrict Americans’ access to public land and interfere with state and private water rights. If 43 Representatives and lawmakers are concerned over this Proposal and how it will affect the American people, we the people, should be concerned as well.

Please submit your comments opposing this ill-advised Proposal. It is litigious, and contrary to the public interest.

Comment at http://regulations.gov

Subject line: Forest Service Proposed Directive on Groundwater Resource Management, Forest Service Manual 2560, FS-2014-0001-0001.


Wendy Brown-Barry & Kevin D. Barry,
Mariposa