Watershed scoping section for Brumley grazing allotment EA

[Lance Christie]

I contributed this section to a comprehensive scoping document being prepared by the Three Forests Coalition for the Brumley grazing allotment Environmental Assessment. -Lance

March 23, 2009

TO:              Mary O’Brien, Wayne Hoskisson, Kevin Mueller, William E. Love, Season

                 Martin, John Carter, and Jim Catlin

FROM:   Richard Lance Christie, Grand County Water Planning Administrator

RE:              Watershed/sole source aquifer section for scoping comments on Brumley

                 Grazing Allotment Environmental Assessment

The recharge area for the pristine groundwater aquifer which resides in the Glen Canyon Group of sandstones uplifted by the Manti La Sal laccolithic intrusion was designated a Sole Source Aquifer recharge area by the United States Environmental Protection Agency in the January 7, 2002, Federal Register, volume 67 #4, pages 736-738.  All of the Brumley grazing allotment lies within this designated recharge area except for the easternmost part of the Geyser Pass unit which drains into the Dark Canyon watershed.

This Sole Source Aquifer constitutes the culinary water supply for the City of Moab and for the customers of the Spanish Valley Water and Sewer Improvement District south of the City of Moab Municipal limits in Spanish Valley.  A total of some 8,000 permanent residents and over a million tourists a year are served by these two culinary water systems.  The total water budget for the Sole Source Aquifer is unknown.  Research findings on quantity and chemical constituents in groundwater reaching the Colorado River at the Matheson Preserve by Dr. Kip Solomon of the University of Utah suggest that the City of Moab and Spanish Valley water retailers may be diverting close to the maximum amount which can be drawn from the Sole Source Aquifer without damaging it.  A definitive U.S.G.S. study of the Sole Source Aquifer has been designed, and was authorized but is not yet funded under the Water Resources Act of 2008.  Absent having a definitive determination by the U.S.G.S. as to how much water can be diverted from the Sole Source Aquifer, from what locations, for culinary supply, we must prudently operate on the assumption that the amount of water currently authorized by the Utah Division of Water Resources for diversion from the Sole Source Aquifer is the total amount divertable.  Both the City of Moab and Spanish Valley Water and Sewer Improvement District have water conservation plans in place in order to meet culinary needs within current withdrawals from the Sole Source Aquifer, e.g., the Spanish Valley system is installing a secondary water system to meet outside watering needs with untreated, surface-diverted water.

In order to maintain current levels of diversion of water from the Sole Source Aquifer to meet culinary demands, the aquifer must maintain historic rates of recharge. 

Designation of a Sole Source Aquifer subjects significant federal actions within the aquifer recharge area by other agencies to review by the U.S. EPA.  Such review of actions which may damage the aquifer may result in prohibiting the proposed significant federal action, mitigating it to prevent damage to the aquifer when this is possible, or a determination that the significant federal action does not pose a threat to the Sole Source Aquifer and may proceed as proposed.

Historically, U.S. EPA reviews of proposed significant federal actions have focused on risk of contamination of a Sole Source Aquifer, not rates of recharge to it.  However, we now have the new consideration of changes in precipitation regimes due to climate change from increased levels of greenhouse gases in Earth’s atmosphere.  According to the U.S.G.S., the Southeastern Utah region will become slighly drier under predicted change conditions, but the major change predicted is in the nature of the precipitation that falls.  Less of total annual precipitation is predicted to be in the form of snow, and less in the form of gentle rains, both of which tend to maximize the amount of precipitation moisture that percolates through the vadose zone into the aquifer in its recharge area.  Instead, a larger percentage of annual precipitation will come in the form of brief, intense rains during storms.  To maintain aquifer recharge at or near historic rates, a solid vegetative cover must be restored to and maintained on the aquifer recharge area so that the velocity of falling raindrops is broken by striking standing vegetation or litter, and the resulting droplets which reach the surface are retained in contact with the soil by a maze of vegetable matter - micro-berms of soil held by plant roots, crowns, and litter - which prevents accelerated runoff.

Thus, the dominant economic value of the U.S. Forest Service-administered lands within the EPA-designated Sole Source Aquifer recharge area is its value as watershed.  Multiple-use management of these lands by the USFS should be keyed to restoration and management of the aquifer recharge area lands to maximize their hydrological function as watershed recharging the Sole Source Aquifer.  Timber harvest, domestic livestock grazing, mineral and oil and gas exploration and production, and recreation uses are not automatically precluded from these lands, but must be allowed only under such conditions as are compatible with restoration and maintenance of hydrologic function of the Sole Source Aquifer recharge area.  If management of a use such as domestic livestock grazing has as its objective the mitigation of that use’s potential negative effects on the hydrologic function of the aquifer, and monitoring shows that management is not successful in mitigating negative effects, then the terms of management of the use must be modified until they are successful in mitigating hydrological function degradation from the use, or the incompatible use must cease.  The Sole Source Aquifer and its recharge area is fixed in place geologically. Grazing, oil and gas exploration, motorized recreation, et al, can occur in many places on the Manti La Sal National Forest, and any economic benefit to local economies from them is minor by comparison to the value of the pristine groundwater culinary supply provided by the Sole Source Aquifer.

We therefore submit that the central scoping issue for the Brumley grazing allotment Environmental Assessment is: how is domestic livestock grazing to be managed and monitored in a USFS management program the prime objective of which is restoration and maintenance of the hydrologic function of the recharge area of the Sole Source Aquifer?

Technical Reference 1734-6 was designed to be the guidebook for rangeland health management for both the USFS and BLM.  It is a detailed manual on how to measure range conditions that maximize hydrologic function of a watershed, with monitoring being done by non-technical personnel such as volunteers, ranch hands, et al.  According to Interpreting Indicators of Rangeland Health, range conditions which maximize precipitation capture due to vegetative cover characteristics serve as the best overall indicator of rangeland ecological integrity.  Thus, the monitoring protocols described in T.R. 1734-6 serve to evaluate rangeland condition whether one’s concern is hydrologic function of the watershed, species diversity, wildlife habitat, or forage biomass productivity.

We are aware of numerous case studies in which domestic cattle were used in successful programs of restoration of western rangelands, both BLM and USFS-managed, in such states as Wyoming, Colorado, and New Mexico.  The party in charge of these restoration efforts in most cases was a private rancher with ecological values serving sound economic sense (in all case studies, forage carrying capacity of the restored rangeland doubled in terms of sustainable AUM yield and the nutritive value of forage improved).  Descriptions of some of these efforts are contained in Nathan F. Sayre’s The New Ranch Handbook: A Guide to Restoring Western Rangelands, and on the Internet under the ManyOne Network’s Earth Restoration Portal in Aspect Two, Plank Two, Chapter Two of the “Renewable Deal” blueprint for ecological restoration of the North American Continent’s ecosystems with a sustainable, non-polluting, renewables-based human civilization on it.

All successful rangeland ecological restoration efforts by ranchers involved active, intelligent management of domestic livestock: brief, intensive grazing in defined paddocks with water sources in each, with the cattle being moved when measure of forage consumed reached pre-determined benchmarks; placement of the cattle in a given paddock at different times during different grazing seasons to avoid repeated grazing pressure on the same forage species and/or to allow certain forage species to go to seed before grazing; and rotating rest of paddocks from grazing in a given year according to the restoration plan or as a consequence of condition, e.g., due to drought.

We do not know if a USFS allottee for the Brumley allotment is willing or capable of undertaking such active restoration management.  If not, then the allotment should be withdrawn from domestic livestock grazing as a watershed protection preserve.