KEY AND COMMON QUESTIONS AND ANSWERS PROPOSED GROUNDWATER DIRECTIVE FSM Overview of the Directive s Purpose

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1 KEY AND COMMON QUESTIONS AND ANSWERS PROPOSED GROUNDWATER DIRECTIVE FSM 2560 Overview of the Directive s Purpose 1. Why is the Forest Service proposing the groundwater directive? Water availability and quality are a concern across the country for ecosystem viability and for human use. National Forest System lands provide sources of drinking water for an estimated 60 million people in 32 states and Puerto Rico. To appropriately manage the watersheds on National Forest System lands, the Forest Service needs to account for and address all of the water resources on those lands as a single hydrologic system, consistent with the current scientific understanding. The hydrologic system includes the continuous movement of water on, above and below the surface of the Earth and can be represented by the water cycle. The agency manages the headwaters and recharge areas of locally and regionally important rivers and aquifers. In most places, streamflow and associated ecosystems are sustained during dry periods by the discharge of groundwater. There is a clear need for the Forest Service, in continued cooperation with the states and tribes, to take an active role in comprehensively managing the human activities that potentially affect water resources on National Forest System lands. Effective ecosystem management of National Forest System lands requires taking a comprehensive view of watersheds and water resources on those lands. Through comments on specific proposed Forest Service decisions and through other avenues, the public has increasingly indicated that they expect the Forest Service to review and address potential impacts to groundwater resources as part of the analysis it performs to support its decisions and actions. At least one court decision has already affirmed that the Forest Service has this responsibility. Cooperative management of activities that have the potential to affect groundwater resources by the Forest Service, tribes, and state agencies will benefit the American public with more dependable, higher-quality water supplies for human uses and protection of aquatic and riparian ecosystems. The proposed directive would provide a systematic framework and consistent approach to evaluate new proposals and their effects on groundwater resources on the national forests and grasslands. It would emphasize the importance of identifying and characterizing these groundwater and groundwater-dependent resources and existing uses, monitoring and protecting those resources, and accounting for those uses during planning and approval. 2. What are the objectives and expected outcomes of the proposed groundwater directive? The proposed directive would establish goals and clarify responsibilities for consistently considering potential effect of activities to groundwater resources at each level of the Forest Service. The proposed directive also would provide clear direction for evaluating proposed Forest Service activities and special uses that could affect groundwater resources on National Forest System lands and provide for measurement and monitoring of major groundwater withdrawals.

2 The Forest Service expects that implementing the proposed directive would raise the level of awareness of the importance of groundwater resources for National Forest System lands. These actions would provide management consistency across the agency regarding proposed agency activities and special uses that potentially impact groundwater resources. The directive would assist with developing an inventory of the groundwater-dependent ecosystems on National Forest System lands. Further, through this proposed directive, the Forest Service could better respond to changing conditions (such as drought, climate change, land use changes, needs for additional water supplies) in an informed manner, while sustaining the health and productivity of National Forest System lands and meeting new demands in a responsible way. 3. What is the Forest Service s role in sustaining groundwater resources? Congress has directed the Forest Service to consider effects to water resources on National Forest System lands, and protect those water resources, through a variety of statutes. These include administering National Forest System lands to secure favorable conditions of water flow (Organic Administration Act of 1897), for navigable stream protection (Weeks Law of 1911), and to mitigate floods, conserve surface and subsurface moisture, and protect watersheds (Bankhead-Jones Act of 1935). The 2012 Forest Planning Rule (see FR p , Vol. 77, No, 68 / Monday, April 9, 2012, Sect 219.8(a)(2)) recognizes this responsibility by directing that Forest Service plans are to include plan components, including standards or guidelines, to maintain or restore: (iv) Water resources in the plan area, including ground water. The Forest Service recognizes that many of its activities, and authorized activities on National Forest System lands, have the potential to affect groundwater resources that are critical to maintaining healthy watersheds. By restoring and maintaining healthy ecosystems and watersheds, the Forest Service sustains the infiltration capacity of forest and grassland soils, thereby sustaining the associated groundwater systems as well as connected surface water bodies, dependent ecosystems, and other groundwater users. In addition, under its special uses authority, the Forest Service regulates proposed uses to minimize adverse effects to National Forest System natural resources. 4. What does the proposed groundwater directive mean by management of groundwater resources? Management of groundwater resources in the proposed directive refers to assessing how Forest Service decisions and activities may affect groundwater resources, and taking steps to ensure those decisions and activities minimize negative impacts to those resources. Groundwater is considered within the broader context of all resources on National Forest System lands and their interactions as they relate to Forest Service responsibilities. It does not mean the Forest Service is to perform the types of management activities that states perform with respect to allocation of water. The Forest Service recognizes and specifically acknowledges the role of states in the proposed directive. The Forest Service functions as both a proprietor and sovereign owner of federal land by carrying out the directives of Congress in administration and management of National Forest System lands. The Forest Service continues to respect state authorities for allocation of water use, and protection of water quality. Although the term manage groundwater is used frequently in the directive, we specifically mean to inventory and evaluate

3 data and to monitor the effects of Forest Service approved activities with a potential to impact groundwater resources on the national forests and grasslands. The proposed directive in no way was intended to suggest that the Forest Service will become involved in the allocation or appropriation of water for use. Rather, the proposed directives apply to Forest Service actions to engage in, authorize, or regulate activities on National Forest System lands that have the potential to affect groundwater resources. 5. Would the proposed groundwater directive give the Forest Service any new authorities? No. The proposed directive simply clarifies that the existing authorities mandating agency protection of water resources on National Forest System lands includes groundwater. There are some additional procedural requirements in the proposed directive, including establishing procedures for reviewing new proposals for activities that affect groundwater on National Forest System lands, inclusion of a re-opener clause in groundwater-related authorizations to address the uncertainty in assessing impacts, requiring the evaluation of potential impacts to groundwater from authorized activities on National Forest System lands, and providing for measurement and reporting of substantial impacts to groundwater. Relationships with States and Tribes and Their Authorities 6. How would the proposed groundwater directive affect states, territories, and tribes? In the proposed directive, the Forest Service explicitly recognizes the important role that states and tribes play in managing water resources, including groundwater. The Forest Service would continue to work cooperatively with states and tribes to ensure that resources on national forests and grasslands are managed appropriately to meet legal mandates and the needs of the public. One of the key provisions of the proposed directive is to foster cooperative, collaborative, and mutually beneficial working relationships with the states and tribes concerning activities that affect groundwater on National Forest System lands. 7. What would cooperatively managing groundwater with states mean in practice? The Forest Service recognizes that states have specific authorities with respect to the allocation of water use, including groundwater. The Forest Service, as a federal land management agency, has an obligation to ensure its decisions and activities comply with applicable federal and state laws. The proposed directive does not change that relationship, and the phrase groundwater resource management as used in the directive does not presume to change any existing authorities or responsibilities. The Forest Service will engage and work with states within this framework to ensure that agency decisions and activities meet the state groundwater resource objectives, as well as achieve Forest Service objectives for management of National Forest System lands.

4 8. Would the proposed groundwater directive change the way state water quality regulations or tribal water quality standards are promulgated or administered? No. The intent of the proposed directive is to clarify our existing authorities and responsibilities; a directive cannot create new authority. Federal and state water regulations and water quality standards pertaining to groundwater would continue to be applicable. Likewise, there would be no change in the process for setting tribal water quality standards through EPA. 9. How will the proposed groundwater directive influence cleanup decisions regarding contamination from hazardous material spills? This proposed directive does not change any of the requirements for management or cleanup of hazardous materials or any associated contamination. Agency procedures are covered by applicable federal and state law and separate agency direction. The proposed directive simply clarifies applicability for groundwater. 10. Will there be an increase in regulatory responsibilities for states and water users? The proposed directive does not create any new regulatory responsibilities or change existing responsibilities for states or water users. The proposed directives create some additional requirements for the Forest Service in the way it administers its authorizations for use of National Forest System lands for water facilities under the terms and conditions of a special use authorization. However, the Forest Service anticipates that this would only apply to a fraction of most groundwater users on National Forest System lands. In most cases, there would be no additional terms and conditions beyond those that might otherwise have been required. A number of the requirements in the proposed directive, such as for a water conservation plan, are restated from existing Forest Service directives to clarify their applicability to groundwater, and are not new. 11. How would this proposed groundwater directive affect state-issued water rights or tribal water rights settlements? The Forest Service recognizes the importance of state-managed water allocation procedures, and the proposed directive does not affect those procedures in any way or impose any new requirements on holders of state-issued water rights. Likewise, the proposed directive does not affect existing or future tribal water rights settlements. 12. Would the proposed groundwater directive affect water compacts or water rights settlements negotiated between a state or tribe and the federal government? No. The proposed directive will not affect the provisions of water compacts or settlements.

5 13. How would the proposed groundwater directive affect special use permits to use National Forest System land for surface water facilities? The proposed directive does not affect special use permits for surface water use facilities. It applies specifically to protection of groundwater. 14. The proposed directive assumes that groundwater and surface water are hydrologically connected, unless demonstrated otherwise. What is this assumption of interconnectivity based on, and would this give the Forest Service the authority to grant or deny water rights related to groundwater or surface water? The assumption that groundwater and surface water are connected is based on the welldeveloped scientific understanding that they commonly behave as a single system in most settings. 1 As noted in the directive, the Forest Service recognizes that this will not always be the case. The assumption that that the two systems are interconnected allows the Forest Service to better ensure that analysis of a situation recognizes critical connections between the two should there be no site-specific information to suggest otherwise. This is consistent with the approach taken by many states, such as Colorado. However, the final approach in each case will be based upon the specifics of that situation. The proposed directive does not change the existing authority of the states to allocate water, and has no bearing on state law presumptions for purpose of use allocation. 15. Under the proposed groundwater directive would the Forest Service be regulating or otherwise asserting authority over activities that occur off National Forest System lands? No. 16. The proposed directive requires Forest Service managers to assert federal reserved water rights to groundwater. What is the basis for this requirement and how would it affect existing state water right procedures, including adjudications? The Forest Service has existing policy requiring agency managers to assert federal reserved water rights for administrative uses necessary to carry out the agency s land management responsibilities. Those uses include administrative offices, pack stock, and firefighting. The proposed directive simply restates this policy to clarify that the source of water for those uses includes groundwater. 1 See Ground Water and Surface Water: A Single Resource, USGS Circular 1139, 1998 (

6 Minerals Activities 17. How would the proposed groundwater directive affect the way oil and gas development and mining are permitted and administered on national forests and grasslands? No new regulations or requirements are proposed for locatable, leasable, geothermal, or mineral material operations. These mineral categories include oil and gas, coal, phosphate, and hardrock minerals. The proposed directive outlines existing groundwater protection strategies that should be considered in the permitting of these mineral operations on National Forest System land by the Forest Service. The Forest Service has existing procedures for approving or authorizing certain mineral operations on National Forest System lands. The proposed directive clarifies how the Forest Service plans to consider potential effects to groundwater when it is approving or authorizing mineral operations so it can be more systematic and predictable for applicants, tribes, state and local agencies, other users of water in the area, and the public. 18. How would the proposed groundwater directive affect the way hydraulic fracturing for oil and gas development is managed on national forests and grasslands? Hydraulic fracturing has been used to enhance recovery of oil and gas from traditional sources on National Forest System lands for decades. Hydraulic fracturing to recover oil and gas from shale and other tight rock formations has many of the same potential impacts as other methods of oil and gas development. A key difference between hydraulic fracturing for development of shale (and other tight oil and gas source rocks) and that for traditional oil and gas development is the need for large volumes of water. The proposed directive will require a detailed assessment of alternative water sources and potential impacts to groundwater prior to authorization by the Forest Service. 19. What is an example of permitting and administering of oil and gas development on national forests and grasslands under the proposed groundwater directive? No new requirements are proposed for oil and gas operations. The proposed directive simply outlines established groundwater protection strategies to improve awareness and understanding. For example, the Forest Service would work with appropriate state agencies or the Environmental Protection Agency (EPA) to make sure that all holders of authorizations for minerals or energy development appropriately address compliance with the EPA s Underground Injection Control Program or the state equivalent to protect underground sources of drinking water. The Forest Service would also work with the Bureau of Land Management to assure adequate protection of groundwater as part of federal mineral leasing decisions.

7 Non-Minerals Permitting 20. What would be the anticipated impacts, if any, to special use permitted activities, such as recreation activities or utility electric line routine maintenance? The proposed directive will have little or no impact on most authorized activities on national forests and grasslands, including special uses. The proposed directive does not require a different standard for adequate assessment of groundwater effects for administrative activities or special uses. In many cases, a simple consideration of the nature of the activity will indicate that significant impacts to groundwater resources are unlikely. For example, it is unlikely a recreational trail would require a groundwater resource analysis unless the proposed trail route might impact a groundwater-dependent ecosystem. Another instance where some groundwater resource evaluation would be merited is for the installation of a water supply well for a campground. A special use permitted activity that involved groundwater withdrawal or subsurface injection above the limit specified in the proposed directive might be subject to terms and conditions to protect resources and monitor the withdrawal or injection. For other special use permitted activities, the proposed directive specifies that potential impacts to groundwater be considered, to the extent relevant, but does not impose any requirements in those cases. 21. Would the proposed groundwater directive require changes to any existing authorizations or permits? No. The proposed directive would only apply to new or renewed permits and authorizations, not already excluded elsewhere in the directive, and only to the extent the activities covered by the application are addressed by the terms of the directive. It is expected that most new or renewed permits and authorizations will not be materially affected by the proposed directive. 22. Would the new considerations for groundwater under the Forest Service existing special use authorizations amount to a permit for groundwater use? The proposed directive does not establish any new policy or claim authority to change the state role in water allocation. The proposed directive clarifies that existing Forest Service authority and policy, which requires an authorization for use and occupancy of National Forest System lands, and that such authorizations contain terms and conditions necessary to protect federal land and resources, and the environment. For example, a proposed well to exercise a state-issued water right could adversely affect a groundwater-dependent ecosystem that supports critical species. A special use authorization would be used to specify that the well be located, constructed, and operated in a manner that would avoid or minimize impacts to the groundwater-dependent ecosystem. The Forest Service would work with the permit applicant and the state to find an acceptable approach.

8 23. What would the new requirements for monitoring and mitigation entail? The requirements for metering and monitoring in the proposed directive generally consist of metering the quantity of water withdrawn, monitoring of potential impacts, and reporting the results to the Forest Service. These requirements would potentially apply to large capacity wells (potential sustained production rate of 35 gallons or minute or more), community water supply systems, and certain injection wells. If a state has equivalent requirements, the special use permit could reference or incorporate them as satisfying the requirements of the directive. 24. Are there any new fees proposed by the proposed groundwater directive? The proposed directive would not establish any fees. It would reiterate that any existing fee requirements should be part of the permitting or approval process. 25. How would the proposed groundwater directive change the way community water supplies are permitted and administered on national forests and grasslands? Under the proposed directive, at the time of permit issuance or renewal, permit holders for all wells and spring developments capable of withdrawing 35 gallons per minute or greater would be required to monitor and report groundwater withdrawals (35 gallons per minute is equivalent to 50,400 gallons per day; 6,737 cubic feet per day; or 0.15 acre-feet per day). The Forest Service expects that most recreation residences and small lands and recreation special uses would fall below this threshold. In addition, all new and reissued authorizations involving a water well or water pipeline with the substantial potential to adversely affect groundwater resources on National Forest System lands would include terms and conditions that require monitoring for impacts on water resources. 26. What is an example of permitting and administering of water supply wells on national forests and grasslands under the proposed groundwater directive? The proposed directive would provide consistent approach for evaluating new and renewed special use permits for water wells and water pipelines that would involve use of groundwater resources on national forests and grasslands. These provisions do not apply to authorized minerals or energy development on national forests and grasslands. There are some additional procedural requirements that the directive may impose on certain high volume uses of groundwater. All new and reissued authorizations involving a water well with the substantial potential to adversely affect groundwater resources on national forests and grasslands would include terms and conditions requiring monitoring for impacts on water resources. Since most wells pose little harm to groundwater resources, only a small subset of wells would fall into this category. The monitoring and reporting requirement would be phased in through inclusion in authorizations at the time of issuance or re-issuance. Permit holders for all wells and spring developments capable of withdrawing 35 gallons per minute or greater would be required to meter volumes and report groundwater withdrawals

9 quarterly to the local Forest Service unit. The metering requirement would affect only a small subset of wells including community water systems, aquifer storage and recovery projects, and water bottling operations. Most recreation residences and small lands and recreation special uses would fall below this threshold. 27. How would the proposed groundwater directive impact grazing permit holders? The proposed directive would direct the Forest Service to work cooperatively with appropriate State agencies to ensure that applicable state and federal water-related laws and regulations are implemented on NFS lands to protect groundwater for such purposes as outdoor recreation, authorized special uses, permitted livestock grazing, and fish and wildlife management. The proposed directive would clarify groundwater needs to be included in any evaluations of the effects of grazing. Similar to other permits involving groundwater withdrawal, the Forest Service evaluates whether grazing permits involving groundwater withdrawal are adversely affecting other national forest and grassland resources. If there are issues and the withdrawal is permitteeowned, then the agency would work with the permittee to identify solutions and/or establish conditions in a new or renewed permit to address those issues. If the water supply is owned/operated by the Forest Service, which is the case for a large number of range improvements, the Forest Service would be responsible for addressing the issues. In addition, as long as a permittee-owned grazing withdrawal is less than 35 gallons per minute, a hand pump, or a windmill, there is no requirement to meter the flow. Additionally, for permittees not withdrawing large amounts of groundwater (greater than 35 gallons per minute) the proposed directive is unlikely to affect permit conditions. Relationship to other Forest Service Policies and other Federal Agencies and Programs 28. How is the proposed groundwater directive related to the Forest Planning Rule? The 2012 Forest Planning Rule directs that Forest Service plans are to include plan components, including standards or guidelines, to maintain or restore: (iv) Water resources in the plan area, including ground water; (see FR p , Vol. 77, No, 68 / Monday, April 9, 2012, Sect 219.8(a)(2)). The proposed directive provides support for addressing this requirement. 29. How would the proposed groundwater directive work with the proposed BMP directives that were issued concurrently? Both proposed directives were published for public comment at the same time. The public comment period for the proposed BMP directives is 60 days (until July 7, 2014). The public comment period for the proposed groundwater directive is 90 days (until August 4, 2014). Tribal consultation is for 120 days, ending on September 3, The proposed directives for BMPs do not directly relate to the proposed directive for groundwater. The groundwater directive positions the Forest Service to address agency management practices and proposals that may affect groundwater resources. The proposed BMP directives are focused on Forest Service management practices with a potential to impact surface water quality.

10 30. What role would other federal agencies, such as the United States Geological Survey (USGS), have with the proposed groundwater directive? The proposed directive would be implemented by the Forest Service. However, the Forest Service routinely relies on cooperative expertise from the USGS, other federal, state and tribal agencies, and other organizations in addressing complex resource management problems on National Forest System lands, including locating, investigating, or assessing groundwater resources. 31. How does the Environmental Protection Agency role regarding groundwater compare to the Forest Service role and how will delegated state-run programs be affected? The Environmental Protection Agency sets minimum standards under the Safe Drinking Water Act for the quality of drinking water provided by public water systems, regardless of whether the water originates as surface water or groundwater, and sets standards for the operation of drinking water treatment facilities. The Environmental Protection Agency also regulates the subsurface injection of wastes to protect groundwater quality. In addition, the agency requires groundwater protection as part of non-point source pollution control and provides grants to protect groundwater quality. The Environmental Protection Agency also encourages the development and implementation of source water protection programs at the state and local level. Most states implement these Environmental Protection Agency programs. Several groundwater-related programs are delegated to the states by the Environmental Protection Agency. The Forest Service has a long history of working cooperatively with states to clean up contaminated sites, protect drinking water supplies and develop Total Maximum Daily Loads - a calculation of the maximum amount of a pollutant that a waterbody can receive and still safely meet water quality standards. This directive will not affect these or any other delegated programs. Groundwater Dependent Ecosystems 32. What is the Forest Service definition of a groundwater-dependent ecosystem, and would all such ecosystems be equally protected under the proposed groundwater directive? Groundwater-dependent ecosystems are defined in the proposed directive as follows: Groundwater-dependent ecosystems are communities of plants, animals, and other organisms whose existence and life processes depend on access to or discharge of groundwater, such as springs, fens, seeps, areas of shallow groundwater, cave and karst systems, hyporheic and hypolentic zones, and groundwater-fed lakes, streams, and wetlands. This not a regulatory term; rather it is a technical term used to recognize those ecosystems that have a significant dependence on groundwater for their survival and function. Not all groundwater-dependent ecosystems have the same functions or values. It is likely that most will not require specific protective measures in the context of a given proposed use of National Forest System lands. A site-specific assessment by the Forest Service of their characteristics and importance will be required to make that determination.

11 33. What is the timeline for developing the inventory of groundwater-dependent ecosystems? There currently is no established timeline for developing an inventory of groundwater-dependent ecosystems on National Forest System lands. In 2012, the Forest Service developed and published a groundwater-dependent ecosystem inventory field guide (FS GTR WO-86b), which is available for the administrative units to use. Approximately twenty-seven forests and grasslands to date have initiated an inventory. This number continues to increase as more administrative units recognize the importance of groundwater resources. 34. If a new stock water development is established, could that site become a new groundwater-dependent ecosystem and would the Forest Service require it to be protected? It is important to note that the term groundwater-dependent ecosystem is not a regulatory term and by itself it does not imply any required legal or other protection. A constructed stockwatering feature could acquire the characteristics of a groundwater-dependent ecosystem over time, such as coming to support a natural community of groundwater-dependent plants and animals. However, any assessment of such an ecosystem would take into account its origin and purpose, as well its existing characteristics, including whether the sustaining groundwater flow is natural or artificial. It is unlikely such a feature would be considered for protection. Directive Release Process 35. Can the states and tribes provide input on the proposed groundwater directive? Yes. The proposed directive is draft, for public review and comment. The Federal Register notice was published on May 6, The public comment period is open for 90 days, ending on August 4, The tribal consultation period is occurring simultaneously, but is open for 120 days, ending on September 3, Comments on the proposed directive will be considered in development of the final directive. 36. Does the text of the Federal Register announcement of the directive determine its purpose and meaning? The language in the Federal Register notification is only intended as a summary of the content of the directive and does not determine its meaning. The text of the proposed directive should be referred to for questions about the specifics. If a question or concern is not addressed in the text of the proposed directive, a formal comment could be submitted. 37. Shouldn t the Forest Service be proposing a regulation on groundwater management before (or at same time) as proposing the directive? The proposed directive governs the internal operations of the Forest Service, and how it responds to and evaluates proposals that have the potential to impact groundwater on National Forest System lands. The proposed directives do not establish rights and responsibilities for persons

12 outside of the government, nor do they concern subject matter for which formal rulemaking is required under the Administrative Procedure Act. 38. Why was the proposed groundwater directive released at the same time as the new Environmental Protection Agency/Army Corp of Engineers rule? The EPA/ACOE proposed rule concerning the applicability of the Clean Water Act was published for public comment on April 21, EPA and ACOE are accepting comments on that proposed rule until October 20, The proposed Forest Service groundwater directive was published for public comment on May 6, 2014, and it is available for public comment until August 4, There is no formal process for coordinating releases of documents for public comment or other announcements by different federal agencies. Each agency makes that determination independently based on a variety of factors, which may or may not include the timing of document releases or announcements by other federal agencies. Miscellaneous Issues 39. Wouldn t the proposed groundwater directive, or some of the wording in the directive, potentially lead to the Forest Service having to adhere to a higher than intended standard for groundwater assessment and protection? As noted in the Federal Register, the proposed directive is intended to position the Forest Service to be more consistent on how it assesses effects to groundwater. It is not intended to require more extensive assessments or greater protections of groundwater than would otherwise be required by existing law and policy or as a result of reasonable professional assessment of conditions in any particular situation. The goal is for the proposed directive to help ensure that the Forest Service is consistently recognizing the level of assessment and protection that is needed, commensurate with the scope of a proposed activity. Past and current claims of inadequate assessment of impacts to groundwater from proposed activities partly stem from a lack of consistency in Forest Service approaches to groundwater assessment, along with assumptions by external interests about what the Forest Service should be doing in the absence of an established groundwater policy. The proposed directive would provide a clearer, more consistent, and more credible approach to addressing groundwater, taking into consideration local conditions, thereby reducing legal challenges based on claims of inadequate groundwater assessments and analyses. 40. How would the proposed groundwater directive affect water emergencies such as drought? The proposed directive addresses the siting of water supply facilities in response to water supply emergencies. The Forest Service would work with public water suppliers to develop safeguards, contingencies, and permanent solutions when proposing new or expanded water supply facilities in response to emergency water supply shortages.

13 41. What is the current level of technical groundwater expertise available within the Forest Service? The Forest Service currently has four dedicated groundwater specialists that provide technical support to the national forest and grasslands with the potential to add more. In addition, there are a number of other specialists across the agency with training or experience in groundwater. If circumstances require it, a forest or grassland can contract the services of a qualified groundwater specialist. Finally, the Forest Service has ongoing training and technical resources to assist employees across the agency understand and address groundwater issues.

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