Groundwater Directive Comments
Submitted by National Ground Water Association
Comments on Draft U.S. Forest Service Groundwater Directive
The National Ground Water Association (NGWA) commends the Forest Service for its efforts to bring
groundwater into a more integrated view of water resources; promote informed planning and decision
making; and establish clear roles, responsibilities, and procedures.
To avoid any possible confusion, we recommend stating right up front that this directive relates only to
activities on NFS (National Forest System) lands and not effects from activities on adjacent lands. In
addition, it is easy to interpret the document as overly ambitious and creating an additional layer of
bureaucracy.
Also, as noted in the document (see page 15 or 17), the involvement of qualified groundwater
professionals is critical when groundwater issues are under consideration. The Forest Service currently
has limited expertise in groundwater and funding that will require staged implementation and priority
setting. We suggest providing more clarification on priorities and emphasizing “to the extent
practicable” more often. A training program may also be needed to properly implement the directive.
Specific comments on the document are as follows:
Page 8, Section 2560.02(3): Objective 3 states “To consider the effects on NFS groundwater resources
of all proposed activities on and uses of NFS lands (bold font added) and to avoid, minimize, or mitigate
adverse effects to the extent practical or as required by law.” We do not believe that this objective is
realistic as stated. Given limited resources and expertise, the Forest Service will need to prioritize where
it focuses on groundwater resources.
Page 8, Section 2560.03(4)(a) and (b): Items a. and b. under “Effects of Proposals on Groundwater
Resources” seem very open-ended. Also note that here and several other places the directive mentions
the need to consider not just quantity and quality but also “timing.” We understand this point but note
that the issue of timing will likely require some sort of analytical or numerical modeling beyond the
scope of the decision making. A clarification of scope is needed here.
Page 9, Section 2560.03(6)(e): The statement is made “Obtain water rights under applicable State law
for groundwater and groundwater-dependent surface water needed by the Forest Service (FSM 2540).”
Should not water rights always be obtained under applicable State law?
Page 9, Section 2560.03(6)(f): The statement is made “Evaluate all applications to States for water rights
on NFS lands and applications for water rights on adjacent lands that could adversely affect NFS
groundwater resources, and identify any potential injury to those resources or Forest Service water
rights under applicable State procedures (FSM 2541).” More careful wording is suggested as this could
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Groundwater Directive Comments
Submitted by National Ground Water Association
be interpreted as the Forest Service overstepping its bounds. Also, “on adjacent lands” seems beyond
the scope of the directive as we understand it.
Page 11, Section 2560.03(9)(b) and (c): The Association appreciates the inclusion and recognition in the
directive of the NGWA consensus-developed standards for water well construction and
decommissioning of abandoned wells.
Page 16, Section 2560.04h(3): Note that the requirement for Forest and Grassland Supervisors to
“Inventory connections between the groundwater and surface water resources under their jurisdiction,”
is a very challenging and subjective task compounded by limited expertise in hydrogeology.
Page 17, Section 2560.04h(5): The statement is made “Evaluate all applications for State water rights on
NFS lands and those on adjacent lands with the potential to affect NFS groundwater resources.” Again,
this could be misinterpreted and includes “on adjacent lands” which seems beyond the scope of the
directive.
Definitions (Pages 18-22, Section 2560.05)
The document uses a number of non-standard and incorrect definitions of terms. In particular,
groundwater is defined as all subsurface water. This is in direct contradiction to the standard
terminology used by hydrogeologists worldwide that groundwater is that part of the subsurface water in
the saturated zone under pressure greater than that of the atmosphere; i.e. that contributes water to
wells. The document should stick with standard terminology. We recommend the following changes:
Aquifer: Change “significant” to “useful” in the definition.
Confining unit: This term is not used elsewhere in the report. Note also the definition is not correct as
confining units may contain large amounts of water. A simpler definition is that a confining unit is “a
rock unit that is distinctly less permeable than adjacent aquifers.”
Groundwater: As noted this definition is incorrect. Groundwater is that part of the subsurface water that
is in the saturated zone in which all of the interstices or voids are filled with water under pressure
greater than that of the atmosphere.
Groundwater resources: It is unusual to include groundwater dependent ecosystems as part of
“groundwater resources.” This may cause confusion.
High-capacity well: Could change “Non-artesian wells” to “Wells” in the last sentence.
Qualified groundwater personnel: NGWA offers a voluntary certification program called the Certified
Ground Water Professional (CGWP), which is built on core competencies in the areas of groundwater
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Groundwater Directive Comments
Submitted by National Ground Water Association
hydrogeology and hydraulics, groundwater geochemistry, groundwater modeling, groundwater
remediation, geology and geomorphology, scientific writing and presentation, and ethics.
Recharge: This definition is incorrect as it is misusing the term infiltration in the definition. Replace
“infiltration of water into the groundwater” with “downward flow of water reaching the water table.”
Also, the phrase “or a man-made feature, such as a storage pond” seems unnecessary.
Sustainable use: Suggest replacing with “use of groundwater in a manner that can be maintained for an
indefinite time without causing unacceptable environmental, economic, or social consequences.”
Unsaturated zone, vadose zone, or zone of aeration: Definition may not be needed. Also note that the
unsaturated zone and vadose zone are not equivalent. The definition also does not account for perched
aquifers.
Page 22, Section 2561(1): The statement is made that “Assume that there is a hydrological connection
between groundwater and surface water, regardless of whether State law addresses these water
resources separately, unless a hydrogeological evaluation using site-specific data indicates otherwise.” It
seems like this could be made in a way that seems less confrontational with States. We agree that a
hydrological connection generally should be assumed, but it is important to recognize that those legal
aspects under State authority, which may or may not make this assumption, should be followed as
appropriate.
Page 23, Section 2561.1: Under item 2561.1, mention is made of aquifer storage and recovery (ASR).
Because different people use this term in different ways, we suggest using “managed aquifer recharge”
in its place and including this term in the Definitions.
Page 28, Section 2562.1(1): The use of “new treatment technology” is recommended. It is not clear why
the treatment would need to be “new.”
Page 39, Section 2568(2): Under Strategies for Sustaining Groundwater Resources: Use of “artificial
recharge” should be replaced with the more current term “managed aquifer recharge.” (see previous
comment relative to use of the term ASR on page 23)
National Ground Water Association – Who We Are
NGWA is a not-for-profit professional society and trade association for the groundwater industry. Our
members from all 50 states include some of the country’s leading public and private sector groundwater
scientists, engineers, water well contractors, manufacturers, and suppliers of groundwater-related
products and services. The Association’s vision is to be the leading community of groundwater
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Groundwater Directive Comments
Submitted by National Ground Water Association
professionals that promotes the responsible development, use and management of groundwater
resources.
Contacts for Further Information
William Alley, Ph.D.
Director of Science and Technology
walley@ngwa.org
800.551.7379, ext. 531
Christine Reimer
Director of Government Affairs
creimer@ngwa.org
800.551.7379, ext. 560
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