Final Comments: August 30, 2012 Comments on Strategic Directions for U.S. Geological Survey Water Science, 2012–2022—Observing, Understanding, Predicting, and Delivering Water Science to the Nation—Public Review Release, Open‐File Report 2012‐1066 Submitted by National Ground Water Association (NGWA) 601 Dempsey Road Westerville, OH 43081 800.551.7379, ext. 560 Contact: Christine Reimer The following comments are submitted in response to U.S. Geological Survey’s (USGS) request for comments on the document Strategic Directions for U.S. Geological Survey Water Science, 2012–2022—
Observing, Understanding, Predicting, and Delivering Water Science to the Nation—Public Review Release, Open‐File Report 2012‐1066. The comments are being submitted on behalf of the National Ground Water Association (NGWA). NGWA is the world’s largest association of groundwater professionals, representing public and private sector engineers, scientists, water well contractor, manufacturers and suppliers of groundwater‐related products and services. General Comments: NGWA recognizes the USGS as the premier Federal non‐regulatory water‐
monitoring and natural resource science agency. Association members have identified groundwater availability as a significant challenge facing the nation. Most States across the country are either experiencing groundwater shortages now or predict shortages in the next 20 years, according to a series of NGWA‐sponsored surveys of private and public sector groundwater professionals. The current widespread drought conditions only magnify the value of groundwater because it is the source of base flow to streams and wetlands, and it is slower to feel the effects of sudden hydrologic changes; thus when groundwater reserves fall short, the long‐term implications are significantly more serious. The surveys showed that there is no one cause of shortages or expected shortages, but rather a combination of quality and quantity related causes. Groundwater professionals also identified the need for additional Federal funding for cooperative groundwater quantity and quality data collection as the most useful Federal action. The USGS has a key role, in cooperation and collaboration with its public and private sector partners, to help provide and make accessible the fundamental information and tools for decision‐makers. 1 Final Comments: August 30, 2012 Specific Comments: Page 2, Column 2, Subpoint 1: NGWA suggests the wording be changed to (changes in italics): Providing society the data and information it needs regarding the status and trends in the amount and quality of water in all components of the water cycle at high (?) temporal and spatial resolution nationwide; Additionally, the definition of the term “high” as related to temporal and spatial resolution is unclear. It is important that USGS consider the appropriate scale so as to complement and assist State and local activities. In the groundwater area, NGWA would see the USGS principal role as focusing on data and information at the regional and national scale. Page 2, Column 2, Subpoint 4 – Anticipating and responding to water‐related emergencies and conflicts; and: Please consider whether the term “conflicts” is the best here. The scientific and lay press has carried reports and articles on the potential for water conflicts among nations, including the possibility of armed confrontation. The State Department‐requested report released earlier in 2012 raises the potential for water shortages to lead to instability for some countries. Dependent on the scope of action anticipated, the word “competition” may be an appropriate substitute. Page 3, Column 1, Paragraph 1: How will the USGS ensure they will provide “unbiased knowledge?” What types of bias are we referring to here? Page 3, Column 2, Paragraph 2 – …Therefore, it is essential to understand the spatial and temporal interactions between water supplies and needs at all scales: The paragraphs leading up to this sentence discuss scales, including down to the city scale. The USGS performs comprehensive local monitoring to understand the hydrologic system in an area. However, the private sector also plays an important role in consulting to and providing services to cities seeking to install or enhance their water supplies, for example. USGS, as a government agency, provides valuable information and data upon which this private‐sector work is based. NGWA strongly encourages a clear statement in this document that reconfirms USGS’s commitment, as expressed in written policy statements crafted in collaboration with the private sector, to avoid duplication of and competition with private sector scientists and engineers. State agencies also undertake State, regional or local scale work that fits within the USGS mission area. Collaboration rather than competition is critical there as well. Page 5, Societal Issues and Water Science: The following are potential questions that society may pose and that may merit consideration as an addition to the current listing: 


How is water allocated? Is it a resource in commons or a resource owned under a water rights paradigm? How will infrastructure moving, treating and discharging water be financially supported? 2 Final Comments: August 30, 2012 Page 5, Column 1, Bullet 4 – Is our water supply “safe” for people, industries, and ecosystems? Safe is a word that is difficult to define and may vary among various water uses. As competition for water has increased, brackish groundwater is being substituted for fresh water sources for some uses, including both drinking water and non‐drinking water. The Association suggests the following revision: 
Is a water supply of sufficient quality available to meet the needs of people, industries, energy production, and ecosystems? Page 6, Column 1, Paragraph 5, …The USGS is the premier water‐monitoring and science Bureau within the Federal Government: The non‐regulatory role of USGS is a key feature that the Survey brings to the water monitoring and science area. NGWA suggests highlighting that important fact. Possible change would be to: The USGS is the premier non‐regulatory agency for water‐monitoring and natural resource science within the Federal Government. Page 7, Column 2, Bullet 8 – Training the next generation of water scientists and technicians: Ensuring an adequately trained work force that can assist in meeting the nation’s water supply needs is a challenge identified by NGWA. USGS is well recognized for its science and research efforts. It is not only important that students be brought into the geosciences and trained but the effort must extend throughout their professional lives. The participation of USGS scientists in NGWA events and those of other professional societies is critical to transferring information and cutting edge research to the public and private sector practicing professionals and decision makers who are involved in the day‐to‐day management of water resources. In addition, training on monitoring protocols provided to State and local partners would help ensure quality data is being collected for the national monitoring effort in a cost‐effective manner. Page 7, Column 2, Paragraph 9 – …Two other major strengths of the USGS are a business model that supports a high level of partnering with other agencies, academia, and the private sector… ‐ NGWA agrees that partnering and collaboration are important and will become increasingly critical as resources, both manpower and funding, are stretched at all levels. The Association encourages USGS to continue down this path, including providing leveraging resources through grants as appropriate, such as those envisioned in the Subcommittee on Ground Water’s (SOGW) framework document. Page 8, Figure 3: The figure could be better integrated with the text. Additional substance could be extracted from the Figure, such as the interrelationships among geology/climate/human domains or the elements intervariability. The concept of stressors to water resources could be introduced here. Page 9, Highlight 2: Suggest using an alternative paleo study better focused on water quality changes through time rather than the proposed example of lead concentrations from air emissions. 3 Final Comments: August 30, 2012 Page 10, Table 1: Table 1 misses the point as currently designed. The proposed priority actions are too wordy. It is unclear as to how prioritization was established. The Table is too cumbersome to demonstrate a goal‐oriented strategy. Page 11, Column 1, Expand and Enhance Water‐Resource Monitoring Networks: Consider adding visuals, such as maps, to show the distribution and gaps geographically and by resource type in current networks. Page 11, Column 1, Bullet 1 – Design and develop a more nationally consistent, Federally funded backbone network of surface‐water, groundwater, and water quality monitoring stations that is supplemented by the use of qualified records collected and furnished by local, State, or other Federal agencies.(See also page 21, Strategic Action 2 and page 23, Strategic Action 7.): The Association thanks the Survey for identifying within the Water Science Strategy that a priority should be placed on expanding and enhancing water‐resource monitoring networks – surface water, groundwater and water quality. NGWA concurs that hydrologic data are the foundation of any understanding of the Nation’s hydrologic systems. NGWA also appreciates the recognition given to the national groundwater monitoring network framework as a potential model for cooperative water monitoring efforts moving forward. As you are aware, public and private sector professionals, representing government agencies at all levels and many water organizations, shared their expertise in developing the framework, and the Association appreciates the Survey embracing the SOGW’s work. NGWA strongly supports the work of the SOGW and the proposed national groundwater monitoring network. The current draft USGS Water Science Strategy document’s wording, “supplemented by the use of qualified records collected and furnished by local, State or other Federal agencies” is unclear, however, as to whether Federal funds would extend to local or State partners. The availability of Federal grant funds to State and local partners to cost‐share development and implementation of a national groundwater monitoring network is critical to successful nationwide implementation, as pointed out in the SOGW’s framework document implementation section (page 64, SOGW Framework Document 2009). Such funding allows Federal, State and local resources to be leveraged, avoiding costs to the Federal government from developing redundant infrastructure and monitoring, while supporting the local and State governments’ increased costs in upgrading to a consistent nationwide monitoring approach and providing access to the selected data records. Also, a subtle but important distinction between the wording in the USGS Water Science Strategy document and the SOGW framework document is that the framework document refers to backbone sites; not a backbone network. NGWA recommends that the draft USGS Strategic plan be revised to read: (changes in italics) Design and develop a more nationally consistent, Federally funded backbone of surface‐water, groundwater, and water quality monitoring stations that may be operated by the Federal government or by qualified State/Tribal entities. Backbone sites would then be supplemented by the use of qualified records collected and furnished by local and State agencies that receive Federal grant funding support, or other Federal agencies to develop national surface‐water, groundwater and water quality monitoring networks. 4 Final Comments: August 30, 2012 (Note: As background, refer to pages 15, 60, 64 and 65 of the SOGW Framework Document 2009) NGWA strongly supports a Federally funded network for surface‐water monitoring that is critical as well to understanding the hydrologic system. Page 12, Highlight 3: Consider adding a description of how data are telemetrically securely transmitted, stored and analyzed. Provide information on how the network is tested for integrity. Page 14, Section 1, Water Use Information: Water use information is the third of three key areas that the Association recommends USGS focus on over the next five years as it moves forward on a Water Census. The other two areas, as mentioned above, are development and implementation of national surface water and groundwater monitoring networks, in collaboration with State and local partners. Page 14, Column 1, Paragraph 1: Create an active hyperlink within the document to the NRC report. Explain briefly and with greater clarity what the recommendations of the NRC report were. Page 18, Figure 5: Suggest moving the figure up to page 5 under highlight 1. Page 22, Column 2: Current wording: A vision for this network was provided by the ACWI Subcommittee on Ground Water (Advisory Committee on Water Information, 2009), in their definition of “backbone” sites. The ACWI vision calls for monitoring wells in places where the groundwater is not disturbed by pumping or land use and sites where development has affected groundwater, and the ACWI specifically calls for coverage in both shallow groundwater – where surface development is most likely to affect quality – and deep aquifers that are tapped for public supply. The suite of measurements included in a groundwater‐contaminant…. This section appears to unintentionally blend two different USGS programs and/or ACWI statements. The concepts for a national ground water monitoring network are based on monitoring of principal and major aquifers and a more limited list of constituents than page 22 of the USGS Water Science Strategy appears to cover. Also, the concept of backbone sites is separate from the description below. The Association proposes the following as a possible clarification. Proposed revision (changes in italics): A vision for this network was provided by the ACWI SOGW (Advisory Committee on Water Information, 2009), that calls for monitoring wells in places where the groundwater is not disturbed by pumping or land use and sites where development has affected groundwater. Additionally, the ACWI calls for coverage in both shallow groundwater – where surface 5 Final Comments: August 30, 2012 development is most likely to affect quality – and deep aquifers. The suite of measurements included in a groundwater‐contaminant…. (Note: As background, refer to page 15 and 45 of the SOGW Framework Document 2009) Page 31, Column 2, Objective 2: Is the USGS working in partnership with other Federal agencies, such as the U.S. Army Corps of Engineers, the Federal Emergency Management Agency, or the National Park Service to identify and track hydrologic hazards (see highlight 5, page 33)? Page 34, Column 2: How will the 3D/4D models be calibrated and validated? For additional information, contact: Christine Reimer National Ground Water Association 601 Dempsey Road Westerville, OH 43081 800.551.7379, ext. 560 creimer@ngwa.org 6