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COMMENTS OF FRIENDS OF THE RIVER AND THE CALIFORNIA WILDERNESS COALITION CONCERNING THE SIERRA NATIONAL FOREST LIVING ASSESSMENT: DESIGNATED AREAS; WILD AND SCENIC RIVERS
July 1, 2013
Incorrect Characterization of Recommended Wild & Scenic Rivers
The Sierra National Forest Living Assessment wiki (Chapter 15: Designated Areas; Wild and Scenic Rivers; Inventoried Potential Wild and Scenic Rivers) states that segments of the San Joaquin River, Middle Fork San Joaquin River, and South Fork San Joaquin River are “inventoried” rivers “still being considered for designation.”
These statements are simply incorrect. The Forest Service recommended federal Wild & Scenic River protection for segments of the San Joaquin River, Middle Fork San Joaquin River, and South Fork San Joaquin River in the 1991 Sierra National Forest Plan. This decision is reflected in the 1992 Record of Decision:
“The Plan makes a recommendation for wild and scenic river designation for all segments of the San Joaquin on the National Rivers Inventory (NRI) except for two miles of river above high water level of Mammoth Pool Reservoir.” ROD pg. 3
These river segments are not “still being considered for designation” as the wiki asserts. The Forest Service may consider and decide to reverse its current recommendation for these segments in the upcoming plan revision, but the 1991-92 recommendations for these segments remain in place.
The Forest Service is not required to reconsider previously recommended rivers. The draft revised Forest Service Handbook states that previously recommended rivers “need not be re-evaluated unless applicable changed circumstances warrant consideration by the responsible official.” (Proposed FS1909.12, Chapter 80, Sec. 81.21, pg. 6, Version—02/14/2013)
If the Sierra Forest Supervisor believes that the recommended segments of the San Joaquin River require re-evaluation, than the applicable changed circumstances warranting this re-evaluation should be documented in the Living Assessment.
Comprehensive Assessment of Non-NRI Rivers
Although Friends of the River is gratified that the wiki documents the independent study conducted by Friends of the River and others in 1990 concerning the eligibility of Dinkey Creek for possible Wild & Scenic River protection, this wiki discussion begs the question as to whether the Forest Service intends to comply with the commitment made in the 1992 ROD to conduct a comprehensive assessment of non-NRI rivers on the Sierra Forest. Such a comprehensive assessment, which is the standard required in the Forest Plan Rule and Forest Service Handbook, has never been completed for the Sierra Forest (despite the three year deadline promised in the 1992 ROD). Friends of the River expects that the Forest Plan Revision shall include a comprehensive assessment on non-NRI rivers, including Dinkey Creek. It should be noted that the 1990 study report for Dinkey Creek requires significant updated with relevant new resource information.
The comprehensive assessment in the Forest Plan Revision should also include a suitability study and recommendation for the lower segment of the Kings River determined eligible in the 1991 Kings River Management Plan. This suitability study should be conducted in cooperation with the adjoining Sequoia National Forest.
Comprehensive River Management Plans
The Sierra Forest Living Assessment wiki notes that Wild & Scenic Rivers already designated by Congress (including segments of the Merced and Kings Rivers) are managed according to Comprehensive River Management Plans (CRMPs) developed in 1991. The Forest Plan Revision provides an opportunity to update the CRMPs with any new and relevant information, including changes in visitor use, listings of threatened and endangered species, new resource information, revised planning procedures, etc. The Living Assessment should include a discussion as to whether the 1991 CRMPs should be updated in the Forest Plan Revision.