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Response to Public Comment
Listed below are summaries of comments by J. Mark Ward for the Utah Association of Counties followed by a response from USGS. The summary of each comment is linked to the original document submitted by J. Mark Ward.
Comments from J. Mark Ward for the Utah Association of Counties
Complete letter from J. Mark Ward (pdf)
And while the study area of the draft USGS report includes a major portion of the Snake Valley groundwater basin proper, it fails to include the following five hydrologically connected parts of the common Great Salt Lake Flow System Aquifer that lies beneath the Snake Valley ground water basin: 1) Tule Valley, 2) Fish Springs Flat, 3) Dugway-Govt. Creek Valley 4) Deep Creek Valley and 5) Great Salt Lake Desert immediately north of Snake Valley.
RESPONSE
The study area for the BARCAS study was determined using Federal legislation (Section 301(e) of Public Law 108-424) to conduct a water-resources study in White Pine County and adjacent areas of Nevada and Utah. The study area was defined as including hydrographic areas in White Pine County. Entire hydrographic areas were included in the study. By including entire HAs, the study area boundary extended into surrounding counties in Utah and Nevada.
The hydrogeology of these seven areas is essential to understanding the Great Salt Lake Desert Flow System Aquifer. They are hydrologically connected to the Hamlin Valley and Snake Valley basins and could be impacted by the proposed ground-water development. Omission of these seven areas constitutes an important flaw in the study as a whole, as well as a failure to abide by the directive of the Lincoln County Land Act statute. Again, that statutory directive issued not in reference to the given groundwater basins per se, but rather in reference to the alluvial and deep carbonate aquifers of those groundwater basins. Thus for the Hamlin Valley and Snake Valley groundwater basins, the study area must include the above-mentioned seven areas in order to comply with the Statute and give an adequately complete hydro-geological picture that the Statute requires.
RESPONSE
The legislation described above allows for latitude in delineating the extent of the study area. Entire regional flow systems were not included; rather, specific HAs with some portion located within White Pine County were included. The project was funded using SNPLMA (Southern Nevada Public Land Management Act) monies and generally restricts research projects to locations within White Pine and Lincoln Counties, Nevada.
RESPONSE
The addition of 7 hydrographic areas in the Great Salt Lake Desert Flow System is beyond the scope of the current BARCAS report.
That Area of Interest specifically includes six of the seven areas mentioned above: Pine Valley, Wah Wah Valley, Tule Valley, Fish Springs Flat, Dugway-Govt. Creek Valley and Deep Creek Valley. The Stipulated Agreement calls for the study, investigation, monitoring, protection and mitigation of impacts in the Area of Interest that may result from any SNWA groundwater pumping activities. Given that DOI bargained for the monitoring and protection of these these six areas as part of the overall Area of Interest in the Stipulated Agreement, and did so presumably because of the obvious hydrological connection as part one common groundwater aquifer, it is untenable that USGS would shrink the study area of the draft USGS report down from the Stipulated Agreement’s Area of Interest and lop off these six areas for purposes of the draft USGS report, especially given the nature of the statutory directive.
RESPONSE
The USGS did not “shrink” the BARCAS study area down from the Stipulated Agreement’s Area of Interest. By the time that a stipulated agreement between DOI and SNWA was reached (September 8, 2006), the 30-month BARCAS project (beginning in December 2004) was well underway.
