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Final opportunity to submit comments on the LONG OVERDUE Comprehensive River Management Plans for Owens River Headwaters and Cottonwood Creek, which were designated Wild & Scenic Rivers in 2009. 


Submit Your Comments by April 14!

What's happening?

Friends of the Inyo was actively involved in the designation of the Owens River Headwaters (ORHW) and Cottonwood Creek as Wild and Scenic Rivers (WSR) in 2009. We worked for years to Congressionally protect these free-flowing rivers and the water they supply to humans and wildlife. The development of Comprehensive River Management Plans (CRMPs) is a fundamental provision of the National Wild and Scenic Rivers Act; such plans are intended to be completed within three years of designation. After 12 years of inaction, and thanks to litigation, the U.S. Forest Service is finally completing this task.

In August of 2021, we submitted comments on the draft plans. Now the Inyo National Forest has released their final environmental analysis and a second round of draft plans for these rivers, but the feedback they received during the last comment period in August of 2021 was largely ignored. Unfortunately, the revised plans fall short on addressing the issues raised during the August public comment period and do not provide meaningful protections for these Wild and Scenic Rivers.

For the management plans to be effective, they must consider and address lands and facilities, recreation, and current and future actions and use the Best Available Science to make determinations about management. The final plans should include strong standards, guidelines and management actions that protect the free-flowing condition of the rivers, water quality and their identified Outstanding Remarkable Values (ORVs).

What can I do?

Once again, we are encouraging our members to submit written comments to the Inyo National Forest on the second round of draft plans and the accompanied Environmental Assessments. Outlined below is what needs to be included in revisions of each final draft. Submit your comments by the Inyo National Forest's deadline of Thursday, April 14, 2022, using the talking points below. Please refer to the instructions and links at the bottom of this email when submitting your comments.

Talking Points

Owens River Headwaters
Final Draft Plan

  • Must analyze current and projected groundwater extraction from the watersheds of Deadman, Glass and Dry Creeks. Points of groundwater extraction that must be considered include Mammoth Mountain Ski Area, recreational housing tracts and campgrounds, as well as the state road maintenance yard at Crestview.
  • The environmental analysis and final plans must cite the Best Available Science from published research, not unpublished work that attempts to justify groundwater mining.
  • The environmental analysis must include information on potential water pollution sources and propose management actions that address water quality problems. The Forest Service has a responsibility to proactively protect and enhance the water quality of the Owens River Headwaters Wild and Scenic River.
  • The proposed User Capacity Limits do not represent recreational use over multiple years and grossly overestimate the carrying capacity of the Wild and Scenic River. Further, recreational capacity should focus on facilities and management actions that will create sustainable use of the river corridor into the future. 

Cottonwood Creek
Final Draft Plan

  • Incorrectly references the river as being within the Desert Renewable Energy Conservation Plan area and being subject to Conservation Management Actions. This needs to be corrected. 
  • Should add recreation as an Outstanding Remarkable Value for fishing, hiking, camping, hunting, and other possibilities for recreation that Cottonwood Creek provides. This is included for the BLM portion of the river but is omitted for the Inyo National Forest portion.
  • Needs to add Geology as an Outstanding Remarkable Value due to the presence of many important and unique geological features. These include Lower Cambrian Trilobites, which are the subject of ongoing research at White Mountain Research Station.
  • Should recognize the eligible tributaries of Cottonwood, as they contribute to its Outstanding Remarkable Values. These include 3.7 miles of South Fork Cottonwood Creek and 3.4 miles of Poison Creek.
  • Should be analyzed as an alternative in the Environmental Assessment permanently retiring the Cottonwood Creek grazing allotment to protect the Outstanding Remarkable Values of botany, fisheries, and wildlife.

BOTH Plans:

  • Should also include standards, guidelines and management actions that protect the river corridor from water contamination, and activities that contribute to erosion, sedimentation, and riparian vegetation loss.
  • Should incorporate an annual monitoring plan that would include annual surveys for recreational use, instream flows, water quality and quantity, wildlife, and historic and prehistoric sites.
  • Should include descriptions of previous restoration or project work in the corridor that would inform management.


Comments for both the
Owens River Headwaters and Cottonwood Creek
Wild and Scenic River CRMP's are due by
Thursday, April 14th.
Submit your comments today!

Review documents and maps here. Click on the “analysis” tab to read the Environmental Assessments and final draft plans. Click on the “comment/object on this project,” or go here to enter your comments or attach your comment letter. There is an "Español" link on the top right hand side of the comments page that allows for comments to be submitted in Spanish as well. 

You can also mail hard copy comment letters to Adam Barnett, Inyo National Forest, 351 Pacu Lane, Suite 200, Bishop, CA, 93514. The office business hours for those submitting hand-delivered comments are: 8:00 am to 4:30 pm Monday through Friday, excluding holidays. Please state “Inyo National Forest CRMP” in the subject line when providing electronic comments, or on the envelope when replying by mail. Mr. Barnett is also available to answer questions and provide additional information as needed. Please contact him at adam.barnett@usda.gov or (760) 920-8104. 

Thank you for providing feedback to the Inyo National Forest on their environmental analysis and draft plans. Together we can make sure these plans protect these free-flowing Wild and Scenic Rivers for future generations of people and wildlife. 


Friends of the Inyo
621 W Line St Suite 201  | Bishop, California 93514
(760) 873-6500 | info@friendsoftheinyo.org

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