Testimony of Rebecca Mills, representing the Coalition of National Park Service Retirees, at the Nevada State Water Engineer Hearing November 8, 2011

My name is Rebecca Mills. I am here representing the Coalition of National Park Service Retirees, which is a non‐partisan, non‐profit organization comprised of former employees of the National Park Service, whose mission is to defend the parks and programs of the National Park Service. I retired from the National Park Service in May, 2002, after serving for nearly seven years as Superintendent of Great Basin National Park.

Potential Effects of the Groundwater Pumping Proposal in Spring Valley on National Park Resources

A groundwater pumping scheme such as that proposed by the Southern Nevada Water Authority is likely to affect a multitude of resources in the Great Basin region. We are concerned about this project because National Park resources are to be protected for future generations, so that our grandchildren and their grandchildren will be able to experience these special American places, resources, and values. There is not yet enough information to assure that Park resources will not be adversely affected by this project as it may affect resources within the park boundaries and resources outside the park boundaries that are vital to the park’s natural systems and the visitors’ experience. Our testimony today is focused on Great Basin National Park but we recognize that this project may have consequences for other Parks in the area (e.g., Lake Mead National Recreation Area).

Mission of Great Basin National Park

National Parks are considered the “crown jewels” of the nation’s natural and cultural heritage. They are established to preserve, unimpaired, and in perpetuity, unique and diverse aspects of our national heritage. Only 58 national parks have been designated in the United States, and Great Basin National Park is one of them – the only National Park entirely in the State of Nevada. The Park was established “in order to preserve for the benefit and inspiration of the people a representative segment of the Great Basin of the Western United States possessing outstanding resources and significant geological and scenic values…” (Public Law 99‐565). This law further stated that the Park Service is to "protect, manage and administer the park in such a manner as to conserve and protect scenery, the natural, geologic, historic and archeological resources of the park, including fish and wildlife and to provide for the public use and enjoyment of the same in such a manner as to perpetuate these qualities for future generations." In establishing the Park, Congress provided that its mission would include interpreting the entire Great Basin region, an area extending from eastern California through western Utah, including most of Nevada and portions of Oregon and Idaho. For all these reasons, the well‐being of not just the “range” resources within the boundaries of Great Basin National Park, but also the “basin” resources outside park boundaries, and certainly the resources in Spring Valley , are critical to both the

sustainability of the park’s natural resources and systems and the visitors’ park experience and understanding of the Great Basin region.

General Management Plan for Great Basin National Park

The Park’s General Management Plan is the principal document that interprets the park’s enabling legislation to guide the park’s management and development, and it is publicly available through the park’s website. A General Management Plan is adopted only after extensive analysis of several alternatives and public comment. Adopted in 1993, Great Basin National Park’s General Management Plan refers many times to the critical importance of Spring Valley (as well as Snake Valley) to fulfilling the Park’s mission and requires park management to review, evaluate, and make recommendations regarding any proposals for development in the valleys and to preserve the vistas associated with landscapes in perpetuity.

For example, in its Summary of the Proposed Action the GMP states: “Natural resource management activities under the proposed action would recognize that Great Basin National Park comprises only a portion of a much larger ecosystem centered around the South Snake Range. The park would be managed as an integral part of this larger ecosystem, and full consideration would be given to the potential effects of actions inside and beyond park boundaries.”

The GMP’s Summary of the Proposed Action also states: “To preserve the significant views of the Snake Valley and Spring Valley basins, which are an integral part of the Great Basin experience, the Park Service would review, evaluate, and make recommendations to local governments concerning all proposals for major developments or activities that might affect the visual integrity of the valleys.

Grazing, small agricultural developments, and daily ranching activities would not be subject to viewshed evaluation.”

In its section on Planning Issues and Concerns, the GMP states: “The views across Snake Valley and Spring Valley as visitors approach the park and from various locations within the park greatly enhance experiences and are a significant park resource. Although these valleys are not within the park boundary, they are critical in conveying the theme of ‘the Great Basin physiographic region’ to visitors. Without the contrasting valley basins, the mountainous lands inside the park can illustrate only a portion of that theme. The loss or visual impairment of these basins as a result of major industrial, commercial, or military activity would alter the pastoral basin scene that adds a critical dimension to the national park. The general management plan includes recommendations for preserving scenic resources within the Great Basin region.”

Later, in the Planning Perspective regarding Exceptional Resources, the GMP states: “Great Basin provides exceptional views of the two broad basins to the east and west and the surrounding mountain ranges. At present, these vistas are relatively undisturbed by human developments. They are important because they offer breathtaking scenery and because the natural landscapes enhance the park's ability to interpret the Great Basin physiographic region and the forces that shaped it.... Spring Valley dominates views to the west from Wheeler Peak and other points along the western crest of the South Snake Range in the park.”

Also the GMP states: “The area of eastern Nevada that includes the park has air quality exceeding the highest standard in the United States. Visibility from the park often exceeds 120 miles. The ability to view broad areas of basin and range topography and distant mountains is central to interpreting the entire Great Basin region, one of the park mandates established by Congress. In addition, because of the superior air quality and the area's general lack of artificial night lighting, Great Basin is one of the finest areas in the United States for experiencing the night sky.”

The GMP reiterates that the valley basins are “extremely important to the

Great Basin visitor experience. From a number of park viewing areas people can see nearly 100 miles, with commanding vistas of the valley basins and the mountain ranges beyond.” It concludes this paragraph by stating: “If Great Basin National Park is to be more than just a name, the integrity of the views associated with landscapes must be preserved in perpetuity.”

The General Management Plan also requires specific actions to preserve the pristine quality of the park’s water resources and to cooperate with other agencies to preserve wildlife and wildlife habitats, including Threatened, Endangered, and Sensitive Species and their habitats.

Air Quality, Atmospheric, and Visual Resources, including Visual Intrusion

The Bureau of Land Management’s Draft Environmental Impact Statement (DEIS) notes that air pollutant emissions will occur during the 11‐year construction, disturbance, and reclamation phase of the project. There will also be a “minor increase in air pollutant emissions” from operation and maintenance. In addition, the DEIS notes that there is a “dust generation risk from soil surface drying” as well as “loss or reduction of basin shrubland vegetation” as a long term pumping effect. The DEIS also notes that “changes in vegetation communities could gradually change the scenic views in terms of color, texture, density, and vegetation patterns.”

Groundwater pumping in Spring Valley will likely result in air pollutant emissions and dust over the short and long term‐‐‐during construction, operation and maintenance, and cumulatively into the future from partial or complete drying of springs, wetlands, wet meadows and other areas in the Valley. While the specific effects on air quality/visibility in the vistas of Spring and Snake Valleys and within Great Basin National Park are unknown, it is probable there will be a diminution in the air quality. The pristine quality of the night sky is a significant resource value of Great Basin National Park, and night sky

interpretation, which depends on clean air, is one of the Park’s major interpretive programs. Artificial lighting will be required the length of the pumping project infrastructure, which will to an unknown extent decrease night sky visibility within Great Basin National Park.

Air quality monitoring demonstrates that the air quality and visibility of Great Basin National Park is among the best in the country. This significant asset is very susceptible to deterioration. The Park website (www.nps.gov/grba) states: “Studies of the effect of visibility on park visitors show that slight increases in air pollution are much more distinct and objectionable when and where the air is cleanest (O'Leary 1988).“

Not only will the ability to see be affected, but this project will also alter what will be seen. The industrial nature of the project infrastructure will change the Park’s current rural, natural, and agricultural viewsheds. According to the DEIS, groundwater pumping in Spring Valley is estimated to result in substantial reductions of groundwater discharge for evapotranspiration. The DEIS estimates a 77% reduction at the full buildout plus 75 years and an 84% reduction at full buildout plus 200 years.

Similarly significant impacts are noted for springs, streams, and water balance. Such a reduction in water resources of Spring Valley will inevitably affect Spring Valley’s vegetation, associated wildlife habitat, and likelihood to produce dust and other pollutant emissions.

Plant and Wildlife Resources

The DEIS notes that “the project would potentially reduce available moisture in the root zones of vegetation communities that transpire (evaporate) large quantities of soil water through plant leaves”

Changes outside the park in composition of plant communities in Spring Valley could have effects on wildlife inside the Park. Reductions in groundwater levels and inputs to surface flows would affect wildlife habitats. It is not known at present what wildlife, including special status bird and bat species that migrate to and from the Park, would be affected.

More studies are needed to determine what effects the changes in the valleys would have on plant and wildlife resources within the Park.

Soundscape

Along with pristine air quality and visibility, Great Basin National Park resources include large areas of remarkably natural soundscapes. While the Park is not a designated Wilderness, most lands within the park are managed to protect wilderness qualities, which include tranquility and solitude. It is unknown to what extent groundwater pumping in Spring Valley will intrude upon the natural soundscapes within the Park. In the absence of such information a sound judgment cannot be made concerning the potential impact of SNWA’s proposed pumping and pipeline in Spring Valley on the Park’s distinctive qualities of tranquility and solitude.

Water Resources

The U.S. Geological Survey reported in 2006 in their “Characterization of Surface‐Water Resources in the Great Basin National Park Area and Their Susceptibility to Ground‐Water Withdrawals in Adjacent Valleys, White Pine County, Nevada” that water resources, both surface water and springs, within the Park boundaries could potentially be susceptible to groundwater pumping in Snake Valley. Its report indicated that pumping in Spring Valley could have an effect on groundwater levels in Snake Valley, due to the interbasin water flow between the two valleys at the southern end of the Snake Range. Studies to determine more specific possible effects are ongoing and are expected to be published in 2012.

Monitoring and Mitigation

Currently the Park and other agencies, including the Southern Nevada Water Authority, are establishing baseline inventories of water and other resources and monitoring potential effects of groundwater pumping in Spring and Snake Valleys. This effort is ongoing concurrent with other studies taking place. We believe that not enough is yet known to be able to predict accurately the effects on Great Basin National Park resources. And we are concerned, if and when monitoring reveals a significant impact, it could be too late to mitigate the impact. Adaptive management strategies outlined in the BLM’s DEIS consider changes in distribution of pumping and also cessation or reduction of pumping as potential mitigation measures for adverse impacts. However, it could take many years before any of these strategies would begin to change the impact, and by then vegetation communities might already be irreparably altered, affecting wildlife habitats as well as air quality.

Park Values

Great Basin National Park is a wonder, a portion of the enormous Great Basin region that the United States Congress set aside to be preserved unimpaired and in perpetuity for future generations. Many people visit the Park from all over the world, but its importance to the nation is its representation of this unique High Desert region. The Park with its surrounding valleys is a place of vastness, where time and space seem to unravel and extend. The vistas appear almost totally natural, uninterrupted by human development. It is easy to imagine the millions of years of geologic change as you look out from the mountain range. The quiet is almost palpable. You can hear ravens ‘wings as they glide up slope for their evening roost. There are aspen groves, babbling brooks, and delicate straws decorating the Lehman Cave ceiling. Bristlecone pines, which can live for up to 5,000 years, cling to the mountain cirque.

Remarkably diverse native ecosystems climb the mountain in successive altitude zones. After dark, the array of stars is indescribably bright, with infinite points of light slowly drifting across the sky as the earth moves. Not many places in the United States have such pristine air and dark skies. Many people say‐‐‐and I am one of them‐‐‐that this Park is a place where a person can feel centered, alive as a creature dependent on the earth, aware of one’s place in time, in the great sweep of geologic and human history, and in space, under a sky lit up with the fires of stars millions of years distant. It is nearly impossible to quantify these values. It is our duty and our privilege to preserve them.