National Park group -- background paper

The Coalition of National Park Service Retirees has posted a background paper: More Science Needed for Great Basin Ground-water Pumping Project This is an organization of retired Park Service employees who care deeply for the natural resources of America. The quality of this document attests to their professionalism as well. In addition to this background paper you can find several associated letters we all could use as starting points for letters of our own (Letters page) This document is a must-read for anyone who wants to know more about the SNWA proposal, especially as it relates to Great Basin National Park. Below are some excerpts from the paper.

Their conclusion:

Enough science has been developed to know that there will likely be adverse effects from the proposed ground-water pumping project, including effects on GBNP. Using different modeling efforts, the Myers, NPS, and USFWS estimate proposed pumping effects of a similar order of magnitude in Spring Valley. However, these and other available studies are incomplete in various respects. The Myers model covers only Spring Valley. The SNWA model, while larger, excludes the Goshute Indian Reservation and USFWS Fish Springs National Wildlife Refuge, which need to be evaluated. The SNWA model also uses a conceptualization of ground-water hydrology about which scientists disagree. A predictive model is needed that is developed by a science agency like the USGS, with no land management, preservation, or development agenda and with rigorous peer review. It will produce objective, scientific predictive estimates of future effects from the proposed pumping. Therefore, the CNPSR urges the U.S. Geological Survey (USGS) to conduct or approve additional science sufficient to predict accurately the effects of proposed pumping on GBNP. This could be the proposed “BARCASS II” or a combination of peer review, testing of available models, and any additional research required, as determined by USGS. Until these predictive estimates are available, SNWA should not begin its large-scale ground-water pumping from Spring Valley. This is the only certain way to protect the resources of Great Basin National Park.

On the Spring Valley stipulation agreement:

“Stipulation for Withdrawal of Protests”.) The agreement’s common goal is to avoid any effects to resources within Great Basin NP and unreasonable adverse effects to other federal resources and to the scenic values of, and the visibility from, GBNP. The goals of the agreement and the actions it specifies are critically important. However, the agencies agreed to monitor effects, rather than prevent them. Instead of waiting for sufficient information to predict effects, the parties agreed to collect baseline data, then continue to collect data and refine existing models while pumping is in progress, and evaluate effects as they occur. The agreement includes no protocol specifying target water level measurements to trigger specific mitigation actions. The agreement’s 3 committees, each of which includes representatives of the 4 Interior agencies plus the SNWA, are expected to recommend decisions about monitoring and mitigation by consensus. Consensus decision-making can be both time-consuming and ineffective when vested interests are in conflict. If they cannot reach consensus, they can turn to an unnamed third party or the Nevada State Engineer. There is no language in the agreement regarding compliance enforcement, should decisions not be implemented. Even if decisions are reached and pumping is reduced or ceases, adverse effects will continue at least for decades. Hence, the agreement is neither detailed enough nor strong enough to allow the parties to meet their laudable goals. As a consequence of the agreement, the State Water Engineer did not hear testimony from the DOI agencies

USGS Report of Likely Effects on Great Basin NP:

A U.S. Geological Survey (USGS) 2006 report (“Characterization of Surface-Water Resources in the Great Basin National Park Area…” by Elliott, Beck, and Prudic: SIR 2006-5099) states that Park surface-water resources will likely be susceptible to proposed ground-water withdrawals from Snake Valley. However, pumping in Spring Valley could affect ground-water levels in Snake Valley, because the two areas likely are hydrologically connected south of the Park. The report did not further evaluate this potential, nor effects on wildlife that move in and out of Spring Valley from and to the Park.

USGS "BARCASS I and BARCASS II"

A joint USGS and Desert Research Institute “Basin and Range Carbonate Aquifer System Study”(“BARCASS I”) funded expressly to evaluate effects of the SNWA project, will conclude by December of 2007. This study will integrate geologic, hydrologic, and geochemical information to improve upon known data, but because of time and budget, will not be able to predict effects of pumping. It will provide the necessary information for future development of a calibrated ground-water flow model to assess potential impacts of the pumping project (“BARCASS II”). However, no funds are available for BARCASS II.

SNWA ground-water flow model:

Mr. Timothy Durbin of SNWA developed a calibrated ground-water flow model for SNWA. The model can be used to develop predictions. However, SNWA has chosen not to present these predictions to the public.

National Park Service (NPS) predictive estimates:

Dr. Paula Cutillo of the NPS made predictive estimates using the Durbin SNWA model that showed that there would be a “drawdown of up to 200 ft in the area of the pumping wells after 75 years of pumping”. (Exhibit #2504)

Mr. Tod Williams, Resource Manager for GBNP, identified 5 springs in the Park that are within ¼ mile of the USGS report’s (Elliot et al) “susceptibility area” for Spring Valley. (USNPS Exhibit #2501)