Background Paper: More Science Needed for Great Basin

Ground-water Pumping Project

Summary:

More science is needed before Southern Nevada Water Authority (SNWA) is permitted to begin pumping ground-water from valleys on the west and east sides of Great Basin National Park (GBNP). This is the only certain way to protect the resources of GBNP. The Coalition of National Park Service Retirees (CNPSR) urges that:

1.              The U.S. Geological Survey (USGS) conduct or approve additional science sufficient to predict accurately the effects of proposed pumping on GBNP; and

2.              The Nevada State Water Engineer hold in abeyance the SNWA water rights applications until effects of the proposed pumping on Great Basin NP are better known.

The Proposed Project:

Southern Nevada Water Authority (SNWA) proposes to pump up to 180,000 acre-feet per year (af/y) from rural Nevada and Utah in order to meet Las Vegas’ growing water needs---including 91,220 af/y from Spring Valley immediately west of GBNP and 27,512 af/y from Snake Valley east of GBNP.

The Nevada State Water Engineer

Hearings were held in September of 2006 before the Nevada State Water Engineer who will determine whether to grant any or all of the Spring Valley water rights applications filed by the SNWA for the proposed project.

The 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.

The USGS “BARCASS I and BARCASS II”: A joint USGS and Desert Research Institute “Basin and Range Carbonate Aquifer System Study”(http://nevada.usgs.gov/barcass/ “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 at http://water.nv.gov/hearings/spring_valley_hearings/August 4th/)

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 at http://water.nv.gov/hearings/spring valley hearings/)

Myers Report: Hydrogeology of Spring Valley:

Dr. Tom Myers, Hydrologic Consultant, published results in June 2006 using his ground-water model for the Spring Valley basin. (Western Environmental Law Center’s Exhibit #3001 at the above website.) The report concludes: “The water rights applications of the Southern Nevada Water Authority in Spring Valley will, if granted as requested, lower the water table in Spring Valley by more than 200 feet within 100 years…Discharge to springs and wetlands will drop by a third within 100 years. Points of interest defined for protecting sensitive species will also be affected. Shoshone Ponds and springs on Sacramento Pass will be affected significantly in less than 20 years.” His report also states: “Monitoring and mitigation is not likely to prevent unacceptable impacts to the springs and groundwater levels. Water levels recover very slowly from just 100 years of pumping…”

U.S. Fish and Wildlife Service (USFWS) estimates:

Dr. Roger Congdon of USFWS estimated effects using the generalized, regional USGS model (Schaefer and Harrill, 1995) and reported that “water table levels in the alluvial aquifer could decline by 200 feet or more following 200 years of pumping at the proposed rates” and “there would be a residual cone of depression remaining for at least 100 years following cessation of 200 years of pumping at the proposed rate. Potential effects to local water resources could persist through much of the recovery period.”(Exhibit #2001 at the above website)

Environmental Impact Statement:

The Environmental Impact Statement (EIS) for the ground-water pumping project, managed by the Bureau of Land Management (BLM), is expected to take until 2008. The EIS will “analyze the potential environmental and human resources that could be affected by the SNWA proposal to develop groundwater resources on public lands in rural Clark, Lincoln, and White Pine counties”. Without accurate predictive estimates of the effects of pumping, it is difficult to know how BLM will complete its analysis.

Department of Interior (DOI) Stipulated Agreement with SNWA:

On the eve of the hearings before the Nevada State Engineer on 9/11/06, four DOI agencies---NPS, USFWS, Bureau of Indian Affairs (BIA), and BLM---withdrew their protests against the Spring Valley water rights applications filed by SNWA, in exchange for stipulated monitoring, management and mitigation to be conducted primarily by SNWA. (At above website, see

“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 (like those cited above).

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.

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Prepared for the Coalition of National Park Service Retirees 9/28/06