The following is the comment letter that SPA send via the USPS to the NPS on 6/15/18. All comment letters need to be emailed or post marked by July 2, 2018. Each SPA member has also submitted an individual comment letter to the NPS. We encourage anyone that has not already done so to send in or email their comment letter. You are welcome to use the content we used, but try and put it in your own words. This letter is long and you can use all, none, or some of it "as you see fit". The important thing is to make yourself heard!
You can post your comment letter via email to Comment Form to NPS
or send it via the US Postal Service to Superintendent Mike Reynolds, Death Valley National Park, P.O. Box 579, Death Valley, CA 92328
Saline Preservation Association (SPA)
P.O. Box 1941
Lancaster, CA 93539-1941
June 15, 2018
Mr. Mike Reynolds
Superintendent, Death Valley National Park Service (NPS)
P.O. Box 579
Death Valley, CA 92328
Dear Superintendent Reynolds:
The Saline Preservation Association (SPA) is a503(c)(3) non-profit organization providing an informational conduit as well as advocacy between and among governing agencies and the widely diverse community who visit the Saline Valley and its Warm Springs. SPA is deeply committed to the preservation of the area as well as good relationship with concerned stakeholders. SPA has approximately 1,400 members, who visit Saline Valley from almost every state in the United States as well as international locations. Our organization is diverse with respect to race, color, religion, creed, sex, sexual orientation, national origin, ancestry age, veteran status, disability and military service.
The SPA Board (7 elected members) has read the Draft Management Plan / Environment Impact Statement (EIS), attended all NPS Informational meetings, and vetted the following comments through the SPA membership. SPA commends the NPS recognizing Saline Valley Warm Springs Site as eligible for listing in the National Register of Historic Places (NRHP), however the NPS should continue the current planning process until a Cultural Landscape Inventory and Report are prepared as recommended by the Determination of Eligibility (DOE).
The Draft Management Plan / EIS have 1 through 4 Alternatives in regard to the proposed NPS management of Saline Valley. Alternative 5 is considered by NPS to be the “preferred alternative”. The NPS stated in their Information Meeting that Alternative 5 was an option and that similar to the Draft Management Plan / EIS other Alternatives may be considered. SPA believes, many of the proposed issues in Alternative 5 would have an adverse impact to the unique recreational, social, ethno-historic and cultural experience of Saline Valley. SPA has created its own SPA Alternative (attached) that incorporates components of Alternatives 1, 2 and 3. SPA seeks to preserve the unusual degree of magic, freedom and ownership people feel when visiting Saline Valley. This directly correlates to contribution, self-sufficiency, and the desire to help out when things need to get done.
Listing for Historic Preservation
The Historical Section of the Draft Management Plan / EIS notes that: “As of September 2017, consultation with the State Historic Preservation Officer (SHPO), tribes, and the public are ongoing; however, the park is treating the Saline Valley Warm Springs Site as eligible for listing in the NRHP, as previously stated. The historic DOE also recommended that a Cultural Landscape Inventory and possibly a Cultural Landscape Report be prepared for the Saline Valley Warm Springs Historic Site (New South 2015),” (page 62).
SPA strongly encourages the NPS to wait until a Cultural Landscape Inventory and Report are prepared, and determination is made about formal status under NRHP, – before finalizing the Draft Management Plan / EIS. Many of the components of Alternative 5 specify plans to remove those very features that are core to the cultural experience of what exists today, and upon which such a determination rests.
Feral Burros and Proposed Fencing
SPA shares the concerns stated in the Draft Management Plan / EIS about the feral burros. However, we believe that this problem can be successfully done WITHOUT the need for an expensive fence around the entire area. SPA supports artistic fencing around the source pools and settling pond, Alternative 2. Rather than removing the Burro Spring and killing the native mesquite trees, SPA would install a heavy screen over the Burro Spring trough, leaving the siphon hose in to water the mesquite. This would effectively keep most water sources away from the burros. This is outlined in the SPA Alternative, Feral Burro Access. SPA does not want to put fencing around the tubs themselves as proposed in Alternative 3 as that would take away from the “Saline Experience” and “wild feral burros” would not venture to a water source with people in them.
Additionally, SPA feels that fencing the entire area as proposed in Alternative 5, would harm native non-burro wildlife. The fence would also be subject to possible vandalism, not to mention flash flooding, which would leave dangerous fence debris in the environment. This could create a long term hazard if NPS lacked funding to adequately remove and/or maintain the fence. NPS stated during informational meetings, the difficulty of acquiring maintenance funding. The addition of the fences as proposed in Alternative 5 will become a maintenance resource drain.
To keep people from feeding the burros, SPA will initiate an aggressive educational campaign, similar to the successful campaign that stopped people from feeding the bears in the Mammoth area. SPA proposes to absorb the costs of pamphlets, bumper stickers and posting “don’t be an ass, don’t feed our burros,” on the forum and email that message out to the SPA members.
SPA urges the NPS to give a priority to relocating the habituated burros at the Warm Springs. There are only about 10 of them. They would be easy to capture and easy to find homes for since they are so domesticated and accustomed to people. Our experience is that feral burros elsewhere in Saline Valley are not habituated and avoid humans. We think that it is unlikely that they will invade the Warm Springs area.
Non Native Vegetation
SPA strongly opposes the removal of the lawn and palm trees. This includes the living state as well as after they die. SPA agrees the palm trees and lawn are nonnative, but they are NOT invasive. Both palm trees and lawn cannot survive without regular water. To date there is no evidence of palms or lawn anywhere else in Saline Valley. Planting other types of trees would negatively change the look, feel, and ecosystem at the Warm Springs. There are no native tree species which could be substituted for the palm trees that will provide equivalent benefits. The palms may not be native to this area, but are naturalized and are present in desert regions across California, (and in fact are an integral visual aspect of the NPS Furnace Creek Visitor’s Center. The Draft Management Plan / IES (page 81) attempts to compare containing the spread of palm trees to containing the spread of saltcedar (tamarisk). Tamarisks are invasive, and should be removed. Palm trees are containable.
The lawn is a central gathering place for the users of the Warm Springs. It is the heart for socializing, potlucks, sharing road and other safety information, educating new visitors about the warm springs, and other important connections. The lawn provides major benefits and will not spread, because there is no water elsewhere. The lawn and palm trees are clearly part of the ethno-historic experience of Saline Valley.
SPA would propose a program monitoring palm tree development in Saline Valley and would eradicate those trees if they were to be discovered in other parts of Saline Valley. SPA would also apply the same attention to the lawn. SPA is not opposed to the removal of the palm trees at what NPS refers to as the upper fenced springs and strongly supports the removal of tamarisk.
SPA is strongly opposed to the proposed requirement of a permit prior to arriving at the Saline Valley. During the NPS Informational meetings it was said there was not a specific permitting plan. There are too many unanswered questions, including: who will enforce this permitting system, who will administer the permits, how to obtain them and do they meet basic cost-benefit analysis. If the goal of the permit is to “keep track” of visitors and “impart park regulations” SPA would work with NPS on visit censuses and informational signs about regulations.
If a permit system is implemented, SPA wants to ensure permits stay free, easily accessible online, and onsite for the visitors of the Saline Valley that come out and decide to stay or those that plan their vacation around visiting Saline Valley. Online permitting is challenging as much of the Park does not have cell service. SPA has kept visitor counts for 10 years and would argue that even during high use times; there was always enough camping space available.
SPA is strongly opposed to any future permit fee. This would undermine the very stewardship visitors have in Saline Valley. By imposing a fee, visitors are now “renting” their space in Saline Valley. The expectation would be that the NPS is now the landlord and responsible for the care and maintenance of Saline Valley. Does NPS expect the users to pay a fee and donate items, time and effort for its upkeep? SPA believes this would create a problem where one currently does not exist. Saline Valley has existed for decades at no cost, by the volunteers that visit it. Further, a fee could discriminate against many of the long time users that lack the recourses to pay such a fee, but are willing to donate time and effort for its maintenance. SPA would also bring attention that an NPS permit fee could violate 36 CFR 71.9 (attached), which specifically forbids the collection of a fee unless the NPS provides potable water, refuse containers, and someone onsite to collect the fees. Bottom line, don’t make Saline Valley a developed campground, don’t impose a fee.
Stewardship of Recreation Elements by NPS Partners
SPA supports the component of Alternative 3 “Stewardship of Recreation Elements by NPS partners”. From 2001 to 2006 SPA had a memorandum of understanding (MOU) with Death Valley National Park. SPA would like to negotiate another MOU concerning the Saline Valley Warm Springs area. This would focus on keeping the Saline Valley Warm Springs as close as possible to the current experience, minimal maintenance of tubs and campsite maintenance.
SPA strongly supports Camping Areas in Alternative 2, unrestricted dispersed camping areas and strongly opposes designated camping. Currently campers chose sites when they arrive based on site-specific needs, the weather and wind conditions, their particular vehicle type, and accessibility to various amenities such as pools or lawn. SPA supports defining camping boundaries, but assigning campsites is not workable. Please keep the camping as it is – it works.
SPA is opposed to the increasing the distance from camping 100 feet to 200 feet from the source springs. During all of the NPS Informational meetings the issue of camping no closer than 200 feet from the source springs was brought up. At all of the NPS Information meetings, the NPS stated this was a “misprint” and the NPS meant to stay with its current rule of, “no camping within 100 feet of a source springs”. SPA would like something in writing to assure them that the no camping within 100 feet of a source springs (NPS current policy) will continue.
SPA supports the NPS Campfires section, as proposed in Alternative 3 NPS-provided fire enclosures, grates, grills or fire pans. Given a choice of the aforementioned, SPA supports non anchored, heavy NPS fire pits. SPA will work with NPS for the removal of fire pits that are not NPS-provided, as well as to educate the user community.
SPA supports the Toilet Management section as proposed in Alterative 3 requiring the pumping of vault toilets on an “as needed” basis. SPA also highly recommends the addition of another vault toilet at the Palm Springs. This could be accomplished for the price of the proposed fence around the entire area. The fence as stated above is unnecessary, but another vault toilet for the Palm Springs should be an NPS priority.
SPA would propose this alternative
be changed to Emergency Vehicle Assistance and remain during the tenure of the current camp host. SPA would encourage the NPS to clearly post signage at the end of pavement that there is no emergency vehicle assistance beyond this point. This may encourage visitors to be self-sufficient. That said, having Emergency Vehicle Assistance is a health and safety issue and its removal should be considered in that context.
SPA supports dishwashing stations. However we feel the need for filters to be unnecessary. Filters do not address any issues brought up in the management plan. However, if that is what is required to continue having dish washing stations, filters would be acceptable. SPA supports signage warning visitors the dishwashing water is non-potable. SPA will encourage the use of biodegradable dishwashing liquids.
Co-Management with Timbisha Shoshone
SPA understands the NPS and Timbisha Shoshone are working on a co-management plan. NPS stated at four Informational Meetings held over the last week of May that the co-management plan would not supersede the Draft Management Plan / EIS. Neither SPA nor any SPA member has been included in the co-management plan and its content, scope, and / or interaction within the Draft Management Plan / EIS. Therefore it’s difficult to comment on this issue. The Draft Management Plan / EIS states,
“The waters of the warm springs in Saline Valley are a source of puha for the Tribe, a life force energy.”
In this context, SPA supports Nonnative vegetation section of Alternative 3, only as it pertains to the upper springs. This would return the Upper Springs to its natural state. This might allow traditional use of the Upper Springs by the Tribe.
The maintenance of the Saline Valley has been done successfully by volunteers, in cooperation with a volunteer Camp Host, for decades. Each visitor to the Saline Valley has understand that he/she is a volunteer, with the responsibility of policing the area, observing guidelines for proper food storage and disposal of trash, and helping with the cleaning of the pools and outhouses. The more the NPS relies on explicit rules and regulations, the less likely visitors will feel that the Warm Springs are their responsibility to be maintained on a voluntary basis. If visitation increases owing to expanded publicity and recognition of the Saline Valley as a National Park destination, newly arrived visitors, uninformed about the tradition of volunteerism, may take the attitude of “let the government take care of it,” rather than taking responsibility for minimizing their individual impact. Signage and rules and permits cannot accomplish as much as the traditional culture of cooperation and mutual responsibility that has characterized the Saline Valley throughout its history.
Any Management Plan must seek to encourage a continuing spirit of volunteerism and individual responsibility.
President, Saline Preservation Association
Attached 36 CFR 71.9
Attached SPA Alternatives
Cc: Mike Ramsey, SPA Treasurer
Michelle Hamilton, SPA Secretary
Tim Hynes, SPA Director
Fred Dickson, SPA Director
Gary Kremen, SPA Director
Bonneau Dickson, SPA Director