This is the preliminary SPA Position Paper on the Draft Saline Valley Hot Springs Management Plan. This paper represents the combined opinions of the Board Members. Many facets of this Management Plan are still unclear to us, so our position may evolve or change between now and the deadline for public comments as we learn more about this Plan. The upcoming Public Meetings will offer us the opportunity to do more learning.
Meanwhile, remember that SPA represents the User Community. Your input will be welcomed as we try to sculpt our final response. If you have an opposing viewpoint, feel free to speak up. All responsible suggestions will be considered. This is our last chance to influence the management of the Saline Valley Warm Springs. Speak your piece or forever hold your peace.
We’ve known that this draft plan was coming. The SPA Board has listed their support, opposition, and concerns in regard to the Saline Valley Warm Springs Draft Management Plan & EIS (Draft Management Plan).
SPA questions holding Informational Open Houses over the Memorial Day weekend, which is prime vacation time for most families. This will cause many of the User Community to miss these informational meetings. The National Park Service (NPS) should consider extending the comment period beyond July 2, 2018, so that those who are able to attend the meetings can update the User Community.
SPA opposes fencing the entire area between the Lower Springs and the Palm Springs as outlined “Under alternative 5, the fencing to restrict feral burro access would be installed around the disturbed areas of Lower Spring and Palm Spring (figure 15). The fencing would encompass approximately 140 acres and the perimeter would require approximately 3.7 miles of fencing. (page 134-135 of the Draft Management Plan). The NPS clearly states, “The park has a “no burro or wild horse” goal and has a three-phase strategy to remove all wild horses and feral burros from the park, as stated in the park’s 2002 General Management Plan, “(page 12 of the Draft Management Plan). Fencing 140 acres with a perimeter of approximately 3.7 miles would be a waste of valuable resources, an eyesore to the visitors who come to this oasis for the majestic open view of our land, and with the planned removal of the burro population, entirely unnecessary. SPA recognizes the need to remove the feral burros and supports the NPS Plan to remove the feral burros.
SPA is not opposed to the “installation of the artistic wooden fencing around the source springs at Lower and Palm Springs (figure 12). The perimeter of the four sections of fencing at Lower Springs would be approximately 0.072 mile (301 feet) and 0.014 mile (74 feet) at Palm Spring, encompassing a total of approximately 0.044 acre. installing artistic fencing to surround the source springs at the Lower and Palm Springs, and the settling pond to prevent access to water sources by feral burros as outline in Alternative 2” (page 127 of the Draft Management Plan).
SPA is opposed to the removal of the pipe from the burro springs. This supplies water to a riparian zone that benefits everyone and everything. A lot of native trees have been lost through the years due to water diversion or non-native trees. The trees growing in the new riparian zone are a native species of mesquite. The wildlife (coyotes, ravens, kangaroo rats, migratory birds and water fowl) will also lose out a result of this removal of this siphon; aka pipe. SPA is not opposed to the removal of the trough.
SPA opposes “the removal of campsites within 200 feet of source springs” (page 21 of the Draft Management Plan). The source springs are above ground level and not subject to contamination run off. In addition, the NPS installed pit toilets further prevent any fear of contamination from buried waste. The removal of campsites within 200 feet from source springs is excessive and would reduce camping areas by 6 acres. SPA supports the current policy of campsites no less than 100 feet of source springs.
SPA is not opposed to the removal of nonnative palm trees from the upper springs. SPA does question the NPS definition that, “the palm trees are invasive, meaning that their presence at the Saline Valley Warm Springs could cause harm. Bird and coyotes carry the seeds of these nonnative invasive palms to other riparian areas” (page 45 of the Draft Management Plan). All palm trees including the ones at the upper springs were human planted and SPA sees no evidence of palm trees growing in other areas of the desert that were NOT human planted.
SPA supports the NPS plan to not remove nonnative palm trees at the Lower and Palm Springs, but as they die they would not be replaced with nonnative palm trees.
SPA is opposed to the removal of the lawn. The lawn was installed in 1955 and as stated in the plan, “the removal of the lawn, a contributing feature of the area of historic significance, could diminish the ability of recreational users to use this as a gathering point and activity area,” (page 112). The lawn is an integral part of the Saline experience. The lawn is not invasive, it needs water to survive. SPA does recognize the need for proper storage and containment of fertilizer.
SPA is opposed to the removal of the vehicle support facility. The NPS talks about the importance of human safety and yet they state, “the remoteness of the area and the time it takes for park personnel to travel to the warm spring make the response times approximately 2 to 6 hours depending on the availability of personnel’”(page 67 of the Draft Management Plan). SPA believes retaining the vehicle support facility provides good support, assists with human safety and reduces the reliance on scarce resources. The camp host should have the ability to patch a flat tire, rather than leave someone without a spare or have Miller towing come out at $200 per hour. SPA is not opposed to OSHA approved storage bins for hazardous materials and clean-up of the vehicle support facility.
SPA is not opposed to dispersed camping in designated areas, but is opposed to designated campsites. The NPS talks about overflow parking during high use, but SPA has not seen a time when there was not adequate camping. SPA would support mapping or even paddle markers “to limit sprawl into undisturbed areas and wide-spread impact from car camping,” (page 85 of the Draft Management Plan).
SPA opposes the overnight permit process as presented in this plan. It is vague, confusing and a hardship for visitors. Saline Valley is remote and requiring visitors to drive hundreds of miles to a NPS Visitor center is not practical. There is mention of an “online system” of permitting, but currently there is no “online system”. In addition, how is the overnight permit going to be enforced?
SPA is not opposed to the removal of user-created fire rings or the installation of, “NPS-provided fire enclosures, grills, or firepans,” (page 20 of the Draft Management Plan). SPA is not opposed to the requirement of users to haul out their ash and charcoal from fires at individual campsites.
SPA is not opposed to signage and filters at the dishwashing stations, but questions who will pay for the filters and who will be in charge of changing them.
SPA has no opinion on the Chicken Strip.
SPA is not opposed to OSHA approved containers for bleach and cleaning supplies. In fact, if the NPS had mentioned their concern in any of the meetings they’ve had with SPA, we probably would have already solved this “problem”.
SPA strongly supports an additional pit toilet at the Palm Springs.
The core visitors of Saline Valley have developed and maintained the area for over 80 years using their own time, resources and money. New visitors to the area are surprised at how clean the area is and find it hard to believe it is all maintained by volunteers and the camp host. When SPA met with NPS, they too remarked how clean the area was following the highest use President’s day weekend. “Park personnel have described the community as effective in handling instances of unruly or loud visitors and visitors who do not follow the general camp cleanliness guidelines,” (page 67 of the Draft Management Plan).
“The Saline Valley Warm Springs area of historic significance is also recommended significant under Criterion A for social history and an “area of historic significance for the recreational users. Populated by a segment of American society that had become disillusioned with the political and social establishment. At present, the site seems to be overlaid with the many layers of countercultural beliefs of its users,” (page 10 of the Draft Management Plan).
When the NPS sought “public comment” during their Scoping Plan from June to August 2012, the majority of the comments were to “leave the place as it is, or to return it to BLM.”
When the NPS sought “public comment” during their “Report of Alternatives,” from February to April, 2014, 85% of the comments were in support of Alternative 1 “no action” or Alternative 2 Regulatory Compliance. Only 11% of the comments were in support of Alternative 3.
Other than, “public comment” the core visitors to Saline Valley were not consulted by NPS.
The Saline Valley Preservation Association (SPA) was established in 1986 as a 501 nonprofit and has a membership base of approximately 1,070. SPA was mention once on page 109 in the 382 pages of the Draft Management Plan. “February 2001, a former Death Valley National Park Superintendent, and a former SPA President signed a memorandum of understanding (MOU). This MOU defined certain volunteer efforts that were provided by members of SPA including reasonable care, sanitation, public safety, public information, mutual communications, resource conservation, and visitor use (SPA 2001). This MOU expired in 2006 and has not been renewed.”
SPA supports establishing or renewing the MOU with the National Park Service. From 2006 to the present SPA has sought two way communications with NPS. SPA knew the management planning was mandatory and wanted to be included in the Draft Management Planning. SPA was not invited to meet with the NPS until November 11, 2016 and only then it was a formality and an opportunity to introduce ourselves and let the NPS know that SPA wanted to work with them in the future regarding the NPS management plan and EIS.
SPA recognizes that, “ Saline Valley was designated as one of these special use areas in which tribal members are “authorized to use these areas for low impact, ecologically sustainable, traditional practices pursuant to a jointly established management plan mutually agreed upon by the Tribe, and by the National Park Service,”(page 7of the Draft Management Plan). SPA is opposed to the lack of transparency with regard to the development, language and intent of the established management plan between the Tribe and the National Park Service. NPS talks about co-management of Saline Valley with the Tribe, but does not specify what that would entail. NPS talks about allowing for traditional practices, but doesn’t indicate what those might be. To date, SPA has not seen even a draft of this plan. According to “the Index’” (page 213 of the Draft Management Plan) the Timbisha Tribe and/or an MOU with the Timbisha are mentioned on 55 pages of the 382 pages of the Draft Management Plan.
In conclusion, these are the concerns and issues that have been identified by the SPA Board. If you chose to include these in your comments or letters, please do so in your own words. It’s important that your letters appear genuine and not just cut and pasted from some list of talking points.