Wells-to-Guzzlers Environmental Assessment page 1 of 43 

ENVIRONMENTAL ASSESSMENT for

a Proposal to Convert 12 Ranching Wells 

into Wildlife Guzzlers 

Mojave National Preserve, California 

Mojave National Preserve 

2701 Barstow Road 

Barstow, CA 92311 
Wells-to-Guzzlers Environmental Assessment page 2 of 43 

TABLE OF CONTENTS 

SECTION I: PURPOSE OF AND NEED FOR ACTION ................................... 3 

Introduction ................................................................ 3 

Purpose and Need ............................................................ 3 

Background .................................................................. 3 

Related Laws, Policies, and Other Planning Documents ........................ 7 

Environmental Assessment .................................................... 8 

Issues and Impact Topics .................................................... 9 

Issues and Impact Topics Identified for Further Analysis .................... 9 

Impact Topics Considered but Dismissed from Further Consideration............ 11 

SECTION II: DESCRIPTION OF ALTERNATIVES ..................................... 13 

Introduction ................................................................ 13 

Alternative A (No Action) ................................................... 13 

Alternative B (Proposed Action) ............................................. 14 

Alternative C (Science-Based Management) .................................... 15 

Elements Common to All Alternatives ......................................... 15 

Alternatives Considered but Eliminated from Further Evaluation .............. 15 

Environmentally Preferred Alternative ....................................... 17 

Impairment .................................................................. 17 

SECTION III: AFFECTED ENVIRONMENT ........................................... 19 

Introduction ................................................................ 19 

Location and General Description of Mojave National Preserve and the Project 

Area ........................................................................ 19 

Physical Resources .......................................................... 19 

Biological Resources ........................................................ 21 

Cultural Resources .......................................................... 22 

Use of the Preserve ......................................................... 23 

SECTION IV: ENVIRONMENTAL CONSEQUENCES ...................................... 24 

Introduction ................................................................ 24 

Methodology ................................................................. 24 

Criteria and Thresholds for Impact Analyses ................................. 24 

Criteria and Thresholds for Impact Analyses of All Other Issues ............. 25 

Impairment Analysis ......................................................... 25 

Cumulative Effects .......................................................... 26 

Alternative A (No Action) ................................................... 27 

Alternative B (Proposed Action) ............................................. 29 

Alternative C (Science-Based Management) .................................... 32 

Environmentally Preferred Alternative ....................................... 34 

SECTION V: COORDINATION AND CONSULTATION .................................... 37 

SECTION VI: LIST OF PREPARERS ............................................... 38 

SECTION VII: REFERENCES ..................................................... 38 

LIST OF FIGURES 

Figure 1. Mojave National Preserve .......................................... 4 

Figure 2. 12 Wells Proposed for Conversion to Guzzlers ...................... 5 

LIST OF TABLES 

Table 1. Comparison of Impacts .............................................. 35 

APPENDICES 

Appendix A. Minimum Requirements Analysis ................................... 39 

Appendix B. National Park Service Press Release ............................. 43 
Wells-to-Guzzlers Environmental Assessment page 3 of 43 

SECTION I: PURPOSE NEED FOR FEDERAL ACTION 

INTRODUCTION 

California Department of Fish and Game (CDFG), in cooperation with the National 

Park Service (NPS), has proposed to retrofit 12 ranching water developments into 

wildlife guzzlers. The existing wells were originally installed and operated 

for cattle ranching. Most of the larger cattle grazing leases in Mojave 

National Preserve have been retired; in consequence, use of the associated wells 

has been discontinued and in many instances windmills, pump jacks, and other 

equipment have been removed by the ranchers. 

PURPOSE AND NEED 

The National Park Service is considering the issuance of a special use permit 

to facilitate a proposal from CDFG to reactivate historic man-made water 

sources for wildlife use. CDFG has proposed to redesign the water developments 

into wildlife guzzlers. CDFG has identified the need to augment the existing 

population to return wildlife populations to pre-well removal and/or shutoff 

conditions and numbers. Drought conditions over the past decade have 

increased the urgency to implement this proposal. 

This environmental assessment (EA) addresses wildlife water needs in Mojave 

National Preserve. It examines natural and artificial sources of water. The 

CDFG proposal is assessed in comparison with other alternatives to consider a 

range of options and effects on wildlife and the surrounding environment. The 

EA considers the advisability of obtaining more information in order to 

adequately define the water needs of wildlife in Mojave National Preserve. 

BACKGROUND 

History of Cattle Ranching in the Mojave Desert, California

Cattle have been grazed in the Mojave Desert for over 100 years. Cattle 

ranching in the desert uses a system of water developments to move animals 

between various areas of forage to avoid over-utilization and maximize livestock 

production. The rancher turns off the water in one area and turns it on in 

another to move cattle within the allotment. When the wells are turned on 

through the use of windmills, pumps, generators, and so forth, water fills into 

a watering trough or other similar basin above ground. The watering troughs 

remain filled as long as the wells are turned on. Troughs are allowed to go dry 

when not in use. 

When the California Desert Protection Act was passed in 1994, it established the 

rights of cattle ranchers to continue grazing at their 1994 levels. Since then, 

several ranchers have willingly sold their lands and grazing rights. Most of 

these lands have been donated to the US Government and the associated grazing 

allotments have been retired. The ranchers have the right to remove their 

personal property, including range improvements (Public Law 91-646, as amended). 

Range improvements would include fences, water tanks, pipelines and windmills 

(43 CFR 4120.3-6 Removal and compensation for loss of range improvements). 

Because the above-surface materials are being relocated elsewhere, the ranchers 

have shut off the wells that were providing the water for cattle. Ranchers have 

been removing their personal property since 2001. 
Wells-to-Guzzlers Environmental Assessment page 4 of 43 

Figure 1. Mojave National Preserve 
Wells-to-Guzzlers Environmental Assessment page 5 of 43 

Figure 2: 12 Ranching Water Developments 
Wells-to-Guzzlers Environmental Assessment page 6 of 43 

Wildlife Management Policies in Mojave National Preserve

Wildlife management at Mojave National Preserve is summarized in the Preserve’s 

General Management Plan (April 2002). Consistent with existing laws and 

policies, the GMP identifies Mojave’s wildlife management goal to preserve and 

protect native wildlife and their natural habitat such that they support selfsustaining populations of native species. 

Wildlife Guzzlers and other Artificial Water Developments in Mojave National 

Preserve

Six big game guzzlers were installed in the East Mojave National Scenic Area in 

the 1970s and 1980s. They are located on Old Dad Peak (3), Kelso Peak, Piute 

Peak, and Clark Mountain. There are also 133 small game guzzlers scattered 

throughout Mojave. An NPS survey team was able to relocate 117 of these and 

assess their condition in 2004. 

These guzzlers were installed over the last 70 years by agencies and interest 

groups prior to the creation of Mojave National Preserve. Their purpose is to 

enhance or replace natural waters otherwise used for livestock, for use by 

wildlife. California Department of Fish and Game and volunteers have performed 

periodic maintenance on some of the guzzlers. 

The GMP also addresses wildlife guzzlers in Mojave. It allows for the continued 

maintenance and repair of existing artificial wildlife watering facilities – 

130-plus small game guzzlers and six big game guzzlers in 1994 – for native 

wildlife if found necessary to replace water lost due to previous human 

activities. In particular the GMP states: 

“Simultaneously, with the retention of these developed water sites, the 

National Park Service will actively begin to restore natural water sources 

to be self-sustaining. When a water source becomes self-sustaining, the 

artificial facility will be removed. The National Park Service has no 

jurisdiction over developed water sites on private land.” (April 2002, p. 

70) 

Natural Water Sources in Mojave National Preserve

Numerous seeps and springs occur in Mojave National Preserve. Depending on 

rainfall these water sources can number from over 100 to almost 200. During 

droughts many of these springs are reliable, perennial water holes including: 

Piute Spring fed by recharge in the New York Mountains and storage in the 

alluvium of Lanfair valley, Soda Springs along the edge of Soda Dry Lake near 

the terminus of the Mojave River drainage, and Cornfield Spring fed by mountain 

front recharge in the Providence Mountains. Several regional water table 

aquifers extend partially into the park. The largest groundwater system in 

Mojave is the northerly extension of Fenner Valley. The total area of the 

Fenner Valley watershed is about 1100 square miles with about half inside the 

park boundary. Recharge to this system occurs primarily in the park at a rate 

estimated between 5000 and 70,000 acre-feet per year. East of this is the 

Lanfair watershed. Lanfair is the smallest groundwater system, 225 square 

miles, entirely within the park but is important for resources because of its 

approximately 150 gpm discharge to Piute Spring. About 90% of the Kelso 

groundwater system, approximately 650 square miles in area, is inside the park 

and supplies water to the park’s main Visitor Center and to the Union Pacific 

Railroad. About half of the lower Mojave River system, with an area of about 

950 square miles, lies within the park boundary while the remainder is up 
Wells-to-Guzzlers Environmental Assessment page 7 of 43 

gradient from the Preserve. This is the water supply for the town of Baker, the 

park’s maintenance and employee housing, and the Desert Studies Center at Zzyzx. 

The north side of the park falls within the Ivanpah system, comprising an area 

of 435 square miles, about half of which lies inside the park boundaries. This 

system supplies water to a cluster of casinos at Primm on the Nevada state line 

and to the Mountain Pass mine in California. Finally, a corner of the Shadow 

Valley system, lies within the park and provides groundwater supplies to a gas 

station and a private residence. 

Many small springs and seeps are fed by shallow, perched aquifers typically 

associated with the margins of mountainous areas. Since the volume of water in 

these perched zones is small, they are much more responsive to changes in 

precipitation -- flowing extensively during wet years and going dry during 

extended droughts. Nearly all ephemeral and perennial sources of water in the 

park have been modified extensively historically. Modifications include 

tunneling, hand dug wells, drilled wells, dams in drainage channels, excavated 

earthen catchments, and pipeline diversions. 

Regardless of whether they have been altered, most water sources are available 

for wildlife use. The small springs and seeps are used by plants, wildlife, and 

for domestic or commercial purposes. The National Park Service is currently 

studying wildlife use of developed and undeveloped water sources in Mojave 

National Preserve. Up to 32 infrared-triggered cameras are being installed at 

various locations to record wildlife activity at these locations. Data will be 

collected with the cameras and through direct staff observation during the 

driest season. Data collection by these means began in 2005. 

The California Department of Fish and Game believes the retirement of grazing 

allotments in Mojave National Preserve in the past five years has had a 

detrimental effect on wildlife populations. Because of these retirements and 

the shut-offs of associated ranching wells, CDFG has asserted, “it is critical 

to wildlife conservation within the Preserve to have many of these historical 

water sources reactivated by utilizing more appropriate technology in the form 

of wildlife guzzlers” (August 30, 2004 letter to Mary G. Martin, 

Superintendent). 

RELATED LAWS, POLICIES, AND OTHER PLANNING DOCUMENTS 

Servicewide and Park Specific Legislation and Planning Documents 

The NPS Organic Act directs the NPS to manage units “to conserve the scenery and 

the natural and historic objects and the wildlife therein and to provide for the 

enjoyment of the same in such a manner as will leave them unimpaired for the 

enjoyment of future generations” (16 U.S.C. § 1). Congress reiterated this 

mandate in the Redwood National Park Expansion Act of 1978 by stating that the 

NPS must conduct its actions in a manner that will ensure no “derogation of the 

values and purposes for which these various areas have been established, except 

as may have been or shall be directly and specifically provided by Congress.” 

The Organic Act prohibits actions that permanently impair park resources unless 

a law directly and specifically allows for the action(s). An action constitutes 

an impairment when its impacts “harm the integrity of park resources or values, 

including the opportunities that otherwise would be present for the enjoyment 

of those resources and values.” (NPS Management Policies 2001 1.4.3). 

NPS Management Policies 2001 also require the analysis of potential effects of 

each alternative to determine if actions would impair park resources. To 

determine impairment, the NPS must evaluate “the particular resources and values 
Wells-to-Guzzlers Environmental Assessment page 8 of 43 

that would be affected; the severity, duration, and timing of the impact; the 

direct and indirect effects of the impact; and the cumulative effects of the 

impact in question and other impacts.” (NPS Management Policies 2001 1.4.4). The 

NPS must always seek ways to avoid or minimize, to the greatest degree 

practicable, adverse impacts on park resources and values. However, the laws do 

give the NPS management discretion to allow impacts to park resources and values 

when necessary and appropriate to fulfill the purposes of a park, as long as the 

impact does not constitute impairment to the affected resources and values (NPS 

Management Policies 2001 1.4.3). 

NPS units vary based on their enabling legislation and mission, their natural 

and cultural resources, and the recreational opportunities appropriate for each 

unit, or for areas within each unit. This environmental assessment analyzes the 

context, duration, and intensity of impacts related to the alternatives 

associated with conducting bighorn sheep management activities, as well as the 

potential for resource impairment, as required by Director’s Order 12, 

Conservation Planning, Environmental Impact Analysis and Decision Making. 

Mojave National Preserve was created in 1994 with the passage of the California 

Desert Protection Act. In this enabling legislation, the Secretary of the 

Interior 

“shall permit hunting, fishing, and trapping on lands and waters within 

the preserve designated by this Act in accordance with applicable Federal 

and State laws except that the Secretary may designated areas when, no 

hunting, fishing, or trapping will be permitted for reasons of public 

safety, administration, or compliance with provisions of applicable law. 

Except in emergencies, regulations closing areas to hunting, fishing, or 

trapping pursuant to this subsection shall be put into effect only after 

consultation with the appropriate State agency having responsibility for 

fish and wildlife. Nothing in the Act shall be construed as affecting the 

jurisdiction or responsibilities of the States with respect to fish and 

wildlife on Federal lands and waters covered by this title nor shall 

anything in the Act be construed as authorizing the Secretary concerned to 

require a Federal permit to hunt, fish, or trap on Federal lands and 

waters covered by this title.” (PL 103-433 §506(b)) 

The 2002 General Management Plan (GMP) provides overall management direction for 

Mojave National Preserve. It also provides management direction for guzzlers. 

The Wilderness Act of 1964, NEPA (1969), and NPS Management Policies all 

require an assessment of the effects on wilderness values of actions within all 

designated, proposed, or potential wilderness areas. Director’s Order 41: 

Wilderness Preservation and Management (1999) provides guidance for the NPS 

wilderness management program and guides NPS efforts in meeting the letter and 

spirit of the 1964 Wilderness Act. 

Mojave’s enabling legislation designated approximately 695,200 acres of 

wilderness as components of the National Wilderness Preservation System. The 

legal descriptions and maps of the Mojave Wilderness are being finalized at 

present; they will eventually be filed with both houses of the US Congress. 

ENVIRONMENTAL ASSESSMENT 

The EA analyzes two action alternatives plus the No Action alternative and their 

impacts on the human and natural environment. It outlines project alternatives, 

describes existing conditions in the project area, and considers the effects of 

each project alternative on the environment. For alternatives that propose 

actions in wilderness, the EA documents the minimum requirements analysis and 
Wells-to-Guzzlers Environmental Assessment page 9 of 43 

explains the decision process for minimum tool. The EA has been prepared in 

accordance with the National Environmental Policy Act (NEPA) of 1969 and 

regulations of the Council on Environmental Quality (CEQ) (40 Code of Federal 

Regulations [CFR] 1508.9). 

ISSUES AND IMPACT TOPICS 

National Park Service management policies direct that all resources are 

protected in units of the National Park System and effects on those resources 

must be considered when selecting and implementing management actions. Issues 

are related to potential environmental effects of project alternatives and were 

identified by the project interdisciplinary team. Once issues were identified, 

they were used to help formulate the alternatives and mitigation measures. 

Impact topics based on substantive issues, environmental statutes, regulations, 

and executive orders (EOs) were selected for detailed analysis. A summary of the 

impact topics and the rationale for their inclusion or dismissal is given below. 

ISSUES AND IMPACT TOPICS IDENTIFIED FOR FURTHER ANALYSIS 

Soils: The ground surface may be disturbed during construction when tanks and 

drinkers are being installed. There is also a possibility of soil disturbance 

from trenching and burial of underground pipe or other equipment or by vehicular 

traffic associated with guzzler installation. Therefore, impacts to soils will 

be further analyzed. 

Water Resources: Surface waters are rare in desert landscapes, yet are critical 

for maintaining wildlife and accommodating human use. Groundwater resources are 

critical to the maintenance of surface waters and provide much of the water used 

for human consumption. Wetlands and floodplains are also critical water-related 

resources; there exist specific legal requirements for their protection 

(Executive Orders 11990 and 11988). Ranching operations in Mojave both drew 

ground water and diverted surface water from springs and seeps to water cattle. 

Water wells have been drilled for livestock needs, domestic use, and mining 

operations. The National Park Service maintains wells for visitor and 

administrative uses throughout the Park. Any proposal to resume use of these 

developments will have impacts on ground and surface waters. Therefore, impacts 

to water resources will be further analyzed. 

Wildlife: Individual animals, populations, and habitat have the potential to be 

affected by any alteration to water availability. In addition, among the 

comments received during the public scoping period was the suggestion that 

wildlife guzzlers could be used to facilitate the reintroduction of pronghorn 

antelope in the Mojave Desert. This issue requires further study and therefore, 

impacts to wildlife will be further analyzed. 

Vegetation: Vegetation can be both directly and indirectly affected by 

alterations to available water. Plant life is directly dependent on available 

water; the scarcity of water in a desert environment magnifies this 

relationship. Moreover, changes to the wildlife populations will affect the 

composition and abundance of associated plant life. Therefore, impacts to 

vegetation are further analyzed. 

Threatened, Endangered and Sensitive Species: The Endangered Species Act 

directs the National Park Service to consider the effects of management 

decisions on threatened and endangered species. There are four federally listed 

species that occur or might occur in the Preserve: the desert tortoise (Gopherus 

agassizii, known populations as well as designated critical habitat), the Mohave 
Wells-to-Guzzlers Environmental Assessment page 10 of 43 

tui chub (Gila bicolor mohavensis, known populations), the least Bell’s vireo 

(Vireo bellii pusillus, undetermined presence), and the southwestern willow 

flycatcher (Empidonax traillii extimus, undetermined presence). Arizona bell’s 

vireo (Vireo bellii arizonae) has been documented in the Preserve; it is a 

California state listed species. The Mohave tui chub is found only in two 

associated water sources at Soda Dry Lake and will not, therefore, be affected 

by alterations to available water elsewhere in Mojave. Desert tortoise, least 

Bell’s vireo, and southwestern willow flycatcher are all more directly affected 

by the availability of surface water. In addition, desert tortoise populations 

can be affected by the presence of surface water and the potential for 

entrapment and/or drowning in water catchment systems. Therefore, impacts to 

threatened, endangered, and sensitive species are further analyzed. 

Prehistoric, Historic, Cultural Landscape Resources: The National Historic 

Preservation Act directs parks to consider the effects of their management 

decisions on cultural resources. Mojave National Preserve has a rich ranching 

history in addition to ongoing cattle ranching operations. Any alterations to 

the historic cultural landscapes representing former ranching operations must be 

considered. Therefore, impacts to cultural resources are further analyzed. 

Visitor Experience: Mojave National Preserve is popular with visitors for 

wildlife viewing and for hunting. In accordance with the California Desert 

Protection Act, hunting is authorized in Mojave. California Department of Fish 

and Game determines and manages hunting seasons, regulations, permits, and tags. 

Because wildlife populations are affected by water availability, any shifts in 

such water may result in impacts to both game and non-game species and, 

therefore, to hunting and wildlife viewing activities. Therefore, impacts to 

the visitor experience are further analyzed. 

Development and Public Health & Safety: Mojave National Preserve has varied 

infrastructure including that found on public property in addition to numerous 

formerly private land holdings. The original twelve ranching water 

developments proposed for conversion were shut off when ranching operations 

ceased. CDFG desires to reopen and alter these water sources for wildlife use 

but the possibility of the water being used by humans must also be considered. 

Therefore, impacts to existing development are further analyzed. 

Park Operations: The National Park Service is working with California 

Department of Fish and Game to address water availability for wildlife in Mojave 

National Preserve. Under each alternative including No Action, Mojave commits 

to funding, equipment, and staff time. The level of such commitment varies 

according to each alternative. Therefore, impacts to park operations will be 

further analyzed. 

Wilderness: The Wilderness Act directs that parks consider the effects of their 

management decisions on designated wilderness. Nearly half of Mojave National 

Preserve, close to 700,000 acres, is designated wilderness. Although the twelve 

wells originally proposed for conversion to guzzlers are not in wilderness, 

other wildlife water facilities are. Impacts to wilderness under alternatives 

other than the proposed action need to be assessed. Therefore, wilderness and 

Minimum Requirements Analysis are discussed and the Minimum Tool defined where 

possible, based on available information. 

Minimum requirements analysis is a documented process used to determine the 

appropriateness of all actions affecting wilderness (NPS 1999). It is a two step 

process that documents 1) a determination as to if a proposed management action 

is appropriate or necessary for the administration of the areas as wilderness, 

and does not pose a significant impact to the wilderness resources and 

character; and, 2) if the project is appropriate or necessary in wilderness, the 
Wells-to-Guzzlers Environmental Assessment page 11 of 43 

selection of the management method that causes the least amount o impact to the 

physical resources and wilderness character. This document provides the minimum 

requirements analysis for converting wells to guzzlers. 

Directors Order/Reference Manual #41 directs that when determining the minimum 

requirements for a proposed action, the manager will strive to minimize the 

extent of adverse impact associated with accomplishing the necessary wilderness 

objective. The determination as to whether or not an action has an adverse 

impact of wilderness must consider both the physical resources within wilderness 

and wilderness characteristics and values. These characteristics and values 

include: the wilderness’s primeval character and influence; the preservation of 

natural conditions (including the absence of man-made noises); cultural resource 

values, the assurance of outstanding opportunities for solitude; the assurance 

that the public will be provided with a primitive and unconfined type of 

recreational experience; and the assurance that wilderness will be preserved and 

used in an unimpaired (NPS 1999). 

IMPACT TOPICS CONSIDERED BUT DISMISSED FROM FURTHER CONSIDERATION 

Some impact topics were considered but dismissed based on the CDFG’s proposal 

and their explanation of how the work is to be accomplished. For example, prime 

and unique agricultural lands were dismissed from further analysis because the 

lands in question have already been retired from grazing operations. These 

lands are now managed for their natural, historic and cultural values. 

Geology, Paleontology and Topography: Apart from impacts associated with soil 

disturbance, the Preserve’s geological, paleontological, and geomorphological 

features are not expected to be otherwise impacted from alterations to wildlife 

water availability. Therefore, the EA will not further analyze impacts to 

geology, paleontology, or topography. 

Soundscapes: The conversion of ranching water developments to wildlife guzzlers 

may have minor, temporary impacts to the natural ambient sound during 

construction and replenishment activities. There would be no long-term 

impairment to the natural ambient sound. Noise impacts to visitors and to 

wilderness values will be addressed under these other topics in the 

Environmental Consequences section. Impacts to natural sound are not further 

analyzed in a separate Soundscapes section. 

Air Quality: The infrequent use of generators has negligible, localized, shortterm adverse effects on air quality. No measurable impacts are expected; 

therefore this topic will not be further evaluated. 

Socioeconomic Resources: Water availability for wildlife is unlikely to have 

significant impacts on socioeconomic circumstances in Mojave National Preserve 

or surrounding communities. While the local economies are affected by levels of 

visitor use, the degree of such impacts is only indirectly related to the 

proposal’s impacts on wildlife populations and associated effects on visitor 

use. Changes in hunting will affect visitation only during hunting season. 

Significant impacts to local economies from changes to wildlife populations in 

Mojave are unlikely. Therefore, socio-economic impacts are not further 

analyzed. 

The following topics are not further analyzed in this document because of the 

low potential for impacts to these resources. 

Socioeconomic resources 

Designated ecologically significant or critical areas 

Wild or scenic rivers 

Designated coastal zones 
Wells-to-Guzzlers Environmental Assessment page 12 of 43 

Indian Trust Resources 

Ethnographic Resources 

Prime and unique agricultural lands 

Sites on the US Department of the Interior’s National Registry of Natural 

Landmarks 

Sole or principal drinking water aquifers 
Wells-to-Guzzlers Environmental Assessment page 13 of 43 

SECTION II: DESCRIPTION OF ALTERNATIVES 

INTRODUCTION 

This section describes the alternatives considered, including the no action 

alternative. The alternatives described include mitigation measures and 

monitoring activities proposed to minimize or avoid environmental impacts. 

This section also includes a description of alternatives considered early in 

the process but later eliminated from further study; reasons for their 

dismissal are provided. The section concludes with a comparison of the 

alternatives considered. 

ALTERNATIVE A - NO ACTION 

Under this alternative, wildlife would continue to use water provided from 

numerous springs, seeps, and other such natural water sources, and from the six 

big game guzzlers and 133 small game guzzlers already constructed for wildlife 

enhancement in Mojave National Preserve. All ranching water developments would 

remain as they were left by the ranchers in 2000 when the grazing allotments 

were retired and use of these locations was discontinued. The cultural 

resources associated with cattle ranching in the Mojave Desert would be 

protected. Decisions will be made in accordance with the General Management 

Plan for Mojave National Preserve. The GMP specifies Plan Actions for wildlife 

guzzlers as follows: 

The National Park Service will examine the use of and need for all 

big game and small game guzzlers. Guzzlers will be retained for 

native wildlife if they are found to be necessary to replace water 

lost due to actions taken by previous human activities. These 

developed water sites will be retained to allow native populations 

of plants and animals to return to or remain at a previously 

undisturbed population level. Simultaneously, with the retention of 

these developed water sites, the National Park Service will actively 

begin to restore natural water sources to be self-sustaining. When 

a water source becomes self-sustaining, the artificial facility will 

be removed. The National Park service has no jurisdiction over 

developed water sites on private land. The park will modify 

existing water developments (mostly small game guzzlers) to prevent 

desert tortoise from gaining access and to ensure they are able to 

escape from them. 

(Mojave National Preserve GMP, p. 70, April 2002) 

The National Park Service will continue to inventory and monitor Mojave’s 

springs and seeps and restore their natural conditions in retired grazing 

allotments. It will continue to permit CDFG to maintain and repair existing 

wildlife guzzlers in the Preserve. CDFG will also continue to regulate hunting 

within Mojave National Preserve as it has done since the Preserve’s 

establishment in 1994. 

Current monitoring efforts will continue under No Action. These include an 

annual inspection of known spring locations for presence and availability of 

surface water, line transect point counts for mule deer in mule deer habitat and 

for game birds throughout the Preserve, and photographic monitoring for a 

qualitative assessment of water uses by wildlife. 
Wells-to-Guzzlers Environmental Assessment page 14 of 43 

ALTERNATIVE B – PROPOSED ACTION 

Retrofit 12 Existing Ranching Water Developments as Wildlife Guzzlers over Three 

Years 

Alternative B is a proposal from the California Department of Fish and Game 

(CDFG) to transform 12 ranching water developments into guzzlers for use by mule 

deer and other wildlife over a three-year period. The Proposed Action is based 

on harvest data provided by CDFG. CDFG has offered funding and volunteers to 

carry out the work, including constructing the retrofits, monitoring the water 

levels, and, with generators, pumping water into the tanks periodically. CDFG 

would work with the NPS to obtain special use permits, provide monitoring data, 

and resolve issues such as access to sites and the need to avoid or mitigate 

impacts to desert tortoise (Gopherus agassizii), a Federally listed threatened 

species. 

The retrofits proposed by CDFG would not result in a traditional selfreplenishing guzzler design. Rather, these facilities would be well-fed 

drinkers for wildlife. Instead of a water catchment system above ground, the 

drinkers would be filled by well water pumped with generators into a holding 

tank. Generators will be carried to each site every time the drinkers need to 

be replenished. They will not be left onsite. The likely design would expose 

no more than two gallons of water at a time in a shallow basin approximately one 

to two feet above the ground surface. These drinkers would require regular 

maintenance to monitor the water levels and refill the drinkers by pumping well 

water into above-ground tanks. The size of these drinkers is unknown at present 

and will need to be provided by CDFG. (Personal communication, Larry Whalon and 

Bruce Kinney, 10/21/05) Once the design, size, installation, and capacity of 

these drinker systems is known, a more informed analysis may be made regarding 

the frequency of tank replenishment (accounting for evaporation as well as use), 

human traffic congestion, vegetation compaction, and soil compaction and/or 

erosion. 

The twelve wells in question are at least 12 years old. If they have metal 

casings, their average life expectancy is 20 years. Therefore, they are already 

past the majority of their useful life. These wells will need to be inspected 

and certified by a California state certified well contractor. Based on the 

inspections, repairs or replacements may be required before these wells are 

converted to wildlife drinkers. 

To avoid a situation similar to the 1995 bighorn sheep die-off, water quality 

will need to be routinely monitored. CDFG will also be required to submit 

reports on the condition and use of the twelve converted guzzlers. For the big 

game guzzlers in Mojave National Preserve, CDFG records guzzler condition, water 

levels, pellet transect data, maintenance performed, wildlife use, and volunteer 

mileage and hours of labor. NPS and CDFG will need to develop a separate data 

form for the proposed converted guzzlers. This information will be used to 

determine appropriate levels of maintenance to minimize impacts by volunteers 

and CDFG personnel. 
Wells-to-Guzzlers Environmental Assessment page 15 of 43 

ALTERNATIVE C – SCIENCE-BASED MANAGEMENT 

Monitor the Natural Springs and Wildlife Populations of Mojave National Preserve 

to Determine Existence and Extent of Need for Artificial Water 

Alternative C is the same as Alternative A but with an increase in knowledge as 

long-term scientific studies are completed. It proposes to complete the 

scientific studies needed before approving any/all wildlife management 

decisions, as called for in the Purpose and Need statement. This alternative is 

based on guidance issued by the US Department of Agriculture’s Natural Resources 

Conservation Service (NRCS). The NRCS has developed conservation practice 

standards for wildlife watering facilities. Criteria for consideration include 

water quantity, water quality, site conditions, and operation and maintenance 

planning. To adequately assess these conditions, the National Park Service 

would monitor the condition of natural water sources and the health of wildlife 

populations in Mojave National Preserve. Part of this alternative may 

necessitate studies in designated wilderness. A major proportion of high 

quality wildlife habitat is in wilderness. Scientific research under 

Alternative C will contribute to management decisions that promote a balanced 

ecosystem and healthy wildlife populations both in and out of wilderness. 

Impacts to wilderness would be minimized and be counterbalanced by the increase 

in available information. Over the long term, management decisions will be 

based on better information and will, therefore, provide improved protections to 

Mojave National Preserve’s wilderness. 

Alternative B, the Proposed Action, is based on harvest data collected and 

provided by CDFG. Alternative C proposes to expand on this information. It 

would also expand on current or previous research such as the National Park 

Service’s study of wildlife monitoring at developed and undeveloped water 

sources with infrared-triggered cameras (see Background). All research studies 

will be developed and implemented through the National Park Service’s Scientific 

Research and Collecting Permit System. Under this alternative, the National 

Park Service will aggressively pursue funding and collaborative or cooperative 

opportunities to implement these scientific studies. Based on the information 

gained from such studies, wells could possibly be converted to wildlife 

drinkers, or artificial water developments could be repaired, retrofitted, or 

eliminated altogether. 

ELEMENTS COMMON TO ALL ALTERNATIVES 

Alternatives A, B, and C present three separate scenarios for Mojave National 

Preserve but have some elements in common. Under any of the three alternatives, 

the existing 133 small game guzzlers and six big game guzzlers will continue to 

exist in varying conditions and levels of function. The retired grazing 

allotments will remain retired; permits for active allotments will continue to 

be issued for livestock grazing. Undeveloped sources of water in the Preserve 

(i.e., springs and seeps) will continue to exist and will be restored as funding 

and time permits. The Rock Springs Land & Cattle Company Historic District 

nomination will continue to go forward. 

ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER EVALUATION 

Several alternatives were considered but eliminated from further evaluation. 

Most of these ideas were presented during the public scoping period. 

1. Convert All Ranching Water Developments in Mojave National Preserve into 

Wildlife Guzzlers. A proposal to convert the 12 Proposed Wells and all 

ranching water developments that were removed within the past five years 

to wildlife guzzlers does not conform to the GMP. At some estimates, 

there are over 125 separate developments initially installed by livestock 
Wells-to-Guzzlers Environmental Assessment page 16 of 43 

ranchers. Approximately 30-40 artificial water sources (wells) were shut 

off by ranchers when the Kessler Springs, Lanfair, and Valley View grazing 

allotments were retired and an equal number of modified springs were also 

abandoned at that time. The GMP allows for existing water developments to 

be retained where previous human activities resulted in a loss of natural 

waters for wildlife. Once native populations of plants and animals return 

to or remain at previously undisturbed population levels, and 

simultaneously with NPS efforts to actively restore natural water sources 

to self-sustaining conditions, artificial facilities may be considered for 

removal. The GMP does not allow for the development of new wildlife 

watering facilities. The ranching water developments in question were 

constructed and operated specifically for livestock grazing. They were 

not designed or used to support wildlife and, in their existing condition, 

would not serve such a purpose. 

2. Remove all artificial water developments in Mojave National Preserve. 

According to the GMP, some ranching developments – fences, water tanks, 

pipelines and windmills – are the responsibility of the NPS, San 

Bernardino County, or Caltrans and are maintained by these entities. Most 

of these facilities are maintained by the rancher and are the rancher’s 

personal property. If and when a grazing permit is retired through 

private acquisition and donation to the NPA, the rancher is responsible 

for removing all developments that are not otherwise retained as important 

features of the ranching history of the area. Therefore, any proposals to 

remove ranching water developments from Mojave National Preserve can only 

address those developments not considered the personal property of the 

rancher(s) or contributing elements of the ranching history of Mojave 

National Preserve. It would violate the GMP to remove all artificial 

water developments regardless to these two provisions. 

3. Repair and maintain existing guzzlers. CDFG has assumed the 

responsibility for repairing and maintaining existing guzzlers in Mojave 

National Preserve. Mojave National Preserve issues a special use permit 

annually to CDFG to perform basic maintenance and repairs and, on a caseby-case basis, other permits for major construction and tank replenishment 

of the six big game guzzlers (BGGs). Mojave has also issued a special use 

permit for basic maintenance and repairs of small game guzzlers (SGGs) to 

CDFG. This permit covers work to all SGGs outside of wilderness and 

desert tortoise critical habitat. A permit for basic maintenance of SGGs 

within wilderness and/or critical habitat is under separate review. This 

alternative was eliminated because the proposed activity is already being 

reviewed and permitted per NPS regulations. 

4. Retrofit ranching water developments based on inverse proximity to natural 

sources of water. As with the first alternative considered but 

eliminated, this proposal does not conform to the GMP and was, therefore, 

excluded from further consideration. 

5. Retrofit ranching water developments/construct wildlife guzzlers to 

reintroduce Sonoran pronghorn antelope and/or other extirpated wildlife 

species to the Mojave Desert. More information about Sonoran pronghorn 

antelope and other extirpated wildlife species, as well as the use of 

guzzlers to reintroduce said extirpated species, needs to be gathered and 

studied before this proposal can be implemented. The proposal goes beyond 

the scope of this environmental assessment and was, therefore, eliminated 

from further consideration. 

6. Build wildlife guzzlers in the Hackberry Complex burn area to replace 

burned spring developments. As with the first alternative considered but 
Wells-to-Guzzlers Environmental Assessment page 17 of 43 

eliminated, this proposal does not conform to the GMP and was, therefore, 

excluded from further consideration. 

7. Reduce hunting in Mojave National Preserve. In establishing Mojave 

National Preserve, the California Desert Protection Act of 1994 permitted 

hunting, fishing and trapping on lands and water within Mojave National 

Preserve in accordance with applicable federal and state laws. Hunting 

with the boundaries of the Preserve is administered by CDFG and NPS 

regulations. The GMP establishes special hunting regulations in 

accordance with CDFG regulations. Both CDFG regulations and the GMP would 

have to be revised to accommodate a reduction in hunting within the 

Preserve. Such an action is beyond the scope of this environmental 

assessment. 

8. Remove introduced game species from Mojave National Preserve (i.e., 

increase bag limits on targeted species). The GMP identifies Rocky 

Mountain mule deer (Odocoileus hemionus hemionus) and chukar (Alectoris 

graeca), as well as burros (Equus asinus), as the more prominent 

introduced species in the Preserve. No actions to remove mule deer are 

warranted until the genetics of the deer population are studied. The GMP 

does state, “the NPS will encourage reduction in this population of exotic 

birds [chukar] by seeking a higher bag limit, as compared to the native 

quail population. No new releases of these, or other exotic species, will 

be authorized.” This alternative is beyond the scope of this document 

regarding mule deer, and has already been analyzed and complies with NEPA 

for chukar. 

ENVIRONMENTALLY PREFERRED ALTERNATIVE 

The alternative that best meets the criteria of Environmentally Preferred is 

the one that will promote NEPA, as expressed in Section 101 of that Act. This 

alternative will satisfy the following requirements: 

• Fulfill the responsibilities of each generation as trustee of the 

environment for succeeding generations; 

• Assure for all generations safe, healthful, productive, and esthetically 

and culturally pleasing surroundings; 

• Attain the widest range of beneficial uses of the environment without 

degradation, risk of health or safety, or other undesirable or unintended 

consequences; 

• Preserve important historic, cultural, and natural aspects of our national 

heritage and maintain, wherever possible, an environment that supports 

diversity and variety of individual choice; 

• Achieve a balance between population and resource use that will permit 

high standards of living and a wide sharing of life’s amenities; and, 

• Enhance the quality of renewable resources and approach the maximum 

attainable recycling of depletable resources. 

IMPAIRMENT 

The mission of the National Park Service as defined in the Organic Act of 1916 

(16 USC 1) and reaffirmed by the General Authorities Act, as amended (16 USC 1a1), specifically requires that the NPS leave park resources and values 

unimpaired. This prohibition against impairment must, therefore, be addressed in 

any discussion regarding potential impacts to park resources. All alternatives 

are assessed for potential to significantly damage or impair the resources and 

values of Mojave National Preserve. 
Wells-to-Guzzlers Environmental Assessment page 18 of 43 

While Congress has given the Service the management discretion to allow certain 

impacts within parks, that discretion is limited by the statutory requirement 

that the Park Service must leave park resources and values unimpaired, unless a 

particular law directly or specifically provides otherwise. This prohibition 

against impairment ensures that park resources and values will continue to exist 

in a condition that will allow the American people to have present and future 

opportunities for enjoyment of them. 

The impairment that is prohibited by the Organic Act and the General Authorities 

Act is an impact that, in the professional judgment of the responsible NPS 

manager, would harm the integrity of park resources or values, including the 

opportunities that otherwise would be present for the enjoyment of those 

resources or values. An impact to any park resource or value may constitute an 

impairment, but an impact would be more likely to constitute an impairment to 

the extent that it affects a resource or value whose conservation is: 

• Necessary to fulfill specific purposes identified in the establishing 

legislation or proclamation of the park; 

• Key to the natural or cultural integrity of the park or to opportunities 

for enjoyment of the park; or 

• Identified as a goal in the Park’s general management plan or other 

relevant NPS planning documents. 
Wells-to-Guzzlers Environmental Assessment page 19 of 43 

SECTION III: AFFECTED ENVIRONMENT 

INTRODUCTION 

This section provides a description of the existing environment in the project 

area and the resources that could be affected by implementing the proposed 

alternatives. Complete and detailed descriptions of the environment and existing 

use at Mojave National Preserve can be found in the Mojave National Preserve 

General Management Plan (NPS 2002) and on the Park website at www.nps.gov/moja. 

Not all resources within the Preserve would be affected by the conversion of 

ranching water developments to wildlife water facilities. As per Director’s 

Order/Reference Manual #12: Environmental Compliance, this impact analysis is 

focused on those resources that have the potential for direct or indirect impact 

from the three alternatives. 

LOCATION AND GENERAL DESCRIPTION OF MOJAVE NATIONAL PRESERVE

Mojave National Preserve is a 1.6 million-acre unit of the National Park Service 

that represents a combination of Great Basin, Sonoran, and Mojave desert 

ecosystems. Nowhere else in the United States can such a wide variety of desert 

plant life be found in such combinations and in such close proximity. Mojave is 

located in southern California, bounded by Interstate Highways 15 and 40 

approximately halfway between Las Vegas and Joshua Tree National Park. Its 

eastern boundary primarily follows the Nevada-California state line. 

The project area is characteristic of the Mojave Desert, with low precipitation 

(averaging 8 to 23 centimeters, or 3 to 9 inches, per year), low humidity, and 

wide extremes in daily temperatures. Winters are relatively short and mild, and 

summers are long and hot. The prevailing wind direction is from the south during 

the summer and from the north during the winter. 

PHYSICAL RESOURCES 

Air Quality, Visibility, Night Sky: The Mojave Desert Air Quality management 

District manages and enforces the Clean Air Act’s air quality standards in 

Mojave National Preserve. Mojave National Preserve is a class II floor area, 

meaning that it may never be redesignated to class III. The Environmental 

Protection Agency has classified Mojave National Preserve as a non-attainment 

area for ozone and PM10 standards. 

Visibility is probably the most important air quality resource in the desert 

region and is easily affected by dust-generating activities. Local pollution 

sources in the desert consist primarily of particulate matter from off-road 

vehicles, wind-blown soil, mining operations, livestock grazing, and other 

agricultural activities. 

Mojave is a naturally quiet desert environment with very dark night skies. 

Visitors and researchers have opportunities for natural quiet, solitude, and 

star gazing with few human-caused noise or light glare sources. 

Natural Ambient Sound: Mojave National Preserve is generally a quiet landscape 

with occasional, short-term interruptions of the natural quiet. Depending on 

the atmospheric conditions, closeness to a noise source, and topographic 

features, visitors generally experience very little human-caused noised while in 

the backcountry. Most areas in the Preserve are well away from traffic and its 

noise. In other areas, noise is locally concentrated (e.g., off-road vehicle 

use on adjacent lands, railroads, and mining operations). 
Wells-to-Guzzlers Environmental Assessment page 20 of 43 

Soils: The Preserve is home to a wide array of soils, including: soils with 

sandy textures, gravel and cobble cimas; soils with medium textures; soils with 

calcium carbonate accumulations; fine textured soils; soils with a developed 

horizon reflecting age or formation during a different moisture regime; shallow 

soils; and upland soils. Escarpments, ephemeral streams, sand dunes, and lava 

flows are also found in Mojave. Detailed soil surveys have not yet been 

conducted. 

Water: Groundwater runs underneath most of the Preserve, varying greatly in 

depth and quality. Over 200 springs and seeps have been identified within 

Mojave. Many have been altered by livestock grazing improvements such as 

retention dams, pipelines, and troughs. Most are available for wildlife and 

burro use. Small springs and seeps offer isolated, limited water for plants, 

wildlife, and domestic or commercial use. 

Water wells in the Preserve have been drilled for livestock needs, domestic use, 

and mining operations. The National Park Service maintains a number of wells 

for visitor and administrative purposes throughout Mojave National Preserve. 

Mojave’s General Management Plan (April 2002) states, “Surface water and 

groundwater withdrawn for public use will be the minimum amount necessary to 

achieve Preserve purposes. All water withdrawn for domestic use will be 

returned to the watershed system once it has been treated to ensure that there 

will be no impairment of Preserve resources” (p. 34). 

Geology: The geology of Mojave is very complex and diverse due to igneous and 

metamorphic activity and structural deformations associated with these 

activities. Erosional processes have altered the landscape resulting in 

outcrops and rocks ranging from Precambrian to recent ages. 

Mojave National Preserve is characterized by isolated mountain ranges and ridges 

separated by alluvium-filled irregular large valleys. Dividing the Preserve 

approximately in half is the northeast trending Providence-Mid Hills-New York 

Mountain ranges. The principal valleys within the Preserve include Ivanpah 

Valley, Kelso/Cedar Wash, Lanfair Valley, Devils Playground, Piute Valley, and 

the northern area of Fenner Valley. Ivanpah Valley and Kelso/Cedar Wash line up 

in a northeasterly to southwesterly fashion but drain in opposite directions 

because of an inconspicuous northwest trending divide near the town of Cima. 

Both Lanfair and Piute Valleys drain via Piute Wash into the Colorado River. 

The remaining valleys have self-contained drainage systems as demonstrated by 

playa lakes such as Soda and Ivanpah. 

BIOLOGICAL RESOURCES 

The wildlife and vegetative resources of Mojave National Preserve reflect the 

mingling of three major North American deserts – the Great Basin, the Mojave, 

and the Sonoran deserts. Vegetation consists primarily of species common to the 

Mojave Desert but the Preserve also contains floral species of the Great Basin 

and Sonoran deserts and elements of the California coastal zone. Mojave 

National Preserve was established to preserve an ecologically diverse yet 

fragile desert ecosystem comprised of scenic, geologic, and wildlife values 

unique to all three of the abovementioned desert environs. This transition zone 

ranges from 900 to nearly 8,000 feet in elevation and embraces a plethora of 

landforms: cinder cones, sand dunes, dry lake beds, alluvial fans, mountain 

ranges, table-top mesas, large desert bajadas, and valleys. It provides a 

refugium for over 1,000 plant and animal species. 

Vegetation: Mojave National Preserve consists primarily of vegetative attributes 

of the Mojave Desert intermingled with floral species of the Great Basin Desert, 
Wells-to-Guzzlers Environmental Assessment page 21 of 43 

Sonoran Desert, and California Chaparral Zone. Many plant species are 

distributed only within their boundaries while other areas contain species 

normally associated with the California coast. The New York Mountains shares 

species of manzanita, California lilac, oak, and silk tassel with coastal 

California. The Mid Hills have significant stands of Great Basin sagebrush and 

Utah juniper. The strongest association is with the Sonoran Desert whose 

northernmost range is often recognized to intermingle with the southern border 

of the Park. Sonoran plant species such as pancake prickly pear and smoke tree 

are found extending a dozen or more miles into the southeast portion of Mojave 

National Preserve. 

Community types common both to Mojave and elsewhere in the desert include the 

playas, saltbush, creosote-covered flats and alluvial fans, and Joshua tree 

woodlands. The Preserve is unusual in the complexity and density of its Joshua 

tree community which is best represented on Cima dome. The quality and sheer 

vastness of the Joshua tree forest on Cima Dome is unparalleled anywhere else in 

the world. There are seven different types of wash plant species associations 

including catsclaw acacia, smoke trees, and desert willows. Higher elevations 

support grassland sagebrush, blackbrush, pinyon-juniper woodlands as well as 

unique remnant habitats containing small white fir forests and pinyon-juniper 

with oak. The Piute Creek desert oasis also supports a very fragile and limited 

riparian community. A total of 803 species of plants representing 85 plant 

species have been identified in Mojave National Preserve. 

Wildlife: The intermingling of three desert environments has produced 

approximately 35 wildlife habitat types. These diverse habitats support 

approximately 300 species of wildlife. Documented in the literature are 36 

species of reptiles, 206 species of birds, and 47 species of mammals. A few of 

the most notable species include the gila monster, desert tortoise, Mohave tui 

chub, Mojave fringe-toed lizard, regal ring-necked snake, and desert whipsnake. 

Significant avian fauna include the prairie falcon, Bendire’s thrasher, 

California thrasher, gray vireo, golden eagle, Lucy’s warbler, mourning dove and 

Gambel’s quail. Mojave has one of the more significant bat faunas of the 

California Desert. There are also rock squirrels in pinyon-juniper woodland, a 

relict population of dusky-footed woodrats, mule deer, porcupines, mountain 

lions, and desert bighorn sheep. 

Many wildlife species in Mojave National Preserve are considered game and are 

hunted under the California Desert Protection Act and CDFG regulations. Hunting 

results in an imbalance to the ecosystem. Hunted herds are not a natural 

dynamic, and selective hunting practices can skew wildlife population numbers 

and sex ratios. CDFG collects and provides data on annual hunting levels. 

Threatened, Endangered and Sensitive Species

The desert tortoise is listed as threatened under both the Endangered Species 

Act and the California Endangered Species Act. A large portion of the Preserve 

is designated critical habitat for the tortoise. Some of the highest densities 

of tortoise are found in the Ivanpah Valley in the northern end of the Preserve. 

The southwestern willow flycatcher, least Bells vireo, and California yellowbilled cuckoo have limited potential to inhabit the Preserve. Both species are 

federally listed. 

There are no known federally listed or proposed plant species in the Preserve. 

Thorne’s buckwheat is listed by the State of California as an endangered 

species. Two occurrences in the Preserve had been confirmed at the time the 

General Management Plan was written. A complete list of Species of Special 
Wells-to-Guzzlers Environmental Assessment page 22 of 43 

Consideration may be found in the revised draft Environmental Impact Statement 

and General Management Plan (July 2000, p. 428-431). 

Introduced Species

Over 60 nonnative plant species have been identified in Mojave National 

Preserve. Some better known species include tamarisk, goat-head thorns, 

halogeton, cheat grass, and Russian thistle. Mojave also has well established 

populations of nonnative animals including burros, chukar, and Rocky Mountain 

mule deer. 

Paleontology: The Preserve contains a fragile and irreplaceable paleontological 

record. The richness and diversity of that record is unknown as significant 

inventory work has not been performed on the various geologic formations that 

could contain fossil resources. Fossils have many values including (1) 

stratigraphic indicators for correlation of deposits containing them and for 

determination of relative geologic age; (2) records of past life forms showing 

the course of evolutionary trends of plants and animals, and (3) evidence of 

changing paleoenvironments. 

CULTURAL RESOURCES 

Prehistoric Resources, Historic Resources, and Cultural Landscapes

There is significant documentation of archeological information at Mojave. Since 

1997, the National Park Service has been developing the servicewide 

archeological sites management inventory system (ASMIS). Various cultural 

resources studies have examined archeological resources in the Mojave Desert 

region. There is evidence of human occupation from the terminal Pleistocene 

(ca. 12,000 years ago) through the contact period. 

The mountains and valleys of the Preserve contain sites associated with early 

Spanish and American exploration and the survey of the Mojave Desert. The area 

is laced not only with remnants of prehistoric and protohistoric Native American 

trails but also with Euro-American trails, wagon roads, railroads, highways, and 

other early transportation arteries. There are numerous abandoned mining 

operations, settlements, railroad grades and railway structures, and sites of 

military operations against the Native Americans. Fence lines, water tanks, and 

corrals testify to a continuing ranching-grazing industry. Scattered remains of 

homesteads tell of a time when dry land farming was attempted in the Mojave 

Desert, and the outlines of military camps are reminders of World War II when 

American troops trained for military campaigns abroad. 

Cultural landscapes in Mojave reflect past and present mining, ranching, 

railroading, and ethnographic activities. The General Management Plan 

identifies Mojave’s most significant and potentially significant landscapes 

(including that related to historic ranching). The CDFG proposal does not 

clearly specify the locations of the 12 wells to be retrofitted and thus some 

confusion exists regarding their actual names. It can, however, be safely said 

that at least 10 of these locations are considered contributing elements to the 

Rock Springs Land and Cattle Company Historic District nomination. The main 

well at Government Holes was likely first developed sometime in the 1860s and 

was one of the rare water sources not controlled by the large Rock Springs 

interests. This well, in addition to the wells at Barnwell, were not shut down 

with the recent retirement of grazing leases within the Preserve. The cattle 

watering facilities at Barnwell, Vontrigger, and Lanfair all date to the 

dominant period of the Rock Springs Land and Cattle Company between 1894 and 

1927. The Hollimon well probably dates to the early 1920s, while most of the 

others were developed by Claude Halsell in the early days of the OX Ranch 
Wells-to-Guzzlers Environmental Assessment page 23 of 43 

between 1930 and 1948. All of these locations represent cultural landscapes in 

their own right and they are also part of the larger cultural landscape related 

to the Rock Springs Land and Cattle Company and its antecedents. 

There are also three historic landscapes in the Preserve not managed by the 

National Park Service: the Union Pacific’s Los Angeles to Salt Lake City 

Railroad Line, the Boulder Transmission Line, and Mitchell Caverns. 

USE OF THE PRESERVE 

Recreational Activities

Mojave National Preserve provides recreational opportunities to people from all 

over the world. Most of the landscape is open with broad vistas of relatively 

undeveloped land. The vastness of the landscape offers visitors opportunities 

for seclusion and a sense of wilderness even when in a vehicle. The land has 

many extremes and contrasts that people come to experience. 

Most visitation occurs between October and May when an estimated 72% of annual 

overnight visits occur. Some of the more popular recreational opportunities 

include rock climbing, hunting, hiking, equestrian use, bicycling; four-wheel 

drive touring, street-legal motorcycle touring, and backcountry use and roadside 

vehicle camping. 

Wilderness

The California Desert Protection Act that established Mojave National Preserve 

in 1994 also designated approximately half of its 1.6 million acres as 

wilderness. Wilderness areas are given supplemental and permanent protection by 

the US Congress beyond that normally afforded backcountry resources. In 

particular, wilderness is managed to preserve wilderness characteristics as 

defined by the Wilderness Act of 1964. The National Park Service has 

established wilderness use management guidelines that emphasize the principle of 

non-degradation, Leave-No-Trace principles and practices, and prohibited use of 

motorized or mechanized equipment unless excepted by determination of a Minimum 

Requirements Analysis and when a proposed action is deemed essential, the 

definition of Minimum Tool. Certain actions under Alternative C would need to 

be carried out in wilderness to gain enough information to manage and protect 

designated wilderness and associated wilderness values in accordance with the 

Wilderness Act. Examples of these actions might include use of aircraft, 

cameras, water measurement instruments, and other mechanized or motorized 

equipment. 
Wells-to-Guzzlers Environmental Assessment page 24 of 43 

SECTION IV: ENVIRONMENTAL CONSEQUENCES 

INTRODUCTION 

This section presents the likely beneficial and adverse effects to the natural 

and human environment that would result from implementing the alternatives 

under consideration. This section describes short-term and long-term effects, 

direct and indirect effects, cumulative effects, and the potential for each 

alternative to impair park resources. Interpretation of impacts in terms of 

their duration, intensity (or magnitude), and context (local, regional, or 

national effects) are provided where possible. 

METHODOLOGY 

This section contains the environmental impacts, including direct and indirect 

effects and their significance to the alternatives. It also assumes that the 

mitigation identified in the Mitigation and Monitoring section of this EA would 

be implemented under the action alternative under discussion. 

Impact analyses and conclusions are based on NPS staff knowledge of resources 

and the project area, review of existing literature, and information provided by 

experts in the NPS or other agencies. Any impacts described in this section are 

based on preliminary design of the alternatives under consideration. Effects are 

quantified where possible; in the absence of quantitative data, best 

professional judgment prevailed. 

CRITERIA AND THRESHOLDS FOR IMPACT ANALYSES 

The following are laws, regulations, and/ or guidance that relate to the 

evaluation of each impact topic. 

Wildlife, Vegetation, and Threatened & Endangered Species 

Laws, Regulations, and Policies. The NPS Organic Act, which directs parks to 

conserve wildlife unimpaired for future generations, is interpreted by the NPS 

to mean native animal life should be protected and perpetuated as part of the 

Preserve’s natural ecosystem. Natural processes are relied on to control 

populations of native species to the greatest extent possible. The restoration 

of native species is a high priority in national park units. Management goals 

for wildlife include maintaining components and processes of naturally evolving 

park ecosystems, including natural abundance, diversity, and ecological 

integrity of plants and animals. 

Impact Indicators, Criteria, and Methodology. The impacts on wildlife were 

evaluated in terms of impacts to individual animals and wildlife habitat. 

Specific localized impacts were estimated based on knowledge garnered from 

similar past activities. 

The following are standards used by the NPS in interpreting the level of 

impact on wildlife: 

Negligible impacts: No species of concern is present; no impacts or 

impacts with only temporary effects are expected. 

Minor impacts: Nonbreeding animals of concern are present, but only in low 

numbers. Habitat is not critical for survival; other habitat is available 

nearby. Occasional flight responses by wildlife are expected, but without 

interference with feeding, reproduction, or other activities necessary for 

survival. 

Moderate impacts: Breeding animals of concern are present; animals are 
Wells-to-Guzzlers Environmental Assessment page 25 of 43 

present during particularly vulnerable life-stages, such as migration or winter; 

mortality or interference with activities necessary for survival expected on an 

occasional basis, but not expected to threaten the continued existence of the 

species in the park. 

Major impacts: Breeding animals are present in relatively high numbers, 

and/or wildlife is present during particularly vulnerable life stages. Habitat 

targeted by actions has a history of use by wildlife during critical periods, 

but there is suitable habitat for use nearby. Few incidents of mortality could 

occur, but the continued survival of the species is not at risk. 

Impairment: The impact would contribute substantially to the deterioration 

of natural resources to the extent that the park’s wildlife and habitat would no 

longer function as a natural system. Wildlife and its habitat would be affected 

over the long-term to the point that the park’s purpose (Enabling Legislation, 

General Management Plan, Strategic Plan) could not be fulfilled and resources 

could not be experienced and enjoyed by future generations. 

In the absence of quantitative data concerning the full extent of actions under 

a proposed alternative, best professional judgment prevailed. 

CRITERIA AND THRESHOLDS FOR IMPACT ANALYSES OF ALL OTHER ISSUES 

Impacts to soundscapes, visual resources, safety, visitor experience, and 

wilderness were analyzed using the best available information and best 

professional judgment of park staff. 

Terms referring to impact intensity, context, and duration are used in the 

effects analysis. Unless otherwise stated, the standard definitions for these 

terms are as follows: 

o Negligible impacts: The impact is at the lower level of detection; there 

would be no measurable change. 

o Minor impacts: The impact is slight but detectable; there would be a small 

change. 

o Moderate impacts: The impact is readily apparent; there would be a 

measurable change that could result in a small but permanent change. 

o Major impacts: The impact is severe; there would be a highly noticeable, 

permanent measurable change. 

o Localized Impact: The impact occurs in a specific site or area. When 

comparing changes to existing conditions, the impacts are detectable only 

in the localized area. 

o Short-Term Effect: The effect occurs only during or immediately after 

implementation of the alternative. 

o Long-Term Effect: The effect could occur for an extended period after 

implementation of the alternative. The effect could last several years or 

more and could be beneficial or adverse. 

IMPAIRMENT ANALYSIS 

Impairment to park resources and values are analyzed in this section. Impairment 

is an impact that, in the professional judgment of the responsible NPS manager, 

would harm the integrity of park resources or values, including the 

opportunities that otherwise would be present for the enjoyment of those 

resources or values. An impact would be more likely to constitute impairment to 

the extent that it affects a resource or value whose conservation is crucial to 

the cultural or natural integrity of the park or that is a resource or value 

needed to fulfill a specific purpose identified in the enabling legislation. An 

impact would be less likely to constitute impairment if it is an unavoidable 

result that cannot be reasonably mitigated or an action necessary to preserve or 

restore the integrity of park resources or values. 
Wells-to-Guzzlers Environmental Assessment page 26 of 43 

A determination of impairment is made in the “Conclusion” section of all natural 

and cultural resource impact topics of this document. Impairment statements are 

not required for recreational values/visitor use and experience or safetyrelated topics. 

CUMULATIVE EFFECTS 

Cumulative effects are the direct and indirect effects of a proposed project 

alternative’s incremental impacts when they are added to other past, present, 

and reasonably foreseeable actions, regardless of who carries out the action (40 

CFR Part 1508.7). Guidance for implementing NEPA (Public Law 91-190, 1970) 

requires that federal agencies identify the temporal and geographic boundaries 

within which they will evaluate potential cumulative effects of an action and 

the specific past, present, and reasonably foreseeable projects that will be 

analyzed. This includes potential actions within and outside the recreation area 

boundary. The geographical boundaries of analysis vary depending on the impact 

topic and potential effects. While this information may be inexact at this time, 

major sources of impacts have been assessed as accurately and completely as 

possible, using all available data. 
Wells-to-Guzzlers Environmental Assessment page 27 of 43 

Alternative A- No Action 

Soils

With the No Action Alternative, soils would not be disturbed. The existing 

footprints of disturbance around existing developed water sources would be left 

unchanged. 

Water Resources

There would be no impacts to developed or undeveloped water sources from the No 

Action alternative. Any well seal and abandonment work scheduled prior to this 

environmental assessment would be carried out. Such work would reduce impacts 

to the groundwater table and, in consequence, to the surface water sources that 

are fed by groundwater. 

Surface water sources fed from the groundwater table would continue to be 

restored naturally as they have been since the retirement of several grazing 

allotments in the past five years. Other water available to wildlife includes 

over 150 undeveloped springs and seeps, one perennial water source, ranching 

waters in the remaining active grazing allotments, and incidental collections in 

abandoned ranching water catchment systems throughout the Preserve. 

Wildlife

Wildlife populations would remain unchanged from their current status under the 

No Action alternative. They would continue to utilize all available water 

sources in the Preserve. The 12 wells proposed for conversion to guzzlers have 

been shut off for up to five years, beginning in 2000. Animals whose watering 

habitats have been diverted away from ranching water developments that are now 

shut down would continue to utilize other water sources. Actual wildlife use of 

water sources would continue to be inadequately documented under this 

alternative. 

Vegetation

Vegetation would continue to flourish unimpacted under the No Action 

alternative. Plants whose growth had been lessened by ranching water diversions 

would continue to recover since the closure of those diversions. 

Threatened, Endangered, & Sensitive Species

Under the No Action alternative, the habitat for desert tortoise, least Bell’s 

vireo, and southwestern willow flycatcher would remain unchanged. There would 

be neither adverse nor beneficial impacts to these species. 

Prehistoric, Historic, and Cultural Landscape Resources

Prehistoric, historic, and cultural landscape resources will be left intact and 

not be impacted by implementation of the No Action alternative. 

Visitor Experience 

Implementation of the No Action alternative would not change the current visitor 

experience offered at Mojave National Preserve. It would not increase or 

decrease hunting levels. Wildlife viewing opportunities would remain unchanged. 

There is long-term potential for wildlife viewing to improve at undeveloped 

water sources but current available data cannot substantiate this potential. 
Wells-to-Guzzlers Environmental Assessment page 28 of 43 

Development and Public Health & Safety 

Under No Action, the ranching water developments that were shut off when grazing 

allotments were retired will remain closed. Risks to public health and safety 

will be reduced if more wells are sealed and abandoned in accordance with State 

of California Water Code Section 13801. 

Park Operations

Park operations would continue unchanged under No Action. Water sources, both 

developed and undeveloped, would continue to be monitored infrequently based on 

available park resources. 

Wilderness 

Wilderness would not be impacted by the No Action alternative. Because there 

would be no activities in wilderness requiring the use of motorized or 

mechanized equipment, there would be no need to develop a Minimum Requirements 

Analysis (Minimum Tool). The wilderness character in Mojave National Preserve 

would remain unchanged. CDFG and it volunteers current inspect and maintain 

existing guzzlers in Mojave without the use of mechanized or motorized 

equipment. 

Impairment

The No Action alternative would result in either no impacts or negligible 

impacts to the natural and cultural resources of Mojave National Preserve. No 

significant impacts can be identified from the implementation of No Action. 

Cultural resources would continue to be protected. Turning off the ranching 

waters will allow the groundwater table to be replenished and natural surface 

waters to recover. Ranching waters have been turned off for up to the past five 

years. The sites of the 12 proposed guzzlers have been dry since 2000. The No 

Action alternative does not change the status quo. Therefore, this alternative 

will not result in impairment to the resources of the Preserve. 
Wells-to-Guzzlers Environmental Assessment page 29 of 43 

Alternative B- Proposed Action 

Retrofit 12 Pre-existing Ranching Water Developments as Wildlife Guzzlers over 

Three Years 

Soils

If the Proposed Action is implemented, soils would be disturbed at the 12 well 

sites. There would also be soil disturbance for potential trenching work to 

accommodate water lines. The extent of this disturbance cannot be fully 

assessed until better details of the proposed action are provided. This 

disturbance would, nonetheless, likely be temporary and terminate at the 

completion of construction. 

Water Resources

If any of the 12 converted guzzlers are fed from the groundwater table, the 

Proposed Action will potentially lower groundwater levels. In turn, this will 

have a negative impact on undeveloped water sources that rely on the groundwater 

table for replenishment. If CDFG and volunteers replenish the proposed guzzlers 

by transporting water to each site and pumping it into the well, there is a 

possibility of polluting the ground water. The groundwater table is also 

vulnerable to pollution because of its exposure at the ground surface. The 

potential for adverse impacts may be high, but the extent of these impacts to 

ground and surface water is not known until CDFG provides more detail with 

respect to the Proposed Action. 

Wildlife

The Proposed Action would artificially support wildlife populations in Mojave 

National Preserve. Twelve wells that were shut off when ranching operations 

ceased would be converted to guzzlers. The guzzlers would provide water to 

wildlife in areas where there would otherwise not be a water source. This 

alternative has the potential to develop or reinstitute a dependence on these 12 

water sources, resulting in changes to the wildlife populations and an imbalance 

of the ecosystem. When used by cattle ranchers, the wells were turned on and 

off purposely to move cattle around within the grazing allotment. Use of these 

waters by wildlife was incidental and opportunistic; it was not determined by 

climate or seasonal conditions. 

The Proposed Action, therefore, has the potential to develop a dependence on 

artificial waters that did not previously exist, depending on the availability 

of water at the 12 proposed sites. There is also great potential for wildlife 

numbers to increase. Hunting also results in an imbalance to the ecosystem. 

Hunted herds are not a natural dynamic, and their population numbers and sex 

ratios may be skewed by selective hunting practices. Impacts to wildlife game 

species from Alternative B are certain but their full extent is unknown. 

All of the impacts identified here are conditional on the abilities of CDFG and 

its volunteers to regularly repair and maintain the 12 proposed developments. 

If maintenance and repair is discontinued, it is not known what impacts the 

proposed developments might have on wildlife. 

Impacts to species diversity are unknown. 

Vegetation

Vegetation at the 12 well sites would not experience any direct benefit from the 

guzzler conversions. There may be an indirect detrimental impact from increased 
Wells-to-Guzzlers Environmental Assessment page 30 of 43 

foraging and trampling if the conversions encourage a greater wildlife presence 

at these sites. If the 12 converted guzzlers are not regularly maintained and 

repaired, there will be less likelihood of increased wildlife causing adverse 

impacts to the vegetation, but the extent of these impacts to ground and surface 

water is not known until CDFG provides more detail with respect to the Proposed 

Action. 

Threatened, Endangered, & Sensitive Species

Based on CDFG’s proposal (see Alternative B: Proposed Action), the drinkers will 

be placed high enough off the ground to prevent desert tortoises from accessing 

them. Tortoises would not be able to crawl into the catchment systems and 

drown; neither would they be able to use the water in the drinkers. The 12 

proposed sites are outside of desert tortoise critical habitat. It is, 

therefore, unlikely that the Proposed Action will directly adversely impact this 

Federally threatened species. 

Other listed species in the Park would not be impacted by the Proposed Action. 

The Mohave tui chub is physically constrained to two man-made impoundments at 

the Desert Studies Center at Zzyzx that are not affected by the Proposed Action. 

The southwestern willow flycatcher, least Bells vireo, and California yellowbilled cuckoo have limited potential to inhabit the Preserve but have not been 

documented in Mojave. It is highly unlikely that these species would be 

impacted by the Proposed Action. 

Prehistoric Resources

Mojave National Preserve is rich in prehistoric and protohistoric remnants of 

Native American and Euro-American existence in the California desert. Any 

surface disturbance activity will require pre-construction archeological survey 

and NHPA Section 106 clearance. 

Historic and Cultural Landscape Resources

At least 10 of the wells proposed for retrofitting are considered contributing 

elements to the Rock Springs Land and Cattle Company Historic District 

nomination. All of these locations represent cultural landscapes in their own 

right and they are also part of the larger cultural landscape related to the 

Rock Springs Land and Cattle Company and its antecedents. 

There is a high potential for adverse impacts to these cultural landscapes with 

the introduction of guzzler features not typically associated with ranching 

activities. Impacts to cultural landscapes and other cultural resources would 

have to be addressed through consultation with the California SHPO. More 

information from CDFG will be needed before consultation with the SHPO can be 

initiated. 

Visitor Experience 

Converting 12 abandoned wells into guzzlers has the potential to increase 

hunting activities if wildlife populations grow from an increased availability 

of water. Increased potential for wildlife viewing may be offset by the 

potential for increased visitor-to-visitor encounters and associated decrease in 

opportunities for solitude. 

Development and Public Health & Safety

Alternative B would reactivate twelve wells that did not meet California Public 

Safety Code for potable water. This alternative would increase public health 
Wells-to-Guzzlers Environmental Assessment page 31 of 43 

and safety risks to visitors who might drink from these non-potable water 

sources. This risk is low and can be mitigated. Mitigative measures, such as 

appropriate signage, will be selected and implemented based on minimal 

intrusiveness to the ecosystem and to the backcountry to maximize the visitor 

experience of the openness, nature, and solitude of Mojave National Preserve. 

Park Operations

California Department of Fish and Game has pledged funding and volunteer labor 

to implement the Proposed Action. This would include the initial construction 

effort to convert the twelve sites to guzzlers and follow-up and routine 

monitoring. NPS operations would be affected by increased workload of special 

use permits and occasional monitoring of the proposed guzzlers. This additional 

workload would be minor and would be absorbed into daily park operations. 

Wilderness 

The 12 well sites were chosen because of their location outside of wilderness 

and desert tortoise critical habitat. Therefore, the implementation of the 

Proposed Action would not have impacts on wilderness values. 

Cumulative Impacts

The Proposed Action has associated cumulative impacts. The increased 

availability of water will attract all species of wildlife that can utilize 

these guzzlers, including small game, neotropical migratory birds, and predatory 

species – i.e., raptors and ravens. Although the twelve proposed guzzlers are 

located outside of desert tortoise critical habitat, the potential increase of 

ravens in the Preserve also presents an increased threat to the tortoise 

population. Most reptiles may not be able to reach the drinkers and would only 

benefit from spill-over water. They would, nonetheless, be subject to increased 

predation, similar to the tortoise impacts described above. Alternative B will 

create a portal to the groundwater source at the twelve proposed sites. The 

groundwater table will be more vulnerable to pollution – both natural (e.g., E. 

coli) and human-induced (e.g., dumping). It will also be lowered each time 

water is pumped to the surface. A third consideration is the potential for 

wildlife to habituate to the new guzzlers. If, for some reason, these sources 

are not maintained regularly or at all, the survival of these populations will 

be threatened. 

These cumulative impacts have been identified based on a series of assumptions 

about the Proposed Action and its impacts. Until CDFG provides more 

information, it is not known for certain if any of these impacts would result 

from the conversion of 12 ranching wells to guzzlers. 

Impairment

Ranching wells were operated in Mojave for over 100 years. Alternative B would 

return available above-ground water to those levels that existed before 2000, 

when such waters were used for cattle ranching. There is, nonetheless, a lack 

of information on both prior and proposed levels of use of the 12 wells. 

Therefore, impacts are not fully known. Impairment or the lack thereof cannot 

be concluded to result from the Proposed Action. 
Wells-to-Guzzlers Environmental Assessment page 32 of 43 

Alternative C – Science-Based Management 

Monitor the Natural Springs and Wildlife Populations of Mojave National Preserve 

to Determine Existence and Extent of Need for Artificial Water 

Soils

Alternative C, to base management decisions on scientific data of natural 

springs and wildlife in Mojave National Preserve, will involve surveying and 

monitoring undeveloped water sources, wildlife that may use these waters, and 

local habitats. Some of these studies may involve minor to negligible soil 

disturbance. No significant ground surface disturbance or soil sampling will be 

necessary make better informed management decisions at Mojave National Preserve. 

Alternative C will not cause significant impacts to soils or other geologic 

resources. 

Water Resources

Alternative C will involve studies to better understand undeveloped water 

sources (e.g., springs and seeps). Surveying and sampling activities will be 

limited to surface waters that are normally available for wildlife use and will 

have minimal impacts. 

Wildlife

Alternative C will include studies of wildlife that may use developed and 

undeveloped surface waters and the surrounding habitats. Wildlife research will 

likely involve activities such as monitoring by motion-sensor cameras, pellet 

transect data collection, and the like. Impacts to wildlife from scientific 

studies will be negligible or non-existent. 

Vegetation

Scientific studies may be conducted to better understand undeveloped water 

sources, wildlife that may use these waters, and associated local habitats. 

Habitat studies may involve the establishment and monitoring of transects, 

sampling, and measurements, for example. Vegetation will remain largely intact; 

impacts to flora will be minor to negligible. 

Threatened, Endangered & Sensitive Species

There are no known threatened, endangered, or sensitive species in or around 

desert bighorn habitat in Mojave National Preserve. Scientific studies as 

proposed in Alternative C will have little to no impacts on T&E species 

documented in the Park. 

 

Prehistoric, Historic & Cultural Landscape Resources

Cultural resources, including historic and prehistoric resources, may be 

impacted to the extent that some scientific studies may take place near 

culturally significant features. Any studies requiring ground disturbance will 

require archeological clearance before field work can begin. As stated above, 

ground disturbance will be temporary and negligible; therefore, below-ground 

resources should not be impacted. It is Park policy to halt work immediately if 

any such resources are discovered. The Park archeologist must conduct a site 

visit and ensure no impacts to the cultural resources in question before work 

can continue. With these stipulations, adverse impacts to the cultural 

resources will be avoided or minimized to the extent possible. Scientific 

studies should not lead to significant impacts of Mojave’s prehistoric, 

historic, or cultural landscape resources. 
Wells-to-Guzzlers Environmental Assessment page 33 of 43 

Visitor Experience 

Implementation of Alternative C will be focused at locations of undeveloped 

water sources, many of which are in remote areas. Because visitation to these 

areas tends to be low, the number of visitors impacted by the establishment of 

study plots or installation of monitoring equipment will be similarly low. 

Development and Park Operations 

Implementation of Alternative C will be focused at locations of undeveloped 

water sources, many of which are in remote areas. Development and park 

operations will not be impacted by these studies. 

Wilderness

Implementation of Alternative C will be focused at locations of undeveloped 

water sources, many of which are in remote areas. Data will need to be 

collected for sites both inside and outside of designated wilderness to better 

understand the entirety of water availability and wildlife usage throughout the 

Preserve. For water sources located in wilderness, use of mechanized or 

motorized equipment will require a Minimum Tool determination for each study. 

Other potential studies may focus on wildlife population dynamics, game species 

utilization patterns, and other non-intrusive data collection. Studies will be 

selected that will best protect the resources of Mojave National Preserve 

including approximately 700,000 acres of designated wilderness. Minimizing 

impacts to wilderness must be incorporated into the permitting process. The 

Minimum Tool for each scientific research and collecting permit will include 

consideration from the public. 

Cumulative Impacts

As with the impacts identified above, little is known about cumulative impacts 

resulting from Alternative C. Depending on the studies to be performed, it is 

possible for many of the cumulative impacts identified in Alternative B to also 

result from Alternative C over a much shorter period of time. There may, for 

example, be an increase in human-animal encounters during monitoring efforts. 

There might also be more structures (e.g., survey equipment) in the field. This 

would increase the number of potential roosting perches, for example, that could 

be used by raptors and ravens. Scientific research might temporarily impact 

visitor use – e.g., area closures, disruption of the view shed, etc. The 

National Park Service will minimize or avoid cumulative impacts through the 

scientific research and collection permitting process. Only studies that do not 

have significant adverse impacts will be considered, to avoid or minimize to the 

extent possible adverse impacts to the resources of the Preserve. 

Impairment

All impacts identified above may be avoided or mitigated to a minimal level. 

Alternative C would have the same impacts as Alternative A at first. Over time, 

the impacts from Alternative C would decrease as available information increases 

and makes greater contributions to management decisions. The long-term result 

would be greater protection of the resources of Mojave National Preserve. 

Therefore, Alternative C will not result in any impairment to the natural and 

cultural resources of Mojave National Preserve. 
Wells-to-Guzzlers Environmental Assessment page 34 of 43 

ENVIRONMENTALLY PREFERRED ALTERNATIVE 

A final determination of the environmentally preferred alternative cannot be 

made unless more information regarding Alternatives B (Proposed Action) is 

provided. With the information currently available, it can be asserted that 

Alternatives A and C would have the least impacts, and that Alternative B has 

temporary and potential long-term adverse effects. To conclusively determine 

the Environmentally Preferred alternative, more needs to be known about the 

design and function of the proposed guzzlers, wildlife use history and patterns 

of artificial watering facilities and of undeveloped water sources in Mojave 

National Preserve, wildlife populations and population dynamics, and protections 

of groundwater quality and quantity. 

The alternative that best meets the criteria for environmentally preferred is 

Alternative C. At first, Alternative C would produce the same level of impacts 

as Alternative A, No Action. These impacts have been determined to be minor, 

negligible, or mitigable. Over time, as long-term scientific studies are 

completed and more information becomes available, the natural and cultural 

resources of Mojave National Preserve will be better protected by science-based 

management decisions. In this regard, Alternative C would present an 

environmentally preferred outcome over Alternative A.
Wells-to-Guzzlers Environmental Assessment page 35 of 43 

COMPARISON OF IMPACTS Table 1 summarizes the potential long-term impacts of the all four alternatives. Short-term imincluded in this table, but are analyzed in the Environmental Consequences section. Impact inand duration are also defined in the Environmental Consequences section. Table 1. Potential Long-Term Impacts 

IMPACT TOPICS ALTERNATIVE A, 

No Action

ALTERNATIVE B, Proposed 

Action (Retrofit 12 

Ranching Water Developments 

to Wildlife Guzzlers) 

ALTERNATIVE 

Based Man

Soils None Temporary disturbance 

during construction. 

None 

Water Resources Beneficial impacts include 

returning Mojave National Preserve waters to a natural state and restoring springs and the groundwater table. Potential for adverse impacts include a short-term negative effect on game species. There is no evidence of long-term population declines resulting from the No Action Alternative. 

Potential to lower groundwater table and have a negative effect on undeveloped groundwater-fed sources. Potential for adverse impacts may be high. Full extent of impacts remains unknown until CDFG provides more details about the Proposed Action. 

None 

Wildlife 

None Potential dependence on 12 

new guzzlers by wildlife populations. Potential for increase in wildlife population numbers. Impacts are certain but the full extent of impacts remains unknown until CDFG provides more details about the Proposed Action. 

None 

Vegetation 

None Potential negative impacts 

from increased foraging and trampling as wildlife populations and guzzler use increases. 

None 
Wells-to-Guzzlers Environmental Assessment page 36 of 43 

IMPACT TOPICS ALTERNATIVE A, 

No Action

ALTERNATIVE B, Proposed 

Action (Retrofit 12 

Ranching Water Developments 

to Wildlife Guzzlers) 

ALTERNATIVE 

Based Man

Threatened, 

Endangered, & 

Sensitive Species 

None Adverse impacts to desert 

tortoise or other listed species are unlikely. 

None 

Prehistoric, 

Historic, 

Cultural 

Landscape Resources 

None. Historic Register nominations would go forward as planned. Contributing cultural features would continue to be protected under current management policies. No adverse impacts anticipated. 

High potential for adverse impacts to contributing elements of the Rock Springs Land and Cattle Company Historic District nomination. Impacts to cultural landscapes and other cultural resources will require consultation with the California State Historic Preservation Office. 

None 

Visitor 

Experience 

None Potential increased hunting 

activities. Potential increase in wildlife viewing opportunities. Potential increase in visitor encounters and decrease in opportunities for solitude. 

None 

Development and Public Health & 

Safety 

Potential benefit to public health & safety if wells are sealed and abandoned. 

Minor potential for increased risk to public health & human safety that can be mitigated. 

None 

Park Operations None Minor impacts to park 

operations. 

None 

Wilderness None None None 
Wells-to-Guzzlers Environmental Assessment page 37 of 43 

SECTION V: COORDINATION AND CONSULTATION 

The National Park Service hosted a public scoping meeting on June 27, 2005 in 

Barstow, California. Comments regarding the development of a NEPA document 

were accepted until September 1, 2005. Over 2000 comments were received in 

total of which approximately 200 form letters supported the CDFG proposal and 

approximately 1700 form letters opposed it. The balance of the comments were 

written and sent individually. All comments received are preserved in the 

administrative record. 

The alternatives presented in this environmental assessment were developed 

from comments received from the public. The comments were generally divided 

between those supporting the Wells-to-Guzzlers proposal and those against it. 

Alternative D was developed from comments proposing to convert all ranching 

developments into wildlife water sources. Alternative E was similarly 

developed from comments opposing artificial watering sources for wildlife. 

Alternative C resulted from comments by both sides urging science-based 

decisions. 

The EA will be released to the public for a 60-day comment period. In addition, 

the National Park Service will consult with Native American tribes regarding all 

proposed activities. 

Public notice of the availability of this environmental assessment was published in 

local newspapers, and on the Mojave National Preserve Internet website 

(http://www.nps.gov/moja). Individuals and organizations can request the 

environmental assessment in writing, by phone, or by e-mail. The environmental 

assessment was circulated to various federal and state agencies, individuals, 

businesses, and organizations on the park’s mailing list for a 60-day public review 

period. Copies of the environmental assessment were made available at area 

libraries. Agencies and organizations receiving copies include: 

Bureau of Land Management, California Desert District, Moreno Valley 

Bureau of Land Management, Barstow Resource Area 

Bureau of Land Management, Needles Resource Area 

California Department of Fish and Game, Eastern Sierra and Inland Deserts Region 

(Region 6), Bishop Field Office 

California State Parks and Recreation, Providence Mountains State Recreation 

Area 

California State University, Fullerton, Desert Studies Center, Soda Lake 

Southern California Edison 

University of California, Sweeney Granite Mountains Research Center 

US Fish & Wildlife Service, Ventura Field Office 

A copy of the environmental assessment can be obtained by direct request to: 

Mojave National Preserve 

Attention: Wells-to-Guzzlers EA 

2701 Barstow Road 

Barstow, CA 92311 

(760) 252-6101 
Wells-to-Guzzlers Environmental Assessment page 38 of 43 

SECTION VI: LIST OF PREPARERS 

Mojave National Preserve

Danette Woo, Environmental Compliance Specialist 

Debra Hughson, Science Advisor 

Larry Whalon, Chief of Resource Management 

Robert Bryson, Archeologist 

SECTION VI: LIST OF REFERENCES 

California Department of Fish and Game. California T&E Species and Species of 

Special Concern.

California Department of Water Resources. 1991. California Well Standards 

(Supplement to Bulletin 74-81). Bulletin 74-90. 

California Department of Water Resources. 1981. California Water Well Standards. 

Bulletin 74-81. 

National Park Service. 2002. General Management Plan and Final Environmental Impact 

Statement. USDI National Park Service. 

National Park Service. 1999. Directors Order/Reference Manual #18: Wildland Fire 

Management Policy. USDI National Park Service. 

National Park Service. 1999. Directors Order/Reference Manual #41: Wilderness 

Management Policy. USDI National Park Service. 

National Archives and Records Administration. 1994 California Desert Protection 

Act (Public Law 103-433). Accessed online at: 

http://www.gpoaccess.gov/plaws/index.html. 
Wells-to-Guzzlers Environmental Assessment page 39 of 43 

APPENDIX A: Minimum Tool Requirement Analysis, Part 1 

Proposed Action 

Superintendent authorizes use. 

Document and critique incident 

Proceed with project through park compliance 

process 

Disapprove 

other laws and policies? 

Is the action covered by an approved Wilderness Plan (or like plan?) 

Is the proposed action covered by a CE, EA/FONSI, or EIS/ROD? 

Proceed with project through park review process 
Wells-to-Guzzlers Environmental Assessment page 40 of 43 

Proceed with project through park review process 

Defer until compliance is completed. 

MINIMUM TOOL REQUIREMENT ANALYSIS 

PART 2 

Is the Action essential to meet planned Wilderness Objectives? 

Do not proceed 

Can the action be accomplished outside wilderness? 

Conduct outside wilderness 

Determine alternative that has the least impact on Wilderness character and 

resources 

List alternative ways to accomplish the action 

Can the action be accomplished through visitor education? 

Then use: 

Interpretation Authority of Resource Leave No Trace Wilderness Ethics 

Select appropriate Select 

mechanized tool. 

Non- appropriate 

routine uses only 

or 

minimum tool 

administrative and skills 
Wells-to-Guzzlers Environmental Assessment page 41 of 43 

research. 
Wells-to-Guzzlers Environmental Assessment page 42 of 43 

Minimum Requirement Analysis

Decision Screening Questions

1 Does your action insure that wilderness is not occupied and modified? Yes. No 

modification or occupation would occur. 

2 Does your action maintain or move the Wilderness toward less human influence 

within legal constraints? No. Bighorn sheep management activities are within the 

legal framework of the Clark County Conservation Act of 2002, which established the 

Wilderness in Lake Mead NRA. 

3 Does your rationale allow Wilderness to retain solitude and elements of 

surprise and discovery? Yes, as much as possible activities would be restricted to 

periods of low use. 

4 Did you evaluate the traps of making decisions based on economy, convenience, 

comfort, or commercial value? Yes. Options are limited for bighorn sheep management 

activities based on location of sheep populations, feasibility of trapping options, 

and importance of the bighorn sheep herd to the ecosystem of southern Nevada. 

5 Did you look beyond the short-term outputs to ensure that future generations 

will be able to use and enjoy the benefits of an enduring resource of Wilderness? 

Yes. Managing bighorn sheep to allow future generations to experience these 

creatures as part of the enduring Wilderness resource is considered important for 

long-term preservation goals. 

6 Does the alternative support the Wilderness resource in its entirety rather 

than maximizing an individual resource? Effective bighorn sheep management 

supports the Wilderness resource in whole. 

7 Do you recognize the unique characteristics for this particular Wilderness? 

Yes, four Wilderness units are affected. 

8 Does the action prevent the effects of human activities from dominating 

natural conditions and processes? Yes – human activities are restricted and on a 

temporary basis only. 
Wells-to-Guzzlers Environmental Assessment page 43 of 43 

APPENDIX B: National Park Service Press Release 

 

National Park Service 

U.S. Department of the Interior 

Mojave National Preserve 2701 Barstow Road 

Barstow, California 92311 

(760) 252-6102 phone 

(760) 252-6174 fax 

Mojave National Preserve News Release 

 June 6, 2005 Release Number: 05-006 

 For Immediate Release 

 Contact: Danette Woo (760) 252-6107 

Mojave National Preserve to hold public scoping meetings 

The Mojave National Preserve has begun the development of the Park’s Environmental Assessment to 

Convert Wells to Guzzlers (EA). The Preserve has scheduled one public open house session for the 

public to review planning issues and offer input needed for the completion of these plans. 

Superintendent Mary G. Martin said, “The Park is very interested in receiving public input.” See below 

for more information. 

Monday, June 27 from 5 pm - 8 pm 

Holiday Inn Express Hotel & Suites 

2700 Lenwood Road 

Barstow, CA 

(760) 253-9200 

The projected date for completion of a draft EA is September 1, 2005. The public review and comment 

period will commence upon release of this document. If members of the public have any questions on 

the scoping and planning process, they may contact Ms. Danette Woo at 

(760) 252-6107. 

-NPS-