Death Valley National Park

National Park Service

U.S. Department of the Interior

Death Valley National Park

California and Nevada

Environmental Assessment

Scotty’s Castle Waterline Replacement

June 3, 2011

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U.S. Department of the Interior

National Park Service

Environmental Assessment

Scotty’s Castle Waterline Replacement

Death Valley National Park

Inyo County, California

Notes to Reviewers and Respondents

If you wish to comment on the environmental assessment you may mail comments to the name 

and address below. Our practice is to make comments, including names and home addresses of 

respondents, available for public review during regular business hours. Individual respondents 

may request that we withhold their home address from the record, which we will honor to the 

extent allowable by law. If you want us to withhold your name and address, you must state this 

prominently at the beginning of your comment. We will make all submissions from 

organizations and businesses, and from individuals identifying themselves as representatives or 

officials or organizations or businesses, available for public inspection in their entirety.

Please address comments to: Superintendent; Death Valley National Park; Attn: Scotty‟s Castle 

Waterline EA; PO Box 579; Death Valley, CA 92328 or e-mail: 

DEVA_superintendent@nps.gov
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TABLE OF CONTENTS

TABLE OF CONTENTS II

INTRODUCTION 1

Purpose and Need For Action 1

DESCRIPTION OF THE ALTERNATIVES 11

No-Action Alternative 11

Alternative Two: Trenching 11

Alternative Three: Pipe-bursting 11

Actions Common To All action Alternatives 12

Alternatives Considered but Dismissed 15

Environmentally Prefered Alternative 16

Mitigation Measures 17

Comparasion of Alternatives 20

Comparasion of Potential Environmental Impacts 21

AFFECTED ENVIRONMENT 22

Cultural Landscapes 22

Archaeological Resources and Historic Structures 23

Ethnographic Resources 24

Special-Status Species (Threatened and Endangered Species and Species of Concern) 24

Park Operations 26

ENVIRONMENTAL CONSEQUENCES 27

Introduction 27

Methodology 27

Impairment of Death Valley National Park Resources or Values 33

Environmental Consequences—No-Action Alternative 33

Environmental Consequences—Alternative Two: Trenching 37

Environmental Consequences—Alternative Three: Pipe-Bursting 40

CONSULTATION AND COORDINATION 43

LIST OF PREPARERS 45

WORKS CITED 47

APPENDIX A: PROJECT SCOPING MATERIALS

APPENDIX B: CONSULTATION AND COORDINATION LETTERS
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INTRODUCTION

PURPOSE AND NEED FOR ACTION

The National Park Service (NPS) proposes to replace the existing waterline at the Death Valley 

Scotty Historic District, Death Valley National Park, California.

This action is needed because the existing waterline is original to Scotty's Castle, in poor 

condition and continuing to deteriorate. Several short sections of the waterline have been 

replaced over past years due to breakage. The NPS needs to continue providing water to

Scotty's Castle for visitors, residents, and fire suppression; therefore, it is proposed that the 

entire waterline be replaced to avoid a major break that may temporarily shut off water to the 

site.

This environmental assessment analyzes the no-action alternative, two action alternatives, other 

alternatives and their impacts on the environment. This environmental assessment has been 

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

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

1508.9); National Park Service Director‟s Order – 12: Conservation Planning, Environmental 

Impact Analysis, and Decision-making; and the National Historic Preservation Act of 1966 (as 

amended).

PARK PURPOSE, SIGNIFICANCE, AND MISSION

An essential part of the planning process is to understand the purpose, significance, and mission 

of the park for which this environmental assessment is being prepared.

Park Purpose

Death Valley National Park dedicates itself to preserving the unrivaled scenic, geologic, and 

natural resources of these unique natural landscapes, while perpetuating significant and diverse 

ecosystems of the California desert in their natural state. The Park will also ensure the 

maximum protection of wilderness values provided by law.

The purpose and significance of Death Valley National Park are defined in the General 

Management Plan (NPS 2006). According to this document, which is based on the Park‟s 

enabling legislation and Presidential Proclamations, the purposes of Death Valley National 

Park include, among others:

 Preserving the cultural resources of the California desert associated with prehistoric, 

historic, and contemporary American Indian culture, patterns of western exploration, 

settlement, and mining endeavors.

 Providing opportunities for compatible public outdoor recreation and promote the 

public‟s understanding and appreciation of the California desert by interpreting the 

natural and cultural resources.
Contents

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 Retaining and enhancing opportunities for scientific research in undisturbed 

ecosystems.

Park Significance

Death Valley National Park has many elements that are considered significant across various 

disciplines in cultural and natural resources. The following list captures the essence of the 

Park‟s importance to the natural and cultural heritage of the United States of America.

 Scotty‟s Castle, with its architectural style, quality, and priceless collection of antiques 

and art objects, built in a remote, isolated desert location in the early 1900s, is an icon 

that has immense public appeal.

 Death Valley National Park contains an unusually high number of well-preserved 

archeological sites, including rock art and alignments.

 Death Valley National Park has an extensive and well-preserved mining history 

representing over 100 years of mining technology.

 Death Valley has been the continuous home of American Indians from prehistoric 

cultures to the present day Timbisha-Shoshone Tribe.

 Contrary to many visitors‟ first impression, Death Valley National Park‟s natural 

resources are extremely diverse, containing a large variety of plant species and 

community types. The area preserves large expanses of creosote bush valleys and other 

vegetation typical of the Mojave Desert. Extreme conditions and isolation provide 

habitat for an unusually high number of plant and animal species that are highly adapted 

to these conditions.

 Death Valley National Park is one of the largest expanses of protected warm desert in 

the world. Ninety-one percent of the Park is designated wilderness, providing unique 

opportunities for quiet, solitude, and primitive adventure in an extreme desert 

ecosystem.

Park Mission

Death Valley National Park, hereafter referred to as the Park, dedicates itself to protecting 

significant desert features that provide world class scenic, scientific, and educational 

opportunities for visitors and academics to explore and study.

PREVIOUS PLANNING

The proposed Death Valley Scotty Historic District waterline replacement is consistent with the 

primary management objectives for the Park, as stated in the approved General Management 

Plan (NPS 2006). The stated objectives include: 

 Maintain, preserve, interpret, and perpetuate the aesthetic setting, and the natural and cultural resources of 

Death Valley National Park (pg. 4).

 Maintain the public use and administrative support facilities and equipment in a manner that will provide 

visitors safe and enjoyable experiences and prolong the life of the equipment and facilities (pg. 6).
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Figure 1. Project Location and Existing Waterline Map
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ISSUES AND IMPACT TOPICS

Issues

Issues and concerns affecting this proposal were identified from past National Park Service 

planning efforts and internal and external scoping. The issues and concerns identified in the 

planning stage allowed this environmental assessment to focus on those impact topics that have 

the greatest potential to be affected by the proposed project activities. The major issues related 

to this project include both natural and cultural resources and park operations. Natural resource 

issues identified were impacts to special-status species. Cultural resource issues identified 

included impacts to archaeological resources, ethnographic resources, and cultural landscapes. 

Park operations issues identified were related to water for consumptive use and fire 

suppression.

Specific impact topics were identified for analysis within the environmental assessment. These 

impact topics were identified based on Federal laws, regulations, and Executive Orders; NPS 

Management Policies 2006; and professional judgment of staff on what resources may be 

impacted by the project. Resources to which it was determined impacts would be negligible or 

non-existent were dismissed from detailed analysis. Topics dismissed are briefly discussed 

followed by a brief rationale for dismissing specific topics from further consideration.

Impact Topics Selected for Detailed Analysis

Cultural Landscapes

Archeological Resources and Historic Structures

Ethnographic Resources

Special-Status Species

Park Operations

Impact Topics Dismissed from Detailed Analysis

Water Quality, Wetlands, and Floodplains

The 1972 Federal Water Pollution Control Act, as amended by the Clean Water Act of 1977, is 

a national policy to restore and maintain the chemical, physical, and biological integrity of the 

nation‟s waters; to enhance the quality of water resources; and to prevent, control, and abate 

water pollution. NPS Management Policies provide direction for the preservation, use, and 

quality of water in national park units. Executive Order 11988 (Floodplain Management) 

requires an examination of impacts to floodplains and potential risk involved in placing 

facilities within floodplains. Executive Order 11990 (Protection of Wetlands) requires an 

examination of impacts to wetlands. NPS Management Policies, Director‟s Order – 2: Planning 

Guidelines, and Director‟s Order – 12 provide guidelines for proposed actions in floodplains.

The project lies within Grapevine Canyon which drains an area of 14,940 acres (23.3 sq mi) 

and has a relief of 4,000 ft (ranging from 3,000 to 7,000 ft). There is also a perennial spring, its 

associated springbrook, and delineated wetlands within the project corridor.

There has not been a detailed flood frequency analysis for Grapevine Canyon. However, it is 

accepted that the project area is in a 100-year flood zone, and the Park Hydrologist estimates 

that the project area lies within a 50-year flood zone.
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The potential for impacts to water quality related to this project are from possible 

petrochemical spills from machinery or increased sediment loads during flooding. 

Petrochemical spills are unlikely, but, as described in the project mitigation measures any spills 

would be immediately contained and any contaminated soil would be removed. Vegetation 

recovery is expected to restore erosion susceptibility to pre-disturbance levels within one year. 

Mitigation measures would be implemented for sediment control. With implementation of 

mitigation measures, there are no anticipated impacts to water quality from this project and 

water quality is dismissed as an impact topic in this environmental assessment. The impacts of 

the proposed project would not affect the overall functions of floodplains and wetlands, and 

any impacts are expected to be minor and temporary. Therefore wetlands and floodplains are 

dismissed as impact topics in this environmental assessment.

Vegetation

National Park Service policy is to protect the components and processes of naturally occurring 

biotic communities, including the natural abundance, diversity, and ecological integrity of 

plants and animals (NPS 2006 Section 4). Replacing the waterline would have the potential to 

disturb, remove, and eliminate vegetation; however, due to context and intensity, these impacts 

would be negligible. Two plant communities would be impacted in the project areas including a 

Larrea-Atriplex alliance which is widespread and common throughout Death Valley. The other 

plant community that would be affected is a riparian corridor that is largely composed of 

Baccharis, Atriplex and Vitis which are locally common species with high growth rates and an 

expected recovery time of one year. No rare plant species were found in the project area.

With this project there is a potential for the spread of non-native invasive plants that are 

currently established at both the origin and the terminus of the waterline. All of the proposed 

actions would result in a high amount of disturbance as well as traffic in and out of the corridor. 

The area surrounding the water collection tanks at the east end of the waterline is currently 

infested with a large amounts of Russian thistle (Salsola sp.), London rocket (Sisymbrium irio) 

and red brome (Bromus madritensis ssp. rubens). The west end of the waterline is infested with 

more species, although in lower densities, including rabbitsfoot grass (Polypogon 

monspeliensis), five-hook bassia (Bassia hyssopifolia), sowthistle (Sonchus asper), Russian 

thistle (Salsola sp.), halogeton (Halogeton glomeratus) London rocket (Sisymbrium irio) and 

red brome (Bromus madritensis ssp. rubens). With use of mitigation measures, the spread of 

non-native invasive plants would be minimal or non-existent.

Soils

When soil excavation is an unavoidable part of an approved facility development project, the 

Service will minimize soil excavation, erosion, and off-site soil mitigation during and after the 

development activity (NPS 2006 Sect. 4.8.2.4). Soils have not been mapped along the Scotty‟s 

Castle Waterline Replacement corridor; however, general soils information can be determined 

based on the geologic formations from which the soils were derived. The topographic lows on 

either end of the road consist of sedimentary deposits resulting from erosion of higher areas and 

deposition in alluvial fans and drainage channels. Also included are soils derived from deposits 

of evaporates carried in by water, principally limestone, gypsum, and salt. There are also 

volcanically derived soils from erosion of volcanic layers interspersed within the Park (Harris 
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et al. 1997). The basin soils are thicker in the bottom of the basins and grow thinner as the 

slope and elevation increase. Soils in the higher elevations are derived from the mountain rocks 

present in the vicinity and contain rocks and rocky outcrops.

Soils will be disturbed during excavation, but they would be returned to the areas from which 

they were excavated. Other potential impacts to soils are from possible petrochemical spills 

from machinery, or increased soil loss if flooding were to occur within one year of 

construction. Petrochemical spills are unlikely, but any spills would be immediately contained

and any contaminated soil would be removed. Vegetation recovery is expected to restore 

erosion susceptibility to pre-disturbance levels within one year. However, if a flood event 

occurs within a year following the project, the disturbed areas would be vulnerable to erosion. 

See the Mitigation Measure Section for detailed descriptions of required mitigations for soils 

and erosion control. The project‟s impacts on soils are expected to be minor and temporary. 

Therefore, soils are dismissed as an impact topic in the environmental assessment.

Terrestrial Wildlife and Migratory Birds

National Park Service policy is to protect the components and processes of naturally occurring 

biotic communities, including the natural abundance, diversity, and ecological integrity of 

plants and animals (NPS 2006 Section 4). Replacing the waterline would have the potential to 

disturb, temporarily or permanently displace, wildlife or their habitat; however, due to context 

and intensity, these impacts would be negligible. Only the special status bird species would 

have impacts that require detailed analysis (see Affected Environment and Environmental 

Consequences sections).

Animals that would be impacted in the project area include amphibians, birds, mammals, and 

reptiles. The amphibians, reptiles, and small mammals would be impacted the most through 

habitat alteration and mortality. These species are all widespread and common throughout 

Death Valley, have a high reproduction rate, and an expected recovery time of one year. There 

is only one amphibian species, Hyla regila (Pacific Tree Frog) located within the project area. 

The reptile community is composed of Squamata (Snakes) and Iguinadae (Lizards). The small 

mammal community largely composed of four Families: Dipodomys, Neotoma, Peromyscus, 

and Sciuridae. The medium and large mammal communities utilize areas around the Death 

Valley Scotty Historic District, rather than these springs due to human activity.

Larger mammals such as Bighorn sheep (Ovis canadensis nelsoni) and coyotes (Canis latrans) 

travel through the area but prefer areas further from Scotty‟s Castle for food, water, and shelter 

to avoid contact with human activities. Both animals are widespread and common throughout 

the Park. Coyotes have a higher reproduction rate and this project is expected to have no 

impact on breeding success. Although Bighorn have a slower reproduction rate, they avoid this 

area of close contact with humans; therefore, this project is expected to have no impact on the 

population size of the herd.

The majority of bird species observed in this district are migrants that make use of other 

breeding grounds. The Grapevine Springs Complex provides suitable habitat where they can 

rest and feed. Therefore, this project is expected to have no impact on the population size of 

migrant species. Between 20 -30 bird species breed in areas around Scotty‟s Castle surveyed in 
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2005 and 2010 (NPS 2010d). Birds that utilize this area for nesting have opportunities to select 

other territories for breeding behavior. These species have a moderate reproduction rate; 

therefore, it is expected that these species have a recovery time of 1-2 years.

Aquatic Wildlife (Macroinvertebrates)

Aquatic habitats are densely covered with both aquatic plants and riparian vegetation. Openings 

to the springbrook are limited except near Scotty‟s Castle where riparian vegetation has been 

removed or reduced. Aquatic habitats are dominated by several species of springsnails. Several 

of these springsnail are endemic to the Grapevine Spring complex. These include Pyrgulopsis 

micrococcus and Pyrgulopsis margae (Hershler and Liu 2003). At least two other species of 

springsnails (Physidae and Hydrobiidae) are also found in Grapevine Spring (Hershler and 

Sada 1987). 

An aquatic macroinvertebrate survey conducted in September 2010 (HDR/e2M 2011) sampled 

three different locations from the headwater pumphouse to Scotty‟s Castle proper. The 

dominant macroinvertebrates from the three sampled sites were springsnails Hydeobiidae 

(48%) and net-spinning caddisflies Hydropsyche spp. (25%). Other common taxa included 

amphipods (Gammarus spp. and Hyalella sp.), dipeterans (Chironomidae, Simuliidae, and 

Stratiomyidae), and annelids (Oligochaeta). 

There are no known threatened or endangered aquatic macroinvertebrates in the project area. If 

populations exist in the unnatural stream (from existing leaks), the same populations will also 

exist in adjacent natural streams, and fixing the leak will simply result in more water ending up 

in the natural stream course. Adverse impacts would only occur if stream channels were 

disturbed or if the riparian vegetation adjacent to stream channels is affected. Mitigation 

measures would be in place to reduce disturbance to these habitats. Measures would include but 

are not limited to reduced removal of vegetation, pipeline being placed over rather than under 

any portion of the stream channel, and fencing off of stream channels that are near construction 

zones. With use of mitigation measures impacts to aquatic wildlife would be negligible and 

therefore this impact topic has been dismissed from further consideration.

Visitor Experience

The Park Service states in its General Management Policies (2006) that the enjoyment of the 

park‟s resources is part of the fundamental purpose of all parks and that the NPS is committed 

to providing appropriate, high-quality opportunities for visitor enjoyment.

The visitor experience would be affected by the project due to construction noise, the altered 

views within the construction area, and the availability of water. Under the proposed actions, 

short-term effects to visitor use and experience would be expected during construction in the 

form of short-term, minor, adverse cumulative effects. The project‟s impacts are minor and 

temporary; therefore, this topic is dismissed in the environmental assessment.

Safety

The NPS Management Policies 2006 state that the NPS will seek to provide a safe and healthful

environment for visitors and employees (NPS 2006 Sec 8.2.5.1). The deterioration of the 

existing waterline is a safety concern for Park visitors and employees.
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The action alternatives are specifically designed to provide for public health and safety by 

ensuring that potable water and water for fire suppression continue to be provided to the Death 

Valley Scotty Historic District. Water shut-offs during construction would be mitigated by 

providing alternate sources of water, as described in the Mitigation Measures. The waterline 

replacement is expected to result in safety improvements. Public safety would not be adversely 

affected by the selection of either action alternative; therefore, safety is dismissed as an impact 

topic in this environmental assessment.

Visual Resources

The National Park Service has a responsibility to protect air quality under both the 1916 

Organic Act and the Clean Air Act. Accordingly, the Service will seek to perpetuate the best 

possible air quality in parks to (1) preserve natural resources and systems; (2) preserve cultural 

resources; and (3) sustain visitor enjoyment, human health, and scenic vistas. Integral vistas 

have been identified by the Service and are listed in Natural Resources Reference Manual 77. 

There are no regulations requiring special protection of these integral vistas, but the Service 

will strive to protect these park-related resources through cooperative means.

Visual resources may temporarily be affected by the proposed project. Overall, there would be 

a slight and temporary degradation of local visual resources due to dust generated from 

construction activities and presence of construction equipment. These effects would last only as 

long as construction occurred. Impacts would be negligible and short-term; therefore, this 

impact topic was dismissed from detailed analysis.

Designated Critical Habitat, Ecologically Critical Areas, Wild and Scenic Rivers, Other 

Unique Natural Areas

The Park Service recognizes that special designations apply to parts or all of some parks to 

highlight the additional management considerations that those designated areas warrant (NPS 

2006 Sec 4.6).

No areas within the project corridor are designated as critical habitat or ecologically critical 

(NPS 2002), nor are there any existing or potential wild and scenic rivers within the project 

area (NPS 2004). Death Valley is an important natural area, but the proposed action would not 

threaten the associated qualities and resources that make the Park unique. Therefore, this topic 

was dismissed from detailed analysis.

Geology and Geologic Hazards

The Park Service will preserve and protect geologic resources as integral components of park 

natural systems (NPS 2006 Sec 4.8.1.3).

Although ground-disturbing activities would occur under the action alternatives, impacts to the 

geology in the project area are not anticipated. Geologic hazards (e.g., faults and seismic 

activity such as earthquakes) would not be anticipated to affect the project. Faults do exist 

within the waterline corridor, but would not be expected to exhibit activity during project 

construction. Long-term use of the road to the water treatment facilities would be impacted by 

fault activity under both the no-action and action alternatives. Such impacts are not predictable 

or manageable. This topic was dismissed from detailed analysis.
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Air Quality

The 1963 Clean Air Act, as amended, requires land managers to protect air quality. Section 118 

of the Clean Air Act requires parks to meet all Federal, state, and local air pollution standards. 

Section 176(c) of the Clean Air Act requires all Federal activities and projects to conform to state 

air quality implementation plans to attain and maintain national ambient air quality standards. 

NPS Management Policies 2006 (Section 4.7) addresses the need to analyze potential impacts 

to air quality during park planning.

The project area is located in the Great Basin Unified Air Pollution Control District, as 

established by the state of California. This district is classified as a California state nonattainment area for particulate matter (fine dust) less than 10 microns in diameter.

The selection of either action alternative would lead to local air quality being temporarily affected 

by dust and construction vehicle emissions. Hauling material and operating equipment during the 

construction period would result in increased vehicle exhaust and emissions. Hydrocarbons, 

nitrogen oxide, and sulfur dioxide emissions would be expected to be rapidly dissipated. Fugitive 

dust plumes from construction equipment would intermittently increase airborne particulates in 

the area near the project site, but loading rates are not expected to be considerable or long term. 

Overall, there would be a slight and temporary degradation of local air quality due to dust

generated from construction activities and emissions from construction equipment. These 

effects would last only as long as construction occurred and impacts would be negligible and 

short-term; therefore, this topic was dismissed from detailed analysis.

Prime and Unique Farmland

Prime and unique farmlands are protected under the Farmland Protection Policy Act (7 U.S.C. 

4201 et seq.). There are no farmland areas or soils where unique crops are produced within the 

Park boundary; therefore, this topic was dismissed from detailed analysis.

Socioeconomic Environment and Land Use

The project would not change local or regional land use, nor would it appreciably affect local 

businesses outside The Park. Implementation of any action alternative could provide a 

negligible beneficial impact to the economies of Inyo and Nye Counties (e.g., increased 

employment opportunities for the construction work force and revenues for local businesses 

and government related to construction activity). Benefits to the local economy would be 

temporary, lasting only during construction, and negligible overall. Improvements in the 

waterline would not affect concessions within the Park. This topic was dismissed from detailed 

analysis.

Environmental Justice

Executive Order 12898 (General Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations), requires all agencies to incorporate environmental 

justice into their missions by identifying and addressing disproportionately high and adverse 

human health or environmental effects of their programs and policies on minorities and lowincome populations or communities. No alternative under consideration would have health or 

environmental effects on minorities or low-income populations or communities as defined in 
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the Environmental Protection Agency‟s Draft Environmental Justice Guidance July 1996. 

Therefore, this topic was dismissed from detailed analysis.

Museum Objects

The National Historic Preservation Act of 1966, NEPA, the 1916 NPS Organic Act, NPS 

Management Policies 2006, and Directors Order-24 (Museum Collections Management) 

require Federal agencies to consider the effects of their proposed actions on cultural resources. 

Museum collections (historic artifacts, natural specimens, and archival and manuscript 

material) may be threatened by fire, theft, vandalism, natural disasters, and careless acts. The 

preservation of museum collections is an ongoing process of preventative conservation, 

supplemented by conservation treatment when necessary. The primary goal is preservation of 

artifacts in as stable condition as possible to prevent damage and minimize deterioration.

The proposed activities along the waterline replacement corridor would not affect any 

designated storage or display areas for museum objects of the Park. Therefore, this topic was 

dismissed from detailed analysis.

Indian Trust Resources

Secretarial Order 3175 requires that any anticipated impacts to Indian trust resources from a 

proposed project or action by Department of Interior agencies be explicitly addressed in 

environmental documents. The Federal Indian trust responsibility is a legally enforceable 

fiduciary obligation on the part of the United Sates to protect tribal lands, assets, resources, and 

treaty rights, and it represents a duty to carry out the mandates of Federal law with respect to 

American Indian and Alaska Native tribes. There are Indian trust resources in the Park.

The Secretary of the Interior holds 313.99 acres of land in trust (Timbisha 2000) within the 

boundaries of the Park. These lands are located in the Park at Furnace Creek approximately 54 

miles from Scotty‟s Castle. This project will not impact these trust resources. Therefore, Indian 

trust resources were dismissed from detailed analysis.

Soundscapes

In accordance with NPS Management Policies 2006 and Director‟s Order – 47: Sound 

Preservation and Noise Management, an important part of the National Park Service mission is 

preservation of natural soundscapes associated with national park units. Natural soundscapes 

exist in the absence of human-caused sound. Noise associated with the waterline improvements 

would be short-term and localized. Consideration of noise impacts on threatened, endangered, 

and special-concern species are addressed under that impact topic. Therefore, this topic was 

dismissed from detailed analysis.
Mitigation Measures

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DESCRIPTION OF THE ALTERNATIVES

NO-ACTION ALTERNATIVE

This alternative would be the continuation of existing conditions of the waterline at Scotty‟s 

Castle. Should the No-Action Alternative be selected, the National Park Service would respond 

to future needs and conditions associated with the waterline at Scotty‟s Castle in the Park

without major actions or changes in the present course. The existing waterline may fail at 

sometime in the future. If the line were to fail water would not be available for staff and visitors 

or for fire suppression. Short-term, minor repair or improvement activities considered part of 

routine maintenance for functional operation of the waterline would continue under this 

alternative.

ALTERNATIVE TWO: TRENCHING 

Alternative Two proposes to replace the approximately 5,330 foot long water main from the 

storage tanks to the Death Valley Scotty Historic District with a new 8-inch waterline to protect 

employees, visitors, and Park resources. The project would follow an existing, sporadically 

used two-track maintenance road, hereafter referred to as the Spring Access Road, along the 

pipeline with a trench approximately three feet deep and two feet wide. The original pipeline 

would be removed and replaced in-kind. The new pipe would connect both storage tanks where 

their out-flow lines join together and at Scotty‟s Castle near the Stables. The newly laid pipe 

would be reburied.

This alternative would require the use of excavators and machines capable of removing 

vegetation along the entire waterline corridor; excavating a trench wide enough to ensure the 

pipe is laid safely; and removing the old pipe. It is expected that this corridor would be 

approximately 25-30 feet wide over the entire waterline and require removal of most or all

vegetation along the corridor. This alternative would be limited to a maximum amount of 

115,356 square feet of surface disturbance related to vegetation removal and trenching 

activities. 

ALTERNATIVE THREE: PIPE-BURSTING

Alternative Three proposes to replace the 5,330 foot long water main from the storage tanks to 

the Death Valley Scotty Historic District with a new 8-inch waterline to protect employees, 

visitors and Park resources. This alternative would follow the Spring Access Road along the 

original pipeline‟s footprint. The original pipeline would be burst, left in place, and new piping 

inserted into the void. Large trenches would be excavated approximately four feet deep and 

twenty feet wide. Minimally, these trenches would occur every 200 feet, at every elbow joint, 
Mitigation Measures

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and wherever power max couplers or valves are found. Two power max couplers are installed 

every 600 feet along the existing pipeline. 

The new pipe would connect both storage tanks where their out-flow lines join together and at 

Scotty‟s Castle near the Stables. Wherever trenches are excavated, the new pipe would be 

buried. This alternative could require a more limited use of trenching than Alternative Two. 

However, the power max coupler positions were not located using GIS technology. It is 

possible, given unknown locations of the couplers, that trenching would be necessary 

considerably more often than every 200 feet. 

Vegetation removal would occur along the entire waterline corridor in patches, at trench 

locations and locations necessary to maneuver equipment. If trenches are only required every 

200 feet the surface disturbance would be approximately 2,240 square feet. The 2,240 square 

feet would not include disturbance necessary to move equipment in place to lay the pipe (i.e. 

vegetation removal, surface disruption from the equipment‟s blade, tires, or tracks). If power 

max couplers are found frequently along the existing lines or other barriers are located it is 

possible that the disturbance corridor would be 25-30 feet wide over the entire waterline with a 

maximum amount of surface disturbance of 115,356 square feet.

ACTIONS COMMON TO ALL ACTION ALTERNATIVES

There would be no grading or planting of the Spring Access Road following construction of the 

waterline. 

Water supply to Scotty‟s Castle would be shut off intermittently during construction; 

potentially every day for 8-10 hours. If water would shut off for more than a four hour period

an alternate source of potable water would be provided.

Both action alternatives would be designed for a 20-year service life, meeting current and 

anticipated future needs during that period. 

Fill material excavated during this project would be used in place or recycled. There may be 

adequate base materials to utilize in-place recycling techniques or sand fill will be trucked in.

Plants may be salvaged from the construction footprint prior to the project‟s initiation. Yerba 

mansa (Anemopsis californica) is a medicinal plant that may be of interest to the TimbishaShoshone and could be easily harvested prior to construction.

A few cacti were also observed in the waterline corridor that may be salvaged for landscaping 

at the Scotty‟s Castle cactus garden.
Mitigation Measures

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Figure 2. Alternative Two: Trenching Method
Mitigation Measures

14

Figure 3. Alternative Three: Pipe-Bursting Method
Mitigation Measures

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ALTERNATIVES CONSIDERED BUT DISMISSED

The first alternative dismissed was that of using an alternate source for potable water by 

drilling a well. This option is economically unfeasible and would not be consistent with the 

cultural landscape. It would require additional resources to construct and maintain the proposed 

well and pipeline infrastructure, removal of the current system‟s springbox, and would still 

require removal and replacement of the existing pipeline.

The second alternative dismissed was that of replacing the pipeline in-kind above ground. This 

option was dismissed because it would be inconsistent with the cultural landscape.

The third alternative considered and dismissed was that of placing a new, larger holding tank 

upslope from the current tanks. This tank would be situated at an appropriate location so that 

water could reach pressures necessary for fire suppression. This alternative was dismissed 

because it is outside of the scope of the purpose and need and is not appropriate for the cultural 

landscape.

The fourth alternative dismissed was routing the pipeline underneath Bonnie Clare Road. The 

waterline would have to be routed under an active springbrook in addition to the road. This 

action would result in a disturbance of approximately 1,600 cubic yards material directly in the 

springbrook and a loss of 25,800 square feet of surface vegetation along the proposed route. 

This route would also disturb 0.68 miles of the Bonnie Clare Road. Maintenance of this line 

would involve excavating and repairing the road. This alternative would potentially disturb 

Indian Camp, a historically significant site, which is currently being added to the Death Valley 

Scotty Historic District. Due to elevation changes and curves in the road, the proposed route 

may reduce the flow (pressure) and possibly require an in-line pump. This alternative was 

dismissed because it would adversely impact hydrologic functioning of the Grapevine Springs 

complex, result in habitat loss for endemic macroinvertebrates in this spring complex, and 

cause maintenance of the waterline to more difficult and costly.

The fifth alternative discussed was combining Alternative Two: Trenching and routing the 

pipeline underneath Bonnie Clare Road until it reached the area where the Spring Access Road 

was at its closest; then the pipeline would be routed under the Spring Access Road where it is 

currently located. This option was dismissed as it would it would result in new areas of 

disturbance and would increase maintenance costs.

The sixth alternative discussed was not having potable water at Scotty‟s Castle. This option 

would create health and safety hazards for staff, residents and visitors. Fire suppression could 

not occur in a timely manner which would be inconsistent with the General Management Plan. 

Visitors, staff, and residents would have to transport water for consumption and personal 

hygiene. This alternative was dismissed because it would not be compatible with the General 

Management Plan as it would threaten personal health and safety.
Mitigation Measures

16

ENVIRONMENTALLY PREFERED ALTERNATIVE

In accordance with Director‟s Order 12, the National Park Service is required to identify the 

“environmentally preferred alternative” in all environmental documents, including 

environmental assessments. The environmentally preferred alternative is determined by 

applying the criteria suggested in NEPA, which is guided by the Council on Environmental 

Quality. The Council on Environmental Quality provides direction that “[t]he environmentally 

preferred alternative is the alternative that would promote the national environmental policy as 

expressed in section 101 of NEPA, which considers:

 fulfilling the responsibilities of each generation as trustee of the environment for 

succeeding generations

 assuring for all generations safe, healthful, productive, and esthetically and culturally 

pleasing surroundings

 attaining the widest range of beneficial uses of the environment without degradation, 

risk of health or safety, or other undesirable and unintended consequences

 preserving important historic, cultural, and natural aspects of our national heritage and 

maintaining, wherever possible, an environment that supports diversity and variety of 

individual choice

 achieving a balance between population and resource use that would permit high 

standards of living and a wide sharing of life‟s amenities

 enhancing the quality of renewable resources and approaching the maximum attainable 

recycling of depletable resources” (NEPA, section 101)”

The environmentally preferred alternative for this project is the No-Action Alternative. This 

alternative would protect, preserve, and enhance historic, cultural, and natural resources. Under 

this alternative there would be damage to natural and cultural resources over time as routine 

maintenance occurs and breaks in the waterline are repaired. Vegetation and habitat loss may 

occur and archaeological sites may be disturbed. However, damage to resources would occur 

intermittently and in small patches allowing for time for natural resources to recover. Cultural 

resources would not be damaged or removed in the short-term; however, a major break in the 

waterline may result in the inability to suppress a fire at Scotty‟s Castle.

While Alternative 2, Trenching, and Alternative 3, Pipe-Bursting, would ultimately result in the 

same pipeline replacement product in the same location, they are both unattractive in regard to 

environmental preference. Alternative 3 is more environmentally preferred than Alternative 2, 

since it minimizes excavation, and has potentially fewer disturbances to vegetation and cultural 

resources. However, since the extent of required excavation is not known (due to inadequate 

knowledge of the subterranean pipe layout), and the vehicles that would be used to replace the 

pipeline would have to traverse the entire pipeline length (disturbing vegetation and cultural 

resources on the ground surface), this alternative could ultimately result in just as much 

disturbance as Alternative 2, Trenching. 
Mitigation Measures

17

MITIGATION MEASURES

Mitigation measures are common to both action alternatives and have been developed to lessen 

any adverse effects that may occur as a result of Alternative Two and Alternative Three.

General Measures Responsible Party

Ensure that the project remains confined within the parameters 

established in the compliance documents and that mitigation 

measures are properly implemented.

Project Manager

Ensures that the work area boundaries are conspicuously staked, 

flagged, or marked to minimize surface disturbance to the 

surrounding habitat. Machinery storage and vehicle parking will 

only be permitted in designated areas (i.e. existing roadways, 

parking lots, or access routes).

Project Monitor

All protection measures will be clearly stated in the construction 

specifications and workers will be instructed to avoid conducting 

activities beyond the work area boundaries. This does not exclude 

necessary temporary structures such as erosion control fencing.

Project Manager

All tools, equipment, barricades, signs, surplus materials, and 

rubbish will be removed from the project work limits upon project 

completion. Any asphalt surfaces damaged due to work on the 

project will be repaired to original condition. Construction debris 

will be immediately hauled off from the Park or placed in a roll-off 

container and then taken to an appropriate disposal location.

Project Manger

All construction equipment (i.e., mufflers) will be required to be 

properly maintained to minimize noise from use of the equipment. 

All equipment on the project will be maintained in a clean and 

well-functioning state to avoid or minimize contamination from 

automotive fluids. All equipment will be checked daily.

Project Manager

A hazardous spill plan will be in place, stating what actions will be 

taken in the case of a spill, notification measures, and preventive 

measures to be implemented, such as the placement of refueling 

facilities, storage, and handling of hazardous materials, etc.

Project Manager and Safety 

Officer

Erosion control measures will be implemented to minimize minor 

and short-term impacts to water quality. Use of best management 

practices in the project area for drainage area protection will 

include all or some of the following actions, depending on sitespecific requirements:

Project Manager and Hydrologist

 keeping disturbed areas as small as practical to minimize 

exposed soil and the potential for erosion;

Project Manager

 locating waste and excess excavated materials outside of 

drainages to avoid sedimentation;

Project Manager

 installing silt fences, temporary earthen berms, temporary 

water bars, sediment traps, stone check dams, or other 

equivalent measures (including installing erosion-control 

measures around the perimeter of stockpiled fill material) prior 

to construction;

Project Manager

 conducting regular site inspections during the construction 

period to ensure that erosion-control measures were properly 

installed and are functioning effectively; and

Project Manager
Mitigation Measures

18

 storing, using, and disposing of chemicals, fuels, and other 

toxic materials in accordance with Federal, state and local 

regulation.

Project Manager

Soils Responsible Party

Erosion and sediment control will be required (see “General 

Measures”).

Hydrologist or Project Manager

Disturbed areas will be raked perpendicular to the slope. Native 

vegetative material which was removed during construction will be 

laid lengthwise across the disturbed areas (perpendicular to the 

slope).

Hydrologist 

Vegetation Responsible Party

Disturbed areas, along the pipeline will be allowed to return to 

natural conditions with minor treatments.

Botanist

Ground surface treatment will include grading to natural contours 

and vertical mulching to promote natural seeding.

Botanist or Hydrologist

Undesirable plant species will be controlled in high-priority areas 

and other undesirable species will be monitored and controlled, as 

necessary. To prevent the introduction and minimize the spread of 

non-native vegetation and noxious weeds, the following measures 

will be implemented during construction (NPS 2010c).

Botanist

 Mapping and pretreatment of noxious weeds (as recognized by 

the county and/or the state) in addition to the removal and 

destruction of all standing non-native vegetation that contains 

propagules will take place prior to construction and will be 

limited to the designated areas of construction.

Botanist, Exotic Plant Specialist

 Pressure wash and/or steam clean all construction equipment to 

ensure that all equipment, machinery, rocks, gravel, or other 

materials are cleaned and weed free before entering the Park

and the project area.

Project Monitor

 All construction equipment transporting material outside the 

construction limits shall be brushed down after every drive.

Project Monitor or Botanist

 Containment of soil with non-native propagules with the use of 

impenetrable weed mats and gravel in consultation with the 

State Historic Preservation Office to maintain the appearance 

of the cultural landscape or the use of pre-emergent herbicide 

in consultation with Pacific West Region Integrated Pest 

Management to control the invasive plant seedbank.

Botanist, Project Manager, Exotic 

Plant Specialist

 Monitor disturbed areas for at least 5 years (until the 

disturbance has subsided) following construction to identify 

growth of noxious weeds or non-native vegetation. Treatment 

of non-native vegetation will be completed in accordance with 

Directors Order–13, Integrated Pest Management Guidelines.

Botanist

Wildlife / Special-Status Species Responsible Party

All construction and vegetation removal activities will occur

between August 16 and March 14 in order to avoid the nesting 

season for least Bell‟s vireo and willow flycatcher.

Wildlife Biologist

Riparian vegetation adjacent to stream channels will be restored to 

pre-disturbance conditions. Photographic documentation will be 

implemented to obtain this goal.

Botanist, Aquatic Ecologist
Mitigation Measures

19

All portions of the stream will be allowed to recover to preconstruction conditions. This may include bank restoration and 

channel reconstruction.

Aquatic Ecologist, Wildlife 

Biologist, Hydrologist, Botanist

Air Quality Responsible Party

Fugitive dust plumes will be reduced to the extent possible by 

water sprinkling the soil during earth-disturbing activities. Water 

used during construction will be taken from Scotty‟s Castle or the 

Grapevine housing area under limited use guidance.

Project Manager

Cultural Resources Responsible Party

An archeologist will be present onsite, monitoring all work in the 

area of the waterlines corridor to ensure that activities occur within 

the area of potential effect defined for the project and that no 

important information is lost.

Archaeological Monitor

Should unknown archeological resources be uncovered during 

construction, work will be halted in the discovery area, the site 

secured, and the Park will consult according to 36CFR 800.13.

Archaeological Monitor

In compliance with the Native American Graves Protection and 

Repatriation Act of 1990, the National Park Service will also notify 

and consult representatives of American Indian tribes likely to be 

culturally affiliated for the proper treatment of human remains, 

funerary, and sacred objects should these be discovered during the 

project.

Archaeological Monitor

Paleontological remains and archeological specimens found within 

the construction area will be removed only by the National Park 

Service or their designated representatives.

Archaeological Monitor

Collect artifacts on the surface and catalog them. Depending upon 

subsurface deposits partial or complete excavation will occur with 

collection and analysis of artifacts and features.

Archaeological Monitor

Visitor Experience Responsible Party

Water outages of 4 hours or more will require a secondary water 

source to provide potable water to visitors and residents.

Project Manager

Health and Safety Responsible Party

Construction will take place during the cool months to avoid 

excessively high summer temperatures.

Project Manger

One of the following options with will be instigated for fire 

suppression during construction:

Fire Safety Officer

 Maintain a waterline from the storage tanks to the main 

buildings and tie into the existing waterlines in the area of the 

Stables. This water line must be capable of maintaining 

minimum flow of 1,000 GPM (gallons per minute).

Project Manager

 Install an temporary above ground storage tank on the grounds 

of Scotty‟s Castle and staff a Type 1 fire engine with a fully 

qualified crew (with a 4 minute response time) while the water 

supply from the permanent storage tank is shut off. A fully 

qualified crew consists of a Fire Officer, an Engineer and 2 

firefighters.

Project Manager

 Shut off all propane and electricity to the entire Scotty‟s Castle 

area and prohibit all sources of heat and flame. Any accidental 

fire will be suppressed by hand held extinguishers.

Project Manager
Mitigation Measures

20

COMPARASION OF ALTERNATIVES

Alternative1: No-Action Alternative Two: Trenching Alternative Three: Pipe-Bursting

The Park would continue to use the 

existing waterline. Current and 

future needs and conditions 

associated with this waterline would

have to be addressed through

means other than either action 

alternative. Water supply serving the 

Death Valley Scotty Historic District

would continue to be outdated and 

the system would continue to limit 

the reliability of water to the District.

The No-Action Alternative would not 

adequately address the project 

purpose and need of replacing the 

waterline and providing improved 

safety for residents and visitors with 

a more reliable and functional 

waterline system. The proposed 

project is needed because the 

current waterline serving the Death 

Valley Scotty Historic District is 

outdated and continues to have 

small-scale failures. This alternative

would not meet the needs of 

improving reliability and functionality 

for natural resources, cultural 

resources, visitors and staff.

The proposed action would include 

the following elements:

 Construction, operation, and 

maintenance of a waterline.

 Installation of 3,400 linear feet

of buried pipe on the Spring 

Access Road.

 The construction and 

disturbance corridor would be 

no more than 30 feet wide.

 A trench would be dug the

entire length of the waterline.

 The maximum project surface 

disturbance would be 115,356 

square feet.

Alternative Two would adequately

address the project purpose and

need of replacing the outdated 

waterline and providing improved 

availability of water for protection of

natural resources, cultural 

resource, staff, and visitors with a 

more reliable and functional 

waterline system. The proposed 

project is needed because the 

current waterline serving the Death 

Valley Scotty Historic District is 

outdated and continues to have 

small-scale failures. This project 

would meet the needs of improving

reliability and functionality for

natural resources, cultural 

resources, visitors and staff

The proposed action would include 

the following elements:

 Construction, operation, and 

maintenance of a waterline.

 Installing 3,400 linear feet of 

buried pipe on the Historic 

Spring Access Road.

 The construction and 

disturbance corridor would be no 

more than 30 feet wide.

 Trenches would be dug 

approximately every 200 feet 

along the entire waterline and 

potentially the entire length of 

the waterline. 

 The area of the trenches (if only 

needed every 200 feet) is 

estimated at 2,240 square feet. 

There may be additional 

disturbance for equipment 

maneuvering and additional 

trenches.

 The maximum project surface 

disturbance would be 115,356 

square feet.

Alternative Three would adequately

address the project purpose and

need of replacing the outdated 

waterline and providing improved 

availability of water for protection of

natural resources, cultural resource, 

staff, and visitors with a more reliable 

and functional waterline system. The 

proposed project is needed because 

the current waterline serving the 

Death Valley Scotty Historic District

is outdated and continues to have 

small-scale failures. This project 

would meet the needs of improving

reliability and functionality for natural 

resources, cultural resources, visitors 

and staff
Mitigation Measures

21

COMPARASION OF POTENTIAL ENVIRONMENTAL IMPACTS

Potential Environmental Impacts

Impact Topic No-Action Alternative Alternative Two: 

Trenching

Alternative Three: 

Pipe-Bursting

Cultural Landscape

Minor to Major

Direct and Indirect

Adverse

Short and Long-Term

Minor

Direct and Indirect

Beneficial

Short and Long-Term

Minor

Direct and Indirect

Beneficial

Short and Long-Term

Archeological Resources 

and Historic Structures

Historic Structures:

Minor to Major

Direct and Indirect

Adverse

Long-Term 

Archeological Resources:

Minor to Moderate

Direct

Adverse

Long-Term

Historic Structures:

Moderate

Indirect

Beneficial

Long-Term

Archeological Resources:

Minor to Moderate

Direct

Adverse

Long-Term 

Historic Structures:

Moderate

Indirect

Beneficial

Long-Term

Archeological 

Resources:

Minor to Moderate

Direct

Adverse 

Long-Term 

Ethnographic Resources

Minor 

Direct

Adverse

Long-Term

Moderate

Direct

Adverse

Short-Term

Moderate

Direct

Adverse

Short-Term

Special-Status Species

Minor to Moderate

Direct

Adverse

Short-Term

Minor

Indirect

Adverse

Short-Term

Minor

Indirect

Adverse

Short-Term

Park Operations 

Minor to Moderate

Direct and Indirect

Adverse

Short-Term

Moderate

Direct and Indirect

Beneficial

Long-Term

Moderate

Direct and Indirect

Beneficial

Long-Term
22

AFFECTED ENVIRONMENT

LOCATION AND GENERAL DESCRIPTION OF THE PARK

Death Valley National Park is the largest national park unit in the contiguous 48 states. The 

majority of park lands are located in the California counties of Inyo and San Bernardino, but a 

small portion of the Park is located in the Nevada counties of Nye and Esmeralda (Fig. 1). 

California State Highway 190 crosses the Park east to west, and Highway 95 parallels the Park 

north to south on the eastern boundary (NPS 2002).

Death Valley National Park encompasses 3,396,192 acres in the Mojave Desert, a zone of 

overlap between the Great Basin Desert to the north and the Sonoran Desert to the south. The 

Park includes all of Death Valley, a 156-mile long, north/south trending trough that formed 

between two major block-faulted mountain ranges: the Amargosa Range on the east and the 

Panamint Range on the west. Telescope Peak, the highest peak in the Park and in the Panamint 

Range, rises 11,049 feet above sea level and lies only 15 miles from the lowest point in the 

Western Hemisphere in the Badwater Basin salt pan, 282 feet below sea level (NPS 2002).

LOCATION AND GENERAL DESCRIPTION OF THE PROJECT

The 1,529.83-acre Scotty‟s Castle Historic District is comprised of two fenced parcels of land 

separated by a small mountain range. The smaller but more prominent eastern parcel is the 

location of Scotty‟s Castle Complex and was long known as the Upper Grapevine Ranch. This 

parcel is historically significant for its architecture, art, invention, social history, folklore, and 

the current and potential archaeological record. This project would encompass most of the 

historic Spring Access Road (NPS 2009). It would begin at the holding tanks and proceeds 

along the Spring Access Road, in a westerly direction, down Grapevine Canyon and ends near 

the stables.

CULTURAL LANDSCAPES

According to the National Park Service‟s Cultural Resource Management Guideline (Director‟s 

Order – 28), a cultural landscape is “a geographic area, including both cultural and natural 

resources and the wildlife or domestic animals therein, associated with a historic event, activity, 

or person, or exhibiting other cultural or aesthetic values.”

A cultural landscape study is ongoing at Scotty‟s Castle (NPS 2009). NPS is currently writing 

a Historic Resources Study for Scotty‟s Castle for listing in the National Register of Historic 

Places (Livingston 2009). The Park has a Historic Structures Report (1989) for Scotty‟s Castle 

Historic District. The Park also has a Roads Systems Evaluation that was finished in 1996.
23

The Spring Access Road is completely contained within the Scotty‟s Castle Historic District 

and is considered to be an important part of the Park‟s historical and cultural landscape. The 

waterline was initially designed and built by Albert Johnson to supply water to the Death 

Valley Scotty's Historic District. Its functionality is an important part of the cultural landscape 

for the district. Both of these resources are being discussed individually in the Archaeological 

Resources and Historic Structures sections of the EA.

ARCHAEOLOGICAL RESOURCES AND HISTORIC STRUCTURES

Park archeologists have identified several prehistoric archeological resources and historic 

structures in the project area that will be affected by the proposed alternatives. The 

archaeological sites are low density artifact scatters with above ground features, with the total 

artifacts mapped and discovered during subsurface testing usually averaging 100 to 200 

artifacts per site. The sites have been disturbed previously by natural erosion, waterline 

construction and maintenance, powerline construction and maintenance, the Spring Access 

Road (a historic road alignment), and portions of the area were used historically as agricultural 

fields. Additionally, one of the sites was documented and artifacts collected in 1964, without 

proper archeological mapping of those finds. The archeological data potential for these sites has 

been exhausted during the archeological documentation and testing phases. The three sites 

have been recommended "Not Eligible" for listing on the National Register of Historic Places 

under criteria D (that have yielded, or may be likely to yield, information important in 

prehistory or history) due to past disturbances. Timbisha Shoshone Tribal representatives have 

concurred with the finding that the sites were greatly disturbed by the past construction. 

There is still potential for undiscovered archeological resources in areas that could not be 

surveyed due to high vegetation density. Additionally, one buried historic site is known to 

exist in the area, but its locational information has been lost. It is not expected to be close to 

the waterline project area. 

Two historic structures have been identified in the project area. The Spring Access Road (List 

of Classified Structures Number 461566) has been determined eligible by the California SHPO 

as part of the Cultural Landscape for Death Valley Scotty Historic District (NPS 2005). It was 

constructed between 1922 and 1931 for use in the historic landscape, and may have at one time 

been part of Bonnie Clare Road (that part of the alignment was later adjusted to run on the 

outside of the property).As historically intended, it continues to provide a link between the 

main Castle complex and the water supply and conveyance system. The road remains intact and 

contributes to the overall character of the cultural landscape and site circulation. 

The pipeline itself was constructed as part of the Scotty‟s Castle over 80 years ago. The 

pipeline is still the primary conduit for water to Scotty‟s Castle, and has been maintained and 

repaired during its lifespan. Deteriorated sections have been replaced with PVC pipe. The 

pipeline is not listed in the NRHP as part of the cultural landscape or a contributing element. 
24

ETHNOGRAPHIC RESOURCES

Ethnographic resources are defined by the National Park Service as “subsistence and 

ceremonial locales and sites, structures, objects, and rural and urban landscapes assigned 

cultural significance by traditional users” (Director‟s Order – 28). American Indian tribes 

traditionally associated with project area are the Timbisha Shoshone Tribe.

Grapevine Canyon has been identified through ethnographic research as a prehistoric travel 

corridor, the location of an important village, "Maahunu," and is a place of importance for the 

Timbisha-Shoshone Tribe. An ethnographic study has been authored for this area (Johnson 

2006), and continued documentation of the area is occurring as part of this project and others. 

The Tribe also occupied the area during the historic period as laborers during the construction 

of Scotty's Castle, and "Indian Camp," their historic village is located close to the project area. 

SPECIAL-STATUS SPECIES (THREATENED AND ENDANGERED SPECIES AND 

SPECIES OF CONCERN)

The Endangered Species Act (1973), as amended, requires an examination of impacts on all 

federally listed threatened or endangered species. National Park Service policy also requires 

examination of the impacts on Federal candidate species, as well as state-listed threatened, 

endangered, candidate, rare, declining, and sensitive species. Such species could be affected by 

the proposed action through increased noise and human activity, temporary or permanent 

relocation, and outright kills or increased predation or competitive stress. 

Two federally listed species have potential to be present in the project area; the least Bell's 

vireo and the southwestern willow flycatcher. Both species utilize multi-storied riparian habitat 

for nesting and foraging. 

Least Bell's vireo (Vireo bellii pusillus) is one of four geographically isolated subspecies of 

Bell's vireo. It was federally listed as endangered 1986 after being state listed by California as 

endangered in 1980; there is no designated critical habitat in Death Valley. Least Bell's vireo 

was historically common and abundant in riparian communities in central California. Due to 

loss of habitat and habitat fragmentation, and cowbird nest parasitism it experienced severe 

decline in numbers. At the time of listing there was estimated to be only 300 pairs remaining in 

California. Since its listing, numbers have increased and it is expanding into historic range 

(Kus 2002).

Least Bell's vireo is a migratory songbird that winters in southern Baja Mexico and migrates 

north to California for breeding and rearing of young. Least Bell's vireos are small, gray birds, 

lacking distinguishing marks and commonly described as drab. Food source is insects that they 

primarily glean off of vegetation. Nests are generally constructed in dense riparian vegetation 

and are usually about 3' above ground (Kus 2002). 

Due to the geographic isolation of the four subspecies, it is presumed that all Bell's vireo 

documented in Death Valley are of the least Bell's subspecies. Bird surveys have not been 
25

conducted in all suitable habitat in Death Valley but Bell's vireo has been documented in 

Furnace Creek Ranch, Furnace Creek Wash, Johnson Canyon, Mesquite Spring, Saratoga 

Spring, West Side Road, Monarch Canyon, and Scotty's Castle (NPS 2001), (Great Basin Bird 

Observatory 2010). Territorial males were heard singing east of Scotty's Castle 1993 and 1995 

(Heindel, personal communication) and there were likely two breeding pairs in this area both 

years. In 1996 patches of vegetation in the area was removed as part of maintenance activities 

on the water system. Vegetation has grown back since then but there have been no subsequent 

sightings of Bell's vireo in the project area. Surveys were conducted in 1998, 2002, and 2005. 

Southwestern willow flycatcher (Empidonax traillii extimus) is one of four subspecies willow 

flycatchers, genus Empidonax. It was federally listed as endangered in 1995, there is no 

designated critical habitat in Death Valley. Southwestern willow flycatcher continues to 

occupy the majority of its historic range but due to loss of habitat and brood parasitism by 

brown-headed cowbirds numbers have been reduced. Trends in recovery have been difficult to 

establish (U.S. Fish and Wildlife Service 2002). 

Southwestern willow flycatcher is a small migratory songbird that winters in Mexico, Central 

and South America and migrates north for breeding and rearing of young. Southwestern 

willow flycatchers are small greyish olive birds with wingbars and a faint eye ring. They are 

difficult to identify in the field but are genetically distinct from other willow flycatcher 

subspecies. They are insectivorous and use all areas of the habitat for foraging, primarily 

catching insects in air. This bird is a late arrival to the breeding grounds, usually arriving

between May and June. Nesting is generally in dense riparian vegetation with flowing surface 

water present. Vegetation patches are usually mixed species and can include willow, 

cottonwoods, arrowweed and saltcedar; patches vary in size and patchiness both vertically and 

horizontally. Mean size of breeding patches is 21 acres, although patches less than 1 acre in 

size have been used (U.S. Fish and Wildlife Service 2002). 

 

Due to the difficulty in field identification of the subspecies it is not possible to determine if 

many of the sightings of willow flycatcher are of the southwestern subspecies. The willow 

flycatcher has been documented from several locations in Death Valley, including Furnace 

Creek Ranch, Saratoga Springs, and Scotty's Castle and Mesquite Springs (NPS 2001). Many 

of these birds were likely migrants. Breeding ranges are geographically isolated and should a 

breeding willow flycatcher be confirmed, it would likely be the southwestern subspecies. 

Surveys of the Scotty's Castle area in 1998, 2002, and 2005 detected a willow flycatcher in 

2002 (Heindel 2002). 

Species of Management Concern are species that may be state listed, former Category 2 species 

for federal listing, appear on sensitive or rare lists maintained by states or other entities, are 

endemic, or are listed in management documents or otherwise identified as important. Within 

the Scotty's Castle area, a few of the species of management concern that have been 

documented include; Cooper's hawk, common yellowthroat, loggerhead shrike, Lucy's warbler, 

MacGillivray's warbler, orange-crowned warbler, olive-sided flycatcher, phainopepla, sharpshinned hawk, Wilson's warbler, and yellow warbler (NPS 2001and Heindel 2002). These 

species rely on these desert riparian habitats for breeding and foraging; some may breed and 
26

forage exclusively in riparian systems while others may utilize habitat within and outside of the 

riparian systems.

PARK OPERATIONS

The Park operates and maintains several facilities within the Death Valley Scotty Historic 

District. These facilities include (among others) the main structure, Scotty‟s Castle, which is 

used daily for living history tours given by park interpreters; the hacienda that contains two 

resident apartments used for Park staff and offices for interpretive staff; the cookhouse that 

contains offices and public space; and a visitor center. 

All of these facilities contain Heating, Ventilating, and Air Conditioning units (HVACs). 

These units require water to run and must be shut down when water is unavailable. HVACs 

provide for the comfort and safety of staff and visitors during hot summer months. They also 

maintain and protect the museum collection in a stable temperature and humidity range.

Water for the site is provided by area springs. There are holding tanks located east of Scotty‟s 

Castle and the waterline runs from the tanks along the Spring Access Road, in a westerly 

direction, down Grapevine Canyon and ends near the stables. The waterline is original to the 

site. There is no alternate water source currently available in the Historic District. 

Several renovations have been conducted on the existing waterline since its original 

installation. During the winter of 1968-69 a flash-flood extensively damaged the water system 

and extensive repairs were made. In 1982, it was connected to a new, temporary Resources 

Management trailer which was removed in 2005. A sharp decrease in pressure led to the 

attempted cleanout of accumulated travertine in the waterline during 2005 and the repair of the 

overflow line in 2008. Following the decreased water pressure noticed in 2005, the number of 

work orders related to the waterline has increased from 10 during the three year period from 

2002-2005 to 88 from the five year period from 2005-2010. Maintenance of the waterline in 

recent years has become a time and labor intensive.
27

ENVIRONMENTAL CONSEQUENCES

INTRODUCTION

This section describes the potential environmental consequences associated with the no-action 

and action alternatives. The methodologies and assumptions for assessing environmental 

consequences are discussed, including consideration of context, intensity, and duration of 

impacts; cumulative impacts; and measures to mitigate impacts. As mandated by National Park 

Service policy, resource impairment is explained and then assessed for each alternative. 

Subsequent parts of this section are organized by impact topic, first for the no-action alternative 

and then for the three action alternatives.

METHODOLOGY

The National Park Service based these impact analyses and conclusions on the review of 

existing literature and Park studies, information provided by experts at the Park and in other 

agencies, professional judgments and park staff insights, the California SHPOs, input from 

interested local tribes, and public input.

Context, Duration and Intensity, and Type of Impact

The following definitions were used to evaluate the context, intensity, duration, and cumulative 

nature of impacts associated with project alternatives.

Context

Context is the setting within which an impact is analyzed such as local, parkwide, or regional. 

The Council on Environmental Quality requires that impact analyses include discussions of 

context. For this environmental assessment, local impacts would occur within the general 

vicinity of Scotty‟s Castle, while parkwide impacts would affect a greater portion of the Park

and regional impacts would extend outside the limits of the Park.

Duration

The duration of an impact is the time period for which the impacts are evident and are 

expressed in the short-term or in the long-term. A short-term impact would be temporary in 

duration and would be associated with waterline improvements, as well as the period of site 

restoration. Depending on the resource, impacts may last as long as construction takes place, or a 

single year or growing season, or longer. Impact duration for each resource is unique to that 

resource. Impact duration for each resource is presented in association with impact intensities in 

the following “Methodologies” section.
28

Intensity

Impact intensity is the degree to which a resource would be beneficially or adversely affected. 

The criteria that were used to rate the intensity of the impacts for each resource topic are 

presented later in this section under each topic heading.

Type of Impact

Impacts can be beneficial or adverse. Beneficial impacts would improve resource conditions 

while adverse impacts would deplete or negatively alter resources.

IMPACT INTENSITY THRESHOLDS

Cultural Landscape

All available information on the cultural landscape potentially impacted in the Park was 

compiled from Historic Resource Study: Death Valley Scotty Historic District, Carey & 

Company (Livingston. 2009) and the Draft Cultural Landscape Report: Scotty’s Castle 

Cultural Landscape Management, National Park Service, PWRO (NPS. 2010). Predictions 

about short- and long-term site impacts were based on previous investigations by DEVA 

archaeologists and recent studies by Livingston and an intensive survey completed by park 

service personnel. The thresholds of change for the intensity of an impact to cultural resources 

are defined as follows:

Impact 

Intensity Intensity Definition

Negligible

Cultural resources would not be affected or the effects to these resources would be 

below or at the lower levels of detection. Any effects to cultural resources would be 

slight.

Minor

The effects to cultural resources would be detectable. Effects to these resources 

would be small and localized. Mitigation may be needed to offset adverse effects and 

would be relatively simple to implement and likely be successful.

Moderate

The effect on cultural resources would be readily apparent and result in a change to 

the character or the resource over a relatively large area. Mitigation measures would 

be necessary to offset adverse effects and likely be successful.

Major

The effect on cultural resources would be readily apparent and substantially change 

the character of the Historic District over a large area, potentially resulting in large 

amount of loss. Mitigation measures to offset adverse effects would be needed, 

extensive, and their success could not be guaranteed.

Impacts to cultural landscapes are considered permanent when affected by construction or 

when data recovery is necessary.

Archaeological Resources and Historic Structures

All available information on archaeological resources and historic structures potentially 

impacted in the Park was compiled from Historic Resource Study: Death Valley Scotty Historic 

District, Carey & Company (Livingston. 2009); DRAFT Cultural Landscape Report: Scotty’s 

Castle Cultural Landscape Management, (NPS. 2009); and from archaeological clearance 
29

reports based on previous rehabilitations and investigations on the waterline. Predictions about 

short- and long-term site impacts were based on previous investigations by DEVA 

archaeologists and recent studies by Livingston and an intensive survey completed by park 

service personnel in the waterline area of potential effect. The thresholds of change for the 

intensity of an impact to archaeological resources and historic structures are defined as follows:

Impact 

Intensity Intensity Definition

Negligible

Archaeological resources and historic structures would not be affected or the effects 

to archaeological resources and historic structures would be below or at the lower 

levels of detection. Any effects to archaeological resources and historic structures 

would be slight.

Minor

The effects to archaeological resources and historic structures would be detectable. 

Effects to archaeological resources and historic structures would be small and 

localized. Mitigation may be needed to offset adverse effects and would be relatively 

simple to implement and likely be successful.

Moderate

The effect on archaeological resources and historic structures would be readily 

apparent and result in a change to the archaeological resources and historic 

structures character over a relatively wide area. Mitigation measures would be 

necessary to offset adverse effects and likely be successful.

Major

The effect on archaeological resources and historic structures would be readily 

apparent and substantially change the character of the archaeological resources and 

historic structures over a large area, substantial damage would occur resulting in 

large amount of archaeological resources and historic structures loss. Mitigation 

measures to offset adverse effects would be needed, extensive, and their success 

could not be guaranteed.

Impacts to archeological resources are considered permanent if affected by construction or data 

recovery is necessary.

Ethnographic Resources

All available information on ethnographic resources potentially impacted in the Park was 

compiled from Residence without Reservation (Fowler, et al. 1996); Ethnographic Report: 

Rehabilitate Bonnie Clare/Ubehebe Roads (Johnson 2006), and Assessment of Effect: Scotty's 

Castle Waterline Replacement Testing, (NPS 2010b). Predictions about short- and long-term 

site impacts were based on these previous studies concerning ethnographic resources in the 

Death Valley Scotty Historic District. The thresholds of change for the intensity of an impact to 

ethnographic resources are defined as follows:

Impact 

Intensity Intensity Definition

Negligible

Ethnographic resources would not be affected or the effects to ethnographic 

resources would be below or at the lower levels of detection. Any effects to 

ethnographic resources would be slight.

Minor

The effects to ethnographic resources would be detectable. Effects to ethnographic 

resources, including floral and faunal resources would be small and localized. 

Mitigation may be needed to offset adverse effects and would be relatively simple to 

implement and likely be successful.

Moderate

The effect on ethnographic resources would be readily apparent and result in a 

change to the overall landscape over a relatively wide area. Mitigation measures 

would be necessary to offset adverse effects and likely be successful.
30

Major

The effect on ethnographic resources would be readily apparent and substantially 

change the character of the ethnographic resources over a large area, substantial 

loss of ethnographic resources would occur resulting in permanent loss. Mitigation 

measures to offset adverse effects would be needed, extensive, and their success 

could not be guaranteed.

Ethnographic resources impacts would be considered short-term if the ethnographic resources 

are recovered in less than 3 years and long-term if the recovery takes longer than 3 years.

Special-Status Species (Threatened and Endangered Species and Species of Concern)

All Federal agencies are mandated to consider the potential effects of their actions on species 

listed as threatened or endangered under The Endangered Species Act of 1973 (16 USC 1531 et 

seq.), as amended,. If the National Park Service determines that an action may adversely affect 

a federally listed species, consultation with the U.S. Fish and Wildlife Service is required to 

ensure that the action would not jeopardize the species‟ continued existence or result in the 

destruction or adverse modification of critical habitat. NPS Management Policies 2006 states 

that potential effects of agency actions would also be considered for state or locally listed 

species. 

It is the policy of the National Park Service to manage critical habitat of such species and to 

perpetuate the natural distribution and abundance of these species, as well as the ecosystems 

upon which they depend. The U.S. Fish and Wildlife Service was contacted for a list of specialstatus species and designated critical habitats that may be within the project area or affected by 

any of the alternatives (Appendix B). Information on possible threatened, endangered, and 

candidate species, as well as species of special concern, was gathered from published sources. 

Information from prior research at the Park was also incorporated. Known impacts caused by 

development and human use were also considered. The thresholds of change for the intensity of 

an impact are defined as follows:

Impact Intensity Intensity Definition

Negligible

The action could result in a change to a population or individuals of a species but the 

change would be so small that it would not be of any measurable or perceptible 

consequence and would be well within natural variability. This impact intensity 

equates to a U.S. Fish and Wildlife Service “may affect, not likely to adversely affect” 

determination.

Minor

The action could result in a change to a population or individuals of a species. The 

change would be measurable, but small and localized and of little consequence. 

Mitigation measures, if needed to offset the adverse effects, would be simple and 

successful. This impact intensity equates to a U.S. Fish and Wildlife Service “may 

affect, likely to adversely affect” determination.

Moderate

Impacts on special-status species, their habitats, or the natural processes sustaining 

them would be detectable and occur over a large area. Mitigation measures, if 

needed to offset adverse effects, would be extensive and likely successful. This 

impact intensity equates to a U.S. Fish and Wildlife Service “may affect, likely to 

adversely affect” determination.

Major

The action would result in a noticeable effect to viability of a population or individuals 

of a species or resource. Impacts on a special-status species or the natural 

processes sustaining them would be detectable, both in and out of the park. Loss of 

habitat might affect the viability of at least some special-status species. Extensive 

mitigation measures would be needed to offset any adverse effects and their success 

would not be guaranteed. This impact intensity equates to a U.S. Fish and Wildlife 
31

Service “may affect, likely to jeopardize the continued existence of a species 

determination”.

Special-status species‟ impacts are considered short-term if the species recovers in less than 

one year and long-term if it takes longer than one year for the species to recover.

Park Operations

Information on park operations was taken from park documents and records. Park staff also 

provided information. Predictions about short- and long-term site impacts were based on 

previous work and personal knowledge. The thresholds of change for the intensity of an impact 

to park operations are defined as follows:

Impact 

Intensity

Intensity Definition

Negligible

Park operations would not be affected or the effects to Park operations would be 

below or at the lower levels of detection. Any effects to Park operations would be 

slight.

Minor

The effects to Park operations would be detectable. Effects would be small and 

localized. Mitigation may be needed to offset adverse effects and would be relatively 

simple to implement and likely be successful.

Moderate

The effect on Park operations would be readily apparent and result in a change to the 

amount of man-hours to maintain the system. Mitigation measures would be 

necessary to offset adverse effects and likely be successful.

Major

The effect on Park operations would be readily apparent and substantially change 

the character of the Park operations over the entire Death Valley Scotty Historic 

District, Extensive mitigation measures would be needed to offset adverse effects

and their success could not be guaranteed.

Park operations impacts would be considered short-term if they last fewer than eight weeks and 

long-term if it takes longer than eight months.

DIRECT VERSUS INDIRECT IMPACTS

The following definitions of direct and indirect impacts are considered:

Direct – an effect that is caused by an action and occurs at the same time and in the 

same place.

Indirect – an effect that is caused by an action that is later in time or farther removed in 

distance, but is still reasonably foreseeable.

CUMULATIVE EFFECTS

Cumulative effects are the impacts on the environment that result from the incremental impact 

of the action when added to other past, present, and reasonably foreseeable future actions, 

regardless of what agency (Federal or nonfederal) or person undertakes such action. 

Cumulative effects can result from individually minor, but collectively significant, actions 

taking place over a period of time.
32

The Council on Environmental Quality regulations, which implement NEPA, require 

assessment of cumulative impacts in the decision-making process for Federal projects. 

Cumulative impacts are defined as “the impact on the environment which results from the 

incremental impact of the action when added to other past, present, and reasonably foreseeable 

future actions, regardless of what agency (Federal or nonfederal) or person undertakes such 

other actions (40 CFR 1508.7).

Cumulative impacts are considered for all alternatives and are presented at the end of each 

impact topic discussion analysis.

Projects that Make Up the Cumulative Impact Scenario

To determine potential cumulative impacts, projects within the Park were identified. Potential 

projects identified as cumulative actions included any planning or development activity that 

was currently being implemented or that would be implemented in the reasonably foreseeable 

future.

These cumulative actions are evaluated in the cumulative impact analysis in conjunction with 

the impacts of each alternative to determine if they would have any additive effects on a 

particular natural resource, cultural resource, visitor use, or the socioeconomic environment. 

Because some of these cumulative actions are in the early planning stages, the evaluation of 

cumulative effects was based on a general description of the project.

Past Actions

The following past actions could contribute to cumulative effects:

Several larger-scale renovations were conducted on this waterline since its installation. During 

the winter of 1968-69 a flash-flood extensively damaged the water system and extensive repairs 

were made. In 1982, it was connected to a new, temporary Resources Management trailer 

which was removed in 2005. A sharp decrease in pressure led to the attempted cleanout of 

accumulated travertine in the waterline during 2005 and the repair of the overflow line in 2008. 

Following the decreased water pressure noticed in 2005, the number of work orders related to 

the waterline has increased from 10 during the three year period from 2002-2005 to 88 from the 

five year period from 2005-2010.

Other site improvements in the Death Valley Scotty Historic District projects include 

renovation of the Cook House, fire suppressions systems, and replacement of fire hydrants.

Current and Future Actions

Current actions and those projected for the future could also contribute to cumulative effects. 

These include: renovation of the Long Shed, Stables, and Garage and resurfacing/grading of the 

Bonnie Clare Road.
33

IMPAIRMENT OF DEATH VALLEY NATIONAL PARK RESOURCES OR VALUES

In addition to determining the environmental consequences of the action and other alternatives, 

the 2006 NPS Management Policies and Director‟s Order – 12, require analysis of potential 

effects to determine if actions would impair Death Valley National Park resources.

The fundamental purpose of the national park system, established by the Organic Act and 

reaffirmed by the General Authorities Act, as amended, begins with a mandate to conserve park 

resources and values. National Park Service managers must always seek ways to avoid or 

minimize, to the greatest degree practicable, adverse impacts on park and monument resources 

and values. However, the laws do give National Park Service 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 of the affected resources and values. 

Although Congress has given National Park Service management discretion to allow certain 

impacts within parks, that discretion is limited by statutory requirements that the National Park 

Service must leave park resources and values unimpaired, unless a particular law directly and 

specifically provides otherwise. The prohibited impairment is an impact that, in the 

professional judgment of the responsible National Park Service manager, would harm the 

integrity of park resources or values, including opportunities that otherwise would be present 

for the enjoyment of those resources or values. An impact to any park resource or value may 

constitute impairment. However, an impact would more likely 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

 identified as a goal in the Park General Management Plan or other relevant National 

Park Service planning documents

Impairment may result from National Park Service activities in managing the park, visitor 

activities, or activities undertaken by concessioners, contractors, and others operating in the 

park. In this “Environmental Consequences” section, a determination on impairment is made in 

the conclusion statement of the appropriate impact topics for each alternative. The National 

Park Service does not analyze recreational values / visitor experience (unless impacts are 

resource based), socioeconomic values, health and safety, or park operations for impairment.

ENVIRONMENTAL CONSEQUENCES—NO-ACTION ALTERNATIVE

Cultural Landscapes

The deteriorated condition of the existing waterline often requires expedient repairs in case of 

breaks and leaks. These often result in work being done without proper monitoring and may 

have minor, direct, adverse effects on the cultural landscape within the Death Valley Scotty 

Historic District as a result of vegetation removal and equipment use. Under the No-Action 
34

Alternative the waterline would not be replaced and therefore regular emergency repairs would 

likely continue. Further, the event of a major break to the waterline would greatly reduce or 

eliminate fire suppression capabilities, which would threaten the Scotty's Castle Complex in the 

event of a fire. Damage to the complex would have major adverse impacts to the cultural 

landscape.

Past, present and reasonably foreseeable future projects with the potential to affect the cultural 

landscape include the Bonnie Clare Road rehabilitation, Cookhouse reconstruction, and the 

Long Shed and Garage maintenance projects. The Cookhouse reconstruction and Long Shed 

and Garage projects are designed to improve and maintain the features of the cultural landscape 

and therefore these projects would have minor beneficial impacts to the Cultural Landscape. 

Conclusion: Minor, direct, adverse impacts would continue to occur as a result of emergency 

repairs to the waterline. There would be temporary reductions in water flow or complete 

outage when the waterline leaks or break. In the event that a fire should break out during an 

outage it may result in permanent, major, indirect, long-term adverse impacts to the cultural 

landscape (NPS 2009). 

Impairment of Park Resources and Values: Worsening conditions to the waterline are 

considered unacceptable, however, under the no-action alternative; the waterline would 

continue to be repaired piecemeal when breaks occur. Because there would be no major 

adverse impacts to a resource or value whose conservation is (1) necessary to fulfill specific 

purposes identified in the Park‟s establishing legislation, (2) key to the natural or cultural 

integrity of the Park or to opportunities for enjoyment of the Park, or (3) identified as a goal in 

the Park‟s General Management Plan or other relevant National Park Service planning 

documents, there would be no impairment of park resources or values.

Archaeological Resources and Historic Structures

While the waterline itself was constructed in the 1920s, it has undergone replacement and 

repairs over the years that have left it a mixture of materials and fittings. The proposed 

replacement therefore would not cause a direct impact to historic structures. However, the 

event of a major break to the waterline would greatly reduce or eliminate fire suppression 

capabilities and threaten the Scotty's Castle Complex in the event of a fire. If the complex were 

to catch fire during a major waterline outage the Castle may be indefensible. 

Past, present and reasonably foreseeable future projects with the potential to affect the 

Archeological Resources and Historic Structures include the Bonnie Clare Road rehabilitation, 

Cookhouse construction, and the Long Shed and Garage maintenance projects. The cumulative 

impacts of these projects pose only a minor impact to the Archeological Resources and Historic 

Structures.

The No-Action Alternative would have on-going contributions (constant repair) to cumulative 

effects in the short and long-term. These expedient repairs would threaten known and 

unknown cultural resources along the pipeline. There are three identified archeological sites 

along the waterline itself, which have been recommended "Not Eligible" for the National 

Register under Criteria D. However, as there is potential for unidentified cultural resources in 
35

the waterline Area of Potential Effect, the ongoing vehicle activity, excavation, and other 

maintenance activity that would be conducted to repair the waterline would pose a threat to 

these resources. 

Continuing repairs to the waterline and ongoing use of the spring access road must also be 

considered under the no-action alternative. As the waterline has been repaired and replaced 

with PVC in many sections, the overall replacement of this 80 year old waterline is not 

expected to impact the resource. Additionally, the Spring Access Road is still in use as 

historically intended, providing a link between the main Castle complex and the water supply 

and conveyance system. Ongoing use of this road in its original alignment is not expected to 

have an impact on this historical resource 

The cumulative effects of these past, present, and reasonably foreseeable future actions, in 

conjunction with the No-Action Alternative, would have minor to moderate, direct impacts on 

archaeological resources. 

Conclusion: The deteriorating condition of Scotty‟s Castle waterline constitutes a moderate 

impact to archaeological resources. The threat of a non-functioning fire suppression system 

would leave the entire complex vulnerable to complete destruction. Furthermore, the 

waterline‟s functionality represents the inventiveness of Albert Johnson and was a critical 

component to the atmosphere of the complex. The cumulative effects of these past, present, and 

reasonably foreseeable future actions, in conjunction with the No-Action Alternative, would 

have minor to moderate, direct effects on the archaeological and historic structures resources of 

the Scotty‟s Castle Complex. In the event that a fire should break out during a major water 

outage it may result in major permanent, in-direct, long-term adverse impacts to historic 

structures. 

Impairment of Park Resources and Values: Worsening conditions to the waterline are 

considered unacceptable, however, under the no-action alternative; the waterline would 

continue to be repaired piecemeal when breaks occur. Because there would be no major 

adverse impacts to a resource or value whose conservation is (1) necessary to fulfill specific 

purposes identified in the Park‟s establishing legislation, (2) key to the natural or cultural 

integrity of the Park or to opportunities for enjoyment of the Park, or (3) identified as a goal in 

the Park‟s General Management Plan or other relevant National Park Service planning 

documents, there would be no impairment of park resources or values.

Ethnographic Resources

Grapevine Canyon has been identified through ethnographic research as a prehistoric travel 

corridor, the location of an important village, "Maahunu," and is a place of importance for the 

Timbisha-Shoshone Tribe. An ethnographic study has been authored for Grapevine Canyon 

(Johnson 2006), and continued documentation of the area is occurring as part of this project 

and others. The Tribe also occupied the area during the historic period as laborers during the 

construction of Scotty's Castle, and "Indian Camp," their historic village is located close to the 

project area.
36

The Tribe has indicated that they would rather the park abandon the current waterline 

alignment and drill a well closer to Scotty's Castle. Under the No-Action Alternative 

ethnographic resources would continue to be affected by ongoing maintenance of the area, and 

the park would need to continue coordinating with the Tribe and maintenance staff to ensure 

that repairs would not impact the known and unknown archeological sites and ethnographic 

resources in the area. The cumulative effects of these past, present, and reasonably foreseeable 

future actions, in conjunction with the No-Action Alternative, would have minor, direct 

impacts on ethnographic resources. 

Conclusion: The No Action Alternative would result in minor, direct, adverse long-term 

impacts to ethnographic resources.

Impairment of Park Resources and Values: Because there would be no major adverse impacts 

to a resource or value whose conservation is (1) necessary to fulfill specific purposes identified 

in the Park‟s establishing legislation, (2) key to the natural or cultural integrity of the Park or to 

opportunities for enjoyment of the Park, or (3) identified as a goal in the Park‟s General 

Management Plan or other relevant National Park Service planning documents, there would be 

no impairment of park resources or values.

Special-Status Species (Threatened and Endangered Species and Species of Concern)

Emergency repairs to the waterline would continue under the No-Action Alternative and may 

result in digging, trampling and loss of vegetation. Waterline breaks could occur at any time 

and repairs would need to be completed, even during times when special-status species are at 

their most sensitive, i.e. breeding, nesting, and rearing young. Repairs to the system may 

involve greater loss of vegetation if the breaks and repairs are not able to be easily located or 

completed. 

Past, present, and reasonably foreseeable future projects with the potential to affect specialstatus species include other roadway-related projects (e.g., the rehabilitation of the Bonnie 

Clare Road, the rehabilitation Cookhouse, Long Shed, or Garage) or water projects (e.g. 

Furnace Creek water system update). Construction noise, as well as temporary or permanent 

displacement and habitat disturbance/loss associated with construction activities such as 

pipeline installation, culvert replacements/ extensions, and facility improvement/construction, 

would have negligible to minor impacts on special-status species. The cumulative effects of 

these past, present, and reasonably foreseeable future actions, in conjunction with the NoAction Alternative, would have minor to moderate impacts on special-status species.

Conclusion: The deteriorating water line has no effect upon special status species, but repair of 

this pipeline does. As the line provides potable water to visitors and staff, as well as life safety 

needs through the fire protection system, the pipeline would be repaired in event of a break or 

blockage. The subsequent loss of riparian habitat would have a localized, long-term, minor to 

moderate, adverse impact on special-status species. 

Impairment of Park Resources and Values: Because there would be no major adverse impacts 

to a resource or value whose conservation is (1) necessary to fulfill specific purposes identified 

in the Park‟s establishing legislation, (2) key to the natural or cultural integrity of the Park or to 
37

opportunities for enjoyment of the Park, or (3) identified as a goal in the Park‟s General 

Management Plan or other relevant National Park Service planning documents, there would be 

no impairment of park resources or values.

Park Operations

Under the No-Action Alternative, there would be no scheduled waterline maintenance activities

with the potential to affect park operations. Ongoing waterline maintenance could adversely 

affect park operations; however, such effects would be short-term and would vary in intensities 

and types of impacts. There would be no changes in the current status of park operations. 

Conclusion: The No-Action Alternative would have negligible to moderate effects on park 

operations.

ENVIRONMENTAL CONSEQUENCES—ALTERNATIVE TWO: TRENCHING

Cultural Landscapes

Alternative Two would require extensive trenching up the entire length of the pipeline across 

Grapevine Canyon. Trenching would follow the Spring Access Road for the majority of the 

waterline. Trenching would require removal of vegetation, which would have a short-term 

benefit to the cultural landscape by bringing the setting more into line with the conditions 

during the period of historic significance. Vegetation is expected to recover within one-year, so 

benefits would be short lived. 

The waterline was initially designed and built by Albert Johnson to supply water to the Death 

Valley Scotty's Historic District. Its functionality is an important part of the cultural landscape 

for the district. Therefore, replacing the waterline to ensure a continued supply of water to the 

Death Valley Scotty Historic District would have a minor long-term benefit on the cultural 

landscape.

Past, present, and reasonably foreseeable future projects with the potential to affect the cultural 

landscape include the Bonnie Clare Road rehabilitation project, the Cook House reconstruction, 

and the Long Shed/Garage maintenance projects. All of these projects may slightly modify the 

cultural landscape. All except for the Bonnie Clare Road project are specifically designed to 

restore and improve the area. These in turn with Alternative Two would have minor impacts 

on the cultural landscape of the area.

Conclusion: Implementation of Alternative Two would have minor, beneficial, short and longterm impacts to the cultural landscape.

Impairment of Park Resources and Values: Because there would be no major adverse impacts 

to a resource or value whose conservation is (1) necessary to fulfill specific purposes identified 

in the Park‟s establishing legislation, (2) key to the natural or cultural integrity of the Park or to 

opportunities for enjoyment of the Park, or (3) identified as a goal in the Park‟s General 

Management Plan or other relevant National Park Service planning documents, there would be 

no impairment of park resources and values.
38

Archaeological Resources and Historic Structures

While the waterline itself was constructed in the 1920s, it has undergone replacement and 

repairs over the years that have left it a mixture of materials and fittings. The proposed 

replacement therefore would not cause a direct impact to historic structures. However, the 

waterline provides water to the Scotty's Castle Complex and is the primary source of water for 

fire suppression. Replacement of the waterline would ensure that water for fire suppression can 

continue to be provided, protecting the Complex in the event of a fire. This would have a 

moderate, long-term beneficial impact on historic structures.

Alternative Two would involve excavation of a trench running the entire length of the pipeline. 

Heavy equipment would have to traverse the length of the line, along with other maintenance 

trucks and personnel. There are three archeological sites that lay along the course of the 

waterline. These sites have already been affected by past activity, including the initial 

construction of the pipeline and the nearby powerline, vehicular traffic, visitation and reoccurring maintenance. Archeological testing was conducted by the park in December 2010 

and January 2011. The archeological sites were found to be relatively low density artifact 

scatters which have been greatly impacted by the past disturbances, and are recommended 

ineligible for the National Register of Historic Places under Criterion D. The park believes that 

the adverse effect to these resources occurred in the past during the construction and 

maintenance of the waterline and other infrastructure. 

Continuing repairs to the waterline and ongoing use of the spring access road must also be 

considered under as well. As the waterline has been repaired and replaced with PVC in many 

sections, the overall replacement of this 80 year old waterline is not expected to impact the 

resource. Additionally, the Spring Access Road is still in use as historically intended, 

providing a link between the main Castle complex and the water supply and conveyance 

system. Ongoing use of this road in its original alignment is not expected to have an impact on 

this historical resource. 

Past, present, and reasonably foreseeable future projects with the potential to affect the 

archeological resources and historic structures include the Bonnie Clare rehabilitation project, 

the cook house reconstruction, and the Long Shed/Garage maintenance projects. The Bonnie 

Clare Road project may impact other archeological sites in the area. The other projects would 

improve and restore historic structures within the Scotty‟s Castle Complex. When considered 

with Alternative Two, these projects would have a minor impact to historic structures and 

archeological sites.

Conclusion: Overall there would be a moderate, long-term beneficial impact to historic 

structures as a result of improved ability to provide water for fire suppression. As the known 

archeological resources in the project area have been identified and recommended "Not 

Eligible" for listing on the National Register of Historic Places, Alternative Two would have a 

minor to moderate, direct effects on archeological resources as a result of trenching the length 

of the pipeline, including through areas that are covered with vegetation and where 

undiscovered archeological resources may still be present. Impacts to archeological resources 

would be mitigated through the use of the previously described Mitigation Measures. 
39

Impairment of Park Resources and Values: Because there would be no major adverse impacts 

to a resource or value whose conservation is (1) necessary to fulfill specific purposes identified 

in the Park‟s establishing legislation, (2) key to the natural or cultural integrity of the Park or to 

opportunities for enjoyment of the Park, or (3) identified as a goal in the Park‟s General 

Management Plan or other relevant National Park Service planning documents, there would be 

no impairment of park resources and values.

Ethnographic Resources

This region was important to historic and pre-historic peoples for subsistence. Under 

Alternative Two the ethnographic resources of the project would be impacted by clearing of 

vegetation, redirection of water, and the impacts to the archeological resources in the area. The 

grapevine, reeds and wildlife that were drawn to the vegetation and springs are all resources 

were invaluable to prehistoric and historic peoples who occupied the area, and are still held 

sacred to native peoples of the Timbisha-Shoshone. Trenching would require removal of 

vegetation along the waterline corridor, adversely impacting ethnographic resources. 

Vegetation is anticipated to recover within one-year, resulting in short-term, moderate impacts.

Past, present, and reasonably foreseeable future projects with the potential to affect 

ethnographic resources in the area include the Bonnie Clare rehabilitation and future fuels 

reductions projects proposed for the area. These projects also propose to remove vegetation, 

impacting the resources that historic and pre-historic peoples used for subsistence and that the 

modern Timbisha-Shoshone Tribe hold sacred. When considered with Alternative Two, these 

projects would still cumulatively have only moderate impacts to ethnographic resources.

Conclusion: Alternative Two would result in adverse, short-term, moderate impacts to 

ethnographic resources as a result of vegetation removal.

Special-Status Species (Threatened and Endangered Species and Species of Special 

Concern)

Under Alternative Two, trenching and removal of vegetation would result in a short-term loss 

of nearly 6% of the habitat for resident special status species, including the least Bell‟s vireo 

and the Southwestern willow flycatcher. Vegetation would be allowed to grow back once the 

pipeline is replaced and is anticipated to recover within one year of project implementation. 

Use of seasonal restrictions, as described in the Mitigation Measures, would avoid disturbance 

to special status species during their nesting season. Impacts would be localized, short-term, 

minor, and adversely impact special-status species. 

 

Past, present, and reasonably foreseeable future projects with the potential to affect specialstatus species include other roadway-related projects (e.g., the rehabilitation of Badwater Road, 

the rehabilitation of Mud Canyon/Daylight Pass Road, and improvements to California State 

Route 374), the waterline replacement in the Cow Creek area, the Furnace Creek water system 

update, and the Phase II DEVA 500 project at Furnace Creek. Construction noise, as well as 

habitat disturbance/loss associated with construction activities such as re-grading and 

resurfacing roads, shoulder reconstruction, culvert replacements/extensions, pipeline 

installation, and facility improvement/construction, would have short- and long-term, negligible 

to minor, adverse impacts on threatened and endangered species and species of special concern.
40

The cumulative effects of these past, present, and reasonably foreseeable future actions, in 

conjunction with Alternative Two, would have minor impacts on special-status species.

Conclusion: Impacts to special status species as a result of vegetation removal would be 

localized, short-term, minor, and adverse.

Impairment of Park Resources and Values: Because there would be no major adverse impacts 

to a resource or value whose conservation is (1) necessary to fulfill specific purposes identified 

in the Park‟s establishing legislation, (2) key to the natural or cultural integrity of the Park or to 

opportunities for enjoyment of the Park, or (3) identified as a goal in the Park‟s General 

Management Plan or other relevant National Park Service planning documents, there would be 

no impairment of park resources and values.

Park Operations

Replacement of the waterline would improve the Park‟s ability to consistently supply the 

Scotty‟s Castle Complex with potable water for consumption and water for fire suppression. 

After replacement there would be a decrease in need for emergency repairs to respond to leaks. 

This would improve operations by reducing the amount of time Park staff spend repairing the 

waterline and better allowing the Park to schedule out work activities. Emergency repairs often 

take time away from other projects.

Past, present and reasonably foreseeable future projects with the potential to have cumulative 

impacts on park operations include ongoing, routine maintenance of Park facilities; Long 

Shed/Garage rehabilitation and the Bonnie Clare Road rehabilitation project. All of these 

projects will require labor and have the potential to temporarily close certain areas to visitors. 

All projects would improve the condition of Park facilities leading to a long-term decrease in 

maintenance needs. The cumulative effects of these past, present, and reasonably foreseeable 

future actions, in conjunction with Alternative Two, would have short and long-term, negligible 

to minor, beneficial impacts on park operations for the duration of the construction activities.

Conclusion: Overall, Alternative Two would have moderate, long-term, beneficial impacts on 

park operations as a result of decreased need for emergency maintenance and the continued 

ability to provide water to the Death Valley Scotty Historic District.

ENVIRONMENTAL CONSEQUENCES—ALTERNATIVE THREE: PIPE-BURSTING 

Cultural Landscapes

Impacts to cultural landscapes would be the same as described under Alternative Two.

Archaeological Resources and Historic Structures

Alternative Three would involve a combination of pipe-bursting and trenching the entire length 

of the pipeline. The pipe-bursting has the potential to reduce impacts to archeological impacts, 

as fewer trenches may be required. However, since the locations are not known for all power 
41

max couplers, it is likely that trenching will be necessary near or on archeological sites. 

Additionally, heavy machinery will be driven on the Spring Access Road through the 

archaeological sites. The three archaeological sites that are in the waterline project area have 

already been affected by past activity, including the initial construction of the pipeline and the 

nearby powerline, vehicular traffic, visitation and re-occurring maintenance. Archeological 

testing was conducted by the park in December 2010 and January 2011. The archeological 

sites were found to be relatively low density artifact scatters which have been greatly impacted 

by the past disturbances, and are recommended ineligible for the National Register of Historic 

Places under Criterion D. The park believes that the adverse effect to these resources occurred 

in the past during the construction and maintenance of the waterline and other infrastructure. 

Past, present, and reasonably foreseeable future projects with the potential to affect the 

archeological resources and historic structures include the Bonnie Clare rehabilitation project, 

the cook house reconstruction, and the Long Shed/Garage maintenance projects. The Bonnie 

Clare Road project may impact other archeological sites in the area. The other projects would 

improve and restore historic structures within the Scotty‟s Castle Complex. When considered 

with Alternative Three, these projects would have a minor impact to historic structures and 

archeological sites.

Impacts to historic structures would be the same as described under Alternative Two.

Conclusion: Overall there would be a moderate, long-term beneficial impact to historic 

structures as a result of improved ability to provide water for fire suppression. Alternative Two 

would have a minor to moderate, direct effects on archeological resources as a result of driving 

heavy equipment on the Spring Access Road, and trenching in certain areas, including through 

areas that are covered with vegetation and where undiscovered archeological resources may 

still be present. It is anticipated that the impacts to archaeological resources would be slightly 

less under this alternative than under Alternative Two. Impacts to archeological resources 

would be mitigated through the use of the previously described Mitigation Measures. 

Impairment of Park Resources and Values: Because there would be no major adverse impacts 

to a resource or value whose conservation is (1) necessary to fulfill specific purposes identified 

in the Park‟s establishing legislation, (2) key to the natural or cultural integrity of the Park or to 

opportunities for enjoyment of the Park, or (3) identified as a goal in the Park‟s General 

Management Plan or other relevant National Park Service planning documents, there would be 

no impairment of park resources and values.

Ethnographic Resources

Impacts to ethnographic resources would be the same as described under Alternative Two.

Special-Status Species (Threatened and Endangered Species and Species of Special 

Concern)

Alternative Three involves pipe-bursting where possible, and trenching where pipe is not able 

to be burst. If fully successful, this alternative would have 40% of the vegetation removal of 

Alternative Two. If it is unsuccessful, it may have up to 100% of the vegetation removal of 

Alternative Two. Pipe-bursting, trenching and removal of vegetation would result in a short-
42

term loss of approximately 3 - 6% of the vegetation and habitat for special status species. 

Vegetation would be allowed to grow back once the pipeline is replaced. Use of seasonal 

restrictions, as described in the Mitigation Measures, would avoid disturbance to special status 

species during their nesting season. Impacts would be localized, short-term, minor to 

moderate, and adversely impact special-status species. 

Past, present, and reasonably foreseeable future projects with the potential to affect specialstatus species include other roadway-related projects (e.g., the rehabilitation of Badwater Road, 

the rehabilitation of Mud Canyon/Daylight Pass Road, and improvements to California State 

Route 374), the waterline replacement in the Cow Creek area, the Furnace Creek water system 

update, and the Phase II DEVA 500 project at Furnace Creek. Construction noise, as well as 

habitat disturbance/loss associated with construction activities such as regrading and 

resurfacing roads, shoulder reconstruction, culvert replacements/extensions, pipeline 

installation, and facility improvement/construction, would have short- and long-term, negligible 

to minor, adverse impacts on threatened and endangered species and species of special concern.

The cumulative effects of these past, present, and reasonably foreseeable future actions, in 

conjunction with Alternative Three, would have minor to moderate impacts on special-status 

species.

Conclusion: Impacts to special status species as a result of Alternative Three would be 

localized, short-term, minor, and adverse as a result of loss of approximately 3-6% of the 

special status species habitat within the Historic District. 

Impairment of Park Resources and Values: Because there would be no major adverse impacts 

to a resource or value whose conservation is (1) necessary to fulfill specific purposes identified 

in the Park‟s establishing legislation, (2) key to the natural or cultural integrity of the Park or to 

opportunities for enjoyment of the Park, or (3) identified as a goal in the Park‟s General 

Management Plan or other relevant National Park Service planning documents, there would be 

no impairment of park resources and values.

Park Operations

Impacts to park operations would be the same as described under Alternative Two.
43

CONSULTATION AND COORDINATION

SCOPING

A press release initiating public scoping and describing the proposed action was issued on June 

29, 2010. A letter initiating scoping was mailed or emailed to a total of 39 recipients or 

viewing locations. One comment was received during the scoping period on the proposed 

project, and it was supportive of the park writing an Environmental Assessment.

The following agencies, organizations and libraries received notice of the public scoping period 

and will receive a notice of the availability of this environmental assessment:

Amargosa Conservancy

Amargosa Valley Library

Beatty Chamber of Commerce

Bishop Branch Library

Bureau of Land Management

California Department of Fish and Game

California Desert Protection League

California Native Plant Society

Center for Biological Diversity

Death Valley „49ers

Death Valley Conservancy

Death Valley Natural History Association

Desert Protective Council

Desert Research Institute

Furnace Creek Inn and Ranch Resort

High Desert Multiple Use Coalition

Inyo County Board of Supervisors

Lone Pine Branch Library

Lone Pine Chamber of Commerce

National Parks Conservation Association

Native American Rights Fund

Pahrump Community Library

Ridgecrest Branch Library

Sierra Club, Nevada Desert Committee

State Water Resources Control Board

Hardcopies of this environmental assessment will be available for public viewing at the library 

locations listed above and at the Furnace Creek, Scotty‟s Castle and Stovepipe Wells visitor 

contact stations.

AGENCY CONSULTATION AND COORDINATION

The undertakings described in this document are subject to section 106 of the National Historic 

Preservation Act, as amended in 1992 (16 USC 470 et seq.). The National Park Service 
44

conducted an archaeological survey in the waterline area of potential effect in March and April 

2010, and conducted archeological site testing in December 2010 and January 2011. 

Consultations with the California SHPO and the Timbisha-Shoshone Shoshone Tribe were 

initiated on June 29, 2010. A copy of the archaeological testing plan was provided to the 

Timbisha Shoshone THPO on December 14, 2010. 

The park has continued to discuss the project with the Timbisha THPO and Tribal Historic 

Preservation Committee. Park archeologist Leah Bonstead and Cultural Resources Manager 

Blair Davenport met with the Timbisha Shoshone THPO and Tribal elders on February 9, 2011, 

and discussed the project and the condition of the archeological sites in the area of potential 

effect. The THPO agreed that the disturbance to the sites had been in the past, and that the 

future work, while it would continue to disturb the sites in the historical area of disturbance, 

they did not believe it would be an adverse effect. The Timbisha recommended that Grapevine 

Canyon and associated sites be documented as a resource in order to better protect the area, and 

provide NPS and Tribal members with a better knowledge of the area and its importance. The 

park will be working on this documentation with the Timbisha and an outside ethnographer in 

order to better document this important resource.

A report detailing the results of the archaeological testing project was sent to the California 

SHPO and Timbisha Shoshone THPO on March 25, 2011. As of the time this environmental 

assessment was released, no comments had been received. The park requested in the March 25 

consultation letter that the California SHPO and Timbisha Shoshone THPO provide comments 

on the project impacts and site determination of eligibility during review of the Environmental 

Assessment. Therefore, a copy of this environmental assessment will be sent to the SHPO and 

Tribal Historic Preservation Officer upon completion.

In accordance with section 7(c) of the Endangered Species Act of 1973, as amended (16 USC 

1531 et seq.), it is the responsibility of the Federal agency proposing the action (in this case the 

National Park Service) to determine whether the proposed action would adversely affect any 

listed species or designated critical habitat. The Park initiated consultation with the U.S. Fish 

and Wildlife Service on June 29, 2010. A biological assessment was sent to the Service for 

consultation on April 8, 2011. Results of consultation will be disclosed in the decision 

document. 

REGULATORY CITATIONS

 Act of August 25, 1916 (National Park Service Organic Act), PL 64-235, 16 USC § 1 et 

seq. as amended.

 National Historic Preservation Act, as amended, PL 89-665, 80 Stat. 915, 16 USC § 470 

et seq. and 36 CFR 18, 60, 61, 63, 68, 79, 800.

 Native American Graves Protection and Repatriation Act, PL 101-601, 104 Stat. 3049, 

25 USC §§ 3001-3013.

 Presidential Memorandum of April 29, 1994 Government-to-Government Relations 

with Native American Tribal Governments, 59 FR 85.

 Clean Air Act, as amended, PL Chapter 360, 69 Stat. 322, 42 USC § 7401 et seq.

 Endangered Species Act of 1973, as amended, PL 93-205, 87 Stat. 884, 16 USC § 1531 

et seq.
45

 Executive Order 11988: Flood Plain Management, 42 FR 26951, 3 CFR 121 (Supp 

177).

 Executive Order 11990: Protection of Wetlands, 42 FR 26961, 3 CFR 121 (Supp 177).

 Executive Order 11991: Protection and Enhancement of Environmental Quality.

 Executive Order 13007, Indian Sacred Sites (61 CFR 26771)

 Farmland Protection Policy Act of 1982, PL 97-98.

 Federal Water Pollution Control Act (commonly referred to as Clean Water Act), PL 

92-500, 33 USC § 1251 et seq., as amended by the Clean Water Act, PL 95-217.

 Fish and Wildlife Coordination Act of 1958, as amended, PL 85-624, 72 Stat. 563, 16 

USC § 661 et seq.

 National Environmental Policy Act of 1969, PL 91-190, 83 Stat. 852, 42 USC § 4321 et 

seq.

 Protection and Enhancement of Environmental Quality, Executive Order 11514, as 

amended, 1970, Executive Order 11991, 35 Federal Register 4247; 1977, 42 Federal 

Register 26967.

 Resource Conservation and Recovery Act, PL 94-580, 30 Stat. 1148, 42 USC § 6901 et 

seq.

 Secretarial Order 3175, Departmental Responsibility for Indian Trust Resources.

 Secretary of the Interior‟s Standards and Guidelines for Archeology and Historic 

Preservation (36 CFR 68).

 Soil and Water Resources Conservation Act of 1977.

 Watershed Protection and Flood Prevention Act, PL 92-419, 68 Stat. 666, 16 USC § 

100186.

LIST OF PREPARERS

This environmental assessment was prepared under the direction of and by the Park staff. The 

following DEVA employees provided invaluable assistance in the development, information 

gathering, writing, and technical review of this environmental assessment:

Death Valley National Park

Victoria Wilkins – Environmental Protection Specialist

Stacy Holt – Environmental Protection Assistant

Kelly Fuhrmann – Chief of Resource Management

Wayne Badder – Chief of Maintenance

Leah Bonstead – Archeologist

Christopher Brosman – Archeology Technician

Jane Cipra – Botanist

Linda Manning – Wildlife Biologist

Richard Friese – Hydrologist

Kevin Wilson – Aquatic Ecologist

Dashiell Hibbard – Biology Technician

John Stark –GIS Specialist

John Elks – Buildings and Utilities Supervisor
46

Tom Buck – Buildings and Utilities Work Leader

Carre Shandor – Facility Management Specialist
47

WORKS CITED

Great Basin Bird Observatory

2010 Death Valley Bird Surveys. Great Basin Bird Observatory, Reno, NV 

Halterman, Murrelet

1998 1998 Survey Results for Bell's Vireo Survey Sites in the Scotty's Castle and Mesquite 

Springs Areas, Death Valley National Park. 

Halterman, Murrelet

2005 Surveys in Death Valley National Park for Least Bell‟s Vireo and Southwestern Willow 

Flycatcher, 2005. Contract # GS-10F-0073L (Bonnie Claire & Ubehebe Roads 

reconstruction and rehabilitation. Southern Sierra Research Station. Reno, NV.

Harris, Ann G., Esther Tuttle, and Sherwood D. Tuttle

1997 Geology of National Parks, Revised Printing, Fifth Edition, Chapter 46, Death Valley 

National Park.

HDR/e2M

2011 Aquatic invertebrate survey near Bonnie Clare Road. Final Report to Death Valley 

National Park, 38 pp.

Hershler, Robert, and Hsiu-Ping Liu, and Fred Thompson

2003 Phylogenetic relationships of North American nymphophiline gastropods based on 

mitochondrial DNA sequences. Zoologica Scripta 32:357-366.

Hershler, Robert, and Don Sada

1987 Springsnails (Gastropoda: Hydrobiidae) of Ash Meadows, Amargosa Basin, CaliforniaNevada. Proceedings of the Biological Society of Washington 100:776-843.

Heindel, Tom and Jo

2002 Furnace Dreek Water System and Scotty's Castle Bird Surveys conducted in April and 

May 2002 by Tom & Jo Heindel. Bishop, CA.

Holladay Engineering Co.

2010 Title 1 Scoping Trip Report, PMIS 126519: Replace 8 inch Cast Iron Water Main to 

Scotty‟s Castle Complex. Payette, ID.

Johnson, L.

2006 Ethnographic Report: Rehabilitate Bonnie Clare/Ubehebe Roads. Prepared for 

Engineering Environmental Management Inc. by Johnson Consulting Independence

Research Center. Report submitted to National Park Service.

Kus, B.

2002 Least Bell's Vireo (Vireo bellii pusillus). In The Riparian Bird Conservation Plan: a 

strategy for reversing the decline of riparian-associated birds in California. California 

Partners in Flight. http://www.prbo.org/calpif/htmidocs/riparian_v-2.html
48

Livingston, Dewey

2009 Historic Resource Study: Death Valley Scotty Historic District. Context and 

Significance Statement, Carey & Company.

National Park Service (NPS)

2001 Threloff, Douglas L., In cooperation with U.S. Geological Survey, J. Mark Sappington. 

The Birds of Death Valley National Park: A Comprehensive Database of Records 

Between the Years 1891 and 2000. 

2002 Death Valley National Park General Management Plan. April 2002. Available: 

http://www.nps.gov/deva/Deva_gmp/DEVA_GMP.htm.

2003a Animals of Death Valley National Park. Available: 

http://data2.itc.nps.gov/nature/animals.cfm?alphacode=deva&loc=1.

2009 Pacific West Regional Office, Cultural Landscape Program. Draft Death Valley Scotty 

District Cultural Landscape Report. National Park Service, Pacific West Region. 

Oakland or Seattle office will publish

2010a Bacon, Kurt T., Kristen N. Lalumiere, and Amy L. Fesnock. Assessing Potential 

Impacts on Small Mammal Species within the Bonnie Claire Rd Project Area. Joshua 

Tree National Park. Manuscript on file at Death Valley National Park, Cow Creek, 

Wildlife Biology Office.

2010b Brosman, Christopher. Draft Scotty‟s Castle Waterline Rehabilitation, Cultural 

resources Project No. 10-041, DEVA 2010A. Manuscript on file. Death Valley National 

Park, Cow Creek, Archaeology Office.

2010c Cipra, Jane. Scotty‟s Castle Waterline Survey, Death Valley National Park: July-August 

2010. Manuscript on File. Death Valley National Park, Cow Creek, Botany Office.

2010d Hibbard, Dashiell and Manning, Linda (reviewer). Bonnie Claire Road Wildlife report 

Summary: Report for Scotty‟s Castle Waterline Project: PMIS # 126519. Manuscript on 

file. Death Valley National Park, Cow Creek, Wildlife Biologist Office.

U. S. Fish and Wildlife Service

2002 Southwestern Willow Flycatcher Recovery Plan. Albuquerque, New Mexico. i-ix + 

210 pp., Appendices A-O 

Weatherwax, M. (managing ed.)

2002 The Jepson Desert Manual. Vascular Plants of Southeastern California. University of 

California Press, Berkeley and Los Angeles, CA.
49

APPENDIX A: PROJECT SCOPING MATERIALS
50

APPENDIX B: CONSULTATION AND COORDINATION LETTERS