Here's the latest on the Las Vegas 300 mile pipeline drawn out from the Snake and Spring Valley aquifers further north. Similar to the opposition against the peripheral canal of CA, NV residents came out in full force at a recent SNWA board meeting to voice their opposition to the SNWA's pipeline madness..


"Vegas Blinks"

"BREAKING NEWS: The much vaunted “up or down” vote on the proposed Great Basin pipeline that General Manager Pat Mulroy reportedly demanded of her board at the Southern Nevada Water Authority today descended into a long, polite and more than a little bit bizarre political retreat. Rather than confront her board to commit to the pipeline, as it was reported that Mulroy would do by the Las Vegas Review-Journal, Mulroy instead asked it for permission to do what she was doing already: Cooperating with the ongoing US Bureau of Land Management environmental review process and hammering out a Snake Valley monitoring agreement.


Why the damp squib, or as board members called it, the “misunderstanding?” The normally accurate R-J reporter Henry Brean may have invented a non-existent showdown*, duly followed up on by its editorial pages and those of the Las Vegas Sun. Or someone might have pointed out to Mulroy the unseemliness of demanding that her board approve a project that has not yet been cleared under the National Environmental Policy Act. Or Mulroy might actually have thought better than to dare her board vote on a project that as yet has no fixed price tag.

At any rate, at 12.57pm, the Board of the Southern Nevada Water Authority voted unanimously to approve these two motions to do with the proposed Great Basin pipeline:

7. … Direct staff to proceed with state and federal permitting processes, fulfill the requirements of stipulated agreements, and complete the necessary biologic and hydrologic monitoring efforts to support these activities.

8. Authorize the General Manager to execute, in materially the same form, the Agreement for Management of the Snake Valley Groundwater System among the State of Nevada, the State of Utah and the Authority, and the Snake Valley Environmental Monitoring and Management Agreement between the State of Utah and the Authority.

Selected quotes from more than 40 public comments, along with remarks from the Board, may be found at “Pipeline, what pipeline?”

*UPDATE: Henry Brean writes: “The board members made a big show of saying that today’s vote was not on whether or not to build the pipeline, and technically that is correct. However, had they voted today not to continue with the EIS [environmental impact statement] and permitting process, the project would stop. And not merely the part of it in Snake Valley, but all of it since the EIS concerns the entire pipeline right of way. Of course, no one expected them to do anything other than exactly what they did, and I think I made that clear in my reporting leading up to today’s vote. The tone of your blog post suggests otherwise, though. The implication is that I and the R-J mislead people. I, of course, strongly disagree with that.”

This post, which began live during the board vote, has been updated repeatedly. Last update: 6.30am August 21, 2009"


above article found @;
http://chanceofrain.com/las-vegas/las-vegas-blinks/#more-6003


"Pipeline? What Pipeline?"

"IF August 20th in Las Vegas proved anything, it’s what can happen when a publicity stunt backfires.

What had been hyped by a local newspaper and Pat Mulroy, general manager of the Southern Nevada Water Authority, as an “up-or-down” vote on the Las Vegas pipeline project soon gave way to embarrassed disclaimers from members of the SNWA board. They were ”not voting upon starting to build a pipeline” assured director after director but rather “voting upon continuing a process to pursue environmental permits.”

The meeting room was packed with Nevadans there to beg the SNWA board for mercy or sing the praises of White Pine County, the place of springs and seeps that SNWA’s proposed 300-mile pipeline would tap most heavily (photos above). After 20 years of pursuing the pipeline project, SNWA general manager Pat Mulroy has the stomach to face down pudgy-cheeked, cap-in-hand octogenarian ranchers whose family farms her pipeline will surely dewater. But yesterday in Las Vegas, her relatively new board did not. Mulroy won her “up-or-down vote” to keep on doing her job for another day, but the 40 speakers from the estimated 300 protestors present won hearts and minds.


Mulroy, who along with her deputy Kay Brothers took the floor first, gave a 45-minute presentation of her Water Resource Plan. The gist: the drought on Colorado compels Las Vegas to build this pipeline. It has to be shovel-ready when Colorado River shortages kick in.

Then for nigh on three hours, members of the audience took to the microphone, some for the pipeline, most against it. These are quotes from some of the 40 people given three minutes each at the mike.

“Albuquerque is down to 80 gallons per day. Las Vegas is at 250. Take that 250 gallons and make it 80 and avoid pipelines and dams.” – Snake Valley hotelier Terry Morasco

“I wish I could show you Antelope springs. It is a pond, it is dry now.” — Gary Perea, County Commissioner, White Pine County, home to three of five valleys currently targeted by Las Vegas

“I’m afraid [for] the 23,000 working men and women of the Southern Nevada Building and Construction Trades Council and our families.” — Las Vegas City Councilman Steve Ross from Ward 6, the fastest growing sector of Las Vegas

“As I understand it, you don’t need a political showing for your staff to continue with their environment permitting … I’m just asking for no vote today, no political showing on something that is unnecessary.” — Scot Rutledge, Executive Director, Nevada Conservation League

“You guys are used to looking at Lake Mead. The [Great Basin] aquifer is a very different animal from that. It’s very risky.” — Robin Bell, resident of Ely, Nevada in White Pine County, the target for the majority of Las Vegas’s pumps

“The fact is you don’t turn a spigot and the water comes out unless you do all the long terms plans.. we think it’s critical and crucial that this be approved now. We’ve seen millions of people move to the valley and we’ve consumed billions of gallons less.” — Tom Warden, Howard Hughes Corporation General Growth Properties division

“It strikes me as frankly amazing that this board would feel comfortable with the question of approving a massive project like this without any reliable cost figures.” — Clark County Assemblyman Joseph Hogan

“…29 miles of streams, five kinds of trout, 5,000 year-old bristlecone pines and 40 cave systems …I manage them for you. They’re a national treasure. ” Andy Ferguson on the features of the Great Basin National Park, whose adjoining valleys will be the sites of the heaviest pumping

“My family has lived in this state for six generations. One thing we are standing on [in Las Vegas] is an oasis of hidden water. It’s available through water conservation.” Bob Fulkerson of the Progressive Leadership Alliance of Nevada pointing out how retrofitting of toilets, taps and indoor appliances could find the water that Las Vegas needs within the city, not in rural Nevada. “Brisbane, Australia is down to 38 gallons per capita per day,” he said. Las Vegas is at 250.

“As a board, you have a responsibility that you should stop wasting time and money on a pipeline that will not produce the water.” — Snake Valley Rancher Dean Baker

“There is no surplus water in Snake Valley and when you start pumping the water table is going to go down. I have for 36 years worked with that water. I know what it will do, I will know what it won’t do.” — Snake Valley rancher Cecil Garland

“I don’t understand why you want a 10-year delay on Snake Valley when supposedly there’s an emergency.” — Susan Lynn of the Great Basin Water Network founded to oppose the pipeline

“I don’t want to live in a dust bowl and I’m frightened.” — Margaret Pense, Snake Valley resident

“Myth: we will only develop the pipeline when it’s absolutely necessary. … If you’re Harvey Whittemore in Coyote Springs, ‘absolutely necessary’ is yesterday.” — Launce Rake, former environment reporter of the Las Vegas Sun, now spokesman for Progressive Leadership Alliance of Nevada, on the politically connected Lincoln County land developer Harvey Whittemore whose plans for a vast desert city north of Las Vegas depends on the pipeline project being built

“Why are we still watering the lawns?… why do we still act as if there is no emergency unless it is about voting for this pipeline? It makes no sense to me.” — Henderson resident Steve Rypka

“The groundwater decline [caused by the pipeline] is likely to amount to 20 to 30 the times the decline that has occurred in the last 12,000 years.” — James Deacon, biologist and Professor Emeritus, University of Nevada Las Vegas

“It’s my understanding that today’s vote is not to build the pipeline. I don’t know if there’s a misunderstanding or if people are just emotional … It’s incumbent upon us and staff to pursue everything. One thing is important. There is a neighbor sitting here. I am very concerned about the jobs situation. This project would create thousands of jobs at a time when we desperately need them… Clark County is the economic engine that drives the State of Nevada. … It’s important that there’s reciprocity when Clark County’s in need as well … I’m particularly impressed by the respectfulness that has been shown.” – SNWA director and Clark County commissioner Steve Sisolak

“We’re not voting on whether or not to build this pipeline today. We’re voting on whether or not to continue the environmental impact studies. I do not believe we know everything we need to know … What we’re talking about here is a really important, central feature of what the rest of our lives are going to be.” — Boulder City councilman and SNWA director Duncan McCoy

“If we vote in favor of this, our political futures are toast. We have political targets on our backs.” – Boulder City councilman and SNWA director Duncan McCoy

“How polite you’ve been … Today’s vote is not on final approval to begin the pipeline. Rather it’s a vote to continue to pursue permits and environmental studies in order to be able to proceed … I hope the pipeline is never needed.” — SNWA director and Las Vegas City councilwoman Lois Tarkanian

“There are some things that I’d like to see us pursue further. Are those 80 gallons from people a reality? Does our public really know what they use? … We’ve done a good job [at conservation], I think we can do better.” — SNWA director Susan Brager

“The importance of water is not lost on us.” — SNWA vice-chair and City of Henderson councilman Steven Kirk

“We have been to Ely and to Baker [in White Pine County, target of the pipeline] and we will come again and it’s a beautiful place and it’s a beautiful part of Nevada and thank you for being willing to visit with us.” — Shari Buck, chairperson, SNWA board and mayor of North Las Vegas

8/20 UPDATES: Click on the highlighted words for August 20th board meeting reports Channel Eight Las Vegas Now, Las Vegas Review Journal, a fuller R-J report and results of R-J Clark County poll. Channel 5 (local Fox news) has a slightly misinformed TV report with an on-line poll about the project. Comment period on the UT-NV Snake Valley has been extended in Utah reports the Salt Lake Tribune

8/21 UPDATES: from Aquafornia, news service of the Water Education Foundation: Click on the highlighted words for an update from the Ely Times in White Pine County. The SNWA board meeting is covered in the Las Vegas Sun and the Las Vegas Review-Journal looks at rare and endangered species in the path of the pipeline.

8/22: UPDATE: for a visit to the Snake Valley Ranch of Cecil Garland by Salt Lake Tribune columnist Peg McEntee, click here.

article found @;
http://chanceofrain.com/las-vegas/pipeline-what-pipeline/



Click here for the Southern Nevada Water Authority, proponent of the pipeline plan;
http://www.snwa.com/

Click here for the Great Basin Water Network, the group formed to oppose it;
http://greatbasinwaternetwork.org/



Chance for public comment in writing;

(NOTE: Comments need not be limited to Nevada residents! Anyone who cares about our shared ecosystems in the desert, the future of Great Basin National Park and other natural resources should feel free to question the logic of SNWA's proposed pipeline. Any suggestion of novel techniques for water conservation besides the pipeline would help SNWA managers realize that there are many other options beside the pipeline.)

Comment period on Snake Valley Utah-Nevada Agreement Extended to September 30

Comment period on Snake Valley Utah-Nevada Agreement Extended to September 30, 2009.

Get a copy of the agreement:

http://naturalresources.utah.gov/about-dnr/snake-valley-groundwater-agreement.html

http://water.nv.gov/

Written comments about the agreement will be accepted until September 14, 2009.

Comments may be sent by e-mail to:

snakevalley [at] utah.gov
snakevalley [at] water.nv.gov

Comments may be submitted in writing to:

Snake Valley Agreement
c/o Utah Department of Natural Resources
Division of Water Rights
1594 West North Temple, Suite 220
SLC, UT 84114

Snake Valley Agreement
c/o Nevada Department of Conservation and Natural Resources
Suite 5001
901 S. Stewart St.
Carson City, NV 89701


CONTACT

UTAH: Tammy Kikuchi, Utah Dept. of Natural Resources, office: (801) 538-7326, cell: (801) 918-1290;- tkikuchi [at] utah.gov

NEVADA: Bob Conrad, Nevada Dept. of Conservation and Natural Resources, office: (775) 684-2712, cell: (775) 636-7959, bconrad [at] dcnr.nv.gov

visit site @;
http://greatbasinwaternetwork.org/fray/fray_display.php?id=27

Though as always a vague document written by public agencies, the Snake Valley Utah-Nevada Agreement could recieve comments asking for protection of the springs that emerge from the aquifer. The division of allocated water seems to be a distraction from the main issue that is the SNWA proposed 285 mile pipeline to Las Vegas region (mostly to benefit developers of suburban sprawl like Harvey Whittemore's Coyote Springs!).

Simply put, the extraction and transport of water out of the Snake Valley and into Las Vegas (drainage into Colorado) will lower the water table at the fastest rate possible and result in drying of springs, then followed by the death of the "pump plants" whose roots depend on the water table. This would result in dust entering the atmosphere in large amounts as the dead plants are unable to support the soil with their roots. This example doesn't address the dust, though focuses on the endemic endangered species like spring snail pyrgs and the fish that live on them. Entire food web ecosystems are at risk of collapse and extinction if these springs dry up from permanently lowered water table..


Other problems include land subsidence and aquifer cavern collapse as water leaves the aquifer cavern and the ceiling cannot support the weight of the eroded gravel sediment overburden located above the aquifer caves. This subsidence process occurred in San Joaquin Valley, Ogallala aquifer (Midwest) and Florida limestone aquifers (sinkholes). There is no reason to think that the same process wouldn't happen in Snake Valley..

Please consider sumbitting a comment even if you live outside of the region. These ecosystems coming from aquifers and springs are treasures for everyone, though once gone from overdrawn aquifers, they are treasures stolen from everyone forever..

Thanks all for your continued support..







Comment period on Snake Valley Utah-Nevada Agreement Extended to September 30, 2009.

Get a copy of the agreement:

http://naturalresources.utah.gov/about-dnr/snake-valley-groundwater-agreement.html
http://water.nv.gov/

Written comments about the agreement will be accepted until September 14, 2009.

Comments may be sent by e-mail to:

snakevalley [at] utah.gov
snakevalley [at] water.nv.gov

Comments may be submitted in writing to:

Snake Valley Agreement
c/o Utah Department of Natural Resources
Division of Water Rights
1594 West North Temple, Suite 220
SLC, UT 84114

Snake Valley Agreement
c/o Nevada Department of Conservation and Natural Resources
Suite 5001
901 S. Stewart St.
Carson City, NV 89701


CONTACT

UTAH: Tammy Kikuchi, Utah Dept. of Natural Resources, office: (801) 538-7326, cell: (801) 918-1290;- tkikuchi [at] utah.gov

NEVADA: Bob Conrad, Nevada Dept. of Conservation and Natural Resources, office: (775) 684-2712, cell: (775) 636-7959, bconrad [at] dcnr.nv.gov



Example comment;

(BTW - Anyone pressed for time can send a comment with a few cut and paste sentences, the main idea being SNWA pipeline would lower water table, cause ecosystem and aquifer cavern collapse, land subsidence, followed by severe dust storms from loss of plant's roots supporting soil.)

Comment on Snake Valley Utah-Nevada agreement for aquifer protection;

It is difficult for me to directly comment on the Snake Valley Utah-Nevada Agreement as there are many questions unable to be answered as to the potential outcome of this agreement. From a scientific perspective with the goal of protecting ecological integrity of the Snake Valley aquifers, springs and marsh complexes, there is no certain outcome based upon the distribution of allocated and unallocated water. However, it is very clear to me and many others who have begun researching this aquifer complex that ANY excessive withdrawals by either state would spell disaster for the Snake Valley aquifer and related wetlands ecosystem. This comment will focus primarily on the proposal by SNWA to construct a pipeline capable of extracting large amounts of aquifer water to be transported to Las Vegas region.

The Snake Valley aquifer complex requires long term protection for the benefit of the ecosystem and also the region's human communities that rely upon this aquifer's water for their survival. Significant risks to the Snake Valley aquifer complex would occur by allowing the SNWA's 300 mile water pipeline to Las Vegas to be constructed. One of the primary risks is from aquifer cavern collapse as the overburden of eroded gravel sediments accumulated above the aquifer will no longer be supported by the water underneath. Aquifer caverns in this region are primarily composed of slightly metamorphosed limestone, and a brief visit to the crumbled rubble of Lehman Cave's Talus Room would show the potential of crumbled aquifers following years of overdraft by the SNWA pipeline.

The limestone caverns found at Great Basin National Park's Talus Room were formed and enlarged over the long term wet season years of rainwater percolating downwards and becoming carbonic acid, eating away at the limestone material. According to geological history, the Talus Room's rubble was formed during an interim dry season when the water table dropped several hundreds of meters, resulting in the excessive weight of overburden forcing collapse of the former aquifer's ceiling structure. The ability of the aquifer caverns filled to capacity with water were able to support the overburden's weight under gravity, though loss of the water and replacement with air proved to be insufficient to support such a tremendous burden. It is probable that future drops in the same region's water table due to excessive extractions and transport outside of the region by SNWA's pipeline would result in aquifer caverns becoming empty of water and thus stressed by the gravel overburden's weight, resulting in eventual cavern collapse.

According to studies and research on other aquifers, anytime an aquifer is overdrawn and the cavern partially collapses from weight of overburden without water to support the aquifer's ceiling, the result is compaction of sediments and land subsidence visible from the surface. The land subsidence occurs as the empty space of the aquifer cavern is filled with overburden, and the actual elevation of the ground then drops as the overburden fills the empty space of what once was an aquifer. This process has already been documented in several locations, including the permanent loss of the Midwest's Ogallala aquifer, the San Joaquin aquifer's subsidence of nearly twenty feet and sinkholes regularly appearing throughout Florida as their limestone aquifers are overdrawn to the point of ceiling collapse. In every case thus far, once an aquifer is overdrawn to the point of cavern ceiling collapse and surface level land subsidence, there can be no possible returns to the original storage capacity of the aquifer prior to collapse.

Another risk of excessive extraction from the SNWA pipeline would be to the ecosystem's food pyramid by preventing natural spring formation at intersections between the water table and above ground openings. Springs in this region occur when the water table is high enough to spill out onto the surface, resulting in unique isolated ecosystems capable of supporting their own endemic biota found nowhere else. The biota found here includes several species of plants, algae and other primary producers that photosynthesize sunlight into energy available for animal consumption. The next level of the food pyramid above the primary producer plants are primary consumers; insects, mollusks and other small organisms that feed directly upon the plants. Above them are secondary consumers; fish, birds and mammals that eat the primary consumers. This entire food pyramid ecosystem is depending upon a regular supply of spring water appearing at this same location every year.

One of the focus species of the primary consumer category are spring snails, many considered either threatened and/or endangered because they are unable to travel to other springs and have become their own separate species due to the isolating conditions of the springs located far apart from one another. Each species of spring snail shows physical and physiological traits uniquely evolved in adaptation to their surroundings, usually determined by specific chemical, water and temperature conditions found only in their spring.

One example of the genetic isolation found in spring snail species is the Sub-globose Snake Pyrg (Pyrgulopsis saxatilis), found only in Gandy Warm Springs. Other spring snails endemic to the Snake Valley include the Longitudinal Gland Pyrg (Pyrgulopsis anguina) and the Bifid Duct Pyrg (Pyrgulopsis peculiaris). These spring snails have adapted to specific water conditions in the springs where they and their ancestors have lived for thousands of years.

This entire ecosystem can become non-existent by a long term drop in the water table resulting from excessive extraction by the SNWA's proposed pipeline. Once the spring snail's habitat becomes unlivable, there is a likely potential that the spring snail will be unable to reproduce and survive the loss of spring water. The outcome of this long term human induced drought would be extinction of each unique species of spring snail with no possible returns.

In addition to the spring snails are other secondary consumers that would include the snails at some stage of their life cycle as part of their regular food source. One of these is the least chub (Iotichthys phlegethontis), as mentioned in Appendix 4 of the Utah-Nevada Agreement. Here it states that Snake Valley springs and marshes (Leland Harris Springs, Gandy Marsh and Bishop Springs) play an important role in habitat for the remaining wild populations of the least chub, and without a regular water supply fed by a stable water table the least chub could be extirpated from this crucial habitat. Other threatened fish that depend upon regular surface water supplies from Snake Valley springs include the Bonneville cutthroat trout (Oncorhynchus clarkii utah). Provided that the Snake Valley ecosystem is protected and fish populations are able to increase, these larger native trout species also represent a fisheries resource for humans.

Long term protections are needed for the Snake Valley region's springs and their unique ecosystem inhabitants for several reasons. As conscious beings, we humans recognize that water tables can drop from reasons outside our control, such as long term drought and climate change. We also recognize that our actions independent of climactic processes can also result in the drop of the water table, and this is under our control. We can prevent extinctions of the spring snails and all the other animals that depend upon them simply by maintaining the water table to the levels required for the springs to emerge at their surface locations. To maintain the water table levels we only need to be careful monitoring and allocating water from these springs.

Current human uses of the Snake Valley aquifer water that would alter the water table levels and spring formation include ranching and limited residential uses. The ranching uses of aquifer water remains in the same region, and eventually percolates downwards and recharges the same aquifer, thus maintaining some neutrality between losses from extractions and gains from recharges to the same water table. However, this would not be the case for the SNWA pipeline, where the aquifer water extracted from the Snake Valley complex would never be recharged to the same location, instead would be lost to the Colorado River system and eventually enter the ocean at the Gulf of California. While this may be good news for the beleaguered and overly saline waters of the Gulf of California, it is certainly a death sentence for the spring snails' food pyramid ecosystems that depend upon Snake Valley aquifer water emerging aboveground at the spring locations.

The good news is that with minimal interference the spring snails' food pyramid ecosystem will function normally provided that monitoring of the water table occurs on a regular basis. It would be far more logical and effective to monitor the local ranchers and residential water uses than to further complicate the equation of aquifer extractions and recharge by introducing the SNWA's proposed pipeline capable of extracting far greater quantities with no possible recharge to the original aquifer. Similar to overdrawn then collapsed aquifer caverns and extinction of endemic species, the chance of no possible returns is best avoided. We need to collectively protect the Snake Valley aquifers, springs and all their inhabitants and dependents by preventing the construction of the SNWA's proposed pipeline.

In conclusion, by focusing mostly on divisions between allocations the Snake Valley Utah-Nevada Agreement is not adequate to assess the complexity of the aquifer, spring and marsh ecosystems and the diversity of biota that depends upon regular supplies of water. The Snake Valley aquifer complex is not confined to human imposed state boundaries and needs to be treated as a single ecological entity across both sides of the border. Successful conservation of least chub, spring snails, spotted frogs and other endemic inhabitants of the Snake Valley aquifer complex depends upon maintaining the water table at levels required for regular discharge at surface spring flows. A good rule of thumb for a sustainable water distribution agreement would be “Water that comes from Snake Valley stays in Snake Valley.” Since the Snake Valley covers both Utah and Nevada, the distribution of water to residents and ranches can be fairly even across both states.

The reason for keeping Snake Valley aquifer’s extracted water allocations in the same original valley basin is to balance the extractions with constant recycling by percolating recharge water back into the same aquifer. This is the same process that Las Vegas implements with Lake Mead’s water; all treated wastewater is recycled back into their original supply at Lake Mead. Geological history reminds us that the full capacity of the Snake Valley aquifer was attained only after thousands of years of rainfall during much wetter climates than our current weather pattern. This indicates that steady exports of aquifer water outside of the original basin (i.e., to Las Vegas and the Colorado River) will result in faster rates of depletion and drawdown of the aquifer than by using and recycling the water for recharge into the original Snake Valley basin.


more info @;
http://www.greatbasinwaternetwork.com/

Sorry for the double postings, the previous comment i sent was neutral about the SVUT-NV Agreement because it was vague and i didn't understand it. Below the intro explaining my change of position from previously neutral to now being against the agreement as sent out in the emails to the agencies involved in the comment process is the revised comment.

For the record need to resubmit this to clarify any confusion from my earlier position. Everything else remains the same, though added some short paragraphs on the phreatophyte "pump plants" near the end..



Intro & explanations;

Have recently learned some additional relevant details and am updating my earlier comment. My new position is to be against the Snake Valley Utah-Nevada Agreement. This has changed from my earlier position of neutrality based upon the vagueness of the document and my inability to decipher the politically framed jargon. My field of understanding is in the sciences and ecology, not in politically based legal documents that are designed to confuse the general public and discourage people from participating in these important matters.

My original position of being against the SNWA pipeline from Snake Valley to Las Vegas has NOT changed, I remain steadfastly opposed to the SNWA's pipeline idea. No confusion here.

However, i am in support of attempts made to protect the least chub, spotted frog and spring snails, though i feel the most effective way to accomplish this goal is by monitoring the water table so that it emerges at the springs. Protection of the Snake Valley aquifer would be most effective by keeping Snake Valley water in the Snake Valley and not allowing ANY water exports to distant metropolitan regions in either state.

In addition another reason for my opposition to the SNWA pipeline should be included, water table dropping would result in the loss of pump plants and their roots that stabilize the soils. Following this loss of soil support we can expect severe dust storms entering the atmosphere, eroding topsoil and causing air pollution from particulate matter for downwind residents.

Thanks for being patient and understanding my confusion. Below is the updated comment that should replace my earlier comment sent from the same email address.









Revised Comment on Snake Valley Utah-Nevada Agreement for aquifer protection;

My goal in writing this comment is to protect the ecological integrity of the Snake Valley aquifers, springs and marsh complexes. It is very clear to me and many others who have begun researching this aquifer and springs complex that ANY excessive withdrawals and exports out of Snake Valley by either state would spell disaster for the Snake Valley aquifer and related wetlands ecosystem. This comment will focus primarily on the proposal by SNWA to construct a pipeline capable of extracting large amounts of aquifer water to be transported to Las Vegas region.

The Snake Valley aquifer complex requires long term protection for the benefit of the ecosystem and also the region's human communities that rely upon this aquifer's water for their survival. Significant risks to the Snake Valley aquifer complex would occur by allowing the SNWA's 300 mile water pipeline to Las Vegas to be constructed. One of the primary risks is from aquifer cavern collapse as the overburden of eroded gravel sediments accumulated above the aquifer will no longer be supported by the water underneath. Aquifer caverns in this region are primarily composed of slightly metamorphosed limestone, and a brief visit to the crumbled rubble of Lehman Cave's Talus Room would show the potential of crumbled aquifers following years of overdraft by the SNWA pipeline.

The limestone caverns found at Great Basin National Park's Talus Room were formed and enlarged over the long term wet season years of rainwater percolating downwards and becoming carbonic acid, eating away at the limestone material. According to geological history, the Talus Room's rubble was formed during an interim dry season when the water table dropped several hundreds of meters, resulting in the excessive weight of overburden forcing collapse of the former aquifer's ceiling structure. The ability of the aquifer caverns filled to capacity with water were able to support the overburden's weight under gravity, though loss of the water and replacement with air proved to be insufficient to support such a tremendous burden. It is probable that future drops in the same region's water table due to excessive extractions and transport outside of the region by SNWA's pipeline would result in aquifer caverns becoming empty of water and thus stressed by the gravel overburden's weight, resulting in eventual cavern collapse.

According to studies and research on other aquifers, anytime an aquifer is overdrawn and the cavern partially collapses from weight of overburden without water to support the aquifer's ceiling, the result is compaction of sediments and land subsidence visible from the surface. The land subsidence occurs as the empty space of the aquifer cavern is filled with overburden, and the actual elevation of the ground then drops as the overburden fills the empty space of what once was an aquifer. This process has already been documented in several locations, including the permanent loss of the Midwest's Ogallala aquifer, the San Joaquin aquifer's subsidence of nearly twenty feet and sinkholes regularly appearing throughout Florida as their limestone aquifers are overdrawn to the point of ceiling collapse. In every case thus far, once an aquifer is overdrawn to the point of cavern ceiling collapse and surface level land subsidence, there can be no possible returns to the original storage capacity of the aquifer prior to collapse.

Another risk of excessive extraction from the SNWA pipeline would be to the ecosystem's food pyramid by preventing natural spring formation at intersections between the water table and above ground openings. Springs in this region occur when the water table is high enough to spill out onto the surface, resulting in unique isolated ecosystems capable of supporting their own endemic biota found nowhere else. The biota found here includes several species of plants, algae and other primary producers that photosynthesize sunlight into energy available for animal consumption. The next level of the food pyramid above the primary producer plants are primary consumers; insects, mollusks and other small organisms that feed directly upon the plants. Above them are secondary consumers; fish, birds and mammals that eat the primary consumers. This entire food pyramid ecosystem is depending upon a regular supply of spring water appearing at this same location every year.

One of the focus species of the primary consumer category are spring snails, many considered either threatened and/or endangered because they are unable to travel to other springs and have become their own separate species due to the isolating conditions of the springs located far apart from one another. Each species of spring snail shows physical and physiological traits uniquely evolved in adaptation to their surroundings, usually determined by specific chemical, water and temperature conditions found only in their spring.

One example of the genetic isolation found in spring snail species is the Sub-globose Snake Pyrg (Pyrgulopsis saxatilis), found only in Gandy Warm Springs. Other spring snails endemic to the Snake Valley include the Longitudinal Gland Pyrg (Pyrgulopsis anguina) and the Bifid Duct Pyrg (Pyrgulopsis peculiaris). These spring snails have adapted to specific water conditions in the springs where they and their ancestors have lived for thousands of years.

This entire ecosystem can become non-existent by a long term drop in the water table resulting from excessive extraction by the SNWA's proposed pipeline. Once the spring snail's habitat becomes unlivable, there is a likely potential that the spring snail will be unable to reproduce and survive the loss of spring water. The outcome of this long term human induced drought would be extinction of each unique species of spring snail with no possible returns.

In addition to the spring snails are other secondary consumers that would include the snails at some stage of their life cycle as part of their regular food source. One of these is the least chub (Iotichthys phlegethontis), as mentioned in Appendix 4 of the Utah-Nevada Agreement. Here it states that Snake Valley springs and marshes (Leland Harris Springs, Gandy Marsh and Bishop Springs) play an important role in habitat for the remaining wild populations of the least chub, and without a regular water supply fed by a stable water table the least chub could be extirpated from this crucial habitat. Other threatened fish that depend upon regular surface water supplies from Snake Valley springs include the Bonneville cutthroat trout (Oncorhynchus clarkii utah). Provided that the Snake Valley ecosystem is protected and fish populations are able to increase, these larger native trout species also represent a fisheries resource for humans.

Long term protections are needed for the Snake Valley region's springs and their unique ecosystem inhabitants for several reasons. As conscious beings, we humans recognize that water tables can drop from reasons outside our control, such as long term drought and climate change. We also recognize that our actions independent of climactic processes can also result in the drop of the water table, and this is under our control. We can prevent extinctions of the spring snails and all the other animals that depend upon them simply by maintaining the water table to the levels required for the springs to emerge at their surface locations. To maintain the water table levels we only need to be careful monitoring and allocating water from these springs.

Current human uses of the Snake Valley aquifer water that would alter the water table levels and spring formation include ranching and limited residential uses. The ranching uses of aquifer water remains in the same region, and eventually percolates downwards and recharges the same aquifer, thus maintaining some neutrality between losses from extractions and gains from recharges to the same water table. However, this would not be the case for the SNWA pipeline, where the aquifer water extracted from the Snake Valley complex would never be recharged to the same location, instead would be lost to the Colorado River system and eventually enter the ocean at the Gulf of California. While this may be good news for the beleaguered and overly saline waters of the Gulf of California, it is certainly a death sentence for the spring snails' food pyramid ecosystems that depend upon Snake Valley aquifer water emerging aboveground at the spring locations.

The good news is that with minimal interference the spring snails' food pyramid ecosystem will function normally provided that monitoring of the water table occurs on a regular basis. It would be far more logical and effective to monitor the local ranchers and residential water uses than to further complicate the equation of aquifer extractions and recharge by introducing the SNWA's proposed pipeline capable of extracting far greater quantities with no possible recharge to the original aquifer. Similar to overdrawn then collapsed aquifer caverns and extinction of endemic species, the chance of no possible returns is best avoided. We need to collectively protect the Snake Valley aquifers, springs and all their inhabitants and dependents by preventing the construction of the SNWA's proposed pipeline.

Another reason for opposition the the SNWA pipeline proposal is the risks of water table dropping resulting in dust storms. In addition to loss of animals that inhabit the springs, we can expect loss of phreatophytes, also known as "pump plants", whose deep roots tap into the water table below the overburden and around the springs themselves from a lowered water table. Some examples of phreatophytes include greasewood (Sarcobatus vermiculatus)and the bright yellow fall blooming rabbitbrush (Chrysothamnus viscidiflorus). In addition to providing forage to countless grazing ungulates like pronghorn, elk and deer, the phreatophytes also are important as soil stabilizers.

If the phreatophytes die off because their roots cannot reach a rapidly falling water table, they cannot play their vital role as stabilizers of the already dry surface soils. After the death of the phreatophytes we can expect a steady erosion of the surface soils lacking roots to hold soil particulates in place. This erosion would also occur during windy conditions, resulting in massive dust storms entering Utah and traveling further in the upper atmosphere. This form of air pollution could be prevented by protecting the aquifer's water table so that phreatophytes are able to access a relatively steady water table level.

In conclusion, by focusing mostly on divisions between allocations and ignoring potential risks of excess water extractions and export outside the region, the Snake Valley Utah-Nevada Agreement is not adequate to assess the complexity of the aquifer, spring and marsh ecosystems and the diversity of biota that depends upon regular supplies of water. The Snake Valley Utah-Nevada Agreement is unclear on methods of protections of the least chub and spotted frog that they mention in their Appendix, and their proposals made to distribute water in vaguely defined allocations enable SNWA pipeline advocates a greater foothold than is acceptable. Keeping in mind my original goal of protecting the Snake Valley aquifer from proposed SNWA exports, am voting against the Snake Valley Utah-Nevada Agreement.

The Snake Valley aquifer complex is not confined to human imposed state boundaries and needs to be treated as a single ecological entity across both sides of the border. Successful conservation of least chub, spring snails, spotted frogs and other endemic inhabitants of the Snake Valley aquifer complex depends upon maintaining the water table at levels required for regular discharge at surface spring flows. A good rule of thumb for a sustainable water distribution agreement would be “Water that comes from Snake Valley stays in Snake Valley.” Since the Snake Valley covers both Utah and Nevada, the distribution of water to residents and ranches can be fairly even across both states.

The reason for keeping Snake Valley aquifer’s extracted water allocations in the same original valley basin is to balance the extractions with constant recycling by percolating recharge water back into the same aquifer. This is the same process that Las Vegas implements with Lake Mead’s water; all treated wastewater is recycled back into their original supply at Lake Mead. Geological history reminds us that the full capacity of the Snake Valley aquifer was attained only after thousands of years of rainfall during much wetter climates than our current weather pattern. This indicates that steady exports of aquifer water outside of the original basin (i.e., to Las Vegas and the Colorado River) will result in faster rates of depletion and drawdown of the aquifer than by using and recycling the water for recharge into the original Snake Valley basin.


comments can be sent to these addresses;

COMMENT PERIOD ON SNAKE VALLEY UTAH-NEVADA AGREEMENT EXTENDED TO SEPTEMBER 30
Comment period on Snake Valley Utah-Nevada Agreement Extended to September 30, 2009.

Get a copy of the agreement:

http://naturalresources.utah.gov/about-dnr/snake-valley-groundwater-agreement.html
http://water.nv.gov/

Written comments about the agreement will be accepted until September 14, 2009.

Comments may be sent by e-mail to:

snakevalley@utah.gov
snakevalley@water.nv.gov

More info direct from the source;
http://www.greatbasinwater.net/