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Mojave Preserve water management plan is called ‘affront,’ ‘erroneous and incomplete’ in public comm

The Wild Sheep Foundation called the Mojave Preserve water management plan "insufficient to ensure persistence of bighorn sheep within the Mojave National Preserve," effectively negating over 50 years of conservation work in this part of the desert that have created robust wild sheep populations where few existed before the installation of man-made drinkers.


The period to comment on the Mojave National Preserve water management plan, which calls for the removal of most man-made wildlife water sources, ended Friday. A sampling of the comments received by the deadline show the National Park Service staff advancing this proposal has managed to infuriate just about everyone.

According to the comments, if the plan is implemented, it will violate a wide range of laws and policies, and it fails to use the “best available” science in its analysis, potentially threatening bighorn sheep, desert tortoise, and other wildlife populations across the Mojave Desert, both in and out of the Preserve.

After reviewing over a dozen different comment letters from individual and groups who submitted their comments by the deadline, perhaps the most compelling and scientifically documented rebuttal to the plan to remove wildlife water was submitted by Wild Sheep Foundation. The 30-page letter has over 350 citations in rebutting the plan, referencing scientific papers and other literature in a point-by-point refutation.

“We see the proposed MNP plan for developed water sources as an affront to our efforts on behalf of wild sheep. We recommend abandoning this plan altogether…” said the comment letter signed by Gray Thornton, president and CEO of the Wild Sheep Foundation and Brett Jefferson, chairman of the board.

“[The Wild Sheep Foundation] finds each of the proposed alternatives presented to be insufficient to ensure persistence of bighorn sheep within MNP and, moreover, to be contrary to the conservation of bighorn sheep at the level of the landscape,” they wrote in summary.

The comment letter picks apart the extensive documentation provide in the plan and accompanying environmental assessment, focusing on the flaws in its proposal to remove or relocate wildlife drinkers installed for bighorn sheep in areas later designated wilderness areas.

“Aside from issues analyzed erroneously and incompletely, the plan is completely blind to the effects that removing water devices will have on conservation stewardship and recreation opportunities, including hunting. These issues are explicitly dismissed from analysis, having been declared insignificant.”

It also points out where the plan violates Department of Interior orders and policies.

“No reference is made to USDI Secretarial Orders 3362, 3356, and 3347, or to Executive Order 13443 -- each of which directs federal agencies in various ways to advance conservation stewardship and increase outdoor recreation opportunities, including hunting. Nor is any reference made to how this plan comports with efforts by the National Park Service to comply with those Secretarial Orders.”

The comment letter also attacks the philosophy of the Preserve staff that has promoted such a radical and scientifically unsound proposal.

“Inconsistencies in interpretation and personal philosophies of agency personnel have been identified repeatedly as primary issues facing wildlife conservation in legislated wilderness,” they wrote.

“MNP leadership recognized that ecology was not a serious consideration in the drafting of California Desert Protection Act or subsequent legislation and was in full agreement that the term 'untrammeled' as used in the Wilderness Act of 1964 does not mean ‘virgin’ or unaltered, although many individuals and organizations choose to redefine that word to their advantage…

“Unfortunately, the DMPEA prioritizes the intangible values attributed to wilderness areas over the many successful efforts implemented to conserve one of the world's most iconic large mammals.”

I suspects the bulk of the letter was written by Dr. Vernon Bleich, the preeminent wild sheep biologist in the nation, a former California Department of Fish and Wildlife (CDWF) who has conducted the research in many of the scientific papers referenced for the rebuttal of this document.

This is the letter the CDWF should have written, or at least signed as concurring, because the water management plan is such a disaster for wildlife.

While this comment letter focuses on bighorn sheep water, several other comment letters focused on the removal or abandonment of the vast majority of small game guzzlers on the Preserve. The removal of these wildlife water sources would have a huge impact on the distribution and overall numbers of other, smaller, less iconic wildlife, including pollinating insects, that uses these drinkers. These water sources are important for over a hundred of other species documented to use this water, and they would be removed or abandoned under this plan without documentation of the impacts.

Both the state, which built these wildlife drinkers, and the federal government, who manages the land where they were built, have done a dismal job in maintaining them over the years. That task has largely been taken over by hunter-conservation groups who understand their value and have invested money and volunteer manpower to keep them functioning. These are the individuals and groups who submitted comments on the plan.

Yet, there was not an option in the NPS water plan that would have even allowed for the maintenance of these small water drinkers.

If the National Park Service does not pull this plan back, they will be sued in court – in in all likelihood lose just on scientific grounds. The feedback comments on the water management all agree: The plan is a disaster.


To download a PDF of this Wild Sheep Foundation comment letter, click HERE.

Jim Matthews is a syndicated Southern California-based outdoor reporter and columnist. He can be reached via e-mail at or by phone at 909-887-3444.

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