Mojave From Neglected Space To Protected Place: An Administrative History of Mojave National Preserve

One of the most substantial accomplishments in the short history of the Mojave National Preserve was the autumn 2001 completion of the first General Management Plan for the park. That document was the culmination of a planning process that began even before the area officially belonged to the National Park Service. The plan was produced by park-based planning staff, a rare circumstance that offered a new vision of the future of planning in the national parks. Most modern park planning, especially for General Management Plans, has been conducted by planning staff based in centralized NPS offices. Few modern parks constructed General Management Plans with park staff, largely because of the historical failure of such initiatives. Typically the funding and personnel intended for planning often ended up serving other interests, park staff often lacked the specialized expertise necessary for a plan, and in-house projects of this scale did not often reach completion in a timely fashion.

Mojave National Preserve became a significant exception to that formula. Its GMP was conceived in the crucible of bioregional ecosystem planning, carried through local opposition, the lean time of the Dollar Budget, and the growth that followed. Based in the precepts of national park management, the plan also reflected the particular and even peculiar situation of Mojave National Preserve. The advantage of an in-house GMP quickly became clear. Mojave NP faced different constraints than many of the more traditional units of the park system because of the compromises built into the mission of the park, and on-the-ground knowledge was crucial to negotiating the complicated circumstances of the eastern Mojave. In the end, Mojave planners successfully produced a workable General Management Plan, a document of tremendous importance to the future of the park. The planning process can also be read as a successful instance of park-based planning, and the experience of Mojave's planning team may be used to inform future NPS planning efforts.

After the passage of the California Desert Protection Act seemed inevitable, officials in the Bureau of Land Management and the National Park Service considered some of the potential opportunities for bioregional planning that would exist with such a land transfer. The California Desert was seen by many as an ideal candidate for ecosystem planning. Most of the area was already under the jurisdiction of the California Desert Plan, the earlier desert-wide management plan produced by BLM in 1980. More importantly, some bioregional planning was already underway in the Mojave. The desert and the rest of California were subjected to a 1991 federal and state interagency Memorandum of Understanding on Biodiversity, which "gave impetus to this idea of planning on a multi-ownership, multi-species level." [168] This MOU was informed by multijurisdictional planning work in the western Mojave, which was part of the response by DOI and private landowners to the August 1989 emergency listing of the desert tortoise (Gopherus agassizii) as a threatened species under the Endangered Species Act. Some of the earliest studies of a potential transition of BLM land to NPS control assimilated the language and spirit of bioregional planning, which made sense in the context of the 1991 MOU. The area under consideration for transfer to the Park Service as a Mojave National Park was recognized in the enabling legislation as a juncture of different desert ecosystems found in Death Valley and Joshua Tree, a perfect opportunity for ecosystem planning on a large scale in conjunction with other Park Service units and the BLM. [169]

A large-scale management plan to assist the recovery of the endangered desert tortoise further emphasized the need for regional planning on an ecological basis. In 1992, the Fish and Wildlife Service officially listed the desert tortoise as threatened, and in June 1994 completed the Desert Tortoise Recovery Plan (DTRP), which gave BLM and NPS additional impetus to work together on ecosystem planning. The Recovery Plan called for sweeping management changes on a large amount of public land, both inside and outside future Mojave National Preserve boundaries. [170] The need of BLM and NPS to both closely follow the strictures of the Desert Tortoise Recovery Plan gave added justification to a joint planning process, as both agencies would require the same kinds of expensive experts and both would be facing similar problems.

Department of the Interior planners saw the transition of BLM-controlled lands in the Mojave to Park Service control as an ideal opportunity to plan broadly to increase efficiency and save money. In 1993, the Secretary of the Interior created the California Desert Transition Work Group to plan for the eventual transfer of portions of the desert to the National Park Service if the California Desert Protection Act was passed. The group had a two-part mission, to create a "seamless" transfer, and also to identify ways to save money in the process. The group also looked to take advantage of the National Performance Review, Vice President Al Gore's "reinventing government" initiative, as an additional source of funds for the transition. [171] The work group produced a document in October 1993 titled "The California Desert in Transition," colloquially known as the "Yellow Book." It created a framework for proceeding with a "bioregional management" strategy in planning for the area, and included cost estimates and potential savings for the transition and for the new parks, as well as recommendations for joint and individual agency action. [172] The report was hailed by Secretary of the Interior Bruce Babbitt in his testimony before Congress on the California Desert Protection Act as an example of interagency cooperation and ecosystem planning. [173]

In retrospect, the report was fatally flawed, because the unusual resources and challenges of the future park were not adequately acknowledged. "[T]hey really missed the mark [because] [t]hey looked at it from a traditional Park Service organization," noted Superintendent Mary Martin. [174] The report did not adequately address the issues that made the Preserve unique, such as mining, rights of way, OHV use, and grazing. [175] In one glaring omission, the projected composition of park staff in the first full fiscal year included fifteen full time and eight temporary maintenance personnel, but not a single position dedicated to mining issues. [176] The "Yellow Book" also included just two Department of the Interior agencies, the Bureau of Land Management and the National Park Service. Later efforts in the bioregional planning process integrated the U.S. Fish and Wildlife Service into the discussion, as well as the Department of Defense, responsible for considerable acreage in the California desert set aside as training grounds.

The NPS portion of the joint team that produced the 1993 report was led by Dave Mihalic, and included among its members Frank Buono, then assigned to the Albright Training Center at Grand Canyon National Park. [177] After Babbitt's approval of the "Yellow Book" report, Frank Buono was temporarily assigned to work with Alan O'Neill, Superintendent of Lake Mead National Recreation Area, on further plans for the transition. In July 1994, BLM and NPS jointly produced a task directive, called the "Transition Action Plan," that listed the issues and tasks necessary to implement the CDPA. A total of twenty seven issues were identified in the report, many with multiple recommended actions. For each action, personnel from BLM and NPS were identified to lead the initiative. The innovative Alan O'Neill, who had already significantly improved Lake Mead National Recreation Area, shouldered much of this responsibility; Frank Buono also played a large role in implementation of the task directive. The directive was more detailed and issue-oriented than the Transition Action Plan, and was intended as a supplement, rather than a replacement. [178]

The Transition Action Plan contained the seeds of several initiatives that would become important in the GMP process for Mojave. It set up the Desert Managers' Group, the multi-agency management work group that supported Mojave personnel with planning and other expertise. [179] It also required Death Valley and Mojave to divide the Northern and Eastern Mojave Ecosystem Planning Units into areas of influence for planning purposes. These units, a product of the Desert Tortoise Recovery Plan, gave geographical definition and a name to the planning effort that would include Mojave National Preserve. The plan was for the Northern and Eastern Mojave, or NEMO - a nine-million-acre planning area.

Unlike the other areas created by the Desert Tortoise Recovery Plan, in which the vast majority of land was under the jurisdiction of the Bureau of Land Management, the National Park Service controlled more than half of the NEMO area in Death Valley National Park and Mojave National Preserve. As a result, Ed Hastey, the California State BLM Director, asked the Park Service to lead the NEMO effort. The NPS agreed, and promised to fill three of the positions for the planning team, including the team leader. The BLM provided three more, and FWS one. Marvin Jensen and Ray Murray, Regional Chief of Planning and Partnership, lobbied aggressively to have the planning staff attached to Mojave National Preserve, instead of using planners contracted through a central office, and succeeded in having the planners assigned to the park. [180]

The Park Service advertised for the position of planning team leader in March 1995, identifying Dennis Schramm, who was working in the Alaska Support Office, as an ideal candidate. Schramm was one half of a dual-career couple and turned down the transfer offer unless both he and Marcia, his wife, could be employed. The Park Service could not find positions for both Schramms until July 1995, but meanwhile hired the two other NPS members of the planning team. David Moore, a landscape architect at Sequoia / Kings Canyon National Park, filled the community planner position, and Gordon Reetz, from Chickasaw National Recreation Area, took on responsibility for natural resources planning. Both Reetz and Moore arrived at Mojave headquarters in mid-May 1995, and were instructed by Superintendent Jensen to become familiar with the land. Several field trips soon followed. [181] The newly arrived members of the planning team also helped set up the new headquarters office at Mercado Mall. The structure of the building made it feasible to locate the planning team in a suite a few doors down from the rest of the park staff. Schramm later identified the semi-isolation as very helpful in keeping the planners on track and preventing them from becoming bogged down in day-to-day park business. [182]

The new NEMO planning team met with the Desert Managers' Group, the Desert Tortoise planning management team, and NPS planners from the Denver office in early June 1995, in Barstow. The various parties discussed broadly how to approach the task of creating the NEMO plan, with the intent of formalizing the recommendations in a project agreement. Since none of the Mojave planning staff had worked on a general management plan before, they relied heavily on NPS experts to point them in the right direction. The team discussed "issue-driven" planning versus "goal-driven" planning, and decided that "goal-driven" planning might be a useful tool to defuse some of the intense issue-driven controversy surrounding the Preserve. Intense emotions about certain issues could hold back an issue-driven planning process, but a goal-driven approach would circumvent those issues to an extent and also provide more vision for future park planning. [183]

The planning team decided to use the best available methods to collect public comments about the proposed plan. Everyone on the team was acutely sensitive to the hostility with which some members of the public regarded Mojave National Preserve and wilderness elements of the California Desert Protection Act. "When I came to Mojave, people back at Sequoia were joking about needing to buy flak jackets and making sure I took the target off my back," remembered David Moore. [184] The Forest Service and BLM in Las Vegas, Nevada had recently completed controversial management plans, and the NEMO team sought their expertise in handling public comment. On July 11-13, 1995, the planning team met to work out public comment options and discuss coordination with the Northern/Eastern Colorado and Western Mojave planning efforts. Forest Service and BLM Nevada personnel presented their experiences with different approaches to gathering public comment. Their technique, utilizing several roundtables where comments were collected rather than a single-public-microphone approach, increased numbers of comments and commentators and also defused some negativity. This method was employed by the planning team at all of the public scoping meetings for the NEMO plans, and worked very well. [185]

The planners embarked on an ambitious set of scoping meetings, in an effort to receive suggestions to help shape the course of the management plans. In late July, the team held the first scoping meeting with BLM and NPS personnel from the desert, in order to understand management expectations for the plan. [186] One month later, in late August 1995, the planning team held the first of its public scoping meetings. Local, state, and federal officials and agencies were invited to the Mercado headquarters to talk to the planning team. David Moore remembers this meeting as having a "pretty good turnout" and being "very positive" in tone. The influential members of local communities present at the meeting were members of a traditional pro-tourism "growth coalition," in favor of the park for the economic opportunity it created for their communities and for themselves. [187] It was important for the planning team to receive input from these local elites, as they had a keen understanding of the issues the park was likely to face in the coming public meetings. It was also important to the park that the local leaders had an understanding of the planning process and their role in the future of the park.

The planning team prepared workshops to receive input from the general public, but the Dollar Budget crisis nearly brought a halt to the process. The NPS prepared a pamphlet that described the planning process and the public scoping meeting schedule, which the BLM mailed to everyone on its California Desert mailing list, some 6,000 people, on August 31, 1995. The team published the official notice of intent and EIS for the planning process in the Federal Register on September 5, 1995. [188] The initial public scoping meetings were scheduled for the week of September 21-27, but when the "Dollar Budget" appropriations bill passed out of the Conference Committee on September 19, Mojave National Preserve was in disarray. The management team discussed the possibility of canceling the meetings, because of the more than $15,000 it would cost to hold the workshops. Superintendent Jensen, Superintendent Dick Martin of Death Valley, and Ray Murray, of the Pacific West Regional Office, decided that the meetings should be held as scheduled. [189]

The NEMO team conducted the first wave of public scoping meetings in late September 1995. Two teams of employees headed the meetings. Alan Hagood of the Denver Service Center led those in the northern portion, while Dennis Schramm headed the southern meetings. The BLM Riverside district office helped with administrative support, such as communication with the media and sending letters to interested members of the public. Meetings were held in ten locations throughout the planning area. [190] Registration sheets recorded a total of 252 participants, but many more people attended who did not sign in. [191]

Peter Burk, President of the Citizens for Mojave National Park, wrote that all of the meetings saw a "majority of the people" supportive both of the Preserve and the planning process, but NPS officials remembered a more hostile reception; David Moore identified the Pasadena meeting as the only one where a majority of visitors were pro-NPS. [192] Mary Martin described the situation at the meeting in Needles:

"The audience was just packed, there must have been eighty people there ... Plus there was this one woman, ... she was just screaming through the meeting. And people were really emotionally upset. They didn't like the Park Service and they let us know. They let us know everything that they thought we did wrong, and we were listening." [193]

People opposed to the Mojave National Preserve often displayed cynicism. One local opponent weighed in on the planning process: "It is nice to know we are now a 'bioregion' - we used to be part of the United States," the meetings: "a total waste of time and a waste of taxpayers money," and multiagency planning: "Like tieing [sic] the tails of three alley cats together and throwing them over a clothesline." [194] The planning team structured its approach accordingly, placing an emphasis on listening and educating members of the public. Moore noted that the initial scoping meetings were about more than simply receiving public input. "In a sense," he recalled, "we were like ambassadors." [195]

A typical planning meeting began with Dennis Schramm giving a brief overview of the planning process. The planners then broke into groups of one or two individuals, and staffed the "breakout" tables, each dedicated to a specific issue or theme. Each table had an easel with a large blank paper pad, upon which the planners or individual members of the public wrote or summarized their comments. Occasionally, the planners would also take notes as well. Most comments were summarized for brevity, but since they were recorded in the open, the person who commented enjoyed a reasonable degree of confidence that the remarks were not being misinterpreted. After the meeting, comments were entered into a computer database, printed according to topic, and circulated among members of the planning team. [196]

The usefulness of the initial public input to the planning process was limited. "When we started holding public meetings, the first round people really just wanted to complain about the Act, ... so the actual scoping value of those meetings was minimal, in terms of new ideas or what issues should we address," noted Dennis Schramm. To the public, the process may have looked premeditated, though, because most of the negative public reaction had to do with topics that were not under the park's control, such as wilderness boundary modifications and the complete elimination of grazing and hunting [197]. Dennis Schramm observed another function of the first wave of planning meetings:

"We went out into those communities, we took the congressional wilderness maps, and when people would say 'they closed off every road in the Preserve,' we'd drag out the wilderness maps and say 'which one are you concerned about?' and they'd point it out and we'd go 'that one's still open.' ... The rumor was that all the roads were closed. And the reality was that less than 15% were closed by wilderness. As people began to learn more and more about what the act did, 'oh yeah, we can still use this, oh yeah, I can still hunt out here, oh yeah, there's still mining out here,' that started alleviating some of the concerns that people had had with it." [198]

Despite the public negativity, the first phase of public scoping meetings was considered a success. The planning team received public input, and the public had a good chance to air their concerns about the Preserve and the planning process. A larger threat to the park and the planning process loomed even as the first meetings were being conducted. Salaries of planning staff, unlike those for regular Mojave employees, theoretically were not in immediate danger from the Dollar Budget, because the planners were funded by special planning dollars unaffected by the cut. Nonetheless, the planning staff was definitely affected. Reetz, Moore, and Schramm had all been promised potential staff positions after the GMP was complete. Schramm explained how his salary was safe but his job was not: "my future was at Mojave, once the plan was done, because I was attached to the Mojave staff." [199]

In early 1996, the NEMO team created a fourteen-page newsletter to inform the public of the progress of the planning process. This "Periodic Update on the Interagency Management Plan #1," issued in February 1996, gave summaries of public comments received at the initial public scoping meetings. It also explained the missions of the three land management units, Mojave National Preserve, Death Valley National Park, and BLM lands involved in the NEMO effort, and assured readers that despite the flap over the Dollar Budget, the Preserve and the planning team would continue to function until instructed otherwise by Congress. [200] This newsletter was mailed to only approximately 500 people, as the NEMO team switched to a mailing list developed from agency lists and participants in the scoping process. [201] Some locals read specific details as proof of the illogic of Park Service control; one complained that "there is nothing sensible" about "banning" local recreationists while trying to simultaneously encourage foreign tourists to visit the Preserve. [202]

The planning team made efforts to contact agencies with less substantial stakes in the process that had not participated in the initial scoping meetings. In April 1996, the NEMO team officially notified California's State Historic Preservation Office that the planning process was underway. By law, the Park Service must evaluate all structures more than fifty years old on its property for inclusion on the National Register of Historic Places. Each State Historic Preservation Office is in charge of the National Register nominations for that state, so coordination between Mojave National Preserve and the California office was essential. A month later, the State Historic Preservation Office replied, and a meeting between the NPS and the agency was held in June 1996. The State Historic Preservation Office was interested in the planning process, but had no need to play an aggressive role. Thereafter, the agency kept in touch with the planning team through the formal comment process. [203]

In order to meet the CDPA requirement of consultation with local Native Americans, Dennis Schramm and BLM Archaeologist Rolla Queen met with leaders of the Chemehuevi, Native Americans who historically lived in the area of the Preserve, at their Colorado River reservation on April 23, 1996. More than one year later, on May 19, 1997, NEMO planners met again with the Chemehuevi at their tribal offices. Later that day, planners met with the chair of the Fort Mojave Tribe at tribal offices in Needles. The planning team put together an intertribal meeting, scheduled for July 11, 1997 at the Avi Casino. William "Bill" Mungary, a Native American involved with the American Indian Council of Central California and other groups, conducted the meeting. The planners extended invitations to thirteen tribal groups, as well as selected NPS and BLM officials. Seven tribal leaders attended, representing the Fort Mojave Tribe, Timbisha Shoshone, Chemehuevi, and San Manuel band. In addition, nine BLM and NPS employees were present. [204]

The NEMO team utilized electronic media throughout the planning process to keep the public informed of their progress and to make documents available without the cost of printing. In February 1997, the first NEMO web site came online, hosted by the BLM along with sites for the Western Mojave and Northern / Eastern Colorado planning efforts. In April 1998, after the decision to complete three plans instead of a single joint plan, the NEMO site moved to the Mojave National Preserve website. Both drafts of the EISs and GMPs being prepared by the NEMO team were posted on the Internet site and were also made available on CD-ROM, enabling the government to avoid the $60 per copy printing and mailing costs of the paper version. Approximately 100 copies of the 1998 draft were sent out on CD-ROM, and some 200 copies of the second draft were requested in the CD-ROM format. [205]

In mid-April 1997, the NEMO team mailed its second newsletter and press release, timed to announce a second round of public scoping meetings. These meetings were intended to give members of the public a chance to discuss various plan alternatives. With better media publicity, the second round of workshops attracted at least 330 participants. The ten meetings were held in the same locations as the earlier meetings, except the Independence, California, meeting which was moved to the town of Bishop. [206] After the public meetings were held, the planning team hosted a two-day interagency scoping meeting in Barstow in late April 1997. Twenty-eight participants, representing a variety of federal and state agencies, discussed the public comments and the alternatives. [207]

The planning staff made good use out of data developed by other agencies, discounting the charge of CDPA opponents that the new parks would invalidate the time and money spent on previous planning efforts. Team members consulted existing BLM documents, many developed in preparation for and after implementation of the 1980 Desert Plan. In most cases, the BLM texts provided the planning team with a valuable resource. [208] In a few instances, planners such as David Moore recognized the value of previous planning efforts in a more literal way:

"[E]specially for the Mojave Road — I mean, there had been so much that had been covered, and I'm sure just fought over and argued over earlier with BLM and these use groups, and so [I] felt it was still applicable and just carried it over into our plan. ... I just realized that there was a lot of work and a lot of words that had been shared back and forth over the whole thing." [209]

While planners were writing the first draft of the combined EIS and GMP, the relationship between the NPS and BLM in the NEMO team became a problem. BLM was the lead agency on two other planning initiatives in the California desert, the West Mojave Plan and the Northern and Eastern Colorado Plan, and had little money or staff to devote to the Northern and Eastern Mojave Plan. "It was their lowest priority — in fact, they told us more than once that it wasn't a priority for them," recalled Schramm. At the same time, the NPS portions of the NEMO plan were being funded with Park Service dollars reserved for general management plans. This imposed a sense of urgency on the NPS that did not fit well with the BLM's less intense attitude toward the process. [210] As the combined internal-use draft NEMO plan, more than 800 pages in length, circulated among members of both agencies, BLM withdrew its support for the project. Pressure from the highest echelons of the Department of the Interior forced the bureau to come back to the table, but by then it was clear that a combined document — and combined planning process — was not feasible. Some of the spirit of ecosystem planning remained, and the NPS planning team cooperated with BLM on issues of joint concern such as burro management. [211] The joint planning process ultimately proved too complex, given the different time frames, budgets, commitments, and missions of the agencies involved, for the innovative attempt at ecosystem planning to succeed in the Mojave desert.

The NPS planners utilized contracted assistance to fill in the gaps in the planning team left by BLM's departure. BLM personnel had been an important part of the NEMO team. According to the project agreement, the Park Service provided a team leader, a community planner, and a natural resources expert. The U.S. Fish & Wildlife Service contributed a biologist, and the BLM added cultural resource expertise, Geographical Information Service (GIS) expertise, and clerical staff. The planning team could not adequately proceed until it found replacements for the lost staff. The University of Nevada, Las Vegas Cooperative Park Studies Unit provided GIS services on a contract basis. The NEMO team contracted with the historian Harlan Unrau, of the NPS's Denver Service Center, to manage cultural resource planning. Dean Runyan Associates was hired to produce an Economic Impact Analysis. Jean De Los Reyes was hired as a temporary editor to help compile and revise the draft plans before their 1998 release. [212]

The third planning team newsletter in April 1998 announced that the NEMO effort would generate three environmental impact statements, one each for Death Valley, Mojave, and BLM lands, instead of a single unified document. The newsletter reported that this was intended as a ease-of-use measure, noting that the initial combined draft was 800 pages and growing. In reality, the arrangement reflected the reconciliation of the agencies after BLM pulled out of the planning effort several months previously. The newsletter noted that interested members of the public could choose to receive the plans in electronic format if they wished. [213]

In September 1998, the planning team released the first draft environmental impact statements and general management plans for Mojave National Preserve and Death Valley National Park. Approximately 450 of the printed documents were mailed to various parties, and more than 100 CD-ROMs were produced. The documents were also available on the National Park Service website. The official notice of availability for the plan was published on September 11, 1998 in the Federal Register. [214] In late November 1998, the original ninety day comment period was extended until mid-January 1999, which gave the public a total of 127 days to comment on the draft. [215]

Unlike the first round of scoping meetings, the park encountered criticisms of the draft GMP from both traditional park opponents and those who ordinarily supported NPS efforts. Ten public meetings were conducted October 19-30, 1998, more than a month after the draft documents were issued. Some criticism of the plans was encountered from anti-park critics who had also been critical of the CDPA. Others were upset because the plans did not go far enough to protect the resources of the Preserve. Peter Burk, President of the Citizens for Mojave National Park, called the draft 'multiple-use double-talk,' and pitched his own 'modified proposed action alternative' to better protect park lands and the desert tortoise. In their attempts to recognize the legitimacy of activities expressly permitted by Congress to continue in the Preserve, the planning team came under fire from environmentalists who wanted more strict controls. [216] The planning team received just under 400 individual letters commenting on aspects of the plan. Some 1,800 pre-printed postcards from members of the Sierra Club, the National Parks Conservation Association, and the Wilderness Society were also mailed to the team. [217]

The planning team, working closely with the superintendents of both Mojave National Preserve and Death Valley National Park, realized that the tremendous public interest in the plan called for unusual measures. They decided to create a revised draft and hold another public comment period with public meetings. Some changes took place in the planning team, because after the publication of the first draft, Reetz and Moore moved to staff positions in the park, and when the GMP planning money ran out, Schramm's position had to be funded through the park as well. As a spatial reminder of their new status, most members of the planning team moved into the regular park office, yielding their separate suite to the incoming chief ranger and his staff. [218]

Schramm tackled the job of creating the official Park Service responses to public comments. He rewrote sections of the plans based on public comments. Schramm also reworked the structure of Mojave's plan, rearranging the contents under four umbrella headings designed to clarify the elements of the GMP. Superintendent Martin gave Schramm the flexibility to evade distractions; he only stopped in at headquarters a couple times a week:

"When we went from the first draft to the revised draft, most of the staff had moved into other jobs. So I basically wrote that second revised draft - that's when I spent the three months at home. My kids were in high school, and I was telling them, 'you talk about a term paper, I've got a term paper!' And I was doing two of them - Death Valley's and Mojave's." [219]

The U.S. Fish and Wildlife Service (FWS) coordinated the Desert Tortoise Recovery Plan, and therefore needed to approve of any long-term development plans in critical tortoise habitat. Rather than spend time and money on a formal Biological Opinion, the planning team received FWS reviews of the plans prior to their formal publication, for both the initial draft in 1998 and the revised draft in early 2000. Any FWS changes to the plan were promptly incorporated into the draft GMPs. As a result, the service agreed that it would issue a Biological Opinion on the final EIS when it was published, if all of FWS's concerns were addressed. [220]

In September 2000, Mojave National Preserve and Death Valley National Park released revised draft environmental impact statements and general management plans, and notified some 3,500 people and organizations on the NEMO mailing list. Agency responses to public comments were bound as a separate volume. [221] The revised draft had 92 days of public review, beginning with a notice in the Federal Register on September 6, 2000. [222] Nearly two months later, the planning team held eleven more public meetings about the proposed changes. Including this final round, a total of forty three public meetings were held during the development of the General Management Plan. [223] Planners and park staff received 202 written comments about the revised draft.

After the public comment period expired, the NPS reviewed the comments and decided that respondents raised no new major issues. Since there were essentially only minor corrections to make to the revised draft EIS — the revisions filled only thirty pages, minuscule by EIS standards - planners decided to issue an abbreviated final environmental impact statement, instead of a full version. This abbreviated final EIS/GMP would be read in conjunction with the revised draft for a complete final EIS and GMP. This document, issued June 21, 2001, also contained the public comments received by Mojave National Preserve about the revised draft. As had the revised draft before it, the final EIS/GMP identified Alternative 1, which called for rehabilitation of the Kelso Depot, limited development within park boundaries, and acquisition of non-federal land within the Preserve, as the proposed plan. The NEMO team mailed their fifth newsletter announcing the publication of the abbreviated final EIS and the thirty day noaction period, which was received by some 3,600 people on the planning team mailing list. On July 6, 2001, FWS issued Biological Opinion 1-8-00-F-36, which approved the NPS-preferred alternative in the abbreviated final EIS and GMP as acceptable from the standpoint of the Desert Tortoise Recovery Plan. [224]

One NPS change in the abbreviated final EIS/GMP seemed like a minor correction, but caused a large headache for park staff. The California Department of Fish & Game pointed out in their official response to the 2000 revised draft EIS that the preferred alternative allowed continued hunting of small game, where the Desert Tortoise Recovery Plan specified that only big game or upland game bird hunting should be allowed. The NPS responded by modifying the revised draft to conform to the wording of the Desert Tortoise Recovery Plan, 'prohibit[ing] the discharge of firearms, except for hunting of big game or upland game birds from September through February." [225] Mary Martin described the result:

"[in] the final draft of the GMP, the Cal Fish & Game wrote back to us and not only did they support our hunting issue ... but they pointed out that the Desert Tortoise Recovery Plan called for the elimination of ... rabbit ... hunting. And we had left it in our plan. So we said 'hey great, Fish & Game wants to reduce hunting, we'd support that,' and we took their recommendation. Well then the hunting community heard about it — they were mad at Fish & Game, they were mad at the Park Service, and the last round of public meetings, there were lots of hunters that showed up, lots of hunters that showed up. The hunters were very effective at getting political support." [226]

The hunting issue pitted traditional Park Service constituents, who tended to be antihunting, against hunters whom the Preserve was obliged to accommodate. During the 'No Action Period' that followed the publication of the abbreviated final EIS, Mojave received more than twenty five letters, approximately 200 more form letters, and several petitions opposed to the hunting reduction proposal. The park also received a few letters and almost a thousand emails in favor of the hunting reductions, but the pro-hunting groups had political muscle and the legislative intent of the CDPA on their side. Superintendent Martin received several letters from congressional representatives requesting that she meet with California Fish & Game before a Record of Decision could be issued. The superintendent met with the director and deputy director of CDF&G on August 1, 2001, and NPS staff met with Fish & Game and FWS staff the following day. In both meetings, the Park Service made it clear that the intent of the GMP was to allow upland game bird hunting and prohibit hunting of predators and so-called 'furbearing' species such as rabbits and squirrels. [227]

The issuance of a Record of Decision for the General Management Plan hinged on the successful resolution of the hunting issue. On September 7, 2001, the Park Service asked the Fish & Wildlife Service to amend the Biological Opinion, and restore rabbit hunting, to which FWS agreed almost two weeks later. The Park Service also sought to amend the hunting seasons in the Preserve to make them consistent with the Desert Tortoise Recovery Plan by making their case to the California Fish and Game Commission. As an act of conciliation, the Preserve removed the provision that a one mile no-shooting zone exist around all developed areas in the park, except around the Kelso Depot and Kelso Dunes areas, because CDF&G indicated to the Park Service that the existing 150-yard limit was sufficiently effective. The Preserve received almost 1,400 emails claiming that the new provisions did not comply with the Desert Tortoise Recovery Plan, but the Park Service responded that the U.S. Fish & Wildlife Service, the agency in charge of implementation of the DTRP, signed off on the change as adequate. [228]

Two days after FWS agreed to the changes, on September 21, 2001 NPS Regional Director John Reynolds signed the Record of Decision for the abbreviated final environmental impact statement and general management plan, identifying the preferred alternative as the official future of Mojave National Preserve. Included with the document was a signed copy of the "Floodplain Statement of Findings for the Kelso Depot," required by executive order as a result of the building's location in a major drainage area. [229] Aside from the reversal on hunting, the Record of Decision made only a handful of minor changes, most simply corrections of errors that appeared in the revised draft EIS/GMP. Months later, the various documents, compiled into a bound General Management Plan, were received at headquarters for the everyday use of park employees. [230] After six years of work, Mojave National Preserve had a clear plan for its future.

The implications of the General Management Plan for Mojave National Preserve are obvious — the goals of the park for the next decade or more are spelled out on its pages — but the Mojave plan might also serve as a successful 'proof of concept' for future park-based general management plans in the NPS. Dennis Schramm, leader of the planning team that produced Mojave's GMP, emphasized the rarity of park-based planning in today's NPS. However, he also saw that the Denver Service Center, traditional home of NPS planning teams, receives more political scrutiny and less funding than it needs, opening the possibility that future planning may need to be park-based. Those involved in the Mojave effort hope that their experiences developing the GMP might help future park-level plans succeed.

The Mojave planners identified two key factors in their success: isolation, and contracting. Mojave's plan benefited from having staff completely dedicated to the planning process. Ensconced in semi-isolation in a separate strip-mall office, the planning team was able to work effectively without getting too caught up in day-to-day park affairs. Schramm suggests that park-based collateral duty planners often face an uphill struggle to remain focused on planning, "they just really can't put the time in on it, unless they're given the latitude to work elsewhere." [231] After the planning team was moved back into the main office, Schramm worked from home for three months to complete the revised draft, and his self-imposed exile proved important to his timely success. Mojave's experience with the composition of the planning team may also offer insight to future park-based planning efforts. The Park Service cannot afford to concentrate several planners, an entire planning team, at a single park. One of the key ideas behind the bioregional planning effort was the sharing of resources — in theory, the Park Service only had to pay for three positions on a seven-member team of experts. Once the BLM embarked on its own plan, the Park Service had to find a way to complete the plans on its own, and discovered that contracting could provide much of the needed expertise. Asked about the ability of other parks to replicate Mojave's success, Schramm suggested that:

"if you did it where the superintendent and a key person were park base-funded and involved, and you got a chunk of planning money to contract some support services, you know, I think you could pull it off."