I am a wildlife biologist and botanist. I have been conducting biological surveys throughout the MNP over the past 10 years. My surveys have been completed as an independent biologist to the MNP, Ponderosa Telephone and other private groups. As such, I can provide only data summary information below. The clients "own" the data and I cannot release any information without their written approval. These are my observations:

1. The number of mule deer observations that I have made in the past 10 years has decreased from an average of 15 observations per month to two per month. Summer months are excluded from these observation data (June, July, August).

2. The number of bighorn sheep observed over the past 10 years has decreased from 1.5 per month to 0.08 per month.

3. The density of park visitors encountered while surveying the MNP (excluding residents) has decreased from 22 per month to four per month. These data include observations of several campsite occupants (Mid Hills specifically).

4. The diversity of avian species (birds) observed has decreased over the past 10 years around historic water sources from an average of 18 different species to 12 different species. These data include those species observed flying over each area.

I understand the need to protect the MNP. Over the past 10 years I have noticed a decline in the presence of litter and roadside debris in the MNP. Likewise, I noticed the distribution of debris has become more concentrated along Cima Road and Ivanpah Road than elsewhere in the MNP. This may be a function of road closures and therefore the lack of access to outlying areas by MNP visitors.

My main concern is that by stopping water flow through several areas, the MNP is violating federal law. The U. S. Army Corps of Engineers has identified several drainages in the MNP as jurisdictional waters of the U.S. Impacts to these waters of the U.S. requires Army Corps of Engineers approval via the issuance of a 404 permit. Reduced and then eliminated water flow results in the "take" of species and their habitat, including impacts to wildlife corridors. This is illegal and must be remedied quickly.

It is my understanding that the goal of the MNP is to preserve the area in perpetuity. Does preserving the area include the elimination of wildlife, waters of the U.S., and the general public?

I am forwarding this letter and the information in it to the Los Angeles office of the Army Corps of Engineers.

Long-term biological monitoring must be required to determine if the actions taken to protect the MNP are working. These data suggest clearly that the opposite is happening.

Victor M. Horchar