Comment Deadline on Yellowstone Winter Use Plan Ends Soon

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March 18, 2010 6:00 AM

BLUERIBBON COALITION ACTION ALERT!

Dear Action Alert Subscribers,

SITUATION
The National Park Service (NPS) is preparing an Environmental Impact Statement (EIS) for a Winter Use Plan for Yellowstone National Park. The purpose of the EIS is to establish a management framework Yellowstone's unique and valuable winter recreational resources.

This plan will determine whether motorized winter use of the park (including wheeled motor vehicles, snowmobiles, and snowcoaches) is appropriate, and if so, the types, extent, and location of this use. A Winter Use Plan is needed at this time because:

The NPS is deciding whether snowmobile use should continue, and if so, under what limits and restrictions. The EIS will evaluate the environmental effects of winter use on air quality and visibility, wildlife, natural soundscapes, employee and visitor health and safety, visitor experience, and socioeconomics.

The public comment period for the "scoping" phase of the EIS ends March 30, 2010. Comments in the Scoping process are extremely important. SNOWMOBILERS NEED TO COMMENT BY MARCH 30.

Read more about this continuing saga:  in Yellowstone: Snowmobiling in Yellowstone - Why We Fight  https://www.sharetrails.org/public-lands/snowmobiling-yellowstone-why-we-fight

For questions and other information, contact John Sacklin at (307) 344-2019. More info is also available on the web at: http://parkplanning.nps.gov/YELL

WHAT YOU NEED TO DO:
Snowmobile enthusiast NEED to comment during this initial phase, and if you have ever been to Yellowstone, we need you to comment regarding your experience.

BRC'S THREE-STEP ACTION ITEM
STEP-BY-STEP INSTRUCTIONS ON HOW TO SEND YOUR COMMENTS:

NOTE: Please be polite and, if possible, make your comment letter as personal as you can.

STEP 1: Click on the following link, which will take you to the NPS comment webpage.
http://parkplanning.nps.gov/commentForm.cfm?parkID=111&projectID=29281&documentId=31782
Read and follow the instructions for completing the Comment Form.

STEP 2: Use the comments suggestions below as a guideline for your comments. Cut and paste is okay, but try to make your comment letter as personal as possible.

STEP 3: Take just a minute to add a bit about where you live, any winter visits you have made to Yellowstone, how often you go, how long you have been riding in the area and/or how important the area is to you.

Once you have completed your comments, click the "Submit" button.

Optional:
You may also comment by mail to: Yellowstone National Park, Winter Use Scoping, P.O. Box 168, Yellowstone NP, WY 82190.

COMMENT SUGGESTIONS:

When creating the National Park System, Congress mandated that the Park Service: (1) "promote" and "provide for the use and enjoyment" of park resources, and (2) and "leave [the park resources] unimpaired for the enjoyment of future generations." These are coequal, yet sometimes conflicting, mandates that require the NPS to balance both interests when making management decisions.

The previous management plan took a reasonable approach to snowmobiling, although subsequent analysis indicates daily limits were to low. Snowmobiling in Yellowstone is a delightful, unique and valuable experience. Technology allows us to have that experience and minimize impacts. Guides ensure compliance with all Park Service rules.

The Purpose and Need and the Planning Objectives of this EIS should reflect the socio-economic importance of snowmobiling in the Park. Snowmobiling has a long, rich history. Snowmobiling in the Park is highly valued by those participating. Allowing snowmobiling to occur is consistent with the agency's management plan, the NPS national planning guidelines and the agency's strategic plans. Snowmobiling in Yellowstone is also consistent with recent agency direction to encourage increased visitation to National Parks. Snowmobiling is consistent Congressional direction in the establishment of both the National Park System and Yellowstone National Park itself. All of this should be reflected in the purpose and need statement itself.

Given that recent studies indicate that impacts of snowmobiles have been vastly overstated by some stakeholders, it is appropriate for the agency to develop at least one Alternative that enhances snowmobiling experience. Please consider developing an Alternative that considers increasing the daily limits and an Alternative that considers modification of the Guide system to allow individuals to become certified as guides.

Previous years management has shown a need to alter the daily limit paradigm to include a concept of "peak days." In addition to considering raising the daily limit, at least one alternative should include a flexible daily limit paradigm that allows "credit" for very slow days in order to provide for a higher daily limit on "peak days." Such a system would include a limit, for example, the number of peak days would not exceed a certain percentage of the total season days.

Previous years management also shows a need for flexibility in the gate allocation. For example, if a gate operator knows in advance that they will not use their gate limit, those numbers should be able to transfer to another gate. At lease one alternative should include a flexible gate allocation process.

A key consideration in any NEPA analysis is "context" and "intensity." In past analysis, the agency has focused on potential impacts of snowmobiling without the proper context. The key flaw in previous analysis is that it failed to consider impacts of wintertime activities in the context of year round use. I formally request that the agency consider impacts of snowmobiling in contrast to summer use.

As one who values snowmobile use as a modality to visit and enjoy public lands, I can say that the experience of snowmobiling in Yellowstone provides an unparalleled inspirational experience. The Park's interpenetrate information, provided at the Park Entrance and the destinations as well as by guides is excellent. Snowmobilers leave with an enhanced appreciation of Yellowstone's natural resources.

The scoping information referenced several Plan Objectives, including those related to Visitor Use. One Plan Objective is: "Provide opportunities that are universally accessible." I support this objective because many snowmobilers use snowmobiles for access and recreation because they are physically unable to snowshoe or ski. But I am concerned that the Objective may be interpreted as meaning ALL opportunities should be universally accessible. Such an approach would be like requiring ALL hiking trails in the Park be universally accessible. Also, your analysis should consider that snowmobiles are chosen as a preferred recreation modality by many of the elderly and the handicapped.

At least one alternative should include a one-year (or more) transition period after the EIS is completed in late fall of 2011. Having a decision made on winter access to Yellowstone Park within a very short period, possibly only 30 days before that 2011-2012 season begins, would be a hardship on the snowmobile operators and the general public. This transition period would allow operators and the general public to make appropriate plans for the 2011-2012 season. Snowmobile operators need to place orders for machines in spring 2011, and the public needs to be able to make plans to visit the park with sufficient certainty that will accommodate early vacation planning and airline discounts.

 


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