A Final Opportunity to Protect the Magic of Winter in Yellowstone. Please Make Your Voice Heard!
The deadline for comment is July 18, 2011.
It’s so close you can almost taste, smell and hear the crystalline air, gurgling geysers, and squeak of cold snow underfoot in a Yellowstone National Park that is managed to further restore and permanently protect the natural sights and sounds of winter. So close, but we’re not there yet. You and I have a final opportunity to urge Yellowstone to adopt a permanent plan for winter access that protects the Park and at the same time improves the visitor experience. Please help us complete the transition to a healthier, cleaner, and quieter Yellowstone by commenting right now.
Park officials recently released a Draft Winter Use Plan and Draft Environmental Impact Statement including a “preferred alternative” that the park proposes to adopt. The plan, once finalized, will take effect in December, 2011 and will guide winter activities in Yellowstone for decades to come. The Park Service is accepting public comment on the Draft Plan/DEIS through July 18, 2011.
After 12 years of political wrangling, nearly a million public comments, and, yes, a few discouraging setbacks, Yellowstone National Park is closer than ever to being the winter sanctuary its founders envisioned when they established Yellowstone as our first national park. Under an interim plan – the direct result of legal action by Winter Wildlands Alliance and four coalition partners – the park has made a profound comeback from its days of being overwhelmed by the noise and exhaust of snowmobiles.
The draft plan’s preferred alternative includes some good ideas that deserve praise. Services for skiers, snowshoers, and other low-impact visitors are improved and include a number of side roads set aside as ski and snowshoe routes. This plan acknowledges, finally, the strong public demand for skiing, snowshoeing and other quiet experiences in Yellowstone’s winter season.
However, the preferred alternative authorizes numbers of snowmobiles on peak days that are higher than either the interim plan or the average of the past five years, the number above which the park’s own scientists note will undercut Yellowstone’s resurgent conditions and adversely impact wildlife, natural soundscapes and air quality.
Please take a moment right now to tell Yellowstone’s new superintendent that you want Yellowstone’s winter recovery to continue. That you don’t want the park to slide back to levels of snowmobile traffic that disturbed wildlife, made noise a constant unpleasant companion and diminished the experience of visiting Yellowstone to a degree that led many folks – including you? - to regard the first national park in the world as a place to mostly avoid in winter.
Please ensure a better future for Yellowstone by submitting comments today. The deadline for comment is July 18, 2011.
HOW TO COMMENT: 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=40801
You may also comment by mail to:
Yellowstone National Park
Winter Use DEIS
P.O. Box 168
Yellowstone NP, WY 82190.
Comments will not be accepted by fax, email, or in any other way than those specified above.
See below for a sample letter and talking points. Please cut and paste the points you believe are most important into your letter on the web comment page and be sure to add any relevant personal experience in the park.
____________________________________________________________________________
Sample Comment Letter:
Superintendent Dan Wenk
Yellowstone National Park
Winter Use DEIS
P.O. Box 168
Yellowstone National Park, Wyoming 82190
Dear Superintendent Wenk:
As a Nordic skier [or snowshoer, winter hiker, etc.] who values the natural sights and sounds of Yellowstone in winter, I appreciate the improvements to Yellowstone’s winter environment resulting from reduced motorized traffic and the requirements for cleaner, quieter machines and for commercial guiding of all snowmobiles. I also appreciate your renewed emphasis on providing better services for skiers, snowshoers and other low-impact winter visitors.
Your Draft Winter Use Plan’s acknowledgment that visitors highly value quiet in Yellowstone and your preferred alternative’s proposal to designate certain side roads as ski and snowshoe routes and to limit motorized travel on the east side of the park in March are positive steps.
However, these positive steps are overshadowed by your proposal to allow snowmobile numbers during peak times that are significantly higher than past seasons and higher than your own scientists recommend for protecting park resources and ensuring visitor enjoyment. Your soundscapes experts have verified during recent seasons that when snowmobile numbers declined below 200 per day that visitors’ opportunities to hear sounds like the hiss and splash of erupting geysers at Old Faithful are significantly improved. Furthermore, your biologists have cautioned that if vehicle numbers are allowed to increase from their recent, reduced levels, adverse impacts to winter-stressed wildlife may increase and cause “fitness effects,” reducing animals’ health and the strength they require to survive Yellowstone’s winters.
Your Environmental Impact Statement states that visitors who prefer and expect quiet in Yellowstone National Park will have the opportunity to consult a schedule in future winters to learn which days will have less vehicle traffic and thus less noise and plan their visit for those days. Your suggestion that I check ahead to learn if I will have opportunities to experience winter quiet and natural sounds is, in reality, an acknowledgment that 330 snowmobiles a day during peak periods – an increase of more than 50 percent from recent seasons – is simply too many vehicles in the park. Please don’t contradict your scientific findings and forsake stewardship of the park in order to provide a recreational snowmobiling experience that exceeds current demand.
In addition, please do not modify your requirement that all recreational snowmobilers be accompanied by a commercial guide. You have stated in the Federal Register that the 100 percent commercial guiding requirement has been a “fundamental element” of mitigating unsafe and illegal snowmobile use, which prior to the guiding requirement included speeding, driving off roads, endangering other visitors and disturbing wildlife. Your analysis of winter use have stated that because commercial guiding clusters snowmobiles in larger groups, it has helped provide noise-free intervals. You have also noted commercial guiding has helped snowmobile visitors understand and appreciate the park. In short, please do not contradict your own findings.
I urge you to adopt a long-term winter use plan that caps over-snow vehicle numbers at or below those experienced during the past five winter seasons, numbers at which Yellowstone is on a path to again become America’s most beloved winter sanctuary. Above all, please give Yellowstone a sustainable winter transportation system befitting of the world’s first national park, one that minimizes impacts while accommodating enjoyment of Yellowstone’s unparalleled winter environment.
Sincerely,
Name
Address
____________________________________________________________________________________
Background and Additional Talking Points:
With your help, we've made enormous progress in providing the best possible protection for Yellowstone over the past decade. We’ve eliminated the noisiest and most-polluting forms of winter access and moderated the disruption to wintering wildlife. The park has indeed become healthier as snowmobile numbers have been reduced and visitors have turned increasingly to entering the park under their own power or on more environmentally-friendly snowcoaches. We have a final opportunity to bring permanence to these improved conditions.
The National Park Service has prepared a Draft Winter Use Plan and Draft Environmental Impact Statement for Yellowstone National Park. The purpose of the Winter Use Plan is to establish a management framework for Yellowstone’s unique and valuable winter recreational resources. The plan will take effect in December, 2011, when the present two-year interim plan expires.
You can view the draft plan and proposed alternatives at http://parkplanning.nps.gov/YELL
The Plan’s “Preferred Alternative” proposes a variable use level of over-snow vehicle numbers allowed during the season. This includes up to 330 snowmobiles for half the winter, or about 45 days, up to 220 snowmobiles for a third of the season, or about 30 days and between 110 and 143 snowmobiles per day for a sixth of the season, or about 15 days. Snowcoach numbers would vary correspondingly, ranging from up to 80 snowcoaches during peak periods to 30 snowcoaches per day during low periods.
For the past two winter seasons Yellowstone National Park has operated under an interim plan that allowed 318 snowmobiles and 78 snowcoaches per day to enter the park. The interim plan includes “Best Available Technology” and 100 percent commercial guiding requirements for all snowmobiles. Actual use under the interim plan has been 194 snowmobiles and 40 snowcoaches per day. The average number of snowmobiles for the past five seasons has been approximately 250 per day. During this period of reduced over-snow vehicle traffic Yellowstone’s unique winter ecosystem has experienced a profound resurgence.
Yellowstone’s new superintendent, Dan Wenk, has said it is very likely the final plan will change from the “preferred alternative” before a decision is made later this year. Your comments can help motivate the superintendent to improve upon the preferred alternative by further reducing vehicle traffic; increasing services for skiers, snowshoers and other low-impact visitors; and better protecting Yellowstone’s wildlife and unique natural resources. Following are some points you may want to consider in your comments.
Non-motorized use: The park’s preferred alternative proposes to set aside certain side roads as ski and snowshoe routes. This could include Firehole Canyon Drive, North Canyon Rim Drive, Riverside Drive, Fountain Flat Road, Firehole Lake Drive, Grand Loop Road from Canyon Junction to the Washburn Hot Springs Overlook, and Virginia Cascades. In addition, the preferred alternative proposes that when Yellowstone’s winter season begins winding down in March, motorized traffic going northbound on the east side of the park would end at West Thumb, and coming south on the east side it would end at Canyon. This would keep most of Yellowstone’s east side free of motorized vehicles from March 2 to March 15. This is a positive step for quiet, non-motorized enjoyment of Yellowstone and something you may want to affirm to the park’s managers.
Motorized use: The National Park Service is proposing a patchwork of four different traffic levels across Yellowstone’s winter season. Daily snowmobile numbers would range from 110 to 330. Daily snowcoach numbers would range from 30 to 80. Park officials say the variable traffic levels would provide a mix of visitor experiences with days that would be noisier and days that would be quieter.
In reality, however, on most of the season’s 91 days the preferred alternative would allow a larger number of snowmobiles than visitors have experienced in recent winters when reduced snowmobiling brought easing of noise and less disturbance of wildlife. The proposal to allow daily snowmobile numbers to increase fails to act on scientific findings from those seasons and on the National Park Service’s policies, which require the NPS to “preserve, to the greatest extent possible, the natural soundscapes of the parks.”
The National Park Service’s soundscapes experts measured the effects on listening conditions at Old Faithful in recent seasons as the popularity of multi-passenger snowcoaches has increased and fewer visitors overall have opted to enter the park on snowmobiles. When the number of snowmobiles declined below 200 per day, scientists measured a significant improvement in visitors’ opportunities to hear sounds that define the Old Faithful area such as the hiss and splash of erupting geysers. Yet the National Park Service is proposing to allow up to 330 snowmobiles a day—an increase of over 50 percent from recent seasons—and discloses in its environmental impact statement that noise loud enough to interfere with good listening conditions in Yellowstone would increase compared to the “current condition.”
The National Park Service also acknowledges in its environmental impact statement that its preferred alternative would have a greater adverse impact on wildlife than an alternative that would cap over-snow vehicle numbers at or below the level of the past five seasons. The study reflects that with greater numbers of vehicles, impacts would be greater both to individual elk and bison and to local populations of both species, and that impacts to trumpeter swans and bald eagles could “heighten the probability of adverse impacts on the reproductive success of both species.”
Winter Wildlands Alliance and our coalition partners are concerned that although the preferred alternative includes some positive elements, overall it represents a failure to provide the best available protection of Yellowstone. As such, it represents a de-prioritization of stewardship in the world’s first national park because it chooses to permit greater wildlife disturbance and noise pollution in order to provide a recreational snowmobile experience that exceeds current demand. Yellowstone can, and must, do better.
Nearly eleven years ago, the National Park Service in 2000 adopted a Record of Decision to phase out the use of snowmobiles within Yellowstone National Park by the winter of 2003-2004. Based on sound science and in accordance with National Park Service legal mandates and policies, that decision was overturned by the Bush Administration in 2001. Since that reversal, the public has responded to the winter use debate in Yellowstone in unprecedented numbers. Over 900,000 Americans have submitted comments to the National Park Service. Over 80 percent have urged Yellowstone to end snowmobile use and adopt the “least impacting” means of visiting the Park’s interior in winter—the originally envisioned transition to snowcoach access that subsequent studies verified would best protect park resources. Much of the public comment focused specifically on the critical importance of applying science and upholding the National Park Service’s stewardship responsibility to emphasize conservation over use whenever the two are in conflict.
Former Directors of the National Park Service have come together to emphasize in joint letters to the Department of Interior that weakening protection of Yellowstone by authorizing continued snowmobile use within the Park “would be a radical departure from the Department’s stewardship mission.” They cautioned: “The choice over snowmobile use in Yellowstone is a choice between upholding the founding principle of our national parks—stewardship on behalf of all visitors and future generations—or catering to a special interest in a manner that would damage Yellowstone’s resources and threaten public health. The latter choice would set an entirely new course for America’s national parks.” National Park Service Directors from the last eight presidential administrations specifically pointed out: “…reducing snowmobile numbers still further—from 250 per day to zero—while expanding public access on modern snowcoaches, would further improve the park’s health.”
