Almost a year ago I wrote asking you to lend your voice in support of an interim plan that would have cut the number of snowmobiles in Yellowstone National Park by more than half and continued an encouraging return to clean air and the natural sights and sounds of winter in our oldest national park. Unfortunately, that plan was tossed in favor of the status quo during the waning hours of the Bush Administration.
Now, while it
may seem like déjà vu all over again, I write to urge you to speak out for Yellowstone. Again. The Obama Administration recently reopened public comment on the proposed two-year interim rule to reduce the number of snowmobiles in Yellowstone National Park. The interim rule is the first action taken by the new administration following a decade of principled insistence by citizens like you that stewardship of Yellowstone should be on behalf of the broad public, not the special interest of the snowmobile industry. The proposed rule is also a direct result of legal action by Winter Wildlands Alliance and our coalition partners. It is a step in the right direction, but only a step. 
The temporary plan should go further in reducing snowmobile numbers and expedite the process of phasing out snowmobile use entirely in favor of snowcoaches, which offer a more environmentally-friendly way to access the park in winter. It is time for a clear path forward – one providing for the conservation of our nation’s first National Park. Your voice can help give the Obama Administration credit where it is due while urging the administration not to pull up short in reaffirming the high standards of conservation that Yellowstone embodies. Please, take a few minutes right now to urge the National Park Service to heed its own science and protect Yellowstone and Grand Teton National Parks.
Deadline for comments is September 8, 2009.
Background information, a sample letter, and additional points are provided below.
Over the past decade, the National Park Service has engaged in an extraordinary series of studies directed at the development of a sustainable winter use plan for Yellowstone National Park. After ten years and $10 million of analysis, the agency has only affirmed (and repeatedly reaffirmed) what has long been emphasized by the vast majority of those commenting on the National Park Service’s various winter use proposals: Yellowstone’s air, quiet, and wildlife would be best protected by a plan eliminating the noise and pollution of snowmobiles in favor of access by best-available-technology snowcoaches.
The National Park Service’s extensive monitoring efforts within Yellowstone have underscored these conclusions. In recent winter seasons, with snowmobile numbers averaging around 260 each day, the agency’s own noise thresholds have been consistently violated. At Yellowstone’s West Entrance, benzene and formaldehyde levels have approached and exceeded the thresholds used to assess health risks at hazardous waste sites. Finally, with respect to wildlife, the Park Service’s own biologists have recommended that reduced oversnow vehicle numbers of recent winters be maintained, if not reduced, in order to minimize animal disturbance and thereby avoid adverse fitness effects during Yellowstone’s harsh winter months.
This administration should undertake a prompt and complete transition to snowcoach access within Yellowstone National Park. The Park Service’s interim winter use plan should limit snowmobile use to the five-year average of 260 a day. Moreover, the interim plan should itself be limited to one year.
An electronic form you can use to submit comments on the rule is available at
http://www.regulations.gov/search/Regs/home.html#submitComment?R=09000064809fa1b8
Sample Comment Letter:
Superintendent Suzanne Lewis
P.O. Box 168
Yellowstone National Park, Wyoming 82190
Dear Superintendent Lewis:
As a Nordic skier [or snowshoer, winter hiker, etc.] who values the natural sights and sounds of Yellowstone in winter, I appreciate your first steps to curtail snowmobile use which has continued, even at reduced levels, to harm the park’s resources and values. But I urge the National Park Service to do better than the recommendations in the temporary plan. The temporary plan would allow snowmobile use at levels greater than those that have recently exceeded Yellowstone’s protective thresholds. It is time to begin phasing out snowmobile use.
All of the National Park Service’s studies of winter use alternatives in Yellowstone since 1998 have clearly demonstrated that continued snowmobile use causes a greater level of harm to park resources and that these adverse impacts to air, quiet and wildlife can be minimized with snowcoach access. Snowmobile use compromises visitor enjoyment of the parks' natural conditions. Each NPS study has concluded that Yellowstone would be significantly cleaner, quieter, less hectic, and healthier if snowmobile use is ended. In its independent review of each study, the EPA has verified this central conclusion.
It's time for the National Park Service to implement what its own studies have concluded: "that snowcoach access would provide public motorized access to Yellowstone while having the lowest impact on air quality, water quality, natural soundscapes and wildlife - while presenting the lowest risk of visitor and National Park Service staff health and safety."
Although the proposed plan is temporary, I urge you to change your recommendation and instead limit snowmobile numbers to the five-year average of 260 a day.
This is a wonderful opportunity to put Yellowstone on the right path to protection. I urge you to please implement the transition to snowcoaches—which studies have conclusively identified is the best way to balance public access with preserving these magnificent places for future visitors to enjoy.
Thank you.
Sincerely,
Additional Talking Points:
By providing for a transition to the form of winter access that provides the best available protection of Yellowstone, the Obama Administration can demonstrate its commitment to upholding both science and the highest conservation standards in our national parks.
These standards were forsaken by the Bush Administration. This breach prompted unprecedented alarm from elder statesmen of our national parks.
The National Park Service’s monitoring has determined that levels of snowmobile use well below 318 per day have resulted in impacts exceeding Yellowstone’s thresholds for protecting park resources and human health:
Demand for snowmobiling in Yellowstone has fallen sharply during the last six years. Even as the level of snowmobile use has decreased to as few as 200 snowmobiles per day, however, the National Park Service has documented these continuing problems:
• Noise attributable primarily to snowmobiles remains audible several hours each day, exceeding the Park’s protective thresholds;
• Benzene and formaldehyde have been measured in the Park’s air at levels exceeding health thresholds; and
• National Park Service 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.
By carrying out the National Park Service’s 2000 plan to phase out the use of snowmobiles within Yellowstone National Park, the Obama Administration would respect and respond to the unprecedented level of public concern expressed over this issue:
Since 1998, over 800,000 Americans have submitted comments to the National Park Service on the issue of winter use in Yellowstone. Over 80 percent have urged an end to snowmobile use. Much of the public comment has 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.
Studies have consistently affirmed that snowcoaches are the least impacting winter access alternative for Yellowstone
In every major study it has undertaken since 1998, the National Park Service has determined that the most effective means of protecting Yellowstone’s air quality, quiet and wildlife while providing visitors motorized oversnow access to the Park’s major attractions is to increase snowcoach access and phase out snowmobiling within the Park. The Environmental Protection Agency has independently verified the central conclusion in all of these studies: allowing continued snowmobile use, even with additional restrictions, would result in significantly greater impacts to the Park’s resources than would a system of snowcoach access. These studies have cost taxpayers over $10 million.
Many former Directors of the National Park Service have emphasized in numerous pleas to the Bush Administration that weakening protection of Yellowstone by authorizing continued snowmobile use within the Park “would be a radical departure from the Interior 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.” These 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.”
