Record of Decision; Winter Use Plans for the Yellowstone and
Grand Teton National Parks and John D. Rockefeller Jr., Memorial
Parkway
[Federal Register: December 22, 2000 (Volume 65, Number 247)]
[Notices]
[Page 80908-80956]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr22de00-115]
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DEPARTMENT OF THE INTERIOR
National Park Service
Record of Decision; Winter Use Plans for the Yellowstone and
Grand Teton National Parks and John D. Rockefeller Jr., Memorial
Parkway
Responsible Official:
Dated: November 22, 2000.
Karen Wade,
Intermountain Regional Director, National Park Service.
Record of Decision
Winter Use Plans for Yellowstone and Grand Teton National Parks and the
John D. Rockefeller Jr., Memorial Parkway
Table of Contents
The Decision
Decision
[[Page 80909]]
Actions and Assumptions Common to All Units
Actions Specific to Yellowstone National Park
Actions Specific to Grand Teton National Park and the Parkway
Definitions
Mitigation
Monitoring
Rationale for the Decision
Basis for the Decision
How Environmental Issues Were Considered and Addressed
Factors Other Than Environmental Consequences Considered in
Making the Decision
Findings
Measures Taken To Avoid Environmental Harm
Public Involvement
Scoping
Summary of Public Scoping Comment
Major Issues
Issues or Concerns Not Addressed in the Plans/EIS
Federal Register Notices
Distribution of the Draft Environmental Impact Statement
Public Meetings/Hearings
Comments on the Draft Environmental Impact Statement
Public Response to the FEIS
Consultation
Cooperating Agencies
American Indian Tribes
State Historic Preservation Offices
U.S. Fish and Wildlife Service
Alternatives Considered
Alternative Development
Scope of Analysis in the FEIS
Alternatives
Comparison of Alternatives
Environmentally Preferred Alternative Information Contact
Attachment A--Monitoring and Adaptive Management
Attachment B--Summary of Public Comments on the FEIS
Record of Decision
Winter Use Plans for Yellowstone and Grand Teton National Parks and the
John D. Rockefeller Jr., Memorial Parkway
The Decision
This decision made as a result of the Winter Use Plans Final
Environmental Impact Statement (FEIS) for Yellowstone (YNP) and Grand
Teton National Parks (GTNP) and the John D. Rockefeller Jr., Memorial
Parkway (the Parkway) will guide winter use management in the three
park units. The decision is to select a modified form of alternative G,
as described and evaluated in the FEIS, with the changes to that
alternative explained here. Elements of the decision are given in
detail below as actions and assumptions common to all 3 units, actions
specific to Yellowstone, actions specific to Grand Teton and the
Parkway, mitigation, and monitoring. The maps for alternative G and the
description of each management zone provided in the FEIS, while not
duplicated in this Record of Decision, are features of this decision.
In order to implement portions of this decision, the National Park
Service (NPS) will propose to amend its regulations at 36 CFR 7.13(l),
7.21(a), and 7.22(g). Although this decision is final for the purposes
of this planning project, those elements that will go through the rule
making process may be modified based on further public comments.
Decision
The selected alternative emphasizes cleaner, quieter access to the
parks using the technologies available today. Effective the winter of
2003-2004 and thereafter, it will allow oversnow motorized recreation
access via NPS-managed snowcoach only, with limited exceptions for
continued snowmobile access to other public and private lands adjacent
to or within GTNP. Until then, interim actions will progressively
reduce the impacts from snowmobile use in the parks.
This decision addresses the full range of issues regarding safety,
natural resource impacts, and visitor experience and access. It
addresses the issues in a way that will make it necessary for local
economies to adapt, and for snowmobile users to access the parks using
a different mode of transport.
Actions and Assumptions Common to All Units
Implementation
Unless otherwise noted, the parks will implement all
actions the winter following the Record of Decision (ROD) for the
winter use plans and EIS. Actions requiring a change in regulations
will be implemented once the new regulations are effective.
If it can be demonstrated sufficiently for NPS to
determine that an implemented action has affected or would
substantially affect a concession operation prior to the expiration of
its contract, the action will be implemented only through negotiation
or when a new contract is awarded.
NPS will develop a detailed snowcoach implementation plan
in coordination with gateway communities, concessioners and winter
permittees.
NPS will coordinate with gateway communities,
concessioners and winter permittees and state tourism program resources
on a new marketing strategy designed to facilitate winter visitation by
snowcoach.
Allow a planning and implementation period of 3 (three)
years.
In the winter of 2000-2001, snowmobile and snowplane use
will continue under current regulations. This is a departure from
alternative G. This change is made because the implementation of
changes in snowmobile and snowplane use that require new regulations
could not be made until the 2000-2001 season is nearly over. Waiting
until 2001-2002 to set new limits on snowmobile and snowplane use will
afford ample public notice of the new limits.
In the winter of 2000-2001, actions that do not require
regulations (such as increasing ranger patrols to reduce the
disturbance of wildlife) will be undertaken to reduce the impacts from
snowmobile use.
In the winters of 2001-2003, existing commercial snowcoach
operators will be encouraged to increase their fleet size, and
snowmobile and other new operators will be encouraged to purchase or
lease coaches and reduce snowmobile numbers.
In 2001-2002, daily limits will be set on snowmobile and
snowplane use so that daily use levels cannot increase above the
average peak day use levels of recent years, as shown in table 1,
below.
In 2002-2003, daily limits will be set to limit total
recreational snowmobile use to approximately 50% of the current average
annual use levels at the South and West Entrances of YNP. Current
snowmobile use levels will be maintained from the East and North
Entrances of YNP. See table 1, below.
In 2002-2003 for GTNP and the Parkway eliminate snowmobile
use on the Teton Park Road, all motorized use on Jackson Lake, and all
other recreational snowmobile use except for that on the CDST, Grassy
Lake Road, and access routes to adjacent public lands, with limits
shown in table 1, below.
In 2003-2004 and thereafter, all oversnow motorized
visitor travel in the parks will be by snowcoach, except for limited
routes in GTNP that will remain open for snowmobile access to adjacent
public or private lands and to private inholdings.
Regulation/Enforcement/Administration
Several actions include possible road closures depending
on the results of scientific studies. None of the actions preclude
other closures for safety,
[[Page 80910]]
resource protection, or other reasons as identified in 36 CFR 1.5 or
2.18.
At present no Environmental Protection Agency (EPA)
standards exist for off-road vehicles. If the EPA adopts standards or
measurement methods for vehicle emissions and sound applicable to
winter use in the parks, they will be implemented in accordance with
EPA regulations.
Require all new oversnow vehicles purchased by the parks
to conform to the best environmental standards available, and that
other vehicles are retrofitted whenever possible with new technologies
designed to lower sound and emission levels.
Increase the field presence of park rangers during the
interim period before full implementation of snowcoach access to
monitor, anticipate, detect and mitigate resource and wildlife impacts
and to increase visitor safety.
Resource Protection
Continue scientific studies and monitoring regarding
winter visitor use and park resources. Close selected areas of the
park, including sections of roads, to visitor use if scientific studies
indicate that human presence or activities have a detrimental effect on
wildlife or other park resources that could not otherwise be mitigated.
The appropriate level of environmental assessment under NEPA will be
completed for all actions as required by CEQ regulations (40 CFR parts
1500-1508).
Give a 1-year notice before any closure is implemented
unless immediate closure is deemed necessary to avoid impairment of
park resources or to protect public safety.
Sand, or an equally environmentally neutral substance,
will be used for traction on all plowed winter roads. Before spring
opening, sand removal operations will continue on all plowed park
roads.
Investigate and implement options to reduce the
palatability and accessibility to wildlife of the hydraulic fluid used
in snow groomers.
When snow depth warrants and at periodic intervals,
routine plowing or grooming operations will include laying back
roadside snowbanks that could be a barrier to wildlife exiting the road
corridor.
Visitor Use and Access
NPS will determine visitor use capacities based on studies
that set indicators and standards for desired visitor experiences and
resource conditions. The NPS will monitor indicators to maintain the
conditions for each management prescription. If necessary, techniques
such as reservations, permits, and differential fees will be
implemented. See zone descriptions, monitoring table, and Appendix H
(Recreation Carrying Capacity).
Continue to implement transition and action plans for
accessibility and support the philosophy of universal access in the
parks. The NPS will make reasonable efforts to ensure accessibility to
buildings, facilities, programs, and services. The NPS will develop
strategies to ensure that new and renovated facilities, programs and
services (including those provided by concessioners) are designed,
constructed, or offered in conformance with applicable policies, rules,
regulations, and standards (including but not limited to the
Architectural Barriers Act of 1968; the Americans with Disabilities Act
of 1990 (ADA): the Uniform Federal Accessibility Standards of 1984
(UFAS); and the Guidelines for Outdoor Developed Areas of 1999).
Architectural and Site Access and Programmatic Access: The
NPS will evaluate existing buildings and existing and new programs,
activities, and services (including telecommunications and media) to
determine current accessibility and usability by disabled winter
visitors. Action plans to remove barriers will be developed.
This decision includes an affirmative commitment to
implement strategies designed to provide a reasonable level of
affordable access to winter park visitors.
Backcountry nonmotorized use will continue to be allowed
throughout the parks except where designated otherwise for resource
protection purposes (shown as Zone 11 or area of designated trail use
on alternative map).
Other means of oversnow travel not foreseen in this Record
of Decision must be specifically approved by the park superintendent.
In the third year of the interim period (2002-2003),
snowmobiles in YNP must be accompanied by an NPS permitted guide and
travel in groups of no more than 11 (including the guide). The
superintendent will be authorized to also require groups and guides in
GTNP and the Parkway.
In 2003-2004 and thereafter, permit only NPS-managed mass
transit snowcoaches on designated oversnow roads, other than for
allowable administrative, emergency or other snowmobile access as
specified in other actions in this document.\1\
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\1\ Note: The term ``NPS managed'' refers to permit management.
In this case the mass transportation snowcoach system would be
provided by private concessioners who operate under a permit from
the NPS. Under the terms of the permit or concessions contract, the
NPS may stipulate, among other items, the type of services to be
offered, cost to the public, and number of visitors that may be
served or transported. The NPS may require that the types of
vehicles used meet certain environmental, accessibility and safety
requirements. It is the responsibility of the NPS to monitor all
services offered under permit to ensure that the public and the
parks are being well served. These permits are generally offered for
competitive bidding in limited numbers and are granted for a
specific number of years.
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Through the permitting process phase out all oversnow
vehicles that do not meet the best available environmental standards
for oversnow mass transit travel. Currently, the mass transit oversnow
vehicle that produces the lowest emissions is the conversion van mat
track.\2\ Any oversnow mass transit system in the parks must be low
emission, quiet, safe, affordable, accessible, and comply with the
requirements of EO 11644.
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\2\ Estimates of emissions for conventional vans converted for
oversnow travel indicate that the emissions increase once the
conversion is made. For this reason adherence to EPA regulations for
similar wheeled vans is neither appropriate nor required.
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Allow mass transit snowcoaches only when their sound
levels are at or below 75 decibels as measured on the A-weighted scale
at 50 feet at full throttle. Continue to work with snowcoach
manufacturers and operators to meet a long-term goal to lower snowcoach
sound levels to 70 decibels or lower.
Prohibit late night oversnow travel from about 11 p.m. to
6 a.m. in 2000-2001, and thereafter from about 9 p.m. to 8 a.m., unless
specifically authorized.
Implement an information program on snow and trail
conditions, points of interest, and available recreational
opportunities. Through partnerships, establish park visitor contact
opportunities in gateway communities and utilize state tourism program
resources.
Actions Specific to Yellowstone National Park
In Yellowstone, the NPS will continue to allow the plowing
of Highway 191 and will continue to plow the road from Mammoth to Tower
and Tower to the Northeast Entrance (Cooke City) throughout the winter.
Grand Canyon of the Yellowstone and the McMinn Bench
bighorn sheep area will continue to be closed to winter use.
Winter garbage storage facilities that are wildlife-proof
will be constructed in the Old Faithful, Grant, Lake, and Canyon areas.
[[Page 80911]]
Continue all existing groomed motorized routes (zone 3).
Offer snowcoach service on the East Entrance Road if safety goals can
be met. Management of avalanche danger on the East Entrance Road may
mean unscheduled closures of the road to all travel.
Provide nonmotorized opportunities (e.g., skiing and
snowshoeing) (zones 8 and 9). Examples of existing roads or trails that
will be groomed include Fountain Flats Road and portions of the East
Entrance road.
Where feasible, set parallel tracks on one or both sides
of the snow roads to facilitate nonmotorized access.
Increase interpretive opportunities related to the unique
aspects of the winter environment by providing interpretive programs at
destination areas and warming huts. Provide guided interpretive
programs for organized groups on snowcoaches. Provide interpretive ski
and snowshoe tours and programs such as near Tower, Canyon, Mammoth,
Old Faithful, West Thumb, Madison, and West Entrance.
Increase the size and number of warming huts and other day
use facilities. Place warming huts and restrooms at popular ski
trailheads (for example Tower), as support for motorized staging areas
(for example Norris), and where the existing facility size is currently
inadequate to handle to the dual function of warming hut and
interpretive program staging area (for example, Canyon).
Restrict nonmotorized uses in certain wildlife winter
ranges and thermal areas to travel on designated routes or trails
(zones 8 and 9).
Implement the winter use season during the period from
late November to mid-March.
Reduce administrative snowmobile \3\ use from the 106
currently used and supplement with administrative snowcoaches, subject
to available funding. When practicable, replace administrative
snowmobiles with a type that meets the best available emission and
sound limits.
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\3\ EO 11644, sections (3) and (4).
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Continue allowing personal non-recreation use of
snowmobiles by employees and their families living in the interior of
Yellowstone; however, subject to available funding, provide
administrative snowcoaches for their use and encourage them to replace
their current snowmobiles with cleaner and quieter machines.
Allow limited use of administrative snowmobiles by
concessioners. Require cleaner and quieter technologies as they are
developed (through permit and contracts) and encourage the use of
snowcoaches.
Actions Specific to Grand Teton National Park and the Parkway
In Grand Teton and the Parkway, the following roadways
will continue to be plowed:
Highway 26/89/187 from the south boundary of the park to
Moran
Highway 89/287 from Moran to Colter Bay
Highway 26/287 from Moran to the eastern park boundary
Teton Park Road from Moose Junction to Taggart Lake
Trailhead, and from Jackson Lake Junction to Signal Mountain Lodge;
from Highway 89/287 along the Pacific Creek road to the park boundary;
from Kelly to the eastern park boundary; from Gros Ventre Junction to
Kelly to Shadow Mountain staging area; and the road to the eastern park
boundary at Ditch Creek.
Current winter closures will remain in effect on the Snake
River floodplain, the Buffalo Fork River floodplain, the Uhl Hill area,
Willow Flats, Kelly Hill, and Static Peak.
Reasonable and direct access to adjacent public and
private lands, or to privately owned lands within the park with
permitted or historical motorized access, will continue via paved and
plowed routes or via oversnow routes from GTNP (used by
snowmobiles).\4\
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\4\ 16 U.S.C. 406d-1, et seq.
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Provide opportunities for oversnow motorized trail use
(zone 3) by snowcoaches only on the unplowed, groomed surface of the
highway from Colter Bay to Flagg Ranch, in the future upon the meeting
of certain conditions, and, effective 2003-2004 and thereafter, north
into Yellowstone, and on the Grassy Lake Road.\5\
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\5\ Termination of plowing from Colter Bay to Flagg Ranch is
contingent upon the winterization of facilities at Colter Bay and
expiration and reissuance of a concession contract associated with
Flagg Ranch. The present contract expires in 2009. See Actions and
Assumptions Common to All Units, second bullet under Implementation.
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Provide opportunities for nonmotorized ungroomed winter
trail use (zone 9):
On the Teton Park Road from Taggert Lake Trailhead to
Signal Mountain.
On Antelope Flats.
Near Colter Bay and Two Ocean Lake.
On the unplowed portion of the Moose-Wilson road.
Continue destination and support facilities at Moose,
Triangle X, Colter Bay, and Flagg Ranch, and add warming hut facilities
along the Teton Park Road to provide visitor services and interpretive
opportunities that focus on nonmotorized uses (zone 1).
Limit backcountry nonmotorized use to designated routes to
address wildlife issues in certain wildlife winter ranges, or close
certain areas to all use.
Winterize facilities at Colter Bay to provide a suitable
staging area for snowcoach access.\6\
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\6\ This provision is contingent upon the termination of plowing
from Colter Bay to Flagg Ranch.
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Effective 2002-2003, discontinue the motorized use of
Jackson Lake's frozen surface (no snowplanes or snowmobiles).
Increase interpretive opportunities related to the unique
aspects of the winter environment by providing interpretive programs at
destination areas and warming huts. Provide guided interpretive
programs for organized groups on snowcoaches. Provide interpretive ski
and snowshoe tours and programs at locations such as Moose, Colter Bay,
and Flagg Ranch visitor services.
Phase in administrative snowmobile types that meet the
best available emission and sound limits. Administrative use of
snowmobiles in Grand Teton is limited to law enforcement, utility and
maintenance access, permitted scientific studies, search and rescue or
other use as approved by the superintendent.\7\
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\7\ EO 11644, sections (3) and (4).
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Definitions
Oversnow motor vehicles: self-propelled vehicles intended
for travel on snow, driven by a track or tracks in contact with the
snow that may be steered by skis or tracks in contact with the snow.
This term includes both snowmobiles and snowcoaches.
Snowmobiles: self-propelled vehicles intended for travel
on snow, having a curb weight of not more than 1,000 pounds (450kg),
driven by a track or tracks in contact with the snow, which may be
steered by a ski or skis in contact with the snow.
Snowplanes: self-propelled vehicles intended for oversnow
travel, having a weight of not more than 1,000 pounds (450kg) mounted
on skis in contact with the snow, and driven by a pusher-propeller.
Snowcoaches: self-propelled, mass transit vehicles
intended for travel on snow, having a curb weight of over 1,000 pounds
(450kg), driven by a track or tracks and steered by skis or tracks,
having a capacity of at least 8 passengers.
The phrase gateway communities refers to the towns of
Jackson and Cody,
[[Page 80912]]
Wyoming, and Gardiner and West Yellowstone, Montana.
A designated route for nonmotorized recreation is defined
as a marked or otherwise indicated oversnow travel way.
Mitigation
Mitigation beyond the actions described in the decision is
necessary to reduce disclosed impacts to a level that meets legal
requirements, or that is otherwise acceptable within the framework of
regulations, executive orders or policies. The following measures are
necessary to further mitigate impacts of this decision during the
interim period before full implementation and thereafter.
Air Quality
Park concessions will be required to mitigate the impacts
of air pollution during the interim period by selling only bio-fuels
and synthetic lubes inside the park.
Water Resources
Best management practices will be used during the
construction, reconstruction, or winter plowing of trails and roads to
prevent unnecessary vegetation removal, erosion, and sedimentation.
Separate new or reconstructed winter-motorized trails from
drainages where practicable to mitigate the routing of snowpack
contaminants into surface water.
Any new or reconstructed winter use sanitary facilities
will be constructed in locations and with advanced technologies that
will protect water resources.
A focused monitoring program will reduce the uncertainty
of impacts from oversnow vehicles, and if necessary indicate best
management practices that might be implemented.
Wildlife, Including Federally Protected Species and Species of Special
Concern
NPS personnel will patrol sensitive resource locations to
ensure compliance with area closures.
NPS personnel will increase patrols of locations where
disturbance of wildlife by snowmobile use is most common, to reduce
that disturbance.
Monitoring of eagle populations to identify and protect
nests will continue. The park will continue to support the objectives
of the Greater Yellowstone Bald Eagle Management Plan.
Monitoring of wolf populations will continue.
Lynx surveys will be undertaken to document the
distribution and abundance of lynx in the parks and their relationship
to packed surfaces. The presence of other carnivores will be
documented. The parks will abide by the recommendations of the Lynx
Conservation Assessment Strategy.
Continue to assess grizzly bear abundance, distribution,
and habitat selection, including the location of dens. The information
obtained will assist park managers in protecting important habitats and
planning recreational activities that minimize disturbance to bears.
Monitoring grizzly bear populations will continue in accordance with
the Interagency Grizzly Bear Management Guidelines and the parks' bear
management plans.
Monitoring and protecting trumpeter swan habitats and
nests will continue, including the closure of nest sites, when
warranted, to public access from February 1 to September 15.
Monitoring potential or known winter use conflicts will
result in area closures if necessary to protect wildlife habitat.
Conduct snow track surveys for carnivores (including lynx)
on both groomed and ungroomed routes.
Continue to monitor use of groomed, ungroomed, and plowed
surfaces by bison and other ungulates.
Cultural Resources
Should the discovery of human remains, funerary objects,
sacred objects, or objects of cultural patrimony occur during
construction, provisions outlined in the Native American Graves
Protection and Repatriation Act of 1990 (25 USC 3001) will be followed.
Trails and trailheads will be sited to avoid adversely
impacting known cultural resources, including potential cultural
landscapes. In addition, the use of natural materials and colors for
all permanent signs erected will allow the signs to blend into their
surroundings.
Interim Snowmobile Use Limits
During the winter of 2000-2001 snowmobile use will continue to be
allowed under existing regulations. This deviates from the FEIS since
regulations on use limits will not be finalized until near the end of
that winter season or later. Making a change during that season would
not provide enough notice to visitors, many of whom would have already
made plans to visit the parks before any limits could be finalized.
During the winter of 2001-2002, snowmobile use will be
capped as follows:
Set daily snowmobile use numbers for all three park units
at levels not to exceed the 7-year peak daily average. The visitor
scenario developed for alternative A (see FEIS appendix G) shows
snowmobile use distribution at YNP gateways, and by road segments in
the three parks at both the current daily average and peak average
snowmobile use levels over the past seven years. The scenario provides
numbers that can be expressed as interim visitor use limits. Maximum
daily limits at the entrances will be set at the average peak day
snowmobile use (see Table 1 and footnote at the bottom of the following
page).
For snowplane use on Jackson Lake reissue permits to
permit holders of record and do not issue any new permits. Limit
snowmobile use on Jackson Lake to 30 per day.
If monitoring indicates a trend of significant increase
above average daily use as shown in Table 1, NPS will considering
adjusting the cap downward at other than traditional peak use periods
pursuant to, and as authorized under, 36 CFR 1.5 and 2.18.
In 2002-2003 set daily snowmobile entrance limits to
reduce total recreational snowmobile use to levels that will result in
approximately 50% of the current average annual use level at the South
and West Entrances of YNP. Current snowmobile use levels will be
maintained from the East and North Entrances of YNP.
In 2002-2003 for the Parkway, in addition to limiting use
between Flagg Ranch and the South Entrance to YNP, limit snowmobile use
on the Grassy Lake Road and the CDST in the Parkway to current use
levels.
In 2002-2003 for GTNP eliminate snowmobile use on the
Teton Park Road, all motorized use on Jackson Lake, and all other
recreational use by snowmobiles except for that on the CDST and access
routes to adjacent public lands. Limit snowmobile use on the CDST in
GTNP to current use levels.
In 2003-2004 and thereafter, all oversnow motorized
visitor travel in the parks will be by snowcoach except for limited
routes in GTNP that will remain open for snowmobile access.
[[Page 80913]]
Table 1.--Interim Caps on Snowmobiles in Yellowstone (YNP), Rockefeller Parkway (JDRMP) and Grand Teton (GTNP)
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Historic average 2001-2002 Peak 2002-2003 Daily
Road segments daily use day limits limits
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YNP North Entrance........................................ 41 60 60
YNP West Entrance......................................... 555 1030 278
YNP East Entrance......................................... 37 100 65
JDRMP Flagg Ranch to YNP South Entrance................... 176 330 90
JDRMP Grassy Lake Road.................................... 25 40 25
JDRMP Flagg Ranch to GTNP Moran Junction.................. 25 70 25
GTNP Jackson Lake......................................... 30 30 0
GTNP Teton Park Road...................................... 11 20 0
GTNP Moose-Wilson Road.................................... 3 10 0
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*Implementation of this limit is to ensure that use does not exceed
the historic averages for use on the busiest peak days and the level of
impact associated with it. Use fluctuates daily, increasing especially
during certain holiday periods. Use caps should act to allow such
fluctuations, since this is the nature of business and visitation. This
is why the peak use day represents a cap, to allow the business pattern
to continue. It is not the intent of this cap to allow peak use numbers
to occur every day. If this were to occur then levels would be exceeded
overall, and additional impacts would be incurred. It is the intent of
this cap to replicate the pattern and amount of use that has been
established over an average of seven years.
Monitoring
In order to assess the long-term effects of management actions on
park resources and values resource inventory, monitoring and adaptive
management are incorporated into this decision. The key resources and
values potentially impacted by winter recreation use in the three park
units are air quality, wildlife, sound,\8\ water resources, safety, and
visitor experience. Attachment A outlines specific indicators for
monitoring these resources and values. The indicators will be monitored
to ensure protection of natural resources and park values and evaluate
management success. The selected alternative also includes adaptive
management provisions. It provides for systematic feedback to park
management and allows for adjustment of activities to mitigate
unplanned or undesirable outcomes. Procedures, indicators, standards
and potential management actions for adaptive management are also
presented in Attachment A.
Monitoring programs will be coordinated among the parks. The
programs will function and be coordinated through the planning staffs
of the parks. The development of annual plans and reports will be
coordinated through the planning units, and the planning units will be
responsible for delivering those products. Actual monitoring
responsibilities for park personnel will be assigned through annual
plans.
Monitoring programs will be conducted on a sampling basis for the
purpose of effective use of funds and personnel. It is expected that
initial monitoring will be intensive, both in geographic and temporal
extent, so that correlations can be made and results can be
extrapolated. It is also expected that monitoring over time will become
less intensive and arrive at a low intensity, maintenance level.
Sampling schedules can vary from year to year, focusing on different
areas within the park units.
U.S. EPA expressed concerns about the actions that would be taken
if NPS does not have sufficient funds to monitor winter use in
accordance with the adaptive management part of this decision. Actions
affecting park values for which there are no defined standards, such as
odor, sound or visitor satisfaction, are subject to an adaptive
management approach. If continuing problems are indicated relative to
such impacts, but there are not sufficient funds for focused monitoring
and evaluation of those problems, emergency management actions will be
implemented to eliminate the impact pending the attainment of funds.
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\8\ NPS Director's Order #47 provides guidance for inventory and
monitoring procedures necessary to preserve the natural soundscape.
NPS-77 provides guidance for monitoring and inventory of other
natural resources elements.
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Rationale for the Decision
This section provides the reasons for selecting FEIS alternative G
as the decision and the basis for winter use plans in the three park
units. In arriving at this decision, I have considered the detailed
analysis of effects in the FEIS for a range of alternative plans that
would govern winter use. I have considered how each alternative
responds to the purpose and need for action, to improve existing
conditions in the parks and move them toward a desired condition that
is implicit in NPS mandates. In doing so, I considered the impacts for
each alternative program and weighed them against affirmative direction
for protecting park resources and values, and their enjoyment by future
generations, from adverse impacts or impairment. I also considered the
degree to which each alternative would enhance the condition of
resources or values and their enjoyment. Other considerations include
socioeconomic impacts, effects on lands adjacent to the three parks,
the plans or desires articulated by local communities and nonfederal
governments, and the full body of public comments on the draft EIS. All
these considerations are presented below as they contribute to the
decision.
The fundamental basis for the decision is the direction provided in
laws, regulations, executive orders and policies (mandates) that relate
to human uses of the parks and their effect on park resources and
values. This basis is overlain by the analysis of effects on park
resources and values disclosed in the FEIS. Then, conclusions or
findings are made about the alternatives and their effects in relation
to the key mandates regarding adverse impacts and impairment. Other
considerations are incorporated into the discussion.
Basis for the Decision
Law
The fundamental purpose of the national park system established by
the Organic Act and reaffirmed by the General Authorities Act, as
amended, begins with a mandate to conserve park resources and values.
This mandate is independent of the separate prohibition on impairment
and applies all the time, with respect to all park resources and
[[Page 80914]]
values, even when there is no risk that any park resources or values
may be impaired. NPS managers must always seek ways to avoid, or to
minimize to the greatest degree practicable, adverse impacts on park
resources and values. The laws give the NPS the discretion to allow
some impacts to park resources and values when appropriate and
necessary to fulfill the purposes of a park as long as that impact does
not constitute impairment.
The Organic Act mandate includes providing for the enjoyment of
park resources and values by the people of the United States. The
mandate applies not just to the people who visit the parks--but to all
the people--including those who derive inspiration and knowledge from
afar. NPS policies acknowledge that providing opportunities for public
enjoyment is a fundamental part of the NPS mission. While the policies
permit recreation and other activities, including NPS management
activities, they may be allowed only when they will not cause an
impairment or derogation of a park's resources, values or purposes.
Recognizing that the enjoyment of the national parks by future
generations can be assured only if the quality of park resources and
values is left unimpaired, Congress has provided that when there is a
conflict between conserving resources and values and providing for
enjoyment of them, conservation is to be the primary concern.\9\
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\9\ The Redwood Act of March 27, 1978 serves as the basis for
any judicial resolution of competing private and public values and
interests in the national park system, and affirms the primary
consideration of conserving, unimpaired, park resources and values.
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Regulation
Snowmobiling (specifically) may be allowed only where it is
consistent with the park's natural, cultural, scenic and aesthetic
values, safety considerations, park management objectives, and will not
disturb wildlife or damage park resources.\10\
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\10\ 36 CFR 2.18 Snowmobiles.
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Executive Orders
Areas and trails for off road vehicle use shall be located in areas
of the national park system only if the agency head determines that off
road vehicle use in such locations will not adversely effect their
natural, aesthetic or scenic values. Use will be controlled or directed
to protect the resources, promote safety, and minimize conflicts among
various users of those lands. Also, the agency head shall monitor the
effects of such use that may be authorized, and upon that information
they shall from time to time amend or rescind designations, or take
other actions to eliminate adverse impacts.\11\ If the agency
determines that the use of off-road vehicles (including snowmobiles)
will cause or is causing considerable adverse effects on the soil,
vegetation, wildlife, wildlife habitat, such areas shall immediately be
closed to that use.\12\
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\11\ EO 11644, Use of Off-Road Vehicles on Public Lands, Federal
Register, Vol 37, page 2877, No. 27-Wed. February 9, 1972.
\12\ EO 11989, Off Road Vehicles on Public Lands, Federal
Register, Vol 42, page 26959 No: 101-Wed. May 25, 1977.
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Interpretation of Policy
Impairment is an impact that, in the professional judgment of the
responsible NPS manager, would harm the integrity of park resources or
values, including the opportunities that otherwise would be present for
the enjoyment of those resources or values. Impairment may occur from
visitor use or park management activities.\13\
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\13\ Directors Order #55, September 8, 2000, as amended November
17, 2000.
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NPS Director's Order # 55 define the terms ``resources and values''
as the park's scenery, natural and historic objects, and wildlife,
including, to the extent present in the park: The ecological,
biological and physical processes that created the park and that
continue to act upon it; scenic features; natural visibility (both in
daytime and at night); natural landscapes; natural soundscapes \14\ and
smells; water and air resources; soil; geological resources;
paleontological resources; archeological resources; cultural
landscapes; ethnographic resources; historic and prehistoric sites,
structures, and objects; museum collections; and native plants and
animals. The park's resources and values also include the opportunity
for enjoyment of these resources, to the extent that can be done
without impairing them. The term also includes the park's role in
contributing to the national dignity, the high public value and
integrity, and the superlative environmental quality of the national
park system, and the benefit and inspiration provided to the American
people by the national park and any additional specific purposes for
which a park was established. An impact is more likely to constitute an
impairment to the extent that it affects a resource or value whose
conservation is:
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\14\ NPS Director's Order #47 articulates operational policies
requiring the protection, maintenance or restoration of the natural
soundscape resource in a condition unimpaired by inappropriate noise
sources. Inappropriate noise is that generated by activities at a
level described as excessive, which impacts the park's natural
soundscapes and jeopardizes the natural resources or the purposes
for which the park was created.
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Necessary to fulfill specific purposes identified in the
establishing legislation;
Key to the cultural or natural integrity of the park or
opportunities to enjoy the park; or
Identified as a goal in relevant NPS planning documents.
The 1988 NPS Management Policies state that the National Park
Service will seek to perpetuate the best possible air quality in parks
because clean air is critical to visitor enjoyment, human health,
scenic vistas, and the preservation of natural systems and cultural
resources. The policies also recognize that many natural resources,
including water and wildlife, are sensitive to air pollution.
Additionally, NPS must err on the side of protecting air quality and
related values if there is doubt as to the impacts on park resources of
existing or potential air pollution.\15\ NPS also has recognized that
it must preserve the natural quiet and the natural sounds associated
with the physical and biological resources of the parks. Managers must
monitor sounds and take actions to prevent or minimize unnatural sounds
that adversely affect park resources or values and visitors' enjoyment
of them.
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\15\ 1988 NPS Management Policies, Chapter 4
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The 1988 NPS management policies \16\ also recognize that the NPS
Organic Act directs the agency to provide for the public enjoyment of
parks while leaving resources unimpaired for future generations. The
policies mandate that the use of parks will be resource-based and
nonconsumptive of resources. To the extent practicable, the NPS will
encourage people to come to the parks and to pursue inspirational,
educational, and recreational activities related to the resources found
in the parks. NPS must manage visitor use and, as necessary, regulate
the amount and kind, and the time and place, of visitor activities.
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\16\ 1988 NPS Management Policies, Chapter 8
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NPS must encourage recreational activities that are consistent with
applicable legislation, that promote visitor enjoyment of park
resources through a direct association or relation to those resources
so long as those uses are consistent with the protection of the
resources and are compatible with other visitor uses. NPS must manage
recreational use to protect park resources, provide for public
enjoyment, promote public safety, and minimize conflicts with other
visitor activities and park uses. Finally, unless the activity is
required by statute, NPS will not allow
[[Page 80915]]
a recreational activity in a park if it would involve or result in:
Inconsistency with the park's enabling legislation or
proclamation, or derogation of the values or purposes for which the
park was established
Unacceptable impacts on visitor enjoyment due to
interference or conflict with other visitor use activities
Consumptive use of park resources
Unacceptable impacts on park resources or natural
processes
Unacceptable levels of danger to the welfare or safety of
the public, including participants
Public use of a park is an important reason for the creating and
sustaining the national park system. In developing the winter use plan
and environmental impact statement, the goal of the parks was to
provide for a winter use experience to a wide range of people, not just
to the most physically fit. Given the mandate of the Organic Act, to
preserve and provide for public enjoyment, some level of adverse impact
from visitor use during the winter is acceptable, if the parks mitigate
the impacts to the greatest extent practicable. Should future
monitoring disclose that the impacts are too much for the resources to
sustain, it will be appropriate to further restrict winter visitor use
in the parks.
How Environmental Issues Were Considered and Addressed
Considering present winter use activities, the key management
concerns and objectives relating to park resources and values are: Air
quality, wildlife (especially ungulates), natural soundscapes, and
opportunities for visitor experience (of these resources and values,
including scenic quality and aesthetics). Related concerns that are key
elements in the desired condition are the safety of employees and
visitors, and access for purposes of park enjoyment. Finally, there is
an issue regarding how local, private commercial industries have
developed to serve visitors and facilitate their enjoyment of the
parks.
Natural Resources
The analysis of natural resource/environmental consequences for a
range of alternatives shows clearly that there are overall adverse
impacts associated with snowmobile use in the parks, even when some
areas are closed to that use. Snowmobile use at current levels
adversely affects wildlife, air quality, and natural soundscapes and
natural odors. Further, it adversely impacts the enjoyment of those
values and resources by other visitors. The impact on people who may
visit the three parks once or twice in a lifetime, and who seek the
resources and values for which the parks were created, may be adversely
and irretrievably affected.
Elimination of these impacts is most easily and effectively
accomplished by eliminating snowmobile use. Holding use at current
levels under all alternatives but G would allow documented adverse
impacts of snowmobiles to continue. The level of adverse impact varies
by resource or value, and by alternative, but it is demonstrated to be
more than negligible and often moderate when considered cumulatively
over the three park units. Locally, the impact can be major. The effect
on resources and values is demonstrated to impact the enjoyment of
those resources by other visitors. Mitigation of the impacts of
snowmobiles, as proposed in the different alternatives, is insufficient
to reduce the impacts to a level deemed acceptable within the
constraints of the law, regulations, executive orders and policies
presented as the basis for this decision. Reduction of numbers of
snowmobiles is problematic because carrying capacity studies are left
to the future, and adverse impacts would continue until capacities are
determined and effectively implemented.
Other winter uses and means of access also produce impacts. Cross
country skiing and other nonmotorized forms of recreation are shown to
impact wildlife. Since there are areas that can be identified as
critical to bison and other ungulates, mitigation as proposed in some
alternatives effectively reduces or eliminates the impairment.
Snowplane use, though limited to Jackson Lake, has a dominant and
unmitigated impact on the natural soundscape.
The use of snowcoaches on groomed roads is demonstrated to impact
wildlife, air quality, and natural soundscapes. However, mass transit
snowcoach use effectively mitigates the closure of parks to snowmobiles
and results in much less traffic while allowing winter access for
current levels of visitation. Snowcoaches would impact resources or
values, or the enjoyment of them (at the current level of visitation)
at least a magnitude lower than with snowmobile access. Adverse impacts
of an NPS managed snowcoach system on wildlife, as in alternative G,
would occur at low and mitigable levels.
Factors Other Than Environmental Consequences Considered in Making the
Decision
Safety and Access
Safety issues are related to access issues. Modes of access and
volumes of traffic are primary factors. Presently unsafe conditions can
be improved, as proposed in several alternatives, by separating
different uses and modes of transport, by eliminating wheeled vehicle
use in places, and by eliminating large volumes of oversnow motorized
use especially where ungulates use groomed surfaces. Safety would be
most improved where a number of these measures are combined, as in
alternatives F and G. All alternatives hypothesize impacts on the basis
of motorized oversnow access at current use levels. However, there are
different mixes of snowcoach, snowplane, and snowmobile use,
distributed differently through the range of alternatives. In some
areas, snowmobiles operate on groomed trails in the same locale as
nonomotorized visitors, wheeled vehicles and large ungulates.
Therefore, there is a risk that continued snowmobile use would result
in accidents and is unsafe. In some places, the volume of wheeled
vehicle traffic during the winter--much of which is associated with
snowmobile staging--results in a higher rate of accidents. This
represents a situation that must be remedied. The selected alternative
eliminates the source of most safety concerns, snowmobile use, as well
as wheeled vehicle use on a plowed road that currently has a high
winter accident rate (Highway 89/287 from Colter Bay to Flagg Ranch).
Discontinued plowing of the route from Colter Bay to Flagg Ranch would
also convert Flagg Ranch to an oversnow destination. This would provide
a new opportunity of that nature, similar to that available at Old
Faithful in Yellowstone's interior. Opportunities for developing winter
recreation around Flagg Ranch are abundant. There is a perception that
not plowing the road would make a snowcoach trip from Colter Bay to Old
Faithful too long. Flagg Ranch, as a destination, allows people the
opportunity to break this trip up if they are unwilling or unable to
make the trip to Old Faithful in one day.
Economic Impacts on Local Communities
The impacts of any alternative on economies beyond the gateway
communities are generally negligible. Gateway communities are affected
in different alternatives by entrance closure or area closure (D and
F), or
[[Page 80916]]
closure to snowmobiles and change in allowable modes of motorized
access (B, C and G). Economically, West Yellowstone is most affected
through the range of alternatives because that community is most
directly tied to access via snowmobile. Not coincidentally, the West
Entrance to Old Faithful is the most adversely impacted oversnow route
in the three-unit area.
Consistency With Land Use Plans, Policies or Controls for Adjacent
Lands
Impacts on adjacent lands for all alternatives are described on
pages 434-474 in the FEIS. There are concerns about how any reduction
in snowmobile use within the three parks would translate into increased
use on national forest lands in particular. The Forest Service, a
cooperating agency, indicates that alternative G could result in
conditions that would necessitate amendments to forest plans because
snowmobile use on those lands is at the highest tolerance level
permissible. My determination is that use on national forests is likely
not to increase.\17\ Further, the forests have provided no convincing
evidence or monitoring data to support their concerns, or to support
that the need to revisit their forest plans does not already exist. I
consider that the period of three years being allowed for a transition
to snowcoaches only in the parks will facilitate the monitoring of
recreational snowmobile use on public lands (national forests) in the
Greater Yellowstone Area. I agree that such monitoring is necessary to
develop a baseline for gauging the impacts of future winter management
changes on public lands, and resources therein. Therefore, this is part
of the rationale for allowing a three-year phase in period.
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\17\ I believe the analysis indicating that decreased use in the
parks would result in decreased use generally in the Greater
Yellowstone Area, thereby reducing use on forests not increasing it,
is sound.
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Potentially affected States and counties were involved as
cooperating agencies in the preparation of this EIS (see pages 16-18 in
the FEIS). Through the process, these entities identified no issues
concerning conflicts with any land use plans, policies or controls that
may exist. Any such impacts are inferred in the analysis (FEIS pages
434-435). Concerns expressed by the cooperators are twofold. On the one
hand, they are concerned about increased use on adjacent lands
resulting from the parks' decision, and how it would affect other
public lands, wildlife habitat, and currently groomed snowmobile trail
systems. On the other hand, they are concerned that the decision would
devastate local economies by drastically reducing snowmobile use and
visitation to the area. These positions are in conflict. My assessment
is: first, that snowmobile use is likely to decrease, or at least not
increase, on adjacent lands; and second, that snowcoach access to the
parks will invigorate local entrepreneurs in marketing a special
(albeit different) park experience. As explained elsewhere, the effect
of alternative G on local economies is expected to be of short-term
duration--mitigated by provisions for implementation over time and
allowing communities and businesses to adapt.
Public Comments on the Draft EIS
Comments on the draft EIS are discussed explicitly in the public
participation section of this record of decision. The vast majority of
the comments did not substantively address the merits of the EIS
analysis. Many comments assisted NPS in clarifying or otherwise
improving the disclosure of impacts in the FEIS (as documented in FEIS
Volume III). Most comments (94%) expressed some preference for winter
use management that resembled some alternative evaluated in the draft
EIS. I wish to make clear that, although it is not the primary
rationale for this decision, the public expression of preference is
certainly a factor that I considered. The public's preference in the
large body of comment was evenly divided between those who clearly
wished for continued snowmobile use and those who felt that snowmobiles
should not be allowed in the parks. Four percent of those who commented
indicated there should be no motorized use or grooming of winter routes
in the parks. The overwhelming negative reaction to the preferred
alternative B in the draft EIS, which would have plowed the road from
West Yellowstone to Old Faithful, was a factor in considering a new
preferred alternative for the final EIS.
Findings
Park Values and Resources
The use of snowmobiles and snowplanes at present levels harms the
integrity of the resources and values of these three parks, and so
constitutes an impairment of the resources and values, which is not
permissible under the NPS Organic Act. In YNP, the impairment is the
result of the impacts from snowmobile use on air quality, wildlife, the
natural soundscape, and opportunities for enjoyment of the park by
visitors. In GTNP, the impairment is the result of the impacts from
snowmobile and snowplane use on the natural soundscape and
opportunities for enjoyment of the park by visitors. In the Parkway,
the impairment is the result of impacts form snowmobile use on air
quality, the natural soundscape, and opportunities for enjoyment of the
park.
Under the NPS Organic Act, the NPS may not allow the impairment of
park resources and values, and when there is an impairment, the NPS
must eliminate it. The combination of actions provided for in this
Record of Decision will eliminate the impairment in GTNP following the
winter of 2001-2002, and in YNP and the Parkway following the winter of
2002.
We have also determined that the snowmobile use now occurring is
inconsistent with the requirements of the Clean Air Act (in the case of
YNP and the Parkway), Executive Orders 11644 and 11989, the NPS's
general snowmobile regulations, and NPS management objectives for the
parks. We have determined that the snowplane use occurring in GTNP is
inconsistent with Executive Orders 11644 and 11989 and NPS management
objectives for the parks.
We have determined that the snowcoach use that will occur in YNP
and the Parkway under this decision, and the snowmobile use that will
continue in GTNP in the winter of 2002-2003 and thereafter is
consistent with the requirements of Executive Orders 11644 and 11989
and the NPS's general snowmobile regulations.
There is no current means of mitigation, aside from a reduction of
numbers unsupported by a carrying capacity analysis, that assures
recreation snowmobile use impacts could be reduced, predictably and
soon, to a level that does not impair and adversely impact these
resources and values.
Snowmobile use for official administrative or emergency purposes in
the three park units is specifically allowed under the regulations and
executive orders cited herein as the basis for the decision. Incidental
amounts of snowmobile use in GTNP for purposes of winter access to
inheld private lands or to adjacent public lands as provided under the
establishment legislation for the park.\18\ These are not recreation
uses, per se, that are the subject of analysis in the FEIS.
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\18\ EO 11644, sections (3) and (4), and 16 USC 406d-1, et seq.
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Clean, quiet and odorless snowmobiles are not available at present.
Even with technical advances in snowmobiles, the impacts of snowmobile
use on wildlife, especially ungulates using groomed routes,
[[Page 80917]]
constitutes disturbance and harassment at a time when individual
animals are particularly challenged for survival. The continued use of
snowmobiles as provided in the alternatives studied other than
alternative G is found to be inconsistent with the health and integrity
of resources existing in the three park units. Continued use hinders
the enjoyment of resources and values for which the parks were created,
most notably natural soundscapes, clean and clear air, and undisturbed
wildlife in a natural setting.
The social and economic impacts of the elimination of most
snowmobile use in the parks can be mitigated to a high degree by
providing oversnow access using mass transit snowcoaches. Considering
the analysis of alternatives, there is a clear magnitude of difference
between the impacts of snowmobiles and the impacts of snowcoaches on
natural resource values and the opportunities to enjoy them. This
rationale supports the selection of alternative G.
The use of groomed routes by snowcoaches adversely affects
wildlife, air quality, natural soundscapes, and the opportunity to
enjoy those values, as disclosed in the FEIS, although the adverse
effects are negligible to minor. These impacts are found not to impair
those values and opportunities. This is due to the overall decrease in
impacts to a level described as negligible--with greatly decreased
volumes of traffic and consequent decreases in odor, noise, and
pollutants. The area within the three park units that would be
available for use without audible motorized sound would be maximized
using snowcoach access. An NPS managed mass transit snowcoach system
would assertively implement available technologies for further reducing
the amount of sound and pollution created. It would assertively
implement schedules and strategies and controls for minimizing impacts
on wildlife due to use of groomed surfaces. Additionally, because
operators of snowcoaches will be familiar with park roadways and
trained in appropriate techniques for mitigating the effects of
vehicle-wildlife encounters the potential for wildlife harassment will
be minimized.
Skiing and other nonmotorized uses adversely affect wildlife,
particularly bison, elk, moose, and bighorn sheep. Backcountry use, in
particular, stresses these ungulates at a time when their energy
reserves are low. In areas adjacent to high use nonmotorized routes
animals may adapt to regular passage by humans using a predictable
route. Nonmotorized trail use therefore has fewer adverse impacts than
does unrestricted backcountry use. Therefore by limiting nonmotorized
use in certain winter habitats to designated routes, adverse impacts of
nonmotorized use are suitably reduced. Where the impacts of
nonmotorized travel on wildlife cannot be suitably mitigated through
route restrictions critical winter range will be closed. With this
mitigation, limited nonmotorized use is found to be consistent with
park resources and values, and it facilitates their enjoyment. FEIS
alternative G closes certain important winter wildlife habitat to
nonmotorized use, and limits use in other areas to designated trails
and routes only.
Safety and Access
The analysis shows that impacts on safety of visitors and employees
are associated with snowmobile use. It is found that current use by
snowmobiles represents a risk to health and safety. This risk is
mitigated to the highest degree in alternative G. Risks associated with
NPS managed snowcoach systems are negligible, since there would be
greater controls over speed, time of operation, driver training and
experience, and the volume of traffic on the route. In addition, this
system offers access to the public that is equivalent in numbers to
current use. In doing so, the parks would be accessible to a larger
population of young, elderly, and disabled visitors.
Economic Impacts on Local Communities
It has been found that snowmobile use as currently constituted, and
as evaluated in the range of alternatives, adversely impacts and
impairs park resources and values. Therefore, the use must be
discontinued in order to meet the primary mandates, regulations and
policies of the national park service. This has clear economic impacts
on all the local, gateway communities, permittees and concessions that
are highly dependent upon winter snowmobile use in the parks. However,
the greatest impact on these communities would be closing the parks to
winter motorized access entirely. Alternative G offers an opportunity
for the same level of access that currently exists, while improving
opportunities for people who cannot or choose not to ride snowmobiles.
It is found that the cessation in the future of plowing a portion of
the southern route into YNP, in addition to improving safety, would
create additional opportunities for people to enjoy a destination
winter area (Flagg Ranch) using oversnow transport.
Due to economic impacts (as disclosed in the FEIS), measures are
incorporated into the implementation features of alternative G to allow
communities, permittees and concessioners time to adapt. Considering
the economic impacts, three years are to be allowed for conversion to
an NPS managed snowcoach system, and existing concession contracts will
be honored until they expire. During the first year, snowmobile use
will be continue under existing regulations. During the second year of
implementation, snowmobile use will be subject to daily limits based on
historic peak day use, to avoid the occurrence of days with even higher
use than in the past. Then, one more year of snowmobile use, at
approximately 50% of current levels, will be allowed. This affords
snowmobile operators three years to take advantage of existing
technology for snowcoaches, to realize the investment they presently
have in snowmobiles, and to market new opportunities. NPS will produce
an implementation plan as soon as possible to develop the details of
snowcoach transport in the parks. This plan will be developed in
coordination with gateway communities, concessioners and permittees in
order to insure successful implementation of the alternative. NPS will
also work with these entities to develop and implement a new marketing
strategy for winter recreation in the parks.
Additional measures will be used to reduce impacts to the degree
possible during the interim period. This mitigation includes, but is
not limited to, the following measures (see also the actions and
mitigation sections of the decision, above).
During the interim period, snowmobile and snowplane use will be
monitored and managed in a manner that prevents or mitigates local
impacts to the greatest extent practicable;
Ranger patrols will be increased to facilitate monitoring as well
as detection and on-the-spot handling of impacts particularly for
wildlife disturbance.
Park concessions will be required to mitigate impacts on air
quality by selling only bio-fuels and synthetic lubes inside the park;
Snowmobile tour guides shall receive additional training in
appropriate methods of avoiding wildlife disturbance, and park
personnel will assertively provide similar information to all other
users. Prohibit late night oversnow travel.
In the third year of the phase-in period, all recreation snowmobile
users in YNP must be accompanied by a permitted guide and travel in
groups of
[[Page 80918]]
no more than 11 (including the guide). The superintendent will be
authorized to also require groups and guides in GTNP and the Parkway.
A phase-in period of three years is necessary to allow the creation
and implementation of a functional mass transit system using
snowcoaches.
Measures Taken To Avoid Environmental Harm
The focus of the EIS analysis is to improve environmental
conditions relative to those which exist due to current use and
management. Alternative G best improves environmental conditions, as
demonstrated in the FEIS and this decision rationale. Therefore, the
features of selected alternative G and the mitigation that applies with
this decision are construed as measures taken to avoid environmental
harm. If future monitoring, as provided in this decision, indicates
that impacts are too great to sustain additional use, or that
impairment occurs, it will be appropriate to implement further
management changes. Monitoring plans will describe standards or
thresholds of impact, and management actions that will be taken if
standards are not met. See the monitoring section of the decision,
above.
Public Involvement
Scoping
The NPS accepted public scoping comments from April 14 to July 18,
1998. Scoping brochures were mailed to about 6,000 interested parties,
and 12 public meetings were held throughout the GYA and in Idaho,
Montana, and Wyoming. In addition to local area and regional meetings,
the NPS held four national meetings in Salt Lake City, Denver,
Minneapolis, and Washington D.C. About 2,000 comment letters were
received (about 1,200 of these were form letters), from which about
15,000 discrete comments were obtained. Scoping respondents included
businesses; private and nonprofit organizations; local, state and
federal agencies; and the public at large. Comments were received from
46 states and several foreign countries.
Summary of Public Scoping Comment
Comments received during scoping cover a full range of topics
including issues, concerns, analysis questions, procedural questions,
general opinions, and requests. Comments were sorted into the
categories shown in Table 2, pages 22-24 in the FEIS .
The NPS addressed all comments received in one of two ways: (1)
Either they were analyzed in detail through the development of an
alternative or as a possible impact of winter use; or (2) they were not
analyzed further based on the rationale presented in FEIS Volume II,
Appendix A. The NPS classified comments as major issues or concerns to
be analyzed in detail based on relevance to the decision to be made.
The following section, Major Issues, describes in greater detail those
comment categories considered relevant. Issues or Concerns Not
Addressed in the Plans/EIS describes specific types of comments not
carried forward for in-depth analysis, and the rationale for their
dismissal.
Major Issues
This section summarizes the major issues that relate to the purpose
and need for action for the future of winter use in the three NPS
units. These issues parallel the existing conditions identified in the
FEIS in the purpose and need for action. While common concerns exist
among the issues, they are categorized for purposes of analysis and
alternative formulation. Because the decision regarding the future of
winter use in the GYA is largely programmatic, relevant issues are
those that bear on: (1) Winter programs that might be necessary to
address existing circumstances and achieve desired conditions; and (2)
the effects of those programs. An issue is defined as a point of
contention about the specific possible environmental effect of a
specific management action or program. Generally, comments on the DEIS
about the details of implementing a program are not considered major
issues. Implementation details will be important during future site-
specific analyses under the new plan.
Another opportunity for public involvement is the ability to
comment on the DEIS. No new major issues were identified as a result of
public comments on the DEIS. FEIS Volume III contains the analysis of
public comments on the DEIS, and responses to the comments. Major
issues are described below.
Visitor Use and Access
Various user groups contend that the national parks offer either
too much or not enough of various types of use. Some people are
concerned that the parks do not offer an adequate range of winter
experiences and will not be able to respond to future winter recreation
demand. Others suggested that winter experiences should include
dogsledding, off-road motorized play areas, and increases in both
groomed motorized and nonmotorized trails. Other people voiced concerns
about too much winter use, suggesting that YNP should be closed in part
or altogether, for the winter season. Because of the amount of use
relative to the available facilities, both ski and snowmobile use
sometimes occurs on the same groomed surface. This adds to the
perception of too much use, and leads to other issues relating to
visitor experience and safety. Many people contend that motorized use
has greatly affected opportunities for nonmotorized use in the
surrounding GYA, displacing cross-country skiing and other nonmotorized
recreation to the parks. Another aspect of the issue relates to the
affordability of winter access, and access for disabled, and old and
young visitors. Some argue for increased availability of motorized
access (via snowmobile in particular) to serve these access needs.
Another issue is the high cost of winter access to the parks.
Visitor Experience
Expectations for quality winter recreation experiences are
different for different user groups. This raises contention between
groups for which quiet, solitude, and clean air needs conflict with the
impacts of snowmobiles, especially when facilities for these different
groups are in close proximity to each other. Nonmotorized users are
easily affected or displaced by the sight, sound, and odor of
snowmobiles. While skiing generally does not affect the quality of the
snowmobiling experience, there are safety issues associated with slower
traffic on groomed surfaces used by higher speed vehicles. In addition
the quality of the visitor experience can be affected by the number of
available support facilities (such as parking lots or rest rooms), the
extent to which facilities are crowded, and the availability of
information.
Human Health and Safety
Four primary health and safety issues were identified regarding
winter visitor use:
The effect of motorized vehicular emissions and noise on
employees who are required to travel or work in areas with high traffic
levels. Visitors may be subjected to some of the same impacts.
Speed limits and the frequency of motor vehicle accidents
and fatalities, and the number of nighttime collisions involving
wildlife that often result in severe injury or fatality to both animals
and people.
Avalanche hazards.
Safety risks where different modes of winter transport are
co-located or in close proximity, like the CDST where
[[Page 80919]]
wheeled-vehicles and snowmobiles share the highway right-of-way.
Social and Economic Issues
Many comments reflected the effect of changes in parks management
actions on local communities. Local businesses provide services to
visitors near both parks, and many local economies rely, in part, on
revenues from parks visitors in the winter. Concern was voiced that
eliminating oversnow travel and snowmobiles in particular or closing an
entrance to a park during the winter could have a detrimental effect on
local economies. Other commenters stated that concern for parks'
resources should be elevated above economics.
Natural Resources
Impacts of winter use on natural resources revolve around three
major issues.
The impact of groomed surfaces and their use on wildlife:
Over the last several years, bison have been removed from the
population because they have migrated from YNP to state and private
lands during the winter. Some people commented on the effect that
backcountry skiing might have on wildlife, particularly the
displacement of large ungulates from important winter range.
Air quality: The effect of snowmobile emissions on air
quality was identified as a concern with respect to health, natural
resources, and aesthetic and wilderness values. For example, on high
snowmobile use days in YNP, the visual evidence and odor of snowmobile
exhaust is apparent in some areas. The effect of hydrocarbons, carbon
monoxide, and particulate matter emitted by snowmobiles on water
quality was also a concern.
Oversnow vehicle sound: The sound levels of snowmobiles
and snowcoaches were raised as issues with regard to aesthetics and
wilderness values. For example, on some days it is difficult for most
visitors to travel to an area in YNP where snowmachines cannot be
heard. For this reason some people question whether the use of
snowmobiles and snowcoaches is appropriate in the national parks. Other
people state that the sound of snowmachines has no impact on their
ability to enjoy the parks.
Issues or Concerns Not Addressed in the Plans/EIS
Scoping issues and concerns that were not addressed in the EIS are
listed below. The rationale for their dismissal may be found in the
FEIS on pages 26-28. Essentially the reason for dismissal is that the
issue is being dealt with in another analysis, is beyond the scope of
the purpose and need for action, or is a matter that is governed by
procedural laws (like the National Environmental Policy Act--NEPA).
Privatization
Summer/Winter Use Comparisons
Wildlife Carrying Capacities
Land Use
Economic Effects: Costs
EIS Process
Cooperating Agencies
NEPA and NPS Policy
Scientific Methods and Data
Federal Register Notices
A notice of intent to prepare an EIS was published in the Federal
Register on April 15, 1998, officially beginning the scoping process. A
notice of availability for the Winter Use Plan and Draft Environmental
Impact Statement (EIS) for Yellowstone and Grand Teton National Parks
and the John D. Rockefeller Jr., Memorial Parkway appeared in the
Federal Register, August 15, 1999. The notice indicated that the public
comment due date was November 15. The comment period was extended
twice, once to December 1, 1999, and again to December 15, 1999.
Notices of these deadline extensions were published in the Federal
Register. The notice of availability for the FEIS was published on
October 20, 2000.
Distribution of the Draft Environmental Impact Statement
In August 1999, postcards were mailed to 6000 persons notifying
them of the impending release of the DEIS. Approximately 4,000 draft
documents and summaries were mailed to interested parties during
September 1999. In addition, documents were mailed to agencies,
businesses, organizations, and public officials who had either
requested the document or were generally interested in the management
of winter use in the parks.
Public Meetings/Hearings
Sixteen public meetings using an open house format were held early
in the scoping period ranging from April through July of 1998. Meetings
were held in each of the five gateway communities to the three park
units. Other meetings were held within the region at Dubois and Casper,
Wyoming, Billings and Bozeman, Montana, and Boise, Ashton and
Pocatello, Idaho. Meetings outside the region were held at Denver,
Colorado, Minneapolis, Minnesota, Salt Lake City, Utah, and Washington,
D.C. Public hearings to solicit public comment on the DEIS were held
during the month of October 1999 in the following cities: Idaho Falls,
Idaho; West Yellowstone and Livingston, Montana; Cody and Jackson,
Wyoming; and Denver, Colorado. The proceedings of each hearing were
transcribed and entered into the record. An average of 45 persons spoke
at each hearing.
Comments on the Draft Environmental Impact Statement
Over 48,600 pieces of correspondence were received in response to
the DEIS. Correspondence consisted of individual letters, form letters,
e-mails, telephone calls, and hearing presentations. This body of
comment is summarized, categorized, indexed and responded to in Volume
III (parts one, two, and three) of the FEIS. Part one includes the
summary, individual letters and specific responses to the contents of
the letters. Part two includes the variety of form letters received
(separate letters having the same content) and specific responses to
their content. Part three contains the results of compiling all
comments from all sources, categorizing and summarizing them, and then
providing a response to each. This approach was considered necessary
owing to the extreme volume of public comments on the DEIS. Following
is a brief analysis of recurrent themes in the body of comment, and how
NPS responds to them.
Many commenters expressed consternation about the lack of a ``no
snowmobiling'' alternative in the DEIS, and suggested that impact
descriptions and data to support the EIS and the preferred alternative
were not detailed enough. NPS responds first, that a ``no
snowmobiling'' alternative was provided in the DEIS--alternative G.
Secondly, in some cases the NPS has added information to support the
analysis of impacts in the FEIS. Additionally, NPS is engaged in
programmatic planning, rather than project-specific planning; therefore
analysis and data collection have been conducted on a reconnaissance
level. Further, where data is lacking or unavailable even at that
level, CEQ regulations provide for the decision process to continue
based on best available data and professional application of credible
methods.
Many people stated they could not support any of the DEIS
alternative ``mixes.'' A large number of comments levied criticism on
the preferred alternative--to the point that constructive comments on
the other alternatives were greatly lacking. Three additional
``alternatives'' were proposed: Revised Alternative E (in various forms
provided by cooperating agencies and the Blue Ribbon Coalition),
[[Page 80920]]
the Citizens' Solution (provided by a consortium of conservation
groups), and the Natural Regulation Alternative (provided by The Fund
for Animals).\19\ All such comments were read as the decisions that
people would like to see the NPS make, based upon their opinions about
impacts and their interpretations about laws.
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\19\ Most features of Revised Alternative E and The Citizens'
Solution were covered within the DEIS range of alternatives. Certain
features were either considered to be implementation details or
outside the scope of analysis. The Natural Regulation Alternative,
by advocating no motorized access or groomed routes, was considered
outside the scope of analysis--although some alternatives close
sections of the parks to motorized use, and adaptive management
could conceivably result in other sections being closed over time.
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The body of comment included little substantive information beyond
that disclosed in the DEIS, and did not demonstrate that an alternative
(feature) did not belong in the range of choices available for the
decision-maker. Given the ability of a decision-maker to mix features
from the FEIS range of alternatives, much of the criticism in the
public comment does not apply to the analysis. Regarding the great
amount of comment on the preferred alternative, and perceived lack of
justification for it, the NPS responds by saying that such criticism is
more appropriately applied to the decision. In fact, the NPS changed
the preferred alternative between draft and final EIS whereupon most of
these comments no longer apply.
Some commenters said that the desired conditions or objectives were
too general, and that there is no demonstrated need for management
change. In effect, such comments missed the real issues that are
conveyed by statements of existing conditions. The NPS responds by
explaining that the EIS is programmatic, leading to a plan, which is
general in nature. In addition issues regarding resource impacts,
health and safety, and visitor experience are documented sufficiently
by the NPS to indicate the need for major management changes supported
by a new plan.
Given the scope of analysis, the NPS developed alternatives
(alternative plans) as possible ways to proceed from the current
condition toward the desired condition. The NPS maintains that public
access during the winter is an appropriate objective to be achieved.
Accommodating a variety of recreational uses is also valid. In each
case, activities must be evaluated in terms of impacts on parks'
resources and values, health and safety, and visitor enjoyment.
Alternatives that vary the location, amount and proximity of uses are
needed to assess the relative impact or change from the current
condition. The EIS expresses impacts or changes in terms that allow
people to understand how each alternative satisfies the purpose and
need for action. It is unreasonable to expect that all alternatives
would address all aspects of the purpose and need equally, or that all
alternatives worthy of consideration would have no impacts. In the
final analysis, the NPS concludes that the purpose and need for action
articulated in the EIS is appropriate, and that the range of
alternatives considered in detail is adequate. See Comparison of
Alternatives at the end of this decision document.
Public Response to the FEIS
The FEIS was published and available to the public in hardcopy and
on the internet on October 10, 2000. Summaries of the FEIS were mailed
to about 46,500 interested parties, and about 400 copies of the FEIS
were mailed at that time. The public was able to provide comments up
until October 31. Due to the potential public controversy of the
selection of alternative G as the preferred alternative in the FEIS,
the former Assistant Secretary for Fish and Wildlife and Parks agreed
to solicit public comment on that document. About 10,970 comment
documents were received, including letters, e-mails, and postcards.
Comments were read and evaluated regarding their content. A comment
summary is attached to this decision (Attachment B). Generally, there
were more respondents favoring elimination of snowmobiles from the
parks than those who support continued snowmobiling. State and local
governments and most business interests who responded favor continued
snowmobiling.
Consultation
Cooperating Agencies
The details of cooperation with other agencies are provided on
pages 16-17 and Appendix A of the FEIS. In summary, State and county
governments surrounding the GYA requested and were granted cooperating
agency status (40 CFR 1501.6) in December 1997 and January 1998. The
NPS requested that the US Forest Service become a cooperating agency
because of possible impacts on surrounding national forests from
changes in the parks' winter use management; and the USFS acceded.
Agreements were developed to assign formal roles in the EIS process and
establish expectations. The NPS held its first meeting with the
cooperating agencies on February 13, 1998. Appendix A in the FEIS
(Volume II) further discusses coordination with cooperating agencies.
Through the EIS process, NPS made it clear that veto or decision-
making power does not accompany cooperating agency status. As the lead
agency charged with carrying out the NEPA process under Sec. 102(2)(c)
of NEPA, the NPS retains sole decision-making authority over the EIS
and its process.
There were a number of comments on the DEIS relating to the
designation of cooperating agencies. Many people objected to the
inclusion of the counties in particular, feeling that their involvement
biased the decision-making process and the EIS; others felt that the
NPS did not involve or listen to the cooperating agencies. Most
cooperators stated that there was insufficient time or information to
provide adequate input to the NPS, and that the NPS had not met the
terms of the signed memoranda of agreement. Conversely, many of the
cooperating agencies commented that they had provided good information
that the NPS did not consider or incorporate. A table that illustrates
the extent to which the NPS interacted with cooperating agencies is
contained in Appendix A of the FEIS.
The NPS believes that much of the criticism from cooperating
agencies stems from the time frame for producing this EIS, which is
noted in the cooperating agreements, a lack of experience, and a
fundamentally different perspective on the issues. Few federal agencies
have experience dealing with such a large number of cooperating
agencies on a single NEPA project. With the exception of the USFS and
the State of Montana, few of the cooperating agencies have experience
producing environmental impact statements, and the analyses necessary
in their areas of special expertise.\20\ \21\ NPS believes it met all
of its responsibilities under the cooperating agreements to the best of
its ability under the highly constraining time frame.
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\20\ The CEQ definition of special expertise is: ``statutory
responsibility, agency mission, or related program experience.'' (40
CFR 1508.26)
\21\ Montana has a state law governing environmental policy:
Montana Environmental Policy Act.
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American Indian Tribes
The details of consultation with American Indian Tribes are
provided in the FEIS on pages 18-20. To summarize: NPS is committed to
recognizing the past and present existence of American Indians in the
region, and the traces of their use as an important part of the
[[Page 80921]]
cultural environment to be preserved and interpreted. NPS initiated
consultation along with scoping in May 1998 in accordance with the
Presidential Memorandum of April 29, 1994, ``Government-to-Government
Relations with Native American Tribal Governments'' and in compliance
with a variety of laws, federal regulations, and agency management
policies and directives. Eight tribes were identified as being
traditionally affiliated with the GYA.
By April 1999, an additional 13 contemporary tribes had been
recognized by YNP and GTNP as traditionally affiliated with the GYA.
The NPS notified the 21 affiliated tribes of an affiliated tribal
consultation meeting to be held at YNP on May 20, at which the Plans/
EIS would be one of the planning projects and issues discussed. On
April 23, NPS faxed invitation letters to the tribal consultation
meeting, and four days later the NPS mailed copies of the draft
alternatives to each tribe. During the week of May 3, the NPS made
follow-up telephone calls to each of the tribes, to confirm receipt of
the draft alternatives and encourage participation in the affiliated
tribal consultation meeting on May 20.
At that meeting, tribal representatives voiced concerns that
oversnow motorized vehicles, the grooming of road and trail surfaces,
and the movement of people would negatively impact YNP's bison
population. The affiliated tribes received copies of the DEIS for
review and comment in mid-September 1999, and were notified of six
public hearings on the draft plans in late-September 1999. On October
6, 1999, members of the Assiniboine and Sioux (Fort Peck), Cheyenne
River Sioux, Confederated Salish and Kootenai, Crow, Lac Courte
Oreilles, Nez Perce, Rosebud Sioux, the Winnebago Tribe of Nebraska,
and organizations met with Yellowstone and Grand Teton staff to discuss
the Winter Use Plans as part of fall 1999 government-to-government
tribal consultation meetings.
The NPS will continue to consult with representatives of affiliated
tribes as actions resulting from this plan are implemented. The goal of
consultation is to insure that the affiliated tribes' interests and
concerns are adequately addressed, as well as to develop and accomplish
future programs in a way that respects the beliefs, traditions, and
other cultural values of the American Indian tribes who have ancestral
ties to the area.
State Historic Preservation Offices
In October 1995, a programmatic agreement was developed among the
National Conference of State Historic Preservation Offices (SHPO), the
Advisory Council on Historic Preservation (Council) and the NPS. In
accordance with the agreement and pursuant to Section 106 of the
National Historic Preservation Act (16 U.S.C. 470(f)), consultation
with the Wyoming, Montana, and Idaho SHPOs and the Council was
initiated in May 1998. The NPS sent copies of the scoping brochure (May
1998) and the draft preliminary winter use alternatives (December 1998)
to the SHPOs and the Council. In accordance with their request, the NPS
continued to consult with the Wyoming, Montana, and Idaho SHPOs and the
Council regarding actions described in the Winter Use Plans/EIS that
may affect cultural resources (FEIS Appendix E). The NPS mailed copies
of the Draft EIS to each SHPO and the Council for review and comment.
Before completion of the FEIS, the NPS contacted the SHPOs of all three
states directly, and all offices stated that they had no comments on
the DEIS and saw no need for further consultation.
U.S. Fish and Wildlife Service
The settlement agreement under which the winter use plan and EIS
were produced also required the NPS to prepare a biological assessment
(BA) and request formal consultation with the USFWS pursuant to section
7(a)(2) of the ESA, 16 U.S.C. 1536(a)(2) and its implementing
regulations. To comply, on February 16, 2000 the NPS requested from the
USFWS an updated list of all federally protected threatened,
endangered, proposed, or candidate species that might occur in the
affected area (FEIS Appendix D). Because winter use is highly
controversial, and the NPS was aware of the potential for considerable
post-draft changes, it elected not to initiate consultation at the time
the DEIS was issued. Instead, a BA was prepared for the FEIS preferred
alternative, and subsequently submitted to USFWS on July 5, 2000.\22\
On October 25, 2000, USFWS provided a letter concurring with NPS'
determination in the biological assessment that implementation of the
winter use plans as proposed is not likely to affect threatened or
endangered species or migratory birds in the action area. The letter
notes the coordination between NPS and USFS through the Greater
Yellowstone Coordinating Committee which resulted in a commitment to
monitor possible but unanticipated impacts on grizzly bears as a result
of the action.
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\22\ Actions taken in accordance with Endangered Species
Consultation Handbook: Procedures for Conducting Consultation and
Conference Activities under Section 7 of the Endangered Species Act,
March 1998.
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Alternatives Considered
Alternative Development
Alternative development is described in detail on pages 31-32 and
in Appendix A of the FEIS. The alternatives for the Winter Use Plans
and Environmental Impact Statement for Yellowstone National Park (YNP),
Grand Teton National Park (GTNP) and the John D. Rockefeller, Jr.,
Memorial Parkway (the Parkway) were formulated in response to the major
issues and concerns raised through public and internal scoping. In
addition to the scoping process, the National Park Service (NPS) and
the cooperating agencies met in Idaho Falls, Idaho, for 3 days during
October 1998 to formulate initial concepts for alternatives. Later,
similar workshops were conducted with the staffs in both parks. For a
complete discussion of the concepts generated during the workshops see
FEIS Appendix A.
The NPS planning team evaluated the concepts in terms of their
responsiveness to the major issues and concerns, the decision to be
made, and the purpose and need for the Winter Use Plans. The concepts
were also evaluated against their adherence to current law, park
management guidelines, and NPS mandates and policies. Lastly, each
concept was evaluated for its economic and technical feasibility. The
concepts that best met the above criteria were packaged into the range
of alternatives discussed below. Each alternative proposed considers a
different means of achieving the desired condition of the parks in the
winter while minimizing impacts to park resources.
Scope of Analysis in the FEIS
The scope of analysis determines the range of alternatives to be
considered. The analysis in the EIS is limited to recreation during the
wintertime (about December 15 through March 15, annually).
Geographically, the analysis is limited to recreation management within
the boundaries of the three national park units.\23\ Recreational use
considerations and supporting facilities
[[Page 80922]]
are limited to those that are technically possible at the present time
or are feasible for development and implementation. The range of
alternatives presents options for motorized and nonmotorized winter
recreational use in the three park units considering reasonably
expected technological improvements in emissions and sound of
snowmachines. One alternative evaluates the impacts of current winter
use (per the settlement agreement and CEQ regulations). In this
instance, ``no action'' is interpreted as current management, which is
appropriate for programmatic planning.\24\
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\23\ As a matter of process under CEQ regulations, the impacts
of park management that are known or suspected to occur at other
times and places must be disclosed in the EIS. In this EIS, economic
impacts outside park boundaries are disclosed in the socioeconomic
impacts section. Physical and resource effects are disclosed in the
sections on adjacent lands and cumulative impacts.
\24\ Many commenters on the DEIS stated that the ``no action''
alternative must be ``no snowmobiling'', and that the court
settlement showed that to be the appropriate course of action. The
park service's interpretation of ``no action'' means no change in
general management direction from the present. The settlement
agreement did not include any concessions to claims by The Fund for
Animals, nor did it remove any options within the park service's
discretion for park management from the range of alternatives to be
considered. In approving the settlement agreement, the court
asserted that a comprehensive winter use EIS (in accordance with CEQ
regulations) would be written.
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Alternatives
Alternative A (No Action)
This alternative reflects current use and management practices in
the parks and meets the requirement for including a no action
alternative in an EIS.\25\ Alternative A is a baseline for analysis and
reflects existing conditions. Other alternatives are intended to
improve the existing condition in one or more major issue areas. Issues
associated with alternative A include visitor access difficulties,
visitor experience conflicts, unsafe conditions, and resource impacts.
---------------------------------------------------------------------------
\25\ CEQ 40 Most Asked Questions, question number 3. Where an
existing program is being evaluated, ``no action'' is ``no change in
management.'' ``No action'' may be thought of as continuing with the
present course of action until the action is changed. CEQ states
that in such instances, ``to construct an alternative based on no
management at all would be a useless academic exercise.''
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Alternative B
This alternative provides for a moderate range of affordable and
appropriate winter visitor experiences. Key changes in recreational
opportunities include: Plowing the road from West Yellowstone to Old
Faithful to allow mass transit access by wheeled vehicles, moving the
CDST to a year-round path from Moran to Flagg Ranch, and phasing out
snowmobile use on Jackson Lake. Over the next 10 years, an advisory
committee would make recommendations on phasing and implementing sound
and emission standards for air quality and motor vehicle sound issues.
By winter 2008(2009, strict emission and sound requirements would be
required by all vehicles entering the parks. In addition this
alternative emphasizes an adaptive approach to park resource
management, which would allow the results of new and ongoing research
and monitoring to be incorporated as it becomes available. Adaptive
management increases the Park Service's ability to solve visitor access
and experience issues and resource issues over time. Using the criteria
stated within Executive Order (EO) 11644 (as amended) and its
implementing regulation (36 CFR 2.18), monitoring results demonstrating
disturbance to wildlife or damage to park resources would be cause to
implement actions for mitigating these conditions (for example, closure
to winter visitor use or trail restrictions).
Alternative C
This alternative provides for maximum winter visitor opportunities
for a range of park experiences, with emphasis on motorized recreation,
while mitigating some natural resource impacts and safety concerns. Key
changes in recreational opportunities include: plowing the road from
West Yellowstone to Old Faithful to allow access by wheeled vehicles,
providing a widened highway corridor to accommodate the CDST, and
providing additional groomed trails for both motorized and nonmotorized
uses. This alternative directly addresses issues that arose during
scoping about potential impacts of management change on local
economies. It shows how the range of winter opportunities could be
preserved, applying mitigation primarily in the areas of air quality
and sound impacts.
Alternative D
This alternative emphasizes opportunities for visitor access to the
unique winter aspects of the parks (for example, geysers, geothermal
areas, wildlife, and scenic vistas), and protection of those qualities
and natural resources by phasing in cleaner and quieter modes of
travel. It focuses winter visitor activities near destination areas and
gateway communities. Key changes in recreational opportunities include:
eliminating motorized oversnow access to Yellowstone through its East
Entrance, limiting snowmobile use in Grand Teton and the Parkway to the
CDST and the Grassy Lake Road, eliminating wheeled-vehicle access from
Colter Bay to Flagg Ranch to accommodate oversnow vehicles on the
groomed highway surface, and eliminating snowmobile use on Jackson
Lake. Emphasizing uses in different areas of the park minimizes
conflicts between nonmotorized and motorized users, and addresses
issues about visitor access and experience. Support facilities would
have minimal amenities. In this alternative, visitor access routes and
timing would be modified to provide safer conditions. Over time, issues
regarding impacts on natural resources would be addressed, particularly
in Grand Teton and on the east side of Yellowstone.
Alternative E
This alternative emphasizes the protection of wildlife and other
natural resources while allowing park visitors access to a range of
winter recreation experiences. It uses an adaptive planning approach
that allows the results of new and ongoing research and monitoring to
be incorporated. Key changes to current recreational opportunities are:
eliminating motorized oversnow access in Grand Teton and the Parkway
except for use on the Grassy Lake Road and north of Flagg Ranch into
Yellowstone, and eliminating all winter motorized use on Jackson Lake.
This alternative addresses the full range of winter use issues in
Yellowstone over time, but the current condition would prevail in the
short term. Using the criteria stated in EO 11644 (as amended) and its
implementing regulation (36 CFR 2.18), monitoring results demonstrating
disturbance to wildlife or damage to park resources would be cause to
implement actions for mitigating these conditions (for example, closure
to snowmobile use). Alternative E calls for instituting an advisory
committee to make recommendations about emission and sound standards.
Local, county, state, and federal agencies as well as representatives
from the snowmobile industry and environmental groups would participate
on this committee. In Grand Teton and the Parkway, the full range of
issues are addressed more immediately by limiting oversnow motorized
use to the north end of the park, thus separating uses and eliminating
most resource and visitor experience conflicts relating to snowmobile
use.
Alternative F
Alternative F emphasizes wildlife protection. Key changes in
recreational opportunities include: eliminating all winter access to
Yellowstone's interior through its North and West Entrances,
eliminating motorized oversnow access in Grand Teton and the Parkway
except
[[Page 80923]]
for use on the Grassy Lake Road and north of Flagg Ranch into
Yellowstone, and eliminating all winter motorized use on Jackson Lake.
For YNP this alternative addresses issues regarding protection of
wildlife resources by focusing winter visitor activities near scenic
areas in the eastern and southern portions of YNP. These areas are
generally outside important winter range for large ungulate wildlife
species. In Grand Teton and the Parkway, the full range of issues is
addressed by limiting oversnow motorized use to the north end of the
park, thus separating uses and eliminating most resource and visitor
experience conflicts relating to snowmobile use.
Alternative G (The FEIS Preferred Alternative)
This alternative emphasizes cleaner, quieter access to the parks
using the technologies available today. It would allow oversnow access
on all routes currently available via NPS-managed snowcoach only. Other
key changes in recreational opportunities include: eliminating winter
plowing on the Colter Bay to Flagg Ranch route, making Flagg Ranch a
destination via oversnow transport, and eliminating all winter
motorized use on Jackson Lake. This alternative addresses the full
range of issues regarding safety, natural resource impacts, and visitor
experience and access. It addresses the issues in a way that would make
it necessary for local economies to adapt, and for visitors wanting
motorized oversnow access to the parks to use snowcoaches rather than
snowmobiles.
Comparison of Alternatives
A comparison of alternative actions and the effects of the
alternatives may be found in the FEIS beginning on page 66 (Tables 11
and 12). The following rating process, using the FEIS data, is designed
to illustrate--in a relative fashion--how each alternative meets the
purpose and need for action. The purpose and need elements are
equivalent to the impact topics assessed in the EIS. The rating scale
is defined below.
------------------------------------------------------------------------
Rating Definition
------------------------------------------------------------------------
+4................................ Major beneficial impact
+3................................ Moderate beneficial impact
+2................................ Minor beneficial impact
+1................................ Identifiable but negligible
beneficial impact
0................................. Neutral level--no adverse impact, no
beneficial impact
-1................................ Identifiable but negligible adverse
impact
-2................................ Minor adverse impact
-3................................ Moderate adverse impact
-4................................ Major adverse impact
------------------------------------------------------------------------
With reference to the summarized impacts by alternative in the FEIS
Chapter II (Table 12), a rating was assigned to each cell; e.g., where
a major beneficial impact was disclosed, a +4 was assigned to that
block. This represents a composite rating, and it should be noted that
the detailed effects analysis represented by the rating is found in
Chapter IV of the FEIS. The impact topics were weighted equally in this
rating. All impact topics for all alternatives were rated in this
fashion and then tabulated accordingly. A chart tabulating the ratings
for major impact topics, or purpose and need elements, is shown below.
BILLING CODE 4310-0901-09P
[[Page 80924]]
[GRAPHIC] [TIFF OMITTED] TN22DE00.050
This chart illustrates effects relative to a neutral environmental
baseline reflecting an assessment of no identifiable adverse or
beneficial effect.\26\ In the EIS, the defined environmental baseline
is the existing condition, or alternative A (no action). Therefore,
another data set and chart were generated to normalize the ratings
relative to alternative A. That is, for each impact topic, the
difference between the ratings for alternative A and the analogous
ratings for each other alternative was gauged. For example, alternative
A has a rating of +3 for visitor experience and F has a rating of -3
for the same element; the relative difference (or the scale difference)
between the two is -6.\27\ The resulting chart, below, shows
alternative A as having no effects relative to the existing condition,
and the other alternatives as having positive or negative effects
compared to that base. The chart is an illustration of the extent to
which each alternative meets the purpose and need for action, moving
management from the existing to the desired condition.
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\26\ For such illustrations, the selection of a rating scale has
many possible permutations. In this case, a scale showing positive
and negative values was selected in order to better visualize the
adverse impacts as opposed to the beneficial impacts of each
alternative. An added feature of this scale is that it illustrates
the existing condition, represented by Alternative A, as a condition
to be improved in terms of ``purpose and need'' elements.
\27\ This explains why the chart shows values up to +/-6, when
the rating scale for effects is +/-4. The ``effects'' scale does not
apply to the second chart; it is the relative change from
alternative A that is now illustrated.
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The purpose and need for action, as expressed in Chapter I of the
FEIS, is illustrated fundamentally by describing the desired condition
for the park units and comparing it to the existing condition. The
descriptions are made in terms that relate to park resources and
values, so that there is a direct relationship with mandates,
regulations, executive orders and policies that direct NPS in managing
resources and values. The relationship of existing condition to desired
condition is developed through the most important resources and values
within the context of winter use, as determined in the FEIS.
The intent of actions proposed in the alternatives is to change
management so that parks move from their existing condition toward the
desired condition. Since various important resource elements make up
the existing/desired condition relationship, it is expected that
different alternatives designed to emphasize different concerns will
respond differently to the overall purpose and need for action. As
illustrated in the above chart, this is the case for winter use
alternatives in the three park units.
The above comparison chart illustrates the following
generalizations. The existing condition is represented effectively by
alternative A. Comparing other alternatives to alternative A, it is
clear that all but alternative C respond positively, overall, to the
purpose and need for action. Alternative E would improve the condition
of all resources and values (and the opportunity to enjoy them),
compared to alternative A, but the improvement overall would be of a
fairly low magnitude while retaining the economic status quo. In
alternative G impacts on all resources/values would be greatly
decreased over existing conditions, and decreased overall to a greater
extent than in any other alternative. This improvement would come
primarily at the cost of economic impacts to local communities, also
shown in the above chart. Balancing the positive and negative changes
from the existing condition, alternatives D, B and F rank in that order
below alternative G. All would adversely impact one or two of the four
gateway communities while improving resource conditions. Alternative F
would greatly improve resource conditions, while incurring long-term
adverse impacts on opportunities to enjoy park resources and values,
and on the winter economies of West Yellowstone and Gardiner, Montana.
In showing the generalized and relative comparisons, the chart does
not reflect analysis details. For example, although alternative F
greatly improves
[[Page 80926]]
resource conditions overall, there would still be disturbance to
wildlife associated with snowmobile use at certain times and certain
places. Analysis details such as this apply to all alternatives. The
reader is referred to Table 12 and Chapter IV in the FEIS, where the
detailed analyses are summarized and presented respectively.
Environmentally Preferred Alternative
Based on reduced impacts to human health and safety, air quality,
visitor access, the natural soundscape and wildlife the NPS has
identified alternative G as the environmentally preferred alternative.
The U.S. Environmental Protection Agency, in its comments on both the
Draft and Final EISs, similarly identifies this alternative as its
environmentally preferred action.
Information Contact
For more information on this decision or on the FEIS, please
contact the offices of:
Karen Wade, National Park Service--Intermountain Region, 12795 West
Alameda Parkway, Lakewood, CO 80225.
Steve Iobst, Grand Teton National Park, PO Drawer 170, Moose, WY 80312
Michael Finley, Yellowstone National Park, PO BOX 168, Yellowstone, WY
82190.
Attachment A--Monitoring and Adaptive Management Plans
Standards, Methods, and Intensity by Management Zone
Monitoring and Adaptive Management
Introduction
General resource inventory (and monitoring) and adaptive management
are two approaches to assure the implementation and success of
management actions. General resource inventory and monitoring in
accordance with the National Park Service (NPS) 77 Resource Management
Guidelines (NPS 1991) is a necessary part of the decision that proceeds
from the Winter Use Final EIS (See Appendix I). Adaptive management is
also a component of this decision.
The two approaches are distinguished by the degree of uncertainty
regarding the impacts to park values. Adaptive management is an
appropriate approach when important information pertaining to natural
resource and visitor use management is lacking, and there is a need to
take immediate management action rather than to wait for additional
information to be collected. It is a process of implementing management
decisions as scientifically driven experiments that test predictions
and assumptions in management plans, and using the resulting
information to improve the plans. General resource monitoring is
appropriate where standards exist either in laws, regulations or
general management plans. Techniques must be available to measure
conditions for effective comparison with the standard.
Additionally, the National Parks Omnibus Act of 1998 requires a
program of inventory and monitoring of National Park System resources
to establish baseline information and to provide information on long-
term trends of the condition of national park system resources (16
U.S.C. 5934). The service also must use the results of scientific
research, including monitoring and inventory, in making decisions about
the management of parks (16 U.S.C. 5936).
The Winter Use EIS identifies information needs related to winter
use as it may impact critical park values: air quality, natural quiet,
wildlife, aquatic resources, and visitor experience. Both adaptive
management and monitoring require standards, or thresholds, to
establish baselines upon which to assess degradation to monitored park
values. The initial identification of indicators, standards, methods
and management responses that relate to critical values is located in
FEIS appendix I. This is the basis for developing monitoring plans
under authority of this decision.
Coordination and Responsibility Requirements
Monitoring programs will be coordinated between Yellowstone and
Grand Teton National Parks. The programs will function and be
coordinated through the planning staffs of both parks. The development
of annual plans and reports will be coordinated through the planning
units, and the planning units will be responsible for delivering those
products to management. Other park divisions will coordinate with
planning, and provide resources for performing monitoring tasks.
Adaptive Management Program
The essential first step when formulating an adaptive management
strategy for the affected environment is to articulate the critical
uncertainties, particularly where some information is known about a
specific resource but conclusive evidence is currently unavailable.
Based on current knowledge, a management scenario is then designed to
test specific hypotheses relating to the critical uncertainties.
Monitoring and evaluation strategies are then employed to evaluate
outcomes relative to acceptable thresholds, and assist in the
development of management alternatives. Monitoring within the framework
of adaptive management is critical because of the uncertainty of
predictions based on limited information. It provides systematic
feedback for management, and allows adjustment of activities to
mitigate unplanned or undesirable outcomes.
A critical step in adaptive management involves the National
Environmental Policy Act (NEPA). Each time a new management proposal is
evaluated the analysis must be documented by performing the appropriate
level of NEPA compliance. Some actions, such as permanent road closures
to protect wildlife or the construction of new facilities may require
an additional site-specific NEPA analysis, which includes public
scoping. Some actions might be administrative in nature, or be
implementable through application of a NEPA categorical exclusion (Ref:
NPS 12).
The adaptive management process is shown schematically in Figure 1.
Tables follow that prescribe monitoring standards, methods and proposed
management actions for critical resources in each winter management
zone. These are tables 12 through 22.
Monitoring Program
General resource monitoring applies when adequate information
exists to make informed management decisions. It is the process of
collecting information to evaluate if the objectives of a management
plan are being realized. General monitoring techniques (as opposed to
monitoring conducted within the adaptive management framework) will be
employed to assess impacts to public health and safety; geothermal
features; water quality; threatened and endangered species; trumpeter
swans and some aspects of visitor experience, including access and
circulation. NPS-77, Natural Resources Management Guideline, will be
used initially as a guide to monitoring specific resource areas. As new
techniques are developed, or as commonly accepted procedures become
available, monitoring protocols will change.
Tables follow that prescribe monitoring standards, methods and
possible management actions for critical resources in each winter
management zone. These are tables 1 through 11.
[[Page 80927]]
Annual Monitoring and Adaptive Management Plans
The overall objective for monitoring and adaptive management is to
assess the long-term effects of management actions on park resources
and values. Specific objectives accrue to each winter management zone
(FEIS Table xx and Figures xx and xx). With reference to the following
tables, for each management zone and for each resource of concern,
monitoring indicators are presented. For each indicator, a standard
either exists or is hypothesized (for adaptive management). Also, for
each indicator a monitoring method and intensity is prescribed.
Finally, management actions are indicated if the standards should be
exceeded.
Monitoring and adaptive management plans will be developed annually
during workplanning and budget processes for the coming year. Plans
will be developed through the planning staffs of both park units.
Monitoring will be conducted on a sampling basis for the purpose of
effective use of funds and personnel. The guiding principle for
monitoring is to collect purposeful data--even if the amount is
limited--rather than collecting a great deal of data that cannot be
used statistically to arrive at valid conclusions. Therefore,
monitoring plans will be brief and will cover the following items:
The zones to be sampled, along with the indicators,
standards, and methods to be used.
Specific locations for monitoring, and the planned
intensity--frequency of monitoring.
A schedule (times) for data collection and submittal.
The division or individual that is responsible for
monitoring and reporting.
It is expected that initial monitoring will be intensive, both in
geographic and temporal extent, so that correlations can be made and
results can be extrapolated. It is also expected that monitoring over
time will become less intensive and arrive at a low intensity,
maintenance level. Sampling schedules can vary from year to year,
focusing on different areas within the park units. Monitoring plans
will continue to be coordinated between Yellowstone and Grand Teton so
that common methods are used, efficiency is achieved, and results are
comparable. Annual monitoring reports will be written and publicized
through the planning units of the two parks.
Annual Monitoring and Adaptive Management Reports
Feedback for management is implicit in monitoring and adaptive
management programs. In order for feedback to occur, data must be
collected effectively in accordance with a plan. Data must be captured
in an accessible information system, capable of evaluation and
statistical manipulation. Then, evaluations must be put in meaningful
terms for management. The requirement of a formal report is essential
to meet this need. The report should be published to a standard that is
appropriate for public consumption.
Annual monitoring reports will be brief, and will meet the
following requirements:
Sum up the information collected during the year.
Express conclusions relating to each management zone and
indicator that was monitored.
Extrapolate the conclusions to other areas, when possible
and appropriate.
State the need for applying management actions based on
monitoring.
Make recommendations for changes in monitoring locations,
protocols, techniques or thresholds that should be considered in the
monitoring plan for the following year.
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[[Page 80951]]
Attachment B--Summary of Public Comments on the FEIS
Summary of Public Comment on the FEIS
Introduction
After the FEIS was published on October 10, 2000 the public was
invited to comment up until October 31. The total body of comment
divides into two basic types. First, the content of most of the
documents fell into categories of repeated topics, statements and
rationale that were not explicit to the FEIS analysis. NPS read all
pieces of mail and coded the statements that were made in each. A
summary of this body of comment is provided in a table with
accompanying conclusions. In this category, there were about 10,880
responses in the form of letters, postcards and e-mails. Of these,
6,717 were form letters and 4,163 were not.
A second set of letters and e-mails, numbering 55, is distinguished
by more discussion specific to the FEIS and the process that produced
it. They generally provide greater amounts of detail and rationale for
their statements. This set of correspondence includes the cooperating
agencies, other federal, tribal, state or local agencies (or their
representatives), concessioners, advocacy groups, and a number of
individuals. Most had commented earlier on the Draft EIS. These letters
were read and summarized point by point for the decision maker, to whom
copies of the letters were also submitted. This attachment contains a
general summary of the letters, by group type.
Summary of Coded Comments
Comment letters were coded in order to determine the following
information:
Support for or against a specific alternative
Support for or against individual components of a specific
alternative
Support for or against a specific mode of recreational
oversnow travel
Flaws in the analysis presented in the FEIS
Pertinent new information or data that was omitted from
the FEIS
New alternatives that were not analyzed in the FEIS
Categories of comments and the number received are listed in the
following table. The comments are listed with the most often received
comments descending to the least often received comments. An individual
document may contain from one to many separate comments.
------------------------------------------------------------------------
Count Classification
------------------------------------------------------------------------
6446................................. I support elimination of
snowmobiles in the three park
units.
5491................................. I support Alternative G.
5424................................. The NPS has the responsibility
under its mandate to protect
resources.
4724................................. Snowcoaches are a good means of
allowing access while
eliminating effects on wildlife
and visitor experience.
3324................................. I support the use of snowmobiles
in the parks.
2392................................. The analysis is flawed, science
is bad; numbers that Sierra Club
gave you . . . are biased; etc.
2177................................. The snowmobile industry is trying
hard to meet needs for cleaner,
quieter snowmobiles.
1735................................. Snowmobilers have a right to
personal access to the park.
1480................................. Snowmobiles don't impact
resources, or have minimal
impact.
1413................................. Snowmobiles have significant
impacts on air quality and the
natural soundscape.
1361................................. Support for specific alternative
Revised E.
1182................................. Snowmobiles have significant
impacts on wildlife.
890.................................. Snowmobiles have significant
impacts on the winter visitor
experience.
867.................................. I believe that banning
snowmobiles is an overkill
reaction to problems associated
with current snowmobile
technology.
663.................................. Support for specific EIS
alternative A.
653.................................. Alternative G will have
devastating economic impacts.
567.................................. People should be allowed to visit
the parks using any means of
access they wish.
381.................................. Summer/winter comparisons . . .
i.e., buses versus snowmobiles,
emissions, crowding, wildlife
impacts.
323.................................. The parks are for all the people,
not just the ``elite.''
225.................................. Alternative G discriminates
against snowmobilers; if
snowmobiling is eliminated,
skiing should be eliminated too.
225.................................. No Comment.
184.................................. I would like to see a phase-in of
clean and quiet snowmobiles.
142.................................. Economic impacts of eliminating
snowmobile use are overstated.
111.................................. No Road Grooming.
96................................... Support for specific EIS
alternative C.
94................................... I support clean, quiet and more
environmentally friendly
snowmobiles or snowcoaches.
91................................... Support for specific EIS
alternative F.
65................................... People who are walking and skiing
disturb wildlife more than
people who ride on machines.
59................................... Support for specific EIS
alternative E.
52................................... The analysis is good ....(for
whatever reason).
45................................... The snowmobile industry is not
responsive to needed
technological changes for
environmental protection.
35................................... Support for specific EIS
alternative B.
18................................... No Vehicles.
16................................... Pro-snowplane--Snowplanes don't
impact resources.
12................................... Support for specific EIS
alternative D.
9.................................... Support for specific alternative
Natural Regulation Alternative.
8.................................... NEPA process is flawed and not
enough time to comment on FEIS.
7.................................... Duplicates.
5.................................... There is no feasibility analysis
for snowcoach operation,
snowcoaches will make the park
inaccessible.
2.................................... NPS is not responsive to people
who snowmobile or snowplane.
2.................................... There should be a multiple-use
alternative.
1.................................... NPS should not use military
ordinance for avalanche control.
1.................................... NPS ignored reasonable
suggestions from the cooperating
agencies.
1.................................... NPS' selection was not driven by
facts or need for action.
------------------------------------------------------------------------
[[Page 80952]]
One type of comment that was not included in the overall document
count were e-mails received from an internet polling site named
``vote.com.'' The e-mails that were received were the result of an
ongoing poll about snowmobile use. People responding to the poll were
asked to vote a ``yes'' or ``no'' to the question ``Should snowmobiles
be banned from Yellowstone Park?'' Adjacent to the ``yes'' vote was the
statement, ``People could still take winter tours in cleaner, quieter
snow coaches.'' Adjacent to the ``no'' vote was the statement,
``Banning recreational snowmobile users from the park would hurt local
businesses.'' The results were 619 ``yes'' votes and 1970 ``no'' votes.
There was some conflicting information concerning the privacy policy
statement of ``Vote.com.'' The site states that the vote is
confidential, but the results received included the e-mail address of
each person voting. A comment was also received expressing concern
about the ``Vote.com'' comments.
Summary of Individual Letter Contents
Federal Government, Tribal Governments
Comments on the FEIS were received from: U.S. Environmental
Protection Agency, U.S. Bureau of Reclamation, The Shoshone-Bannock
Tribes, Senator Michael B. Enzi of Wyoming, and from Donald A. Manzullo
of the U.S. House of Representatives' Committee on Small Business.
EPA has no environmental objections to the FEIS preferred
alternative. EPA finds that the FEIS adequately discloses the impacts
of all alternatives, and is improved from the DEIS by adequately
responding to comments from EPA, other agencies and the public.
The tribes recommend the implementation of Alternative F, citing
the description of the alternative as rationale. They further state
that the trust obligations owed by the U.S. to American Indian tribes
outweighs any commitment to snowmobilers or other recreationists , or
to the states of Wyoming, Montana and Idaho. They feel that government
to government consultation was inadequate.
U.S. Bureau of Reclamation expresses concerns about the ongoing
business, research, data collection and administrative travel necessary
for BOR to carry out its duties within the parks. They indicate the
FEIS is unclear about the options BOR has for necessary travel, since
most of the routes used by the agency are designated for snowcoach
travel only, and that the agency must travel in the parks to collect
data necessary in forecasting snowmelt, and reservoir function
including flood control. Winter access is necessary to meet agency
responsibilities.
U.S. Senate, Senator Michael B. Enzi of Wyoming expresses deep
concerns about how NPS has mishandled the opportunity to provide clear
direction and a vision for management. He states that NPS has chosen to
proceed with a politically biased, predetermined conclusion that
excludes the community and places the parks out of reach for most
Americans in the winter. Senator Enzi states that snowcoach access only
is infeasible for several reasons, and that it is evident the
snowmobile industry has available technology to comply with any NPS
noise or emission standards NPS might impose. He also states that NPS
violated NEPA and several other laws in this process.
Donald A. Manzullo, U.S. House of Representatives, Committee on
Small Business references testimony from the July 13, 2000 hearing
before the House Small Business Tax, Finance & Exports Subcommittee
(The Impact of Banning Snowmobiles Inside National Parks on Small
Business, Serial No. 106-68). He states that NPS has ignored the main
thrust of the concerns expressed during the DEIS public comment period
by reiterating support for alternative G. He feels that a snowcoach
only system will not work and that the economic impacts from this
alternative are large.
State Government, Agencies
Comments were received from the governors of the States of Idaho,
Montana and Wyoming, and from State Senator Colin Simpson of Wyoming.
All three states were cooperating agencies in the effort.
Governor Kempthorne of Idaho attaches to his letter a note from
Carl Wilgus, cooperating agency representative from the State of Idaho,
stating that the NPS has ignored, discounted or minimized the good
faith input from the State of Idaho. Mr. Wilgus states that the NPS has
repeatedly missed deadlines and then unreasonably expected the
cooperating agencies to comply with unreasonable deadlines. He states
the NPS prematurely selected a preferred alternative before reviewing
all of the public comment on the DEIS. Among the Governor's comments
are the following. The revised alternative E submitted by the
cooperating agencies was not adequately considered by the NPS. The
cooperating agencies were denied representation on the identification
(sic) team. The choice of alternative G is not grounded in either
scientific fact or public support. The elimination of snowmobiles will
only create greater congestion and safety problems in other popular
locations outside the parks. The loss of the personal freedom to ride
snowmobiles into the parks is an irreversible and irretrievable
commitment of resources. The economic analysis presented in the DEIS is
flawed because the NPS failed to recognize the ``Law of Dimensioning
Returns'' (sic) (that the revenue generated in the winter allows local
businesses to stay open, covers the cost of operations and keeps the
community alive.) None of the alternatives presented in the FEIS are
acceptable to the State of Idaho. The State of Idaho strongly supports
revised alternative E.
The Honorable Colin B. Simpson, Wyoming State Legislature states
that by eliminating the preferred access for 60% of current visitors,
NPS is clearly acting in the biased interest of a minority of its
clients. He indicates the ban is unreasonable and unsubstantiated, and
agrees with the letter from Park County Commissioners (WY). Among other
statements in the letter are: adaptive management provisions could deny
access to the park without due consideration of benefits and enjoyment;
negative economic impact on gateway communities; and the FEIS is flawed
by not addressing economic feasibility of snowcoaches.
Governor Marc Racicot of Montana would like thorough consideration
of the Montana Preferred Alternative that was submitted during the
comment period on the DEIS. Governor Racicot was not satisfied with the
NPS response to Montana's alternative that was published in the FEIS.
In addition, the Governor expresses the following: the lack of effort
to reach a broader consensus (by NPS); request for a complete
evaluation of the Montana alternative to be conducted and provided to
them; request that the NPS include flexibility in Record of Decision
regarding cleaner and quieter snowmobile technology; and request that
the NPS include flexibility with regard to snowcoach only travel to
plan for the possibility that the proposal will not work.
Governor Jim Geringer of Wyoming is extremely disappointed in the
NPS's failure to fully comply with the procedures outlined in the
National Environmental Policy Act (NEPA). He states the FEIS contains
many information gaps, which are the result of an unrealistic timeframe
and a flawed NEPA process. Wyoming does not support alternative G and
indicates that the analysis presented in the FEIS does not support that
alternative as a final
[[Page 80953]]
decision. Other concerns noted include: the state was not adequately
consulted and its information was ignored; cleaner quieter snowmobiles
have an appropriate role to play in the parks; NPS has failed to
conduct a feasibility study of a mass transportation system to service
all entrances; and the Record of Decision should include some type of
escape clause or back-up plan to guarantee public access in the event
snowcoaches fail to provide reliable service from all entrances. The
Governor indicates support for adaptive management including the
utilization of cleaner and quieter snow machines in the parks, as they
are developed and notes there are currently no emission or sound
standards for snowcoaches. He states that NPS will continue to use
snowmobiles, and only when the NPS adopts coach only travel will it be
fair to impose it on others.
Local Government Agencies
Comments were received from commissioners of: Park and Gallatin
Counties, Montana; Park, Fremont and Teton Counties, Wyoming; and Teton
and Fremont Counties, Idaho. A comment was also submitted by the Teton
County (WY) Historic Preservation Board. Five counties were cooperating
agencies in the effort.
The counties' general responses to the FEIS preferred alternative
are:
Park County Commissioners, Montana, express their total
dissatisfaction with the FEIS. The timeline was unacceptable and the
NPS has failed to comply with NEPA and its procedural requirements.
Fremont County, Wyoming states that ``the winter use plan
you are planning to implement is unjust, and based on politics and
emotions rather than science.''
Park County, Wyoming implores NPS to change its decision
from the preferred alternative in the FEIS.
Teton County Board of Commissioners, Wyoming, believes the
selected preferred alternative did not receive adequate analysis and
continues to be disappointed in how the NEPA process was used in the
development of the winter use plans. Teton County initiated the ``Clean
Snowmobile Challenge'', whose results indicate there are feasible ways
to create a clean, quiet machine.
Teton County Commissioners, Idaho, cannot support the
preferred alternative G, stating the only alternative they can support
is A, no action. They note agreement with Fremont County ID in
declaring that the Reclamation Road is an RS2477 highway and is under
local jurisdiction.
Fremont County Board of Supervisors, Idaho, state: ``Our
greatest concerns come from the unknown outcomes as a result of the
FEIS. Snowcoaches are the answer to all questions, according to
alternative G, yet there is no plan for having clean and quiet, or
adequate numbers, of said vehicles in place in the proposed 3 years.''
Gallatin County Commission, Montana, states: ``Generally
we do not find that the analysis and information that you use supports
the preferred alternative. We base our concerns on inconsistencies
between your statement of desired conditions, the data you provide, the
criteria developed by the park service and a departure from the
criteria developed at Idaho Falls in October 1998.'' Much of the letter
quotes liberally from the Draft EIS to support their comments.
Teton County Historic Preservation Board, Wyoming,
indicates the board's consensus is supportive of preferred alternative
G.
Common themes in all letters from the counties include the
following:
The preferred alternative has no basis in scientific fact.
Instead of resolving issues that forced the development of the EIS, the
NPS has opened the door to further litigation.
Alternative G still provides for the administrative use of
snowmobiles by employees living in the interior of Yellowstone. This is
a glaring contradiction.
The NPS made changes to the schedule without consultation
or the consent of the cooperating agencies.
The counties have repeatedly documented how delays in
providing information and modeling data have precluded the counties
from fulfilling their obligations.
NPS reversed its decision to allow the cooperating
agencies to participate on the FEIS planning team.
The alternatives workshop in which the counties
participated did not provide them with the opportunity to provide
meaningful input.
The FEIS ignores the utility of setting an overall
carrying capacity for visitors.
The FEIS ignores the utility of setting an overall
carrying capacity for wildlife.
The cooperating agencies do not support the incorporation
of individual elements of the revised alternative E into the FEIS. The
revised alternative E as submitted by the counties was not intended to
be dissected and is only effective if incorporated as a whole.
Leave the door open to all new technological advances for
snowmobiles and allow them in the parks.
The NPS has chosen to disregard and misconstrue the input
the recommendations of the cooperating agencies.
YNP was set aside as a preserve for recreational enjoyment
and use, and should be continued to be managed with this intent.
The economic impacts of eliminating snowmobiles will be
devastating.
Over regulation by the federal government has been the
demise of many industries.
NPS does not discuss or acknowledge the existence of
current snowmobile technology that would help solve the problem.
The counties strongly disagree with the characterization
of how the alternatives were formulated; banning snowmobiles goes far
beyond what was agreed to.
Alternative G eliminates conflicts, but at the expense of
an entire user group. It appears the resources could be protected and
conflicts minimized while accommodating all user groups.
There is much doubt about the feasibility of going to
snowcoaches only, and how this affects other users and commercial
operators. A feasibility analysis should have been done.
The majority of winter visitors have told you that your
preferred alternative is the one they prefer the least.
We challenge NPS to demonstrate how they've been
cooperative and how cooperation is consistent with the preferred
alternative.
Environmental Groups
Comments were received from groups or from individuals identifying
themselves as speaking in behalf of a group. Comments were received
from the following groups.
Jefferson County Environmental Network, Lakemills,
Wisconsin
Predator Conservation Alliance, Bozeman, Montana
Blue Water Network, San Francisco, California
American Lands Alliance, Washington D.C.
Wildlands Center for Preventing Roads, Boulder, Colorado
Aspen Wilderness Workshop, Aspen, Colorado
Native Forest Network, Bozeman, Montana
Wyoming Chapter of the Sierra Club, Jackson, Wyoming
Greater Yellowstone Coalition, Bozeman, Montana
Schubert and Associates, Glendale, Arizona
[[Page 80954]]
The Ecology Center, Inc., Missoula, Montana
Comments from these groups fall into several categories. Some
groups express support for Alternative G. Some groups give qualified
support to the alternative. Others express support for eliminating
snowmobiles, but also see the need to eliminate any groomed trails and
motorized oversnow use in the parks.
Most groups that support Alternative G indicate that snowmobiles
should be removed from the parks sooner than 3 years if at all
possible. They state that there is broad public support for eliminating
snowmobiles in parks, and are optimistic about elements in the business
community that welcome snowcoach transport. Other related comments are:
Snowmobilers have been given too much time to ``develop
their rights.''
There is no right to engage in a noncomforming use.
NPS should better lay out its plan for transition to
snowcoach only.
Snowmobiles should be removed at the soonest time
possible. Three year ``phase-in'' is unacceptable due to continuing
impacts of noise, wildlife harassment, air pollution, and visitor
disruption.
Continued snowmobile use needs to be brought into
compliance with laws.
Snowmobile ban in the parks will not affect the snowmobile
industry.
Community business leaders recognize there could be
benefits of a snowmobile ban.
There are many places outside the parks that provide
snowmobiling opportunities.
There is broad public support for eliminating snowmobiles
from parks.
Sen. Thomas' solution of separating snowmobilers and
skiers is inadequate because it doesn't address environmental impacts
or noise.
Snowmobilers disregard regulations, disrupting the
integrity of wilderness and wildlife habitat.
Changes will decrease noise, polluted air stresses to
wildlife, and offer visitors a quality experience.
Any trail grooming should still be done without conflicts
with important wildlife habitat.
The decision should also close YNP's east entrance and
eliminate the use of military ordinance.
Interpretation, information and education should be
emphasized in winter management.
NPS risks violation of statutes, regulations and executive
orders. The ROD should express the role of monitoring and that
violations would be cause to halt offending uses.
Implementation of a snowcoach system represents benefits
that far exceed those raised in the FEIS.
NPS can be a catalyst for innovation in snowcoach
technology.
Snowcoach transport should be attractive for visitors and
fit the unique winter setting of the parks. NPS should determine the
best design for this purpose and include current manufacturers,
purchasers and clientele served by existing snowcoaches.
A transition task force should be convened--composed of
NPS, affected businesses and concessioners, local officials and
environmental groups.
NPS should initiate education and outreach to assist in
the marketing of new winter recreation opportunities, to the benefit of
gateway economies.
NPS should investigate programs and funding strategies to
facilitate the creation of a snowcoach mass-transit system, and
affected local businesses should be given initial preference in the new
system.
Those who express qualified support state that the preferred
alternative is an improvement over current management. They indicate:
Pleased that the plan replaces snowmobile use with
snowcoaches.
Snowmobiles affect air, water, sound, visitor experience,
wildlife, and bison movement.
Snowcoach use would continue to facilitate bison leaving
the park in the winter. Winter use should only be allowed to the extent
that it doesn't have this impact.
Would prefer alternative F in the DEIS, along with closure
of YNP's east entrance.
Those who do not support the preferred alternative also generally
express the idea that the ``decision'' is probably the only legal
recourse for NPS because of its mandate. They note that, while the
plans represent an improvement over current management, concerns
remain. Replacing snowmobiles with snowcoaches also should not be
permitted. They indicate:
The parks wildlife and ecosystem will continue to suffer
from groomed routes for snowcoaches.
Continued snowmobile use has unacceptable impacts and they
should be removed immediately.
NPS has no legal mandate to provide motorized access.
The Biological Assessment fails to consider the impacts of
road grooming on federally listed species.
The FEIS is deficient.
A complete ban on groomed routes and termination of all
oversnow motorized use should have been considered in the EIS (a ``true
no-action alternative).
There are no regulations permitting road grooming or
snowcoach operation.
FEIS failed to properly analyze the adverse impact of road
grooming on bison.
NPS failed to properly consider and respond to several
issues raised in comments on the DEIS.
The FEIS range of alternatives is inadequate, based on the
settlement agreement as mandated by the judge.
Many of the analysis points raised in the FEIS actually
affirm the contentions in the lawsuit.
Reserves the right to participate in further litigation.
Business Community, Including Park Concessioners
Comments were received from groups or from individuals identifying
themselves as speaking in behalf of a group. Comments were received
from the following groups.
Riverton Community Development Association, Riverton,
Wyoming.
Pahaska Tepee Resort, Cody, Wyoming.
International Leisure Hosts, Ltd., dba Flagg Ranch Resort,
Tempe, Arizona.
Cody Chamber of Commerce, Cody, Wyoming.
Jackson Hole Chamber of Commerce, Jackson, Wyoming.
West, South and East Gate Operators, YNP, West
Yellowstone, Flagg Ranch, Pahaska Tepee.
Mattracks Inc., Karlstad, Minnesota.
Mr. David McCray, Two Top Snowmobile Rental, West
Yellowstone, Montana.
Mr. F.W. Howell, Yellowstone Arctic Yamaha, West
Yellowstone, Montana.
Mr. Pat Povah, Hamilton Stores, Yellowstone, Wyoming.
Mr. Randy Roberson, Yellowstone Vacations, West
Yellowstone, Montana.
Comments from most groups expressed firm opposition to alternative
G. Some continue to express strong support for revised alternative E,
and believe as stated in previous comments that E would meet the
purpose and need for action. Statements from this body of comment
include:
Closing YNP to public snowmobiling will shift use to other
public lands, and result in impacts on them.
Alternative E is acceptable if the advisory groups are not
packed with anti-multiple use advocates.
Actions of the federal government to eliminate access to
most of the area in the county destroys our means of making a living.
Object to portions of the plan that limit or eliminate
access or types of
[[Page 80955]]
access to the parks. This includes snowcoach only access, adaptive
management, NPS managed snowcoaches, controlled stops in the parks, and
limited to no access at the east entrance of YNP.
Object to portions of the plan that have a negative
economic impact on gateway communities--eliminating snowmobiles takes
away the preferred mode of travel for 60% of YNPs historic visitors.
Object to portions of the plan that allow administrative
snowmobile use, that ignores safety concerns relative to snowcoaches,
ignores inconvenience of snowcoaches, ignores other technical
difficulties with implementing the alternative.
``Snowcoaches only'' is not financially feasible for a
number of reasons.
The FEIS fails to adequately analyze the effects of
increased snow coach operations on air quality, wildlife, the NPS
budget, visitor demographics and the economy.
If numbers are a concern, we believe that all alternatives
have a provision for establishing carrying capacities.
Concerned that the interim use limits, if implemented this
year, would prohibit fulfilling existing reservations.
Because of the greater mileage most people would come to
West Yellowstone, causing even greater congestion there.
Snowcoach travel is too slow and too uncomfortable.
Increasing snowcoaches will cause greater safety hazards.
More people would be hurt in a single accident.
Snowcoaches are too expensive, 20 snowcoaches would cost
1,400,000 a year and would sit idle for 9 months.
Cleaner and quieter snowmobiles are available for
purchase.
The implementation of alternative G will result in
devastating economic effects.
From the east gate the only desirable destination would be
Canyon
Mechanical breakdowns (snowcoaches) would keep visitors
waiting in the cold until help arrives.
The increased speed and number of snowcoaches would
increase safety hazards.
The preferred alternative and the FEIS are biased against
snowmobiles.
In order to accommodate current use levels there would be
lines of snowcoaches at the entrance gates.
Snowcoaches have a 10% breakdown rate--who would retrieve
them?
The parking and storage requirements for the snowcoaches
would be space and cost prohibitive.
If snowmobiles must be banned, plow the road and use buses
instead.
The ``West, South and East Gate Operators'', YNP, West Yellowstone,
Flagg Ranch, Pahaska Tepee corporately submitted a letter, stating that
Alternative G will deny rather than provide access to the visiting
public. The express the right of the public to enjoy the park is of
paramount importance, second only to protecting the park for the
future. Other statements include:
Enjoyment of snowcoach travel vastly diminishes after 90
miles. The alternative eliminates enjoyment of travel to a number of
popular places in the park.
Flagg Ranch stipulates that the alternative would
eliminate access from the south. If the road to Flagg Ranch is not
plowed, the ranch will not open in the winter and it will not be a
destination.
From Pahaska, the only possible destination within the 90
mile enjoyment level would be the Grand Canyon of the Yellowstone. Also
snowcoaches over Sylvan are not advisable due to safety concerns.
Other objections to snowcoaches only are: Insufficient
speed, safety, inadequate technology, capital investment necessary,
mode of travel is not cheaper (than snowmobiles), the public prefers
snowmobiles, and it would be devastating to the economy.
The burden is on NPS to conduct a feasibility study of the
alternative.
Flagg Ranch cannot be a destination resort without a
plowed road to it. The contract requires the plowed road. NPS assured
Flagg Ranch that its contract would be honored.
Interim snowmobile limits will limit the ranch's ability
to operate. This is also a breach of contract.
Elimination of snowmobiles is a breach of the contract,
which doesn't expire until 2009.
Not plowing the road from Colter Bay to Flagg Ranch would
make all of Yellowstone inaccessible to those who have traditionally
entered from the south entrance.
Mattracks Inc., Karlstad, Minnesota, is the only respondent in this
group to support the selection of alternative G as the preferred
alternative and offers the following implementation suggestions:
Suggests a passenger capacity of 6 to 15. A smaller
vehicle does not achieve mass transit goals and larger vehicles may
cause damage to resources.
The NPS should implement EPA emission standards for
snowcoaches.
The NPS should require the use of rubber tracked vehicles
instead of metal or cleated tracks to reduce the sound levels of
snowcoaches. These vehicles have a less aggressive track and may also
run of pavement without causing damage.
Snowcoaches should be of a single inclusive enclosure (no
trailers with passengers).
Snowmobile or Snowcoach Industry, Advocates
Comments were received from:
Birch, Horton, Bittner and Cherot and William P. Horn,
Attorneys for the International Snowmobile Manufacturers Association.
Mr. Virgil Koehler, American Council of Snowmobiles.
Utah Snowmobile Association, Salt Lake City, Utah.
Idaho State Snowmobile Association, Boise, Idaho.
Ms. Adena Cook, Public Lands Director, Blue Ribbon
Coalition, Idaho Falls, Idaho.
Ms. Beth Walsh, Moran, Wyoming.
Mr. Jim Gerber, St. Anthony, Idaho.
All comments in this group are opposed to the selection of
alternative G. Some support the implementation of a revised alternative
E but indicate that since this alternative was not included in the FEIS
their support is given to alternative A, the no action alternative.
Reasons for opposition to the implementation of alternative G in the
parks for the following reasons:
A 21 day review period is unacceptable for such a dramatic
change in alternative preference.
The expertise of a significant cross section of
professionals (cooperating agencies) has been totally ignored.
The snowmobile industry has made many improvements in
technology since 1970.
The benefit of snowcoach travel in the parks is pure
conjecture.
The misuse and abuse of the NEPA process in preparation of
this FEIS is appalling.
The FEIS was crafted to support a decision made in
Washington D.C. requiring significant shifts from the DEIS
alternatives.
The FEIS fails to utilize constructive It would
drastically reduce winter recreation use and enjoyment in derogation of
the acts creating Yellowstone National Park and the national park
system.
Alternative G was concocted after the fact and the NPS has
not allowed the public sufficient time to explore the plan and register
informed comments.
Alternative G would violate existing concessions
contracts--(Flagg Ranch in particular).
Alternative G would have devastating effects on the
economies local communities.
[[Page 80956]]
Snowmobiles produced after 1976 emit no more than 73 dB(A)
at 15 MPH when tested using SAE J1161.
Several studies are cited that indicate that deer are more
likely to move away from ski trails than snowmobile trails and that
they are unaffected by snowmobile traffic.
A University of Wisconsin study found that snowmobile
traffic has no effect on the grain yield of winter wheat.
Six of the seven alternatives offered in the FEIS provide
almost no range of proposals that could possibly be considered as
conscientious multiple use management of public lands.
The change in the preferred alternative from ``B'' to
``G'' without allowing the public to comment proves that land managers
are only listening to the well-funded voices of the minority extreme
advocacy groups.
Comments submitted by ISSA, and the state of Wyoming.
The FEIS exaggerates the environmental effects of
snowmobiles.
The economic analysis presented in the FEIS is superficial
and inadequate.
The FEIS fails to adequately define what would constitute
acceptable impacts from snowmobiles.
Revised alternative E was not seriously considered.
The FEIS version of the ``Existing Condition'' and
``Desired Condition'' was significantly altered from the version in the
DEIS.
Alternative G is totally new and has not been validated by
the public.
The NPS has manipulated visitor use numbers to serve its
own purposes.
The FEIS describes natural soundscapes as a resource not a
value.
The Duffield study is pure conjecture, the FEIS should
have incorporated the more factual State of Wyoming study.
Additional information in the FEIS on social values,
soundscapes and emissions need validation before any conclusions can be
reached.
The NPS was arbitrary and capricious in its decision to
ban snowmobiles and require snowcoaches instead.
The analysis of water quality for alternatives A through F
states that there is no evidence of measurable changes in water quality
from snowmobile emissions yet in alternative G the FEIS concludes that
alternative G addresses the issue of water quality better than other
alternatives.
Snowcoaches will result in a loss of personal freedom and
a poor experience in the parks.
Snowcoaches will be cost prohibitive for many.
Constructing new winter facilities at Colter Bay makes no
sense because the facilities at Flagg Ranch are currently under
utilized.
Construction new winter facilities at Colter Bay would
negatively effect lynx habitat.
If the park service does not plow the road from Colter to
Flagg it will result in longer EMS response times.
[FR Doc. 00-30998 Filed 12-21-00; 8:45 am]
BILLING CODE 4310-01-P
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