March 2, 2012

Comments Needed On SEIS Scoping Alternatives For Winter Use In Yellowstone National Park






SITUATION
The National Park Service (NPS) has released a preliminary range of draft alternatives concerning winter use in Yellowstone National Park for public review and comment. These alternatives are key to the development of a new draft Supplemental Environmental Impact Statement (SEIS). The scoping process is the first step in the creation of the Draft SEIS that will be available for public review and comment in late April, 2012. This Draft SEIS will lead to a Final SEIS in September 2012 and the formal adoption and implementation of a proposed rule governing Yellowstone Winter use late this fall.

The public comment period for the proposed rule ends March 9, 2012, and it is extremely important that the National Park Service hear from you.

SNOWMOBILERS, YOU NEED TO COMMENT BY MARCH 9

The National Park Service intends to have a final EIS, a Record of Decision and a final rule guiding winter use in place before the start of the 2012-13 winter season.

For up-to-date information on the Yellowstone Winter Use issue, visit www.saveyellowstonepark.com

WHAT YOU NEED TO DO:

Listed below are possible areas to comment on. Each area has an asterisk (*) with a comment subject which you can expand on. To help with expanding your comments, there is information listed under that comment subject. This information gives some background to help with your commenting. (Please note these bullet comments can be arranged in any order.)

BRC'S THREE-STEP ACTION ITEM

STEP-BY-STEP INSTRUCTIONS ON HOW TO SEND YOUR COMMENTS:

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

STEP 1: Click on the following link, this will take you to the scoping site and an electronic form for submitting written comments.http://parkplanning.nps.gov/commentForm.cfm?documentID=45665. Just read and follow the instructions.

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

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

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

Optional: 

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

IMPORTANT NOTE: 

Written comments may be submitted through the website, in person or by mail. Comments will not be accepted by phone, fax or e-mail. No bulk comments will be accepted. In addition, comment letters will only be accepted one comment letter per envelope. Due to the project's time schedule, the National Park Service will not entertain any requests to extend the comment period.

COMMENT SUGGESTIONS:

It is important to again include a one-year (or more) transition period after the SEIS is completed in late Fall of 2012. Having a decision made on winter access to Yellowstone Park within a very short period, possibly only 30 days before the 2012-13 season begins, would be a hardship on the snowmobile operators getting equipment ready and the general public scheduling their vacations. 

Comments on Preliminary Range of Draft Alternatives

*ALTERNATIVE 1 - No Action - Park would close to snowmobile/snowcoach use starting with 2012-13 season. When creating the National Park System, Congress mandated that the Park Service: (a) "promote" and "provide for the use and enjoyment" of Park resources and (b) "leave unimpaired for the enjoyment of future generations." These are co-equal, yet sometimes conflicting, mandates that require the NPS to balance both interests when making management decisions. The Park Service needs to provide for snowmobile and snowcoach access to Yellowstone National Park in the winter.

*ALTERNATIVE 2 - Continue Snowmobile/Snowcoach use at 2008 limits. - This could be part of a long range plan for increased access to the Park. With the development of the Non-Commercially Guided concept and additional review by the Park Service, the snowmobile community could be better serviced.

In the case of allowing only ONE Non-Commercially Guided group a day, from all gates, would not be a true pilot program. To properly evaluate the non-commercially guided concept there should be one non-commercially guided trip allowed from each current snowmobile operator a day. In addition, a review of the base allocation for snowmobile operators should be considered with an increased allocation by the non-commercially guided group numbers to each outfitter, the approximate total increase of approximately 120 a day. The new base number for snowmobile allocations per day would be 438. Sylvan Pass would be open to oversnow vehicles.

In the case of the training and education of non-commercial guides, a partnership with the American Council of Snowmobile Associations (ACSA) with resources for training materials and the International Snowmobile Manufacturers Association (ISMA), with their "Safe Rider Program." Commercial Guides should be counted as "administrative travel."

*ALTERNATIVE 3 - Mixed-Use Snowcoaches, Snowmobiles and Road Plowing for Wheeled Vehicles - This concept has been studied and additional review will show that it is not viable and would not provide positive visitor experiences. The cost and wear on Yellowstone Park 's roads would be unacceptable.

*ALTERNATIVE 4 - Transition to BAT Snowcoaches only - The future development of BAT requirements for snowcoaches continues to be in question. It would cost an estimated $5,900,000 to upgrade the current fleet to "highway EPA standard." The creation of a science based BAT for snowcoaches will require many years of development. A "New Snowcoach" may be the only viable option to meet these standards.

*ALTERNATIVE 5 - Sound Event Management - The name of this concept would be changed to "Visitation Events" this name change reflects the entire range of issues surrounding trips into the Park by snowmobile or snowcoach, e.g. concerns on sound, emissions and wildlife encounters. This concept needs more study, and will take a long time to develop. The current snowmobile fleet used in the Park meets a BAT standard that used the EPA standard for snowmobiles, and that BAT was created by tightening EPA standards. The BAT process for snowmobiles, including the EPA's process, took approximately 12 years to develop.  There are no EPA standards for current snowcoaches and the BAT development will take many years to develop and implement. How can this concept of "Sound /Visitation Event Management" be applied until snowcoaches have a BAT standard and have complied with that standard? Sylvan Pass would be open to oversnow vehicles.

Closing the first two weeks and last two weeks of the season to snowmobiles and non-rubber tracked snowcoaches would not provide for the visitor experience that was desired. In addition the ability to provide groomed roads after two weeks of limited plowing and/or rutting of roads would be very difficult and should be studied based on past history. It would be unfair to require current operators to provide both snowmobile and snowcoach trips into the Park, resulting in a negative effect on the Gateway communities that serve the Park.

Not allowing use of snowmobiles and snowcoaches in Park during the first two weeks and last two weeks of the season would have a negative impact on over snow operators and visitors. In addition, on December 15-29, there would be transition days in between as you cannot keep the roads plowed one day and run oversnow traffic the next. There would need to be time for snow to be plowed back onto the road and groomed over a series of days in order to build a useable base for snowcoaches and snowmobiles to operate on safely and effectively. In the March 1-15 time frame there would need to be transition days for plows to break through the thick ice and snowpack that regularly happens. This would take place before commercial wheeled or rubber-tracked vehicles could be used.

*ALTERNATIVE 6 - Sound/Visitation Event Management Limits with Vehicle Limits - This concept needs more analysis and study. Again, as commented on in Alternative 5, does the "one snowcoach equal 7 snowmobiles in one group" use the current non-BAT snowcoach vs. 7 BAT snowmobiles? Or will it only come into play when BAT for snowcoaches is established and implemented? Note: Today some snowcoaches can carry up to 30 people vs. 14 snowmobile riders in a group of 7 which should be increased to 10 machines. What about issues related to the number of passenger carried by a snowcoach as compared to snowmobiles only carrying two riders? In addition, road grooming and snow compaction needs to be studied in its entirety. The cause of rutting of groomed roads need to be identified and corrected. Sylvan Pass would be open to oversnow vehicles.

In addition, it is unfair to require snowmobile operators to provide both commercial snowcoach and snowmobile guides for trips into the park. There needs to be a program that allows sharing of Sound/Visitation events among operators at each gate to meet the publics demand. The economic impact of this requirement should be studied with more detail provided in the draft SEIS. What would be a phasing period? These issues need to be analyzed in the draft SEIS process. How long will it take to develop BAT for snowcoaches? How much will it cost? How will the current fleet of historic snowcoaches owned by the Park Service, and operated by Zantara, fit into BAT for coaches?

*ALTERNATIVE 7 - Variable Use Across Park and Winter Season - This is not workable in the manner presented. In the case of nitrogen oxide (NOx) emissions from snowmobiles, the Park Service does not have the authority to regulate this. The EPA has stated that (NOx) regulation is not need in a winter setting.

Please add my name to the Yellowstone Winter Use mailing list and keep me informed as the Proposed Rule process moves forward.

Sincerely,

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