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,
Signature
Name
Address
City, State or Province, Zip or Postal Code