BlueRibbon Coalition BRC: Only 4 Days Left to Comment On the Yellowstone Draft Winter Use Plan / Deis

Date: 07/14/2011

Dear Action Alert Subscribers,
Just a quick reminder, there are only four days left to comment on the Yellowstone National Park Draft Winter Use Plan and Draft Environmental Impact Statement (Draft Plan/DEIS). (Read our previous alert here) If you haven't already sent in comments, please take just a minute and do it now. The public comment period for the Draft Plan/DEIS ends July 18, 2011, and it is extremely important that the National Park Service hear from you.
BlueRibbon has formed the Yellowstone Task Force which is made up of state and national snowmobile leaders, the snowmobile industry, commercial tour operators, representatives from the affected gateway communities, and elected officials at the county and state level. These groups have reviewed the plan and DEIS, and have suggested comments. Snowmobile enthusiast NEED to comment on the DEIS, and if you have ever been to Yellowstone, we need you to comment regarding your experience.
NOTE: Please be polite and, if possible, make your comment letter as personal as you can.
STEP 1: Click on the following link, which will take you to the NPS comment webpage.
Read and follow the instructions for completing the Comment Form.
STEP 2: Use the comments 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.
You may also comment by mail to: Yellowstone National Park, Winter Use DEIS, P.O. Box 168, Yellowstone NP, WY 82190.
NOTE: Comments may be submitted through the NPS website, by mail or hand delivered to park headquarters in Mammoth Hot Springs, WY. Comments will not be accepted by fax, email, or in any other way than those specified above. Bulk comments in any format (hard copy or electronic), submitted on behalf of others, will not be accepted. In addition, comment letters will only be accepted one comment letter per envelope!
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.
* Snowmobiles have been used to access Yellowstone National Park for over 45 years and should continue to provide a special form of winter transportation.
I understand that, when the National Park System was created by Congress, there was a dual mandate that the Park Service: "promote" and "provide for the use and enjoyment" of park resources, and "leave [the park resources] unimpaired for the enjoyment of future generations." These are coequal, yet sometimes conflicting, mandates that require the NPS to balance both interests when making management decisions.
The Park Service needs to be more user friendly for both snowmobile and snowcoach operators and visitors. The proposed preferred Alternative 7 is too limiting and more restrictive than in the past. This seems to happen with each new EIS process. What is the true goal of the Park Service for Yellowstone National Park and its winter use?
* In the preferred Alternative 7, the number of daily entries into the Park ranges from 110 to 330; these numbers are too low. A range of 400 to 440 would be more reasonable.
The current recommendation of variable limits with a maximum of 330 daily entries is too low. If the Park Service wants to provide opportunity for both commercially guided and non-commercially guided snowmobile access to the Park, the range of daily entries should to be increased to between 400 to 440 per day. Per the DEIS this daily entry range shows no adverse effects to the Park resources.
An entry cap creates actual lower daily entry numbers. How does the daily entry cap do this? It is nearly impossible to fill to the last snowmobile when there is a cap. If the cap were 20 per operator for West Yellowstone, as an example in 2010-11 season, and if the fill rate on average was only 77% of the 20 cap, or 16, resulting in a loss of 4 entries into the Park, it would appear that the demand for entry into the park was down. However, the reason could be a group of five riders wanted to go together and you had only 4 machines left.
* Non-commercially guided access to the Park needs to be considered. The final alternative with increased daily limits needs a system to allow individuals to become certified non-commercial guides.
Not included in the preferred alternative is non-commercial guiding. Many potential visitors would like to guide their own family and not be forced to pay a commercial guide. The cost of renting snowmobiles, most likely rental of clothing and the cost of a commercial guide, limits the affordability for many families. If you remove the guide fees the family Yellowstone trip becomes more affordable. If the family has BAT machines and clothing it is very cost effective.
Looking back at an earlier final EIS decision for the 2004 season, the Park Service had a system including reservations and online training for non-commercial guided groups. That decision was never given a chance. The reason it never had a chance to work was a court action that enjoined the decision for the 2004 season and forced a special regulation to reopen the Park.
* Limiting daily entry into the Park to before 10:30 am will not work and could provide a negative experience for Park visitors.
I feel this will cause bunching, which could lead to a crowded condition. It causes concentration of snowmobile and snowcoach traffic. It seems that the resources would be protected better by dispersing traffic rather than consolidating it. I would like to be able to enter the Park with a group for a half day trip starting at noon.
If I have to enter the Park before 10:30 am this would limit my options to see the Park. I want to have the option of arriving later that 10:30am: so why inflict one more limitation and reason not to come and visit the Park in winter.
What happens when the temperature at 10:30 is 20 below and the Park Service will not allow entry into the Park? Will the Park be closed all day even if at 11:30 the temperature is now only 10 below? The 10:30 entry program will not work!
* The variety of use levels concept with a range from 110 to 330 daily entries a day is too difficult for winter visitor to plan their trips.
Snowmobile and snowcoach operators need to be able to select peak-use days and non-peak-use days according to supply and demand, not the National Park Service variety of use levels concept. In addition, the winter visitor would have great difficulty in planning their winter vacation trip to Yellowstone with the variety of use concept.
The variable use limit concept is too restrictive, and it will result in a loss of 5,728 visitor snowmobile machine days compared to last year. I figured last year's limit at 318 and variety of use levels concept of 110 to 330 as proposed in Alternative 7, both at full usage of the available entries; the difference was 5,728 less machines in the Park, therefore a major decrease.
* The closure of many side roads in Yellowstone to snowmobiles and snowcoaches will eliminate much of the Yellowstone experience!
Using side roads in Yellowstone, like the Fire Hole Falls Road, provides a special experience in the Park. The current system of snowcoaches having all day access and snowmobiles only having access in the afternoon works very well on the Fire Hole Falls side road.
Many of the side roads that are currently open to snowmobiles are so close to the main roads that not allowing snowmobiles access to those side roads will have no effect on the sound level and will force snowmobile groups to pull off on the main road instead of the safer side roads to view wildlife!
* Issues related to quiet times should really be quiet places in Yellowstone. The entire east side of the Grand Loop is very quiet and could easily provide that level of quiet! Important to note, only with transportation--be it snowmobile or snowcoach--could a person enjoy the quiet of the east side of the Park!
* NOx standards for snowmobiles are not part of the current EPA regulations and, in fact, NOx regulations once proposed by the EPA were removed by the courts. NOx is not a significant emission in winter and should not be regulated by the Park Service!
Important to note, the National Park Service lacks authority to set a BAT NOx standard. It is established law that the EPA has the exclusive authority to regulate source emissions under the Clean Air Act (CAA). Moreover, EPA already has adopted standards governing snowmobiles.
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Note: Please add my name to the Yellowstone Winter Use mailing list and keep me informed as the EIS process moves forward.

The BlueRibbon Coalition is a national recreation group that champions responsible recreation, and encourages individual environmental stewardship. With members in all 50 states, BRC is focused on building enthusiast involvement with organizational efforts through membership, outreach, education, and collaboration among recreationists. 1-800-BlueRib -
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