BlueRibbon Coalition BRC: Only 5 Days Left To Comment On Proposed Rule Concerning Winter Use In Yellowstone

Date: 09/01/2011

Only 5 Days Left To Comment On Proposed Rule Concerning Winter Use In Yellowstone
Dear Action Alert Subscribers,
Just a quick reminder, there are only five days left to comment on the proposed rule concerning winter use in Yellowstone National Park. (See previous alert below.) If you haven't already sent in comments, please take just a minute and do it now. The public comment period for the proposed rule ends September 6, 2011, and with the Labor Day weekend coming up, it is extremely important not to wait any longer. The National Park Service needs to hear from you.
Thanks in advance for your support,
Jack Welch
Special Project Consultant
BlueRibbon Coalition
Dear Action Alert Subscribers,
The National Park Service (NPS) has released a proposed rule concerning winter use in Yellowstone National Park for public review and comment. The rulemaking process is in addition to, but separate from, the public review and comment period on the Draft Environmental Impact Statement (Draft EIS) for the park's winter use plan, which was released for public review and comment in early May.
The public comment period for the proposed rule ends September 6, 2011, and it is extremely important that the National Park Service hear from you.
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 2011-2012 winter season.
For up-to-date information on the Yellowstone Winter Use Issue, go to our website
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.)
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 proposed rule and an electronic form for submitting written comments.!documentDetail;D=NPS-2011-0006-0001 Click on the Submit a Comment button in the upper right corner and following 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.
You may also comment by mail to: Yellowstone National Park, Winter Use - Proposed Rule, P.O. Box 168, Yellowstone NP, WY 82190.
NOTE: Written comments may be submitted through the website, in person, or by mail. Comments will not be accepted by phone, fax, or email. 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.

*The Proposed Rule seeks to close many side roads in Yellowstone to snowmobiles and snowcoaches. This closure 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 allowing snowcoaches all day access and limiting snowmobile access to 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 preventing snowmobile access to those side roads will have no effect on the sound level. It will also force snowmobile groups to pull off on the main road instead of the safer side road to view wildlife.
*The concept of varying daily Park entries by snowmobiles ranging from 110 to 330 makes it extremely difficult for winter visitors to plan their trip.
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's 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. Calculations based on the 2010 limit of 318 vs. the variety of use levels concept of 110 to 330 as outlined in Proposed Rule will create an unacceptable decrease of 5728 machines able to enter the Park.
*The concept of non-commercially guided access to the Park needs to be considered in the Proposed Rule. The final alternative, with increased daily limits, needs a system to allow individuals to become certified non-commercial guides.
Not included in the Proposed Rule is non-commercial guiding. Many potential visitors would like to guide their own family and not be forced to pay a commercial guide. The added cost of a commercial guide limits the affordability for many families.
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 system was never afforded the opportunity to demonstrate its value because the court action that enjoined the decision for the 2004 season forced a special regulation to reopen the Park that neglected to include that well conceived provision.
*In the Proposed Rule, the number of daily entries into the Park range from 110 to 330; these numbers are too low. A range of 400 to 440 would be more reasonable.
The current recommendations 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 inherently creates lower daily entry numbers because it is nearly impossible to fill to the last snowmobile when there is a cap. For example: Under the 2010-2011 season cap of 20 per operator for West Yellowstone and the average fill rate of only 77% of that cap (or 16 riders per trip) results in a net loss of 4 potential entries into the Park. It is assumed from the numbers that the demand for entry into the park was down. However, this is not always the case. Often, the reason is that a group of five riders wanted to go together with only four slots available.
*The Proposed Rule limiting daily entry into the Park to before 10:30 am will not work and could provide a negative experience for Park visitors.
This bunching or concentration of snowmobile and snowcoach traffic will lead to an unsafe and unsatisfactory crowded condition, especially as a result of initial entry. The resources would be protected better and safety better served by naturally allowing and dispersing traffic rather than consolidating it in such a short time frame. Many would like to be able to enter the Park with a group for a half-day trip starting at noon.
Forcing visitors to enter the Park before 10:30 am, limits visitor options to see the Park. Actively limiting the option of arriving later than 10:30 a.m. wrongly inflicts yet another 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 Proposed Rule sets up a NOx standards for snowmobiles that 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!
*The Proposed Rule fails to note that snowmobiles have been used to access Yellowstone National Park for over 45 years and should continue to provide a special form of winter transportation.
The National Park System was created by Congress with 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--coexisting mandates that require the NPS to balance both interests when making management decisions.
The Park Service needs to be more user friendly for historical access into Yellowstone National Park by both snowmobile and snowcoach. The Proposed Rule is too limiting and more restrictive than in the past. This trend of restriction is furthered with each new EIS process. This is not the intended goal of Congress when the Park was created and should not be the goal of the Park Service for Yellowstone National Park, including winter use.
*Please add my name to the Yellowstone Winter Use mailing list and keep me informed as the Proposed Rule process moves forward.

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