NPS Record of Decision regarding winter use in Yellowstone and Grand Teton - Frequently Asked Questions
Thanks to Kurt Repanshek at National Parks Traveler for forwarding this along. Today, the National Park Service (NPS) released its Record of Decision on winter use in Grand Teton and Yellowstone National Parks. As expected, the number of snowmobiles allowed in the park has been lowered from 720 per day to 540 per day. Not as expected, Sylvan Pass will remain open whenever there is not an avalanche risk. What follows below is the NPS responses to "frequently asked questions" on their decision.
FREQUENTLY ASKED QUESTIONS - NOVEMBER 20, 2007
Update on Winter Use Planning in Yellowstone and Grand Teton National Parks and the John D. Rockefeller, Jr. Memorial Parkway
WHERE ARE WE IN THE PLANNING PROCESS, AND WHAT HAPPENS NEXT?
Mike Snyder, the Regional Director of the National Park Service, signed the Winter Use Plans Record of Decision for Yellowstone and
National Parks and the
The Record of Decision (ROD) implements most elements of the preferred alternative in the Final Environmental Impact Statement (EIS) that was released in late September. The Final EIS disclosed the environmental impacts of various alternatives but did not make a final decision on the issue being evaluated. The ROD is the document that contains the final decision on winter use management for the parks and explains the rationale behind the decision.
Because the Regional Director's decision involves changes to the rules governing winter use in the parks, publication of a Final Rule in the Federal Register is necessary. The National Park Service plans to publish a Final Rule to implement this Record of Decision in the Federal Register in the very near future, and expects the parks to open for the winter 2007-2008 season as scheduled on December 19, 2007.
The ROD can be found at the National Park Service's Planning, Environment and Public Comment (PEPC) website at
The ROD is also available on CD or in hard copy by writing the Winter Use Planning Team,
WHAT HAPPENS THIS WINTER?
Operations will continue this winter under essentially the same rules that were in effect the past three winters.
The daily entry limits by entrance for
Entrance Commercially guided Commercially guided
BAT snowmobiles snowcoaches
West Entrance 400 34
South Entrance 220 10
East Entrance 40 2
North Entrance 30 14
Old Faithful 30 18
Total 720 78
Yellowstone will conduct avalanche control operations this winter to allow motorized oversnow travel on the East Entrance road across
WHAT CHANGES TO RECENT SNOWMOBILE AND SNOWCOACH USE WILL OCCUR IN
First of all, some things will not change. All snowmobiles in
Fifty snowmobiles a day will be allowed on the one-mile long
Road into the park's southwestern corner. There will be no BAT or guiding requirement on this section of road.
The daily entry limits by entrance for
Entrance Commercially guided Commercially guided
BAT snowmobiles snowcoaches
West Entrance 300 37
South Entrance 170 10
East Entrance 30 2
North Entrance 20 15
Old Faithful 20 19
Total 540 83
* The totals do not reflect the 50 snowmobiles allowed on the
The decision calls for
Beginning with the 2008-2009 winter season, snowmobile and snowcoach travel over
The National Park Service will continue to work with the State of
WHAT CHANGES IN USE WILL OCCUR IN
Twenty-five snowmobiles a day will be allowed to travel on the
Forty unguided, BAT snowmobiles a day will be allowed on
Beginning with the 2011-2012 season, all snowcoaches operating in the parks will be required to meet BAT emission and sound level requirements. This requirement, like that for snowmobiles, is intended to further improve
WHAT IMPACT WOULD THESE NEW DAILY LIMITS FOR SNOWMOBILES AND SNOWCOACHES HAVE ON THE COMMUNITIES NEAR
Last winter, we averaged 290 commercially guided, BAT snowmobiles and 34 commercially guided snowcoaches entering the park per day. The ROD will allow 540 commercially guided BAT snowmobiles and 83 commercially guided snowcoaches to enter the park each day. We believe this provides the potential for economic growth for the communities serving winter visitors to
WHY DOES THE RECORD OF DECISION ALLOW MORE SNOWMOBILES TO ENTER
It doesn't! The ROD will allow fewer snowmobiles in
Under the temporary rules, up to 720 commercially guided BAT snowmobiles were allowed per day in
This limit is similar to our peak day last year (542 on 12/28/2006) but will allow for some increase in use from last winter's average of 290 snowmobiles a day. The limit is also a substantial reduction from the historic average of 795 snowmobiles entering
WHY DOES THE RECORD OF DECISION REDUCE SNOWMOBILE NUMBERS TO 540 A DAY? WHY NOT STAY WITH 720 A DAY LIKE YOU'VE ALLOWED THE PAST THREE WINTERS, AND WHICH YOU SUPPORTED IN THE DRAFT EIS?
The ROD reduces the maximum number of snowmobiles allowed in the park from 720 to 540 per day as a means to better protect park resources.
There's no question we've seen significant improvements in air quality, fewer wildlife disturbances, and a reduction in sound impacts with the managed, limited use of BAT snowmobiles the past three winters when compared with historic, unregulated use. We've now had three full winters to collect and analyze data from limited, managed use. This has helped us refine the models used to analyze the impacts of a variety of alternatives involving oversnow vehicles.
Further analysis and modeling have shown that reducing snowmobile numbers from 720 to 540 a day is one of several actions we need to take in order to better address resource protection, especially sound impacts. Even at current levels of use (290 snowmobiles per day, 32 coaches per day), sound levels were higher than expected, and snowcoach and snowmobile vehicle sounds could be heard for longer periods of time than expected. Monitoring thresholds are already exceeded.
During the winter of 2005-2006, oversnow vehicles were audible on a daily basis consistently between 60% and 80% of the time at
At Madison Junction, snowmobiles and snowcoaches were audible for an average of 55% of the time during the winter use season, exceeding the temporary plan audibility threshold of 50% for travel corridors. The percent time audible for 18 (75%) of 24 days analyzed exceeded 50% (FEIS p. 145). Also at Madison, the sound levels from oversnow vehicles exceeded the Temporary Plan maximum sound level impact definition threshold (70 dBA) during most of the hours of the measurement day (8 a.m. to 4 p.m.) in 2005-2006 (FEIS p. 147).
Finally, oversnow vehicles on the groomed
Reduced snowmobile numbers will also help protect
Regarding wildlife, oversnow vehicle activities may cause a wide range of responses from wildlife with effects at differing scales. For example, collisions between oversnow vehicles and wildlife can cause direct mortality, while single or repeated interactions between such vehicles and wildlife could lead to energy expenditures from flight reactions.
Additionally, exposure to natural (such as wind) or human caused (such as oversnow vehicle traffic) noise may result in a listening area reduction.
Animals can be displaced from important habitats by human activity, or they can experience less obvious effects like elevated heart rate and metabolism which, in turn, can result in high energy expenditures, elevated production of stress hormones, increased susceptibility to predation, decreased reproduction, and diminished nutritional condition. Thus, it is fair to assume that higher oversnow vehicle traffic would result in more frequent responses by, or stress to, wintering wildlife (from FEIS pp. 249-250; see the FEIS for the pertinent citations).
Finally, a substantial portion of the 122,000 comments filed on the Draft EIS in 2007 supported reduced snowmobile numbers, BAT, and 100% guiding for them if the NPS were to continue to allow them (North Wind, Inc., Public Comment Report on Winter Use Plans DEIS, 2007, p. 6, available at http://www.nps.gov/yell/parkmgmt/winterusetechnicaldocuments.htm ).
HOW CAN YOU SUPPORT ALLOWING 540 SNOWMOBILES A DAY WHEN YOU'RE ALREADY EXCEEDING ADAPTIVE MANAGEMENT THRESHOLDS FOR SOUND AUDIBILITY WITH MUCH LOWER SNOWMOBILE NUMBERS?
First, let's back up a bit. BAT snowmobiles are about ten decibels quieter than 2-stroke machines. At 50 feet, the sound of a 4-stroke snowmobile traveling at 30 miles an hour is about as loud as normal conversation in an office or home.
Requiring the use of BAT snowmobiles, placing limits on the number of snowmobiles, and keeping snowmobiles together in guided groups have all reduced overall audibility in the parks compared to unregulated, historic use.
But the question is valid. As noted above, monitoring data shows that even with these improvements, there are times we've exceeded the sound thresholds at current snowmobile and snowcoach use levels, especially in some of the busier travel corridors such as the route from West Yellowstone to
That same monitoring data shows that the reason sound levels have been higher than expected is mainly due to certain models of older snowcoaches. Since they were designed and built many years ago, some of these snowcoaches are louder than their modern counterparts. Administrative use of oversnow vehicles like grooming machines and some 2-stroke snowmobiles also added to the few occurrences when the thresholds were exceeded.
Modeling shows that by upgrading the older snowcoaches to meet modern sound and emission standards, limiting the total number of oversnow vehicles to 540 BAT snowmobiles and 83 BAT snowcoaches a day, and requiring that all administrative snowmobile use utilize BAT snowmobiles will result in lower sound levels than those measured under the level of oversnow vehicle use experienced the past three winters.
Also, the ROD includes an Adaptive Management Program. If monitoring of use levels of snowmobiles and snowcoaches allowed under the ROD indicates acceptable conditions, the NPS will increase use levels to the extent acceptable conditions can be maintained. Conversely, if monitoring of use levels of snowmobiles and snowcoaches allowed under the ROD indicates unacceptable conditions, the NPS will reduce use levels to the extent acceptable conditions can be maintained.
BUT WOULDN'T MORE SNOWMOBILES AND MORE SNOWCOACHES THAN RECENT USE LEVELS IMPAIR AIR QUALITY IN
Air quality has been a big issue regarding winter use in the parks. Yellowstone and
During historic times of unregulated use, an average of 795 two-stroke machines entered
Best Available Technology (BAT) four-stroke machines are much cleaner than the old two-stroke machines. Use of BAT snowmobiles and an overall reduction in snowmobile numbers are two reasons why
BAT snowmobiles are also much cleaner than the older, carbureted engines still in use in some snowcoaches. That's another reason the ROD calls for a BAT emissions requirement for snowcoaches.
While there would be a small increase in emissions if the number of motorized oversnow vehicles increases from recent use levels to the maximum number allowed under the ROD, this increase will not result in any impairment of park air quality. All measures of air quality for pollutants, particulates and visibility are predicted to be well below Federal,
As noted above, concerns remain about benzene levels. One of the tradeoffs with four-stroke machines is that they produce more benzene and some other hazardous air pollutants than the two-stroke engines used historically. With visitation only near 250 snowmobiles per day, two benzene samples at the West Entrance were still near recommended exposure limits (FEIS p. 99). In part for this reason, the NPS will continue air quality and personal exposure monitoring and take steps via the adaptive management plan to remedy any continuing problems with snowmobile emissions.
Reducing the maximum number of oversnow vehicles to 540 BAT snowmobiles and 83 BAT snowcoaches a day helps us ensure air quality standards and personal exposure goals are met.
WHAT ABOUT SNOWMOBILE IMPACTS TO WILDLIFE?
Park scientists have studied the effects of winter use on wildlife since 1999. The maximum number of snowmobiles entering through the park's West Entrance during that period ranged from 324 to 1,874 machines a day. Analysis of the data show this level of winter use did not contribute to wildlife disturbance at the population level. The ROD calls for snowmobile numbers well below the maximum number experienced during the study period.
An analysis of data from the past 35 years shows no evidence that snowmobile use has affected the population dynamics or demographics of bison, elk, bald eagles, or trumpeter swans in
These same studies further show that most animals pay little attention to people on snowmobiles or in snowcoaches, often reacting by doing nothing more than turning their heads. The odds of bison or elk actively responding to the presence of people were somewhat greater when snowcoaches were present.
Finally, the wildlife analysis in the Final EIS demonstrated that the snowmobile and snowcoach limits specified in the ROD would have no greater impacts upon wildlife than if the ROD called for a conversion to snowcoaches only.
As with air and noise monitoring, the NPS will continue wildlife monitoring and take steps via the adaptive management plan to remedy any continuing problems with winter visitor impacts upon park wildlife.
DOES GROOMING OF THE ROADS FOR OVERSNOW TRAVEL HAVE AN IMPACT ON BISON?
Recent studies have found that many factors impact bison travel and distribution throughout the park. Travel corridors are largely defined by rivers and thermal areas that connect foraging areas. The studies found no evidence that bison prefer to travel on groomed roads in the winter.
The ROD calls for implementation of a five-year research project intended to specifically address the question of whether grooming of the Madison to Norris road segment in Yellowstone has led to alterations of bison movements and distribution. The question was identified in a report by Dr. Cormack Gates et al., entitled "The Ecology of Bison Movements and Distribution in and Beyond Yellowstone National Park" (2005, available at http://www.nps.gov/yell/parkmgmt/winterusetechnicaldocuments.htm ).
The research proposal will involve a linked series of experiments that will enable researchers to gain insight into how road grooming and other factors currently affect bison travel. Initially, the research program will include the analysis of existing data on GPS-collared bison, the tracking of additional GPS-collared bison, and the deployment of cameras along travel routes to gain information on the relationship between road grooming and bison travel, without necessitating the closure of the
During the five year period, however, other roads or routes may be investigated to help understand the relationship between snow depth, grooming, and bison movement. For example, the Firehole Canyon Drive may be closed to oversnow travel and the Grand Loop Road gated in that area to allow snowmobile and snowcoach travel, but not bison movement on the main road. Bison would then be forced to travel cross country or along the ungroomed
Following the five years of data gathering and analysis, the NPS, in consultation with the researchers, will consider closing the main
WHY DO YOU WANT TO CONTINUE 100-PERCENT COMMERCIAL GUIDING IN
Because it works. Mandatory guiding under the temporary plan addressed most of the concerns regarding the impacts of historic, unregulated winter use:
- Guiding ensures that only BAT snowmobiles are used.
- The parks are much cleaner and quieter, due to Best Available Technology (BAT) machines, group size, and behavior.
- The need for closures and signage are reduced since guides know the rules. This saves ranger time and reduces visitor frustration.
- Safety has been greatly enhanced. There are fewer intoxicated or underage operators and less speeding.
- Moving violations decreased by 78% from 2002-2003 to 2006-2007, and arrests dropped from 21 to 3 in the same period, due to commercial guiding (after accounting for changing visitation numbers).
- Guides help ensure adverse wildlife encounters and habituated wildlife problems are minimized.
PUBLIC COMMENTS ON THE DRAFT EIS AGAIN HEAVILY FAVORED SNOWCOACH-ONLY ACCESS. WHY DID YOU IGNORE PUBLIC SENTIMENT AGAINST SNOWMOBILE USE A THIRD TIME?
When we first began to seriously examine ways to deal with oversnow vehicle use and impacts more than a decade ago, the alternative of a cleaner, quieter snowmobile did not exist. The only way at that time to protect the park and provide a quality visitor experience was to propose the elimination of snowmobile use in the park.
An agreement to settle a lawsuit halted the implementation of the original decision and plunged us into a new planning effort. It was during this period that manufacturers began to produce 4-stroke snowmobiles, which are much cleaner and quieter than 2-stroke machines.
During the past three winters, we've provided for limited, managed access using only cleaner, quieter, BAT snowmobiles. This has led to significant improvements in air quality and sound levels. It has improved protection of the park and improved the visitor experience.
BAT machines are not in widespread use in other areas where snowmobiles are found. We believe that the vast majority of those favoring snowcoach-only access are against returning to the unacceptable conditions that resulted from the historic, unregulated use of 2-stroke snowmobiles, not the significantly improved conditions experienced with limited, regulated use of BAT machines.
We agree with the vast majority of those who have submitted comments on this subject over the years that historic, unregulated use of 2 -stroke snowmobiles resulted in unacceptable impacts.
A large number of those submitting comments on the Draft EIS told us that if we were to continue snowmobile use in the park, we should continue to require the 100% guiding requirement and should reduce the number of snowmobiles allowed per day. In part for this reason, we reduced the maximum number of snowmobiles allowed in
The National Park Service believes that the limited, managed use of both BAT snowmobiles and snowcoaches for oversnow travel provides for a wide range of visitor experiences without impairing the integrity of park resources or values in full compliance with the Organic Act, the NPS Management Polices (2006), and the Clean Air Act.
WHAT ABOUT THE FUTURE OF SYLVAN PASS ACCESS?
We have worked with the State of
There is substantial avalanche danger on
Rangers must travel through eight to ten uncontrolled avalanche zones just to reach the howitzer. Sometimes the howitzer shells used to bring down snow banks don't go off, leaving hazardous unexploded shells (duds) that can later roll down the mountainside to the road where they pose a threat to visitors and park employees. Over the years, there have also been several instances when park employees or visitors had close calls with avalanches.
The 2000 EIS, the 2003 SEIS, and the Temporary Winter Use EA of 2004 all acknowledged the considerable risk in operating an avalanche control program at
In earlier planning processes, outside agencies including OSHA (2001) and the State of
During this latest planning effort, we had an avalanche expert produce a report on hazards and possible avalanche mitigation strategies. We also brought together a group of technical experts to analyze the risk of a range of avalanche control strategies that might be used at
We have highly trained and experienced professionals who have run a successful avalanche control program at
Yellowstone will conduct avalanche control operations this winter to allow motorized oversnow travel on the East Entrance road across Sylvan Pass, but methods used to reduce the risk of avalanche control operations this winter may result in longer temporary closures between the detection of avalanche risk and the reopening of Sylvan Pass to motorized oversnow travel compared to historic avalanche control operations.
The decision calls for
Beginning with the 2008-2009 winter season, snowmobile and snowcoach travel over
The National Park Service will work with the State of
WHY ARE YOU ELIMINATING MOTORIZED OVERSNOW ACCESS ON THE CONTINENTAL DIVIDE SNOWMOBILE TRAIL (CDST) BETWEEN MORAN JUNCTION AND FLAGG RANCH?
Last winter, just 14 snowmobiles traveled on this section of the CDST. Current or anticipated use levels do not warrant the effort or expense to keep this section of the CDST groomed and open to motorized oversnow travel.
Those interested in through travel on the CDST could transport their snowmobiles on trailers between these locations. Commercial options to transport snowmobiles between these locations may be available.
To accommodate through travel on the CDST, we will lift the BAT requirement for snowmobiles traveling west on the
WHAT ABOUT SNOWPLANES ON
The Final EIS and ROD did not reevaluate decisions about management of winter use that have already been implemented, including the prohibition of snowplanes on
WHY DID IT TAKE SO LONG TO GET A RECORD OF DECISION?
Winter use in the parks has been the subject of vigorous debate for more than a decade. The resulting planning process has been arduous and complex. These issues raised a great number of questions which needed to be adequately answered.
We're confident we have a sustainable, long term plan for winter use for the parks.
YOU SAID THE FINAL RULE HAD TO BE PUBLISHED NO LATER THAN NOVEMBER 19 IN ORDER TO GET THE PARKS OPEN FOR WINTER AS SCHEDULED. WILL THE PARKS OPEN ON TIME THIS WINTER?
The National Park Service plans to publish a Final Rule to implement this Record of Decision in the Federal Register in the very near future, and expects the parks to open for the winter 2007-2008 season as scheduled on December 19, 2007.
WHY DID YOU DO ANOTHER WINTER USE PLAN?
In short, because the two previous Environmental Impact Statements (from 2000 and 2003) were thrown out by different federal courts, leaving the NPS without clear rules to follow for winter use. To issue new rules, the agency produced a third Environmental Impact Statement (EIS) and a new long-term winter use plan, releasing the EIS on September 24, 2007. This is that plan; to allow for winter visitation while this plan was being devised, the agency issued temporary rules (and an associated Environmental Assessment) that covered the last three winters. Those rules have expired.
In more detail, the EIS of 2000 found that historic unlimited and unregulated winter use of 2-stroke snowmobiles in the parks and snowplanes on
The decision arising from the Supplemental EIS of 2003 was to allow limited, regulated use of cleaner, quieter, four-stroke (Best Available Technology) snowmobiles in the parks. That decision was challenged in federal court in
The goal of this current effort is to implement a long-term winter use plan that ensures park visitors have a range of appropriate winter recreation opportunities that do not impair or irreparably harm park resources or values, in accordance with NPS Management Polices of 2006 and all other applicable policies, rules, regulations, and laws.
DOES THE RECORD OF DECISION COMPLY WITH THE NEW NPS MANAGEMENT POLICIES?
Yes, it does.
Virtually every form of human activity that takes place within a park has some degree of effect on park resources or values. That does not mean the impact is unacceptable or that a particular use must be disallowed.
All alternatives contained in the Final EIS and the ROD are in accordance with all applicable laws, regulations, rules, and the 2006 National Park Service Management Policies.
We are dedicated to implementing the NPS mission to preserve and protect the outstanding and significant park resources while providing for high quality visitor experiences. We also remain committed to implementing what is best for the park resources, park visitors, and our employees. We will continue to work with the neighboring communities to support winter use in the greater
The NPS Management Policies of 2006 require analysis of potential effects to determine whether actions would impair park resources or cause unacceptable impacts. Managers must always seek ways to avoid, or minimize to the greatest degree practicable, adversely impacting park resources and values. Laws give managers discretion to allow impacts to park resources and values when necessary and appropriate to fulfill the purposes of the park, as long as the impact does not constitute impairment of the affected resources and values. The ROD does not constitute impairment of or unacceptable impacts to park resources.
The EIS of 2000 found that historic unlimited and unregulated winter use of 2-stroke snowmobiles in the parks and snowplanes on
THIS HAS BEEN A LONG-TERM CONTENTIOUS ISSUE. WHAT IS THE NPS GOING TO DO TO HELP BRING DIFFERENT INTERESTS TOGETHER?
The hallmark of this process has been open information sharing. A decision on winter use planning is not an end, but rather a new beginning of the park's continuing to share information and work with communities, businesses, and stakeholders. All desire to protect park resources while providing visitors with the best possible experience.
The National Park Service remains committed to working with the communities and other interested parties into the future to ensure a long-term sustainable decision for winter use in the parks.