OK, let's take a little longer look at the winter use plan Yellowstone officials are proposing, even if their thoughts are just in the "preliminary" mode right now.
Under the Draft Winter Use Environmental Impact Statement they posted today, Yellowstone officials want to allow up to 720 snowmobiles and 78 snow coaches in the park on a daily basis. At the same time, they believe 140 per day should be allowed in neighboring Grand Teton National Park.
All of these vehicles would have to employ "Best Available Technology" to limit pollution, and guides would be required for snowmobilers.
Ironically, this document surfaced just days after a series of studies came to light that left no doubt that snowmobiles -- even BAT machines -- were polluting the park's air. And yet, in this draft document Yellowstone's researchers don't mention impacts to air quality at all when discussing the cumulative effects of their preferred alternative.
In fact, they don't mention --or I haven't yet found it -- any pollution consequences of this decision, nor the impacts on employees, visitors or wildlife.
What they do mention is that the park's fuel bill could go up, that there could be unspecified renovations of the Old Faithful Inn, construction of a new West Entrance facility as well as an Old Faithful Visitor Education Center, and the park could incur the costs of howitzer ammunition for avalanche control.
Now, I still haven't sifted through each and every of the more than 400 pages that comprise this draft document, so I'm not entirely sure how park officials came to their conclusion that allowing nearly three times the current average of snowmobiles to enter Yellowstone on a daily basis will have "minimal" impacts when the latest air quality studies state that even "best available technology" snowmobiles "are much dirtier than light-duty cars and trucks."
To their credit, park officials are stressing this document is not the final word. Just the same, I am puzzled a bit by this draft, particularly in light of the pledge by both Interior Secretary Dirk Kempthorne and National Park Service Director Mary Bomar that conservation of resources is the prime mandate of the Park Service.
I'm not the only one, either.
"Given what the park's own scientists are reporting on the park's websites, I simply cannot understand how the Yellowstone staff can select a preferred alternative that calls for 720 snowmobiles a day in the park," Rick Smith, a member of the Coalition of National Park Service Retirees, told me. "That number, an almost three-fold increase over the daily average of the last three years, will certainly exacerbate the noise problems that the studies note, significantly increase the amount of pollution in the park, increase the potential hazards to visitor and employee health and safety, and is very likely to increase the percentage of wildlife that already show stress from snowmobile use."
Jon Catton, a Bozeman, Montana-based conservationist who long has followed the snowmobile debate, share's Smith's concern.
"The administration has spent millions of dollars to learn conclusively how the Park Service can provide winter access to Yellowstone and maintain the best air quality and the best conditions for wildlife and quiet atmosphere for visitors who want to enjoy the park's sounds," he says. "And this proposal today says, 'We know how to do it, but we're not going to. Instead we're going to emphasize snowmobiling despite knowing beyond a shadow of a doubt that it's not the best we can do for air quality, for enjoyment of Yellowstone's sounds,' and that's sad."
Some Administrative Background
What makes today's announcement so disconcerting? As I said last week when discussing the latest round of air-quality studies, if the Park Service can turn its back on Yellowstone when it comes to appropriate uses and impacts to resources, what park is immune?
Let's take stock of the Park Service's administrative landscape. It's easy to do, as the agency posts all the pertinent documentation regarding its responsibilities on its web sites. In fact, many of the regulations that govern how Yellowstone officials should manage their park when it comes to impacts are laid down in the Temporary Winter Use Plan Environmental Assessment that was published back in August 2004.
For starters, near the bottom of page 9 of that document and continuing on the top of page 10 it states that under the National Park Organic Act and the Redwood Act that later affirmed that document, "the Secretary of the Interior has an absolute duty, which is not to be compromised, to fulfill the mandate of the 1916 Act to take whatever actions and seek whatever relief as will safeguard the units of the National Park System." (My emphasis)
OK, that's the boiler plate language that is supposed to guide Dirk and Mary. On top of that, if you scroll on down to page 10 you'll notice that the federal Clean Air Act, when it comes to preserving air quality in national parks, requires federal land managers to "assume an aggressive role in protecting the air quality values of land areas" and to "err on the side of protecting the air quality-related values for future generations." (My emphasis)
Keep scrolling, down to page 14, and you come to the Park Service's own Management Policies air quality language, which mimics the Clean Air Act when it says that "the Service will assume an aggressive role in promoting and pursuing measures to protect these values from the adverse impacts of air pollution. In cases of doubt as to the impacts of existing or potential air pollution on park resources, the Service will err on the side of protecting air quality and related values for future generations." (My emphasis)
So with that administrative background, which leaves no question as to the Park Service's mission and responsibilities, why is the agency not erring on the side of the resources? Why is Yellowstone, even in a draft document, settling on a winter-use alternative that is not the least polluting when it knows that another alternative -- that of snow-coach only traffic -- would be cleaner and quieter on the park?
Back to the Science
No one is asking that winter-use be banned from Yellowstone. That's not going to happen, no one wants that to happen. All anyone is asking is that the park's resources -- the water, air, the soundscapes, the wildlife, employees and visitors -- be protected as much as possible.
In the case at hand, the evidence is incredibly strong that the snowmobile option is not in the best interests of those resources.
I already provided you with links to the latest air-quality science. Now let me leave you with one more scientific tidbit, one contained in the "Modeling Sound Due to Over-snow Vehicles in Yellowstone and Grand Teton National Parks" report issued just last month. Way down near the bottom of the report, on page 49 (although your Acrobat Reader might indicate page 84) is a chart that reflects the extent of noise associated with the six alternatives under consideration for the Winter Use Plan.
Alternative 2 is the "Best Available Technology" snow-coach only plan, while Alternatives 1E, 1D and 1B would allow 720 BAT snowmobiles per day. What the chart reflects is the percentage of the park in which you'd be able to hear over-the-snow vehicles 50 percent of an eight-hour day under the various alternatives.
Now, just looking at the chart, there doesn't appear to be any appreciable difference between Alternative 2 and Alternative 1E.
But here's the deal: Under Alternative 2, during 50 percent of your day you'd hear snow coaches in roughly 1 percent of the park, a percentage that translates into some 22,000 acres, or about 34 square miles.
In a park of 2.2 million acres that doesn't seem terrible. But keep in mind that during the winter months Yellowstone's visitation is extremely congregated around Old Faithful, the West Entrance, the Grand Loop Road. In essence, there's very little room for you to escape the sound.
Under Alternative 1E, in about 2 percent of the park -- or some 68 square miles -- you'd hear snowmobiles and snow coaches 50 percent of your day.
Again, is Yellowstone erring on the side of the resources with this proposed preferred alternative?
"Yellowstone is a great park, perhaps our nation's greatest," says Rick Smith. "It deserves our most sensitive care. I just don't see how permitting snowmobile use meets that standard of care."
Neither do I.