What do $10 million worth of studies on the noise and pollution problems associated with snowmobiles in the world's first national park buy you?
Apparently not much, as Yellowstone's just-released draft environmental impact statement on winter use in Yellowstone and Grand Teton seemingly brushes aside not only that science, but also key sections of the Management Policies and would seem to ignore Dirk's declaration that "(W)hen there is a conflict between conserving resources unimpaired for future generations and the use of those resources, conservation will be predominant."
Sadly, the only thing that the arrival of today's hefty document settles is any doubt that the Park Service's desire to see 720 snowmobiles churning through Yellowstone will spawn yet another costly lawsuit and more years of uncertainty for winter visitors to the park.
How do you justify such extensive snowmobile access when the latest studies by Yellowstone's own researchers have documented that:
* Carbon monoxide levels are higher in the park in winter than during the summer.
* While Best Available Technology snowmobiles have reduced emissions, they're still more polluting than light-duty cars and trucks.
* "Since the current numbers (of snowmobiles) are below the allowed number of snowmobiles in the current Winter Use Plan, carbon monoxide concentrations will go up if traffic increases. To maintain the currently allowed number of snowmobiles without degrading air quality further, further reductions in emissions will be needed."
And let's not forget, many of these observations are based on "best available technology" snowmobiles, the machines the industry pointed to when it convinced the Bush administration back in 2003 to conduct the Supplemental Environmental Impact Statement analyzing snowmobile use in the parks.
Now, want to see some numbers associated with those pollution statements?
According to the DEIS, the preferred alternative will generate nearly 4,000 pounds of carbon monoxide emissions per day, versus just 827 pounds under a snowcoach-only plan and 2,523 pounds under the traffic levels (roughly 250 snowmobiles a day) in recent winters.
Hydrocarbon emissions would reach an estimated 375 pounds per day under the preferred alternative and just 22 pounds under the snowcoach-only option, versus 188 pounds per day under current traffic levels.
While nitrous oxide emissions would reach 977 pounds per day under the preferred alternative, they would amount to just 239 pounds under the snowcoach-only alternative compared to 203 pounds under current traffic levels.
In other words, park officials are endorsing a plan that, when carbon monoxide emissions are considered, would be nearly five times as polluting as the snowcoach-only plan and one-and-a-half times as polluting as current traffic levels, which the studies have documented are harming the park.
In terms of hydrocarbon emissions, the preferred alternative is 17 times more polluting than the snowcoach-only alternative and twice as polluting as current traffic levels.
And those are just the impacts tied to air emissions. Noise levels stand to rocket under the park's preferred alternative. According to the park's own analysis, with 720 snowmobiles in Yellowstone on a given day you'll be able to hear the buzzing of snowmobiles across more than 76 square miles of Yellowstone half of the time between 8 a.m. and 4 p.m.
The snowcoach-only alternative would generate noise heard across fewer than 35 square miles half of the time.
And don't forget, since most of the park's winter visitors congregate around the Old Faithful complex, that's going to be one noisy place if this proposal takes hold.
Let's not forget wildlife concerns, either. The latest research out of Yellowstone recommends that "park managers consider maintaining (over-snow vehicle) traffic levels at or below those observed during our study" because of the impact of snowmobiles and snowcoaches on park wildlife.
"We simply are bewildered by the insistence of the park to promote an increase in the number of snowmobiles when even current levels are clearly impacting the resources, contravene the policies and fly in the face of the preferences of the American public," says Bill Wade, chair of the Coalition of National Park Service Retirees' executive council. "This is a NATIONAL park – not a park set aside to provide primarily for the benefits of local or special interests. It is painful to see a national park so far out of step with what is expected of it."
What's particularly startling about this preferred alternative is that the Park Service agreed to prepare this latest EIS, in part, so that it could gather additional data on over-the-snow traffic in Yellowstone under "managed" conditions ... and yet the agency certainly seems to be ignoring or glossing over the results of those studies.
"Guided, limited snowmobile access using cleaner, quieter machines has resulted in quieter conditions, clean air, fewer wildlife impacts, and much improved visitor safety," Yellowstone officials said in releasing the draft.
On Monday, a distinguished panel of seven former Park Service directors signed off on a letter opposing heightened snowmobile access to Yellowstone, saying the recent studies have produced consistent findings by the Park Service that "greater volumes of traffic required by an emphasis upon snowmobiling add dramatically to air and noise pollution and disturbance of Yellowstone's wildlife."
That concern apparently fell on deaf ears in the park.
At Yellowstone, Superintendent Suzanne Lewis was unavailable for comment, jetting off to New York City for an event involving the Yellowstone Park Foundation.
Yellowstone spokesman Al Nash, however, pointed out that "we're not called upon necessarily to choose an alternative that has the least amount of human impact. We are required to choose a future that does not impair the park resources."
Nash also used historic snowmobiling conditions as the benchmark against what Yellowstone officials measure a well-managed winter use program.
"What types of impacts did we have under historic conditions?" he asked. "Look at how much cleaner conditions are in the park under what we've experienced the last three winters, under what we've have under the preferred alternative. Please not that all our alternatives would ensure that we maintain that stringent Class I airshed in Yellowstone."
Nash's reference to the conditions the past three years was odd in that those reduced emissions, relative to historic conditions, were achieved not by cleaner technology but under daily snowmobile usage of roughly one third of what the park's preferred alternative is calling for.
As for the concerns of the former Park Service directors, he suggested they take a close look at the DEIS.
"Some of their concerns and some of their questions I believe are better answered in this draft EIS than they were in that cooperator's review draft that was released in November," he said.
Sadly, in the world's first national park, officials are not aiming for the best possible environmental conditions, but rather those they feel they can get by with.
Somehow they are ignoring studies that warn that carbon monoxide emissions will rise as snowmobile numbers rise above the 250 or so that have entered the park on a daily basis the past three winters.
Somehow they are comfortable with a plan that runs counter to what the wildlife biologists recommend.
Somehow they are dismissing the vast public opinion against continued snowmobile access to Yellowstone.
Perhaps the underlying driver to this preferred alternative is best explained deep within December's report on how wildlife respond to over-the-snow vehicles. On page 20 of that 36-page report the authors noted that:
"...Science cannot resolve issues where policy is advocated due to values judgments and perceptions about what is appropriate in national parks."
In other words, politics can trump science every time.
Public comment on this draft runs through May 31st. Whether an outpouring of opposition to this preferred alternative can succeed where it has failed in the past is questionable, but it's worth pursuing.