Yellowstone National Park, the world's first national park and the place that started the global national parks movement, deserves a better winter-use plan than the one being pushed by park officials.
It deserves a better plan that not only reflects and respects the ideals of the national parks movement and the National Park Service Organic Act, but one that makes economic sense.
National Park Service officials don't need more studies to develop such a plan. Their latest Draft Supplemental Winter Use Environmental Impact Statement -- the fifth full-blown environmental impact study on winter-use in the park in the past dozen years -- offers, and supports, a better plan. In Yellowstone, arguably the crown jewel of the National Park System, officials should continually strive to minimize impacts to the air, water, wildlife, and soundscape. Instead the Park Service is willing to give the snowmobile industry another five years to live up to promises it made as far back as 2004.
"We are basically asking the industry to deliver on the promises that they made in 2004 and 2005 where they said (snowmobiles) would continue to get quieter and cleaner," Yellowstone Superintendent Dan Wenk said last week. "In fact, they haven’t since about 2006, and we’re saying they need to go back and make the machines quieter and cleaner."
At the same time that park officials are willing to hold out hope that another five years will produce the results that Superintendent Wenk says are technologically feasible today, they are willing to, in effect, spend more than $1,100 per person in these trying economic times so a relative handful of visitors can safely ride over-snow vehicles into the park via Sylvan Pass.
That $1,150 figure, attributed to the high cost of grooming and controlling avalanche chutes above Sylvan Pass, grows absurdly large when you consider -- based on the park's $2.5 million winter operations budget and the 285,142 visitors who came to Yellowstone last winter -- that it costs the park, on average, about $9 per winter visitor.
Why, in tight budgetary times, are Yellowstone officials willing to spend so much tax money to facilitate a very small number of over-snow visitors -- just 110 last winter -- over an extremely hazardous area of Yellowstone that otherwise would be unpolluted and quiet?
Economic impact of policies is important. And in terms of Sylvan Pass, it's simply not economically justifiable to keep it safely open.
Even the DSEIS notes that over-snow access through the park's East Entrance and across Sylvan Pass is insignificant in terms of tax dollars Yellowstone generates for Park County, Wyoming (and Cody, specifically), in winter: "Recent lodging and tax data for Fremont (Idaho) and Park counties indicate that declines in snowmobile entries in winter visitation in the park in general, and into Yellowstone in particular, have not detectably impacted the overall winter tourist economy in the counties as measured by monthly lodging tax collections."
Yet seemingly the Park Service ignores its own statement in the DSEIS's Executive Summary that "(D)ismissed from further analysis were alternative elements that were considered but were not technically or economically feasible...."
It was gratifying that Superintendent Wenk wasn't satisfied with the initial Draft Supplemental Winter Use Environmental Impact Statement prepared last summer and directed his staff to take a closer look at some key questions.
But the revisions don't rise to the level of resource protection the Park Service is tasked with. Underlying data for the park's preferred alternative show that that desired alternative could result in unnecessary air quality impacts, and not just from carbon monoxide. Benzene emissions also will increase in the near-term, as will levels of formaldehyde and acetaldehyde, according to numbers contained in the DSEIS.
(Oddly, in writing the DSEIS park planners seemingly pulled some punches when discussing CO emissions. On page 110 of Chapter 3, they wrote that "(M)aximum 8-hour CO concentrations at Old Faithful have declined from 1.2 ppm in 2002/2003 to 0.4 ppm in 2007/2008." But if you turn to page 114, Table 16 shows that while 8-hour CO emissions did indeed dip to 0.4 ppm during the 2007/08 winter season, they rose to 1.7 ppm in 2009/10 before sliding a bit to 0.9 ppm in 2010/11. The numbers get worse when you look at 1-hour maximum levels, which rose from 0.9 ppm at Old Faithful in 2007/08 to 7.6 ppm in 2009/10 and 4.3 ppm in 2010/11.)
Inconsequential Air Pollution?
Yellowstone Management Assistant Wade Vagias offers that those pollution levels are inconsequential, that "if we were starting winter-use planning today, set aside the past 12 years, air quality would be an issue that is basically considered, but dismissed because these levels are so low."
But why, in Yellowstone or any other national park, wouldn't you lower pollutants as far as you feasibly, and reasonably, could? And in Yellowstone, the voluminous research collected on winter-use points to snowcoaches, equipped with the "best available technology (BAT)," as far and away the least-polluting option currently available for winter travel in the park. By a large margin.
According to the data laid out in charts in Chapter 4 of the DSEIS, the current mix of snowmobiles and snowcoaches used in the park (318 snowmobiles and 78 snowcoaches allowed per day the past three winters) generates 138 tons per year of carbon monoxide. Under Alternative 3, which would phase out snowmobile use in favor of 120 snowcoaches per day, CO generation would fall to 104 tons per year.
Under the park's preferred alternative, which could allow upwards of 480 snowmobiles and 60 snowcoaches per day, CO emissions would jump to 252 tons per year until BAT kicked in for the 2017-18 winter season, when CO would dip to 212 tons.
If Alternative 4B were adopted, which would allow just 106 snowcoaches and 20 noncommerically guided snowmobiles into the park per day, CO emissions would drop to 98 tons per year.
Other toxics also could be reduced more so than under the preferred alternative. Benzene emissions from the current mix of over-snow vehicles amounted to 0.17 tons per year. Under Alternative 3, those emissions would fall to just 0.05 tons, while under the park's preferred alternative, they would grow to 0.29 tons until the 2017-18 season, when they'd dip to 0.18 tons, still more than the current fleet.
Park officials realize their plan doesn't deliver short-term results, stating in the DSEIS that under their preferred alternative CO output from snowcoaches and snowmobiles would create a "moderate impact" on park resources until the winter of 2017-18, "when additional CO requirements would be implemented."
As for noise levels, over-snow vehicle travel in the park would be noisier under the preferred alternative than under the daily limit of 318 snowmobiles and 78 snowcoaches allowed the past three winters, according to the park's data.
How Aggressive Are Officials Being In Protecting Yellowstone?
Why is this plan being promoted, when the Park Service's own Management Policies state that the agency "will preserve and protect the natural resources, processes, systems, and values of units of the national park system in an unimpaired condition to perpetuate their inherent integrity and to provide present and future generations with the opportunity to enjoy them"?
More so, the Management Policies add that "the NPS will assume an aggressive role in promoting and pursuing measures to protect air quality related values from the adverse impacts of air pollution." (Emphasis added)
Passing over a cleaner, more economically feasible option, while allowing the snowmobile industry to surpass standards the Park Service established eight years ago and now is proposing to give them a pass for five more years, does not seem aggressive.
The Park Service needs to scuttle its currently preferred alternative and support the winter-use option that truly works the best in reducing air pollution and noise in Yellowstone, protecting wildlife, and which makes the most economic sense in these tough times.