Yellowstone National Park Winter Use DEIS

Superintendent Dan Wenk

Yellowstone National ParkP.O. Box 168Yellowstone National Park, Wyoming 82190
Dear Superintendent Wenk:
The Alaska Quiet Rights Coalition (AQRC) thanks you for the chance to comment on the Yellowstone National Park Winter Use Draft Environmental Impact Statement.
AQRC is dedicated to protecting the rights of Alaskans to quiet places for the benefit of public land users, home and cabin owners, communities, businesses, wildlife, visitors, and future generations.  We believe that natural quiet and natural sounds–the natural soundscape–should be recognized by all public land managers as critical resources in and of themselves that deserve no less consideration than, for example, clean air and water or fish and wildlife and their habitat.  We also believe in a fair and balanced allocation of the public lands for both non-motorized and motorized recreation.  At the federal level, since motorized recreation occurs extensively on BLM and National Forest land (and of course this would include the greater Yellowstone region), and also on National Wildlife Refuge land, it should be prohibited on all designated Wilderness and National Park Service lands.
As our name, and some of the statements above suggest, AQRC virtually never addresses issues outside of Alaska.  But since Yellowstone is such an iconic National Park, and since the snowmobile issue has been such a lengthy and publicly visible one, we have decided to make an exception in this case, and we appreciate the opportunity to comment.
We are very disappointed that the Park does not appear to take its stewardship responsibilities as seriously as we would hope–and as we think most Americans would hope.  The National Park System is a symbol of what is best, most responsible, and most natural in U.S. federal land management.  We would hope that the Park Service would live up to the expectations of the vast majority of Americans who are seeking a truly natural experience, including a natural soundscape, when they visit a unit of the National Park System.
AQRC very strongly recommends that Yellowstone phase out snowmobile use in the Park.  This is not an extreme position.  In fact, the Park Service adopted such position in its Record of Decision in 2000 only to have the Bush administration make one of its many highly politicized decisions and overturn the ROD.  Furthermore, a number of former Directors of the National Park Service support such a proposal, as, through their comments, do several hundreds of thousands of Americans.  In many ways, the Park Service has been a leader in recognizing the importance of protecting, and where necessary restoring, the natural soundscape.  It can set an extremely valuable, and very visible, precedent by taking the practical steps necessary to in fact do that in one of the nation’s premier Parks.
In making this recommendation, we do so being fully aware of the several existing or proposed practices that at least somewhat reduce the adverse effect of recreational snowmobiling in the Park–things like requiring best available technology; mandating that commercial guides accompany all parties; setting aside non-motorized roads and trails; and reducing snowmobile traffic in the east end of the Park at the end of the season.
These mitigating measures should certainly be in place, if not strengthened, if snowmobiles are to be allowed to continue to damage Park resources.  But their mitigating effect pales in comparison to the tremendous benefits that would result if snowmobiles were prohibited (we would, incidentally, expect snowcoaches to continue to be permitted).  Such a decision would not only be in line with the 2000 ROD and the recommendations of past directors and the great majority of the public commenters, but it would be far more consistent with the conclusions of Park Service biologists and soundscape experts.
Finally, it is especially frustrating and disappointing to see that the Service’s preferred alternative would not only allow snowmobiles to continue to degrade Yellowstone’s winter environment, but that the number of snowmobiles allowed in the Park would be more than 50% more than the number that has actually visited the Park in recent seasons.  If snowmobiles are not to be prohibited in the Park, at the very least, in order to demonstrate that the Park Service recognizes the adverse impact of motorized recreational vehicles, and to make a statement about those impacts, the number allowed should be lower than the figure for actual visitation in those recent seasons.
Thank you again for this chance to comment on such an important decision for federal land management in this country.
Cliff EamesBoard MemberAlaska Quiet Rights Coalition