December 7, 2015
Grand Teton National Park
ATTN: Moose-Wilson Planning Team
PO Drawer 170
Moose, WY 83012-0170
Subject: Comments on the Draft Moose-Wilson Corridor Comprehensive Management Plan
Dear Moose-Wilson Planning Team:
We appreciate the opportunity to offer comments from the Coalition to Protect America’s National Parks (Coalition) regarding the Draft Moose-Wilson Corridor Comprehensive Management Plan. The Coalition is a non-profit organization comprised of over 1,100 members; most are former and retired National Park Service employees. Collectively, we have over 30,000 years of experience working in and managing the Nation’s national parks.
The Coalition has long given close attention to the growing concern for protecting park resources in the Moose-Wilson Corridor. For years, as visitation increased and nearby development added uncontrolled consequences of increased thru-traffic, we watched in anticipation as the Park began the complex process of developing a new comprehensive plan for this part of the Park. In a January 14, 2014 letter to the Jackson Hole News and Guide Coalition Chair Maureen Finnerty highlighted the values of this special place, and we joined the effort to find a balanced approach that would – above all – protect the fragile resources of this world-renowned Park. Our engagement continued with a February 6, 2014 comment to the Park during the scoping phase of the process. And, on September 9, 2014, we offered comprehensive comments on the Moose-Wilson Corridor Preliminary Alternatives.
While these aforementioned comment letters were organized around specific questions prescribed by the process, the themes of our proposals remained the same:
- The wildlife and related habitat that make the corridor such a unique and significant area must be preserved.
- The outcome should be a plan that provides appropriate opportunities to use, experience and enjoy the area while protecting park resources.
- The outcome should be a plan that reflects the laws and policies that guide decision-making throughout the National Park System.
- The outcome should be a plan that recognizes that Moose-Wilson is a Corridor that provides key and increasingly essential habitat for grizzly bears, moose, and many more species. Planning must go beyond the point of view that it is simply a road.
- The outcome must be a plan that limits traffic and minimizes congestion in the corridor.
The Coalition supports the National Park Service Preferred Alternative set forth in the Draft Environmental impact Statement (DEIS). In almost every respect, this alternative reflects the concerns and proposals that we have expressed. Generally, and most notably, the Plan is consistent with the laws, policies, and values of the National Park Service. While providing for visitor enjoyment of this significant part of the Park, the Plan clearly gives emphasis to the preservation of wildlife and other resources along the corridor. We don’t believe it is necessary to address each of the many detailed components presented in the Preferred Alternative. Accordingly, the following general proposals, in combination, inspire our support:
- The recommendations set forth in the Preferred Alternative will collectively strengthen preservation of the natural and cultural resources that are part of the Moose-Wilson Corridor and Grand Teton National Park.
- Language and recommendations in the proposed alternative emphasize that the Moose-Wilson Corridor will be managed as a whole rather than simply as a road.
- The proposal to control and carefully manage the volume of traffic is, likewise, a key to achievement of core National Park Service goals and values. We expect that in both the near future, and likely long-term as well, there will be evolving strategies about how best to achieve this goal. The term “adaptive management” seems to call for continuing evaluation, and indicates a willingness to adopt new approaches if needed. Such future adjustments are appropriate provided that new strategies are consistent with the goal of reducing and capping the number of vehicles that use the road at any one time.
- The current footprint of development would be reduced.
- Absence of the much-debated construction of a separate multiuse pathway is also a very important component of the Preferred Alternative. If constructed, the proposed pathway would substantially increase human impact along this corridor. In particular, more bicyclists traveling along a path separated from the road would, inevitably, increase the potential of tragic encounters with grizzly bears, moose, etc. Moreover, the Preferred Alternative includes a number of actions that will improve the safety and experience of bicyclists who will use the existing road, including a reduction in the speed limit, paving the unpaved section of the road, and reducing traffic congestion.
- Traditional non-motorized winter access, without grooming, such as snowshoeing, skiing, and walking, is perpetuated.
As was always the case when we worked in national park areas around the country, we have paid close attention to opposing points of view. It is obvious that groups of local residents, the real-estate industry, and all manner of commuters forcefully assert that the Moose-Wilson Road be managed as part of the local transportation system for Teton County. It is likewise clear that many of these individuals have appealed to local and often sympathetic elected officials in effort to influence the outcome of this planning process. We strongly urge NPS decision-makers to resist such efforts and remain focused on managing the corridor befitting its location in one of the crown jewels of the National Park System. We have learned elsewhere the costs of failure.
Unfortunately, many national park areas are bisected by state highways, including Grand Teton National Park. Of course, many of these roads existed before parks were established. And, in many areas, other park roads are increasingly used as short-cuts for commuters living in ever-growing communities located nearby park boundaries. Invariably, the results of such increased traffic are a significant compromise to wildlife and the quality of visitor experience. Animals big and small die on the roadways; law enforcement rangers are compelled to spend more and more time managing traffic; and the need to maintain and even improve the road for increasing traffic is inevitable. Painful experience informs us that the result of failure to halt such use along the Moose-Wilson Road will be… in one word… UGLY!
In January 2014, I wrote that…”Jackson Hole is widely revered for its unique modern day conservation success story which resulted in the creation of Grand Teton National Park…Jackson has since evolved into a nationally prominent gathering place where the principles of conservation, wilderness and wildlife protection lead the national dialogue.”
We congratulate the National Park Service for the enormous and comprehensive effort given to the planning process so far, and above all for offering a Preferred Alternative that reflects the values at stake.
Chair, Coalition to Protect America’s National Parks