September 19, 2014
Superintendent Cindy Ott-Jones
Attention: Multi-Use Trail
P.O. Box 129
Big Bend National Park, TX 79834
Re: Revised Environmental Assessment for Multi-Use Trail at Panther Junction
Dear Superintendent Ott-Jones:
I am writing to you on behalf of over 1,000 members of the Coalition of National Park Service Retirees (CNPSR), who collectively represent more than 30,000 years of national park management experience. CNPSR studies, educates, speaks, and acts for the preservation of America’s National Park System. The purpose of this letter is to provide our comments on the Revised Environmental Assessment (EA) to Construct a New Multi-Use Trail at Panther Junction in Big Bend National Park (BIBE). CNPSR previously submitted detailed comments in March 2011 on the original EA for the project. While we have many of the same concerns about the newly revised EA, we will limit our new comments to a few key points.
As background for our comments, the vast majority of CNPSR’s 1,000+ members began their careers with NPS near the end of an era when park managers were scrambling to accommodate most traditional and many emerging types of visitor activities in parks. It was during our careers that all of us, from decision makers to field rangers, came to understand that lines had to be drawn so that park resources would not be impaired, and in some circumstances could be restored. In many parks, tough decisions were made to reduce the footprint of past and often inappropriate development and to set limits on many forms of public use. In general, these decisions were fully consistent with the fundamental purpose of parks described in the NPS Organic Act, which is to conserve park resources unimpaired for the enjoyment of future generations. The primacy of resource conservation over visitor use is well established in case law and further reinforced in NPS Management Policies, including Section 1.4.3, which states that “when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation will be predominant.” This understanding of NPS policy provides the basis for our concerns about the revised EA, which presents three alternatives: a No Action Alternative A; the Preferred Alternative B, which is a 10-mile “multi-purpose” hiking and biking trail that would be constructed in two phases of approximately 5 miles each; and Alternative C, a hiking-only trail along the same trail route proposed in Alternative B.
As you know, the National Environmental Policy Act (NEPA) was enacted to make sure that “agencies fully consider the environmental costs and benefits of their proposed actions before (emphasis added) they make any decision to undertake those actions” (NPS Director’s Order12, Section 2.2 A). Unfortunately, both the original and the revised EAs create the impression that NPS decided a number of years ago to build a backcountry biking/hiking trail at BIBE. Perhaps this decision was a response to the 2005 servicewide International Mountain Biking Association (IMBA) general agreement. It has long appeared to us that, subsequent to this decision, an EA, and now a revised EA, were prepared to justify a decision made rather than to guide a comprehensive evaluation about whether this trail is truly needed.
Our specific concerns with specific sections of the revised EA include the following:
NEED FOR ACTION
The EA states that action is needed to provide trail-based recreational opportunities near the Panther Junction area and further relates the need for action to the 2005 MOA [sic] between NPS and IMBA that was established for the purpose of identifying mountain biking opportunities in national parks. The revised EA does not, however, persuasively explain such a need. According to the Park’s website, there are currently 150 miles of unpaved roads within the Park that are open to bicycles, including 101.5 miles of primitive dirt roads suitable for mountain biking. Furthermore, Big Bend Ranch State Park, located just west of BIBE, lists 238 miles of trails open to mountain bikes. Since the proposed action is arguably precedent setting, and since there are already hundreds of miles of bicycle trails already available in and around the Park, we believe that there needs to be a detailed and thoughtful explanation of the Park’s rationale for asserting that a new trail is needed. This is particularly true in the absence of data about the level of mountain biking use the park currently receives in the larger context of the many miles of unpaved BIBE roads and single-track trails near BIBE available for mountain biking. In essence, to adequately describe and justify “need” as prescribed in the Director’s Order 12, the EA should describe what the existing conditions are that need to be changed and/or what the problems are that need to be remedied.
RELATIONSHIP TO OTHER PLANS AND POLICIES
The revised EA implies that the proposed multi-purpose trail is consistent with a broadly worded purpose statement in the Park’s May 2004 Final General Management Plan (GMP) regarding “providing recreational opportunities for diverse groups that are compatible with the protection and appreciation of park resources.” While it would be possible to rationalize a justification for many kinds of new development under that statement, we disagree that the proposed action is consistent with the GMP taken in its totality. The GMP makes no mention of a need for trail-based recreation in the Panther Junction area. Furthermore, in the GMP’s Management Prescriptions described in Table 1, p. 47, it states that in “Backcountry Nonwilderness” locations, which presumably include the proposed project area around Lone Mountain, “resource impacts would be restricted to hiking and stock use (emphasis added), campsites, and approved administrative facilities and activities”. There is no mention in the GMP of the possibility of introducing or allowing mountain biking in Backcountry Nonwilderness areas. Yet the Park introduced the idea of a backcountry mountain biking trail less than two years after the GMP was completed and now declares that the trail is consistent with the GMP. For the reasons stated above, we believe that the proposed mountain biking is not consistent with the relevant wording in the GMP.
While it is true that a limited number of other parks have established trails open to mountain biking, this does not inherently justify the proposal to construct a new 10-mile single-track trail that would introduce mountain biking into a currently undeveloped backcountry area of the national park. Most of the park areas referred to in this section are designated as national “recreational areas, lakeshores, or rivers” whose enabling legislations support a more diverse recreational focus than should occur at a “national park” such as BIBE. When Mammoth Cave National Park (MACA) proposed the new 6-mile Big Hollow mountain biking/hiking trail, it was analyzed within the broad context of the park’s 2008 Comprehensive Trail Management Plan and supported by detailed trail use data. The park’s decision to construct a new single-track trail was juxtaposed with related decisions in the plan to close to bicycles other existing multi-use trails, primarily administrative roads that had allowed hiking, biking and horse riding. This was done, in part, to solve a problem by creating a separation of conflicting trail uses.
In the mid-1990’s, Saguaro National Park (SAGU) decided to permit mountain bicycles on a long-established trail in what is regarded as a front-country area of the Park. This 2 ½ mile long trail is located inside the Cactus Loop Drive, a popular sightseeing road, and is the only trail within the park that is designated for bike use. Over the years since that decision, many requests from mountain bike enthusiasts to allow bicycles on other trails have been denied.
IDENTIFICATION OF THE ENVIRONMENTALLY PREFERRED ALTERNATIVE
The selection of the Park’s Preferred Alternative B as the Environmentally Preferred Alternative is not supported by facts presented in the Revised EA. As described in the Environmental Consequences section of the EA, No Action Alternative A would have no impacts on any natural or cultural resource impact topics while having only minor long-term adverse impacts on Visitor Use and Experience due to the absence of a hiking/biking trail in the Panther Junction area. Compared to Alternative A, both the Preferred Alternative B (hiking/biking trail) and Alternative C (hiking trail only) would each have some level of adverse impacts on all listed natural and cultural resources, as well as adverse impacts on visitor safety. By any reasonable evaluation of the range of potential environmental impacts described for each alternative in the EA, Alternative A would have the fewest impacts and should have been identified as the Environmentally Preferred Alternative.
In closing, the proposed action seems the antithesis of where the Park and NPS should be going as we plan a celebration of the first 100 years of the NPS. The Park’s Preferred Alternative B represents to us a clear reversal in the evolution of NPS management policies toward the long-term conservation of parks. Lacking a strong justification or demonstrated need for constructing a backcountry mountain biking trail at BIBE, CNPSR supports No Action Alternative A.
Thank you for your consideration of these comments.
Chair, Coalition of National Park Service Retirees