January 25, 2023
Cicely Muldoon
Superintendent
Post Office Box 577
Yosemite National Park, CA 95389
Subject: Comments on Visitor Access Management Plan for Yosemite National Park
Dear Superintendent Muldoon:
I am writing to you on behalf of over 2,300 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former NPS directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
On behalf of our members and supporters, we applaud Yosemite National Park (YOSE) for creating this Visitor Access Management Plan. Visitation at peak times, especially holiday weekends and summer months, has been a constant problem for decades, and in our opinion, led to resource degradation and reduced the quality of visitor experiences. The four entrance access roads have limited capacity and cannot be widened without degradation of the resource protection set by law and policy. Prime visitor areas, such as Yosemite Valley, Wawona, and Tuolumne Meadows, currently cannot provide quality visitor experiences due to overcrowding. The pilot reservation systems used over the past few years have provided the park with good background information for this planning process.
Our comments focus on Topic Questions 3 and 4.
We encourage the park to create opportunities for adaptive management strategies as new data is made available. A combination of strategies, such as timed entry, day-use reservations, seasonal reservation systems, and other methods, may be used to refine the plan over time. We believe it is imperative that the park further expand the YARTS transportation system to help reduce visitor vehicle use. YARTS provides an alternative way for visitors to get to the park with a use reservation without the impacts from their vehicles.
Because YOSE is 94 percent wilderness, the Visitor Access Plan must include setting capacity and updating trailhead quotas to ensure the desired resource conditions and the quality of the wilderness visitor experience are protected. We are unsure how the park is going to set visitor access for this large part of YOSE because the previous park wilderness plan was not prepared with proper environmental compliance, and the update to the plan has never been completed.
We believe the park has taken major steps forward by setting visitor capacity to protect river values. The Merced and Tuolumne River Plans have established capacities to ensure that desired conditions of keystone and sensitive resources are maintained at set thresholds. As a group dedicated to concerns regarding national parks, we encourage the planning process to include past monitoring data regarding these current indicators and standards and any actions the park has taken after thresholds have been exceeded as part of the public process. In addition, we encourage the planning process to disclose park operation funding levels to ensure monitoring is being conducted and critical resource conditions are being met.
As the planning process progresses, we are encouraging the park to establish additional scientifically based and peer reviewed indicators, standards, and thresholds for measuring visitor quality and resource conditions in all visitation areas, including the park’s wilderness area. These additions will ensure success and public credibility as the Visitor Access Management Plan is implemented in the future.
We believe a Visitor Access Plan is key to caring for the direction and mandates established in the YOSE Foundation document, Yosemite National Park enabling legislation, and National Park Service policy and law.
We hope that this planning process will be guided by the founding legislation of the National Park Service (NPS). (Text below excerpted from Section 1.4.1 of NPS Management Policies 2006.)
The most important statutory directive for the National Park Service is provided by interrelated provisions of the NPS Organic Act of 1916 and the NPS General Authorities Act of 1970, including amendments to the latter law enacted in 1978. The key management-related provision of the Organic Act is as follows:
[The National Park Service] shall promote and regulate the use of the Federal areas known as national parks, monuments, and reservations hereinafter specified… by such means and measures as conform to the fundamental purpose of the said parks, monuments, and reservations, which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations. (16 USC 1).
Congress supplemented and clarified these provisions through enactment of the General Authorities Act in 1970, and again through enactment of a 1978 amendment to that act (the “Redwood amendment,” contained in a bill expanding Redwood National Park).
The Redwood amendment added the following two sentences to the General Authorities Act provisions:
Congress further reaffirms, declares, and directs that the promotion and regulation of the various areas of the National Park System, as defined in section 1c of this title, shall be consistent with and founded in the purpose established by section 1 of this title [the Organic Act provision quoted above], to the common benefit of all the people of the United States. The authorization of activities shall be construed and the protection, management, and administration of these areas shall be conducted in light of the high public value and integrity of the National Park System and shall not be exercised in derogation of the values and purposes for which these various areas have been established, except as may have been or shall be directly and specifically provided by Congress. (16 USC 1a-1)
As stated in the above text, we strongly encourage YOSE to ensure that cultural and natural resources and “superlative environmental quality” are protected from derogation and to create a Visitor Access Management Plan that sustains resource integrity and accommodates quality visitor experiences. We appreciate the opportunity to provide comments during this early stage of the planning process.
Sincerely,
Michael B. Murray
Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013