January 31, 2023
Rocky Mountain National Park
1000 U.S. Highway 36
Estes Park, CO 80517
Subject: Comments on Day Use Visitor Access Strategy for Rocky Mountain National Park
Dear Superintendent Sidles:
We are 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 Rocky Mountain National Park (ROMO) for working towards the development of your Day Use Visitor Access Strategy. Your early use of Temporary Timed Entry Permit Systems (TEPS) has shown ROMO as a leader in visitor use management for the NPS.
This planning phase specifically requests answers to two questions.
- Based on your desired experiences and protection of the natural and cultural resources at Rocky Mountain National Park, which of the ideas (or combination of ideas) do you think best achieves the purpose of the plan?
- Are there other ideas or changes to current ideas that should be considered and analyzed that are not already presented?
This comment letter responds to both.
The four ideas presented as potential strategies are very well thought out, especially regarding the pros and cons. The Coalition supports any combination of Ideas 1 – 3 that best promote accessibility while protecting park natural and cultural resources.
The Coalition suggests ROMO begin with Idea 1 (Timed-Entry Two Reservation System: Bear Lake Road Corridor and “Rest of Park”) focusing on Ticketed versus Lottery practices, if possible, to reduce administrative challenges related to lotteries. The park could potentially phase into Idea 2 (Set number of Timed-Entry Reservations for Each Entrance Station with Shuttle-Only Access to Bear Lake Road, Glacier Gorge, and Bierstadt) if visitor use data warrants and administrative challenges can be met. Idea 3 (Daily Reservations) could be considered if Ideas 1 and 2 are not effective in protecting natural and cultural resources; the Coalition recognizes that it will mean a reduction in entries per day, reducing visitor access. The Coalition could support the park on any reasonable Ideas or combinations it may consider. However, we suggest that Idea 4 (Metering and Temporary Delays at Entrances) would be the most problematic for the park to administer because of the additions to the staff workload it would entail.
The Coalition supports the Educational and Trip Planning strategies or additional shuttles needed to most effectively manage visitor use. The Coalition also supports additional management in the Longs Peak and sensitive tundra areas, starting with the least challenging administratively and then phasing into more complex management strategies if the data warrant. With both area-specific strategies, efforts to formalize trails and reduce social trailing will help protect sensitive alpine vegetation.
As the planning process progresses and to promote adaptive management strategies, we encourage the park to establish scientifically based and peer-reviewed indicators, standards, and thresholds for measuring visitor quality and resource conditions in critical day-use areas. Effective monitoring and periodic reporting of such findings will promote public understanding and support of the Day Use Visitor Access Strategy as it is implemented and if more complex strategies are needed in the future.
We believe this strategy and any further visitor use management planning is key to the NPS complying with the direction and mandates established ROMO management plans, enabling legislation, and National Park Service policy and law.
We strongly recommend that this planning process 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 ROMO to ensure that cultural and natural resources and “superlative environmental quality” are protected from derogation and to create a Day Use Visitor Access Strategy that sustains resource integrity and accommodates quality visitor experiences. We appreciate the opportunity to provide comments during this stage of the planning process.
Michael B. Murray
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013