September 6, 2023
Cicely Muldoon Superintendent
P.O. 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 2,500 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.
As stated in our earlier letter, on behalf of our members and followers, we applaud the park 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. Lacking public data that states otherwise from the park, we believe the park has exceeded capacities set by the Merced River and Tuolumne River Plans. This is based on the public information that parking capacities have been exceeded which is a primary indicator overall visitor capacity has gone beyond limits set by these plans.
The longstanding overcrowding at Yosemite creates an obvious conflict between the conservation of park resources and values and visitor use, in this case visitor overuse. As stated in NPS Management Policies 2006, Section 1.4.3, “when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant. This is how courts have consistently interpreted the Organic Act.” NPS has tinkered with visitor use management procedures at Yosemite for many years, which has resulted in uncertainty about when and what restrictions may happen next. However, the current planning process has created positive public expectations that the NPS will finally create and implement a thoughtful, long-term approach that provides stable, consistent management of visitor access at the park. As a result, it is essential that NPS complete the plan in a timely manner.
Our specific comments about the proposal are as follows:
As directed by the Wild and Scenic Rivers Act, National Trails System Act, and National Parks and Recreation Act, the National Park Service is required to set a visitor carrying capacity. Because visitors use many areas of the park during their visit, we encourage the park to set an overall visitor carrying capacity and set of desired conditions. We also encourage 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. The monitoring of these indicators will ensure success and public credibility as the Visitor Access Management Plan is implemented in the future.
We believe the park has taken major steps forward by setting visitor capacity to protect wild and scenic river values. The Merced and Tuolumne River Plans have established capacities to ensure 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 (up to today’s date) regarding these current indicators and standards and any actions the park has taken after thresholds have been exceeded as part of the public process. We ask the park service to be transparent of their monitoring of these resource river values and actions related to them.
We encourage the park to create opportunities for adaptive management strategies as new data is made available. A combination of strategies, such as timed park entry, day-use reservations, seasonal reservation systems, peak time limits (such as holidays and core day hours), and other methods may be used to refine the plan over time. The pilot reservation systems used over the past few years have provided the park data that visitation within capacity can be accommodated by timed park entry and reservation systems.
We do not support any additional access road widening to increase visitor capacity. The four entrance access roads have limited capacity and cannot be widened without significant degradation of the resource protection set by law and policy. Prime visitor areas such as Yosemite Valley, Tuolumne Meadows, Mariposa Grove, Tuolumne Grove, Wawona, Crane Flat, and Glacier Point cannot currently provide quality visitor experiences due to overcrowding and severe congestion The pilot reservation systems used over the past few years and various transportation studies have provided the park with good background information on limits of access roads for this planning process. Over the decade, we believe the park has completed the most feasible transportation and parking options for easing traffic conditions. We applaud these past efforts.
We are supportive of limited streamlining of entrance stations (such as digital entrance passes) to accommodate peak flow of cars; however, this action without a limit on visitor access would most likely result in the parking lots filling even earlier than currently. This would not solve Yosemite’s overall visitor carrying capacity and congestion problem. We do not believe expanding infrastructure at the entrance will alleviate congestion in the valley and do not consider it a strategy to pursue.
We believe it is imperative that the park further expand the YARTS transportation system and park shuttle system to help in reducing 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. We strongly support the Park’s shuttle system and strategies for expansion to reduce bus crowding and eliminate the need to use private vehicles to drive to valley scenic sites.
Because YOSE is 94 percent wilderness, the Visitor Access Management Plan must include setting capacity and updating trailhead quotas to ensure the desired resource conditions and the quality of the visitor experience of the wilderness area is protected. This will ensure the park will have overall limits to visitor access limits for this large part of YOSE when it finishes (or “while it is finishing”) past wilderness management planning efforts.
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 codified in the Merced River and Tuolumne River Plan, we believe any new development, beyond the established plans should not be considered as a future strategy. This includes but is not limited to additional parking, major road changes, additional roads, and bicycles trails in these corridors. In the recent public meeting (July 19, 2023) the park stated unequivocally that the River Plans have not been amended.
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 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.