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August 8, 2024

Superintendent Chip Jenkins
Attn: Grand Teton Visitor Use Desired Conditions
Grand Teton National Park
PO Drawer 170
Moose, WY 83012

Subject: Visitor Use and Experience Planning

Dear Superintendent Jenkins:

I write on behalf of more than 2,700 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 50,000 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.

We appreciate the opportunity to comment on your efforts to address growing visitor use and associated concerns for effects on visitor use, experience, and park resources. We compliment you and your staff for developing a user-friendly story map as a good way to get input from those that know the park well, and for presenting a summary table that outlines descriptions of eight management areas, both frontcountry and backcountry as identified on maps, desired conditions for visitor experiences and resources in each area, and the appropriate levels of development, facilities, and services. As an organization whose members are quite familiar with this and other national park units, we acknowledge, if with a bit of chagrin, your park’s very pragmatic definitions of the varied management areas that realistically present different objectives for both resource and visitor conditions.

The overall desired conditions for quality visitor opportunities or resources across the park are concisely and elegantly written, if perhaps not providing as complete an idea of how they will translate to the eight outlined management areas, upon which we do offer a few specific comments:

    • The practical recognition of U.S. Highway 287/89 as a commercial and, to a degree, recreational “pass-through” road would not, we hope, reduce incentives for the park to protect and enhance conditions of cultural and natural resources in that corridor. There are unmet opportunities to facilitate visitor use in the corridor by providing simple but popular facilities, such as picnic areas and restrooms, now unavailable even at existing pullouts and scenic overlooks along the outer highway.
    • It appears that the Snake River in the park is entirely within Frontcountry Zone 2, where visitors should expect moderate escape in a contemplative setting but emphasizes recreation. The Visitor Experience Summary says that visitors to this zone would find a “highly social setting with minimal opportunities for solitude.” Yet commercially guided trips have been long been managed in ways to minimize the appearance of crowding on the river, and we hope this continues. A designated Scenic River stretch under the Wild and Scenic Rivers Act should be called out with more emphasis on protection of its scenic values as well. And floating the river through the park can present considerable risk, yet the summary says that “Visitors would need basic outdoor experience or skill to visit…” This may underestimate the skill needed, especially, but not solely, by private, unguided parties.
    • Similarly, the designated Wild portion of the Snake River appears to include the waterway as it merges into the north end of Jackson Lake; it is challenging to identify this clearly on the landscape, especially as lake levels rise and fall throughout the summer. The area surrounding Jackson Lake all appears to be proposed as the same Frontcountry Zone 2. We offer that canoeing, rafting, or kayaking the river above and into the lake offers opportunities for a wild or certainly primitive and mostly quiet experience, and we urge consideration of such values as you look to zone the areas bounding the northern portion of the lake. The Desired Resource Condition and Appropriate Level of Development summaries do appear to be sensitive to values associated with the Wild and Scenic Snake River, but perhaps some added consideration of the language around visitor experiences is warranted for Frontcountry Zone 2, or the river deserves special mention or a different designation in the map of zones.
    • Relatedly, we recognize that motorized boating provides access to nearly the entire lake, but we suggest that you consider whether the bordering areas could better mirror or align with Backcountry Zones 2 and 3 as outlined just west of the lake. For example, this could offer a less abrupt transition from the lake ‘frontcountry’ zone to a primitive backcountry zone in Waterfalls Canyon, the Owl/Webb/Berry Canyons, and other untrailed or very lightly trailed areas.
    • We see no mention of the term ‘wilderness’ in either parkwide or area-specific desired conditions. Despite the lack of Congressionally designated wilderness in Grand Teton National Park, there is a long pattern of managing proposed wilderness, which exists in the park, as such, or at least to not preclude future designation, in keeping with longstanding National Park Service (NPS) policy. Thus, we ask for your careful consideration of how to incorporate wilderness stewardship goals into the definition of desired conditions in appropriate areas, especially, but not only, in Backcountry Zones 2 and 3.
    • The above comments prompt us to ask how the park has used or plans to incorporate knowledge of current resource conditions and ecologically important areas to develop the zones displayed on the story map. Grand Teton is a fairly small and narrow park, but one that contains significant natural resources that move across its boundaries into other federal agency jurisdictions, we believe that managers should carefully consider cross-boundary opportunities and ecological concerns, such as for wilderness uses in the Two Ocean/Emma Matilda Lakes area northward, for the grizzly bear recovery zone (to become the Primary Conservation Area should bears be delisted from ESA protection), and for ungulate migration corridors.
    • Consider modifying the language around “basic outdoor experience or skill” needed to safely visit Backcountry Zone 1. The subsequent phrases better describe the risks of hazardous terrain, weather, wildlife, and technical challenges, which to an average visitor may not be “basic.”
    • The park might consider mentioning in the table descriptions of Visitor Experience Summary the ease or lack of communication ability via cell phones or other means that are common outside national parks. This can affect visitor perceptions of quiet and ability to enjoy natural sounds, as highlighted in visitor surveys, as well as recreational choices made by visitors to minimize or accept personal levels of risk.
    • While we respect the practicality and need to manage administrative areas primarily for NPS use and to ensure the safety of park staff and their families, those areas do include some important and interesting resources, especially historic properties. We hope that opportunities for visitors to appreciate these resources will be considered, perhaps by providing virtual and/or occasional in- person tours or other special events that allow some look or access into places not commonly open to the public.
    • We regret the omission of the John D. Rockefeller, Jr. Memorial Parkway from this planning effort, as we suggest that it could have been included in several of the management areas, such as Road 2 and Frontcountry 2 or Backcountry 3 or 4. While we recognize that visitor use and capacity currently may not be much of an issue in that park unit, the best time to undertake planning to address future concerns is before they become an issue that demands attention.

We do greatly respect the challenges of visitor use management along with the mandate to protect people and resources. In a future portion of this planning process, we assume that you will address management prescriptions or tools to achieve the desired conditions. Thorny questions likely surround the use of popular things like motorized e-bikes and use of more intensive methods to manage facilities and resources, as well as if or how to limit growth and expansion of visitor use and associated impacts; we look forward to better discussion and understanding of how such operational techniques and tools will be applied in the various management zones. Visitors will doubtless have varying expectations of how ‘active management,’ mentioned for visitor use but potentially applied also to resource management, especially in the face of climate change, should and will be used in the park. And we look forward to hearing more about how the desired conditions, once finalized, will be presented to the public to inform visitor expectations and influence trip planning. In addition, it should help guide priority-setting for park operations, as you and your staff focus maintenance, protection, resource management, and interpretive work to address key targeted issues in areas of highest visitor use or resource impact.

Good luck as you proceed with this important effort. We look forward to public engagement on this in the future.

Sincerely,

Phil Francis Signature

 

 

Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC  20013