Submitted to https://parkplanning.nps.gov/commentForm.cfm?documentID=138824
ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW
September 27, 2024
Cicely Muldoon
Superintendent
Yosemite National Park
P.O Box 577
Yosemite, CA 95389
Subject: Yosemite National Park Visitor Access Management Draft Plan (VAMP)
Dear Superintendent Muldoon:
I am writing on behalf of the Coalition to Protect America’s National Parks (Coalition), which represents over 2,800 current, former, and retired employees and volunteers of the National Park Service. Collectively, our membership represents over 50,000 years of national park management and stewardship experience. Our members include former National Park Service (NPS) directors, deputy directors, regional directors, and park superintendents, as well as a variety of program specialists and field staff. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service.
Many of our members have worked at and/or managed units of the National Park System designated in whole or in part to preserve America’s most significant natural and cultural sites and resources. We have a keen appreciation of procedural requirements and federal agency responsibilities set forth under the National Environmental Policy Act (NEPA) and related implementing regulations and policies, the National Historic Preservation Act (NHPA), and other related implementing laws, regulations, and policies. Similarly, many of us have been involved in managing and/or implementing planning processes regarding visitor use management and user capacity of parks.
We greatly respect the challenges of visitor use management and the mandate to protect people and resources. We support Yosemite National Park’s goal of establishing a Visitor Access Management Plan (VAMP).
Background
The following pieces of legislation – in addition to the founding legislation of Yosemite National Park and the 1980 General Management Plans – should guide the final VAMP plan, as required by current laws, policies, and regulations. Overall, the policies, regulations, laws, and guidelines allow for public use and enjoyment that does not degrade or impair park resources. We are including the excerpts below from these policies and regulations as a preface to our comments and as a reference to the legal and policy guidance that must be followed.
The NPS Organic Act states, “[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.”
Congress supplemented and clarified these provisions in the Organic Act through the enactment of the General Authorities Act in 1970, and again through the enactment of a 1978 amendment to that act (the “Redwood amendment,” contained in a bill expanding Redwood National Park), which added the last two sentences in the following provision. The key part of that act, as amended, is as follows:
Congress declares that the national park system, which began with establishment of Yellowstone National Park in 1872, has since grown to include superlative natural, historic, and recreation areas in every major region of the United States, its territories and island possessions; that these areas, though distinct in character, are united through their inter-related purposes and resources into one national park system as cumulative expressions of a single national heritage; that, individually and collectively, these areas derive increased national dignity and recognition of their superlative environmental quality through their inclusion jointly with each other in one national park system preserved and managed for the benefit and inspiration of all the people of the United States; and that it is the purpose of this Act to include all such areas in the System and to clarify the authorities applicable to the system. 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)
Act of Congress, June 30, 1864 (13 Stat. 325) – granted to the state of California the Yosemite Valley and Mariposa Big Tree Grove and stipulated that the lands “be held for public use, resort, and recreation” and “be inalienable for all time.” (YOSE Foundation Document 2016)
Act of Congress, October 1, 1890 (26 Stat. 650). Set aside Yosemite National Park to be administered by the Secretary of the Interior as a “forest reservation” with the Secretary required to preserve from injury all timber, mineral deposits, natural curiosities, or wonders within the park area and to retain them in their natural condition. The Secretary was also directed to provide against the wanton destruction of the fish and game found within the park and against their capture or destruction for the purposes of merchandise or profit. The act specifically excluded Yosemite Valley and Mariposa Big Tree Grove, leaving them under the jurisdiction of the state of California as provided for in the act of 1864. (YOSE Foundation Document 2016)
Yosemite General Management Plan (1980) – “There are two purposes for Yosemite National Park. The first is the preservation of the resources that contribute to Yosemite’s uniqueness and attractiveness…. The second is to make the varied resources of the park available for their individual enjoyment, education and recreation….”
Yosemite General Management Plan (1980) – “The foremost responsibility of the National Park Service is to perpetuate the natural splendor of Yosemite and its exceedingly special valley.”
National Parks and Recreation Act of 1978 – The VAMP must meet the National Parks and Recreation Act of 1978 (54 United States Code [USC] 100502), including identifying carrying capacities and implementation commitments for areas of the National Park Service unit, including types and intensities of development.
Coalition Comments
VAMP Methodology and People at One Time (PAOT) User Capacities. Alternative B Modifications.
The draft VAMP acknowledges long lines, overcrowding, and congestion problems in Yosemite, even under the current pilot program. The draft VAMP preferred Alternative B strategy is close to what was enacted in 2024 with some modifications. We believe additional measures must be included to seriously correct ongoing crowding, visitor stress, and congestion issues (see text below). Issuing fewer daily reservations (80% of PAOT levels) may be needed to correct these ongoing and substantial impacts on the quality of the park experience. While we support the adaptive management approach, information on the potential range of reservations per day and number of visitors per season or per month would help the analysis of the sufficiency of the reservation system to reduce crowding and congestion and protect resources. The limitation of daily cars, which reduces the number of people, must be incorporated into Alternative B to address impacts on wildlife and other park resources.
The draft VAMP uses existing parking spaces as the primary methodology with staff input to set user capacity, PAOT, without fully considering short and long-term resource impacts. The draft VAMP has limited information on the research data or surveys related to resource or visitor conditions, turnover rates, vehicle data, or quality of visit, that were used in setting user capacity. The final document should specify any research data used to set user capacity at locations not addressed in the Tuolumne River Plan (TRP) and Merced River Plan (MRP). These indicators and thresholds would be mandatory for all alternatives.
The following is excerpted from NPS 2006 Management Policies: “When making decisions about carrying capacity, superintendents must use the best available natural and social science and other information and maintain a comprehensive administrative record relating to their decisions. The decision-making process should be based on desired resource conditions and visitor experiences for the area, quality indicators and standards that define the desired resource conditions and visitor experiences, and other factors that will lead to logical conclusions and the protection of park resources and values. (Emphasis added).” (NPS, 2006)
The draft VAMP states that “visitor capacities are mostly frequently expressed as vehicles at one time, which is the total number of vehicles that can be present in the area at any given point in time.” We understand the rationale of primarily using vehicle spaces to set capacities at one time. However, user visitor capacity is two-dimensional– PAOT and overall daily use. In turn, the user capacity should be driven by resource constraints. The draft VAMP underestimates the total use of the area over time by visitor movements. Consistent and heavy visitation each day, month, and year leads to resource impacts that could be potentially more significant. For example, at Tenaya Lake the user capacity is set by parking spots, and the result is a capacity of 543 people at one time. However, the use per day will be much higher. Hetch Hetchy is another example where a use capacity at one time is set at 305, but overall use is between 400-600 cars (2.9 times the number of cars for total visitors). The VAMP PAOT appears to “grandfather” in existing visitor use and does not seriously consider resource conditions and impacts. If Alternative B is selected, we believe the total numbers of PAOT are too high and will not protect park resources or eliminate crowding and congestion. Overall, these numbers should be set to a lower user capacity.
According to PAOT numbers, the draft VAMP authorizes 9,850 PAOT in new user capacities. This is in addition to the MRP capacities of 21,000 for east and west Valley, 2,570 for Wawona, 2740 for El Portal, and TRP Tuolumne capacities of 4,988 already established by these two completed plans. This number excludes the Sequoia Groves day-use numbers. The total is 30,398 PAOT (or 10,482 cars) at one time which is a low estimate as the Groves day-use numbers are not included in our analysis (and public transportation data is not included). We also noted that the Big Oak Flat area also has not received a user capacity PAOT number. These total numbers seem high if the goal is to protect park resources and, as far as we can tell from the draft VAMP, driven primarily for parking data. Also, these numbers are PAOT, the total number of people in the park using the park per day and the number of cars will be significantly higher. The Environmental Assessment (EA) states, “in July 2019, the peak number of vehicles that accessed the park on a given day was 12,700 vehicles, while the average for the month was 9,400 vehicles.” Thus, the new PAOT numbers indicate the park could have more daily cars than the average day in July 2019. Using the park’s multiplier, this equates to 27,260 to 36,830 visitors (not including buses and NPS and concessions vehicle use). We believe the EA analysis is insufficient, and the VAMP will not effectively reduce congestion and crowding at visitor sites and entrance stations. Alternative B and the final VAMP need to address the estimated overall number of cars and people and the potential impacts on resources and visitor experience.
The draft VAMP also does not specify the level of anticipated growth in shoulder seasons leading to higher yearly visitation, which would directly or indirectly impact park resources. It also fails to state which resource indicators will be reviewed to change management strategy, or what the threshold must be to initiate management action for resource impacts. However, the draft VAMP does acknowledge that visitation will likely grow in the shoulder season, and the reservation period could change. The NPS should set an upper limit to yearly visitation based on visitor experience and the potential impacts to natural and cultural resources at Yosemite over time. Under the proposed Alternative B, visitation could still substantially increase, adversely impacting resources and park operations during winter and shoulder seasons. The cumulative impacts, both indirect and direct, of more visitors per year could have major impacts on park resources such as air quality, soundscapes, wildlife and visitor experience, and park operations and should be addressed in the final VAMP.
In Alternative B, the final VAMP needs to state clearly that the reservation system could be in place through the shoulder season and in winter months (such as February for Horsetail Falls (Firefall)) events. We believe this is a likely foreseeable outcome.
For background, the draft VAMP states, “the reservation system would be in effect to some degree each year from April through October. During the shoulder season months—April, May, September, and October— reservations would initially only be required on weekends and federal holidays. While visitors may not be able to get a reservation for their preferred time on a weekend, they would still be able to enter the park during a weekday during those shoulder months without a reservation.” (VAMP, NPS, 2024)
The draft VAMP cites a projection that Yosemite could see up to a 23% increase in visitation during the peak season, from June through August, up to a 25% increase in the shoulder seasons (April, May, September, and October), and up to a 53% increase in low-season visitation (Fisichelli et al. 2015). Based on news reports and direct communication, the pilot programs indicate reservations should be mandatory for at least a six-month season to achieve the goals of the VAMP. Alternative B should also state that there may be limits to visitors entering the park without a reservation during nighttime hours. We support the park in proposing an adaptive management approach, but there will be a need to regulate the available times for non-reservation entry. Research and projection data indicate that visitation pressure is increasing each year.
Alternative A, C, and D
Alternative A: Current Management would continue current activities without eliminating congestion and crowding or protecting park resources. It should be rejected because it does not meet the goals of the VAMP.
Alternative C and D: These two options, as described, should also be rejected. Alternative D would not limit the number of vehicles throughout the park and would require day-use reservations for Yosemite Valley. This alternative would be physically impossible to implement and not meet the purpose and need described in the VAMP. Alternative C includes a reservation system with timed entry. This Alternative has an additional hurdle and complication that would stress visitors.
Air Quality Impacts
The draft VAMP has not adequately addressed the air quality impacts of expanded overall visitation and current visitation. We do not believe overall air quality impacts have been evaluated in any park-wide plan, and the 1980 General Management Plan environmental analysis is outdated.
For example, a team of researchers from the U.S. Geological Survey, Utah State University and Clemson University have determined the extent and origins of the park-related emissions at Yellowstone National Park. They write:
“Overall, tourism to Yellowstone NP generates an estimated 1.03 megaton CO2 annually, with an average of 479 kg CO2per visitor (Table 4). For a comparison, the average annual per capita CO2 equivalent emissions were 4,600 kg globally, or 14,700 kg for United States residents, in 2019 [62]. We calculated 2,141,076 unique trips to Yellowstone NP in 2021, which influences the total CO2 output, but not per visitor estimates. For all per visitor estimates below, these represent one unique trip (e.g., one person visiting for multiple days during the same trip). Almost 90% of total emissions are from transit to and from Yellowstone NP, while 5% are from transit within the park and 4% are from overnight accommodations. Other park operations, excluding overnight accommodations, contribute slightly more than 1% of total CO2 emissions related to Yellowstone NP tourism (PLOS Climate).
This study estimated that tourism to Yellowstone National Park produces 1.03 megatons — more than 2.3 billion pounds (1.03 billion kilograms) — of carbon dioxide emissions each year
To add context, “Yosemite National Park is designated a Class I area under the Clean Air Act Amendments of 1977 (42 USC 7401 et seq.), which provides special protection for air quality, sensitive ecosystems and clean, clear views. Under section 169A, “Congress declares as a national goal the prevention of any existing impairment of visibility in mandatory class I Federal areas in which impairment results from manmade air pollution.” State and federal permitting authorities must consult with the National Park Service regarding new sources of air pollution and impacts on park air quality related values must be considered in the permitting process. Further, the act requires NPS involvement in natural regulatory efforts aimed at eliminating human-caused visibility impairment in all Class I areas. This designation bestows an “affirmative responsibility” on federal land managers to integrate air resource management into NPS operations and planning for the protection of air quality and related values, including visibility, plants, animals, soils, water quality, cultural resources, and public health, from adverse air pollution impacts. Section 118 of the Clean Air Act requires that federal agencies comply with state regulations, and Yosemite National Park worked in close coordination with the State of California.” (YOSE Foundation Document, NPS 2016)
Soundscapes and Noise Impacts
Noise and soundscape impacts were dismissed from detailed analysis. However, over 90% of the park’s land area is designated Congressionally authorized wilderness. Soundscape impacts at trailheads and developed areas and along roads, specifically Yosemite Valley and entrance roadways, could have significant adverse effects on native bird populations and wildlife. To our knowledge, no park-wide impact analysis has been completed.
We realize the draft VAMP describes a proposed limited monitoring program. However, because it lacks detailed information on implementation, we believe it is inadequate and will not, as written, be successful at indicating resource issues and needed management changes. The descriptions, especially the sound level, are vague. An excerpt from draft VAMP is below.
Soundscapes: Change in Percent Time above Sound Level of Concern Soundscapes in national park system units offer an array of rich and diverse natural sounds in an environment relatively free of sounds generated by humans. These soundscapes are integral to wildlife and ecological health and are an important component of what makes the park a unique place, set aside for purposes expressed in both the NPS Organic Act and the Wilderness Act. Preserving and restoring natural soundscapes are, therefore, an important part of the NPS mission. Intrusive noise impacting natural sounds are of concern because they can impede ecological functions and diminish the National Park Service’s ability to accomplish its resource protection mission. Intrusive sounds are also a matter of concern to park visitors. Visitors at Yosemite directly contribute to the park’s soundscape via transit into and within the park, most notably Yosemite Valley. (VAMP, 2024)
General Natural Resource Environmental Consequences
Although the draft VAMP states the following objective and discusses potential resource impacts (see excerpt below), it does not analyze or detail natural resource impacts. We strongly believe this is a significant oversight that needs to be rectified in the final document.
Reduce Impacts on Natural Resources The park’s natural resources are negatively impacted by traffic congestion, social trailing, and other visitor behaviors during peak use times. Overflowing parking in undesignated areas contributes to vegetation trampling, soil denudation and compaction, and introduction of invasive plants. Social trailing from illegal roadside parking to key destinations often leads visitors closer to vulnerable ecosystems, including meadow and riparian areas, increasing opportunities to disturb wildlife and their habitat. 1-6 Even if visitors park in established locations and stay on designated trails, large numbers of people can have detrimental impacts on wildlife. High or concentrated human presence may cause some wildlife species to avoid places they would otherwise want to be, pushing them to less optimal habitat with lesser food resources. Additionally, increased visitation can further habituate and condition wildlife to human food and trash, which can cause bears and other wildlife to lose their natural avoidance of people, endangering both people and wildlife. Higher volumes of traffic on park roadways also increases the potential for vehicle-wildlife collisions. (VAMP, NPS, 2024)
The draft VAMP acknowledges vegetation trampling yet does not address a means to minimize or eliminate this practice. Vegetation hosts a plethora of critically important invertebrate species that often get displaced and trampled themselves. The same occurs in areas where amphibians and other herpetofauna inhabit, as they are most often not visible to the off-trail user.
In addition, social trailing increases the spread of exotic and invasive vegetation as seeds cling to socks and clothing and can further spread the non-natives, denigrating native habitats.
We acknowledge that the draft VAMP does conduct an analysis of impacts on special status species.
Expansion of Lodging and Visitor Serving Facilities Outside the Park
The growing numbers of lodging units along Hwy 120, in Groveland, Oakhurst, and regionally indicate future visitor demands for Yosemite National Park. The impacts will be significant if Yosemite does not implement a reservation system. The analysis of these foreseeable future demands should be in the final VAMP and help direct the selection of the alternative. The timely implementation of a reservation system is now.
Lack of an Updated Wilderness Stewardship Plan
The park acknowledges that it does not have an updated Wilderness Stewardship Plan, and it needs to be completed. We are concerned that day-use limitations are not in place for the wilderness area, and impacts may occur to wilderness character and condition due to a lack of user capacities. We understand that the current quota system only regulates overnight use, and day-use is unregulated. The Coalition believes the lack of day-use regulation and trail quotas is a major concern in setting the park’s overall user capacity to ensure solitude and wilderness character.
As background, we excerpted this from the Yosemite Foundation (NPS 2016) document:
“Wilderness stewardship plan (in process). Rationale — The purpose of Yosemite’s wilderness stewardship planning effort is to review the management direction established in the 1989 Yosemite Wilderness plan and update it as necessary to better align with contemporary use patterns and NPS policy. Scope — The wilderness stewardship plan would examine and refine the existing wilderness plan to incorporate new information and understanding about changes in visitor use patterns, methods of managing visitor use, techniques for trail design and construction, and concepts for managing stock in wilderness settings. It would also incorporate new policy direction and definitions for wilderness character into the park’s wilderness management framework and review the status of potential wilderness additions. Finally, the plan would determine the extent to which commercial services would be performed in the Yosemite Wilderness. Once completed, the direction in the revised wilderness stewardship plan would apply to both visitor and administrative use (National Park Service and concessioner) in wilderness. While some site-specific actions may be necessary, the primary focus of the plan would be to provide a framework for measuring and monitoring wilderness character to ensure that future management actions would be taken as needed to adapt to changing conditions.” (YOSE Foundation Document 2016)
Outstanding Resources Values and Critical Monitoring
The Coalition believes long-term resource and visitor quality monitoring with science-driven indicators, standards, and thresholds must be developed for this VAMP. The draft VAMP does not have detailed resource-related indicators, and we ask that the final plan provide descriptions of the indicators. We also recommend creating new Indicators with corresponding triggers for management responses related to natural and cultural resource protection. For example, an Indicator that can assess the number and/or location of illegally parked cars damaging meadow vegetation could trigger reduction in cars entering all or parts of Yosemite Valley. Please consider the development of such Indicators since they further address Purpose and Need. The indicators developed for TRP and MRP for Outstanding Remarkable Values are the model to follow. NPS must commit to funding these efforts and altering user capacities or adjusting management if thresholds are exceeded. We believe mentioning these river plan indicators and recent monitoring information in the VAMP for reference is necessary. For credibility, the NPS should make this information available to the public. The VAMP should address how park operations will be able to fund the operational cost of the proposed monitoring in the VAMP and make a commitment to implement it. Because most of the proposed monitoring is vaguely described, we are unsure how it will be implemented.
Currently, there are three Indicators with corresponding triggers for responsive management. These are excellent in helping to adapt any further parking or Vehicles at One Time (VAOT) changes and a great start. The Coalition respectfully recommends expanding the Early AM Arrival Indicator to include the Late PM Arrivals (i.e. after 3:00 or whatever time reservations are not required for the day). This would provide good information on crowding and lines related to those trying to enter after the reservation period. This has been shown to be an issue in other parks. The Coalition also recommends the Indicator developed exclusively for Alternative D – Vehicle Crowding on Roadways (Peak Hour VAOT) be included under Common to All Action Alternative Indicators. It seems like it would be valuable information to have for better decision making.
Closing Comments
In closing, we greatly appreciate the opportunity to comment on this important issue. Reducing traffic congestion and crowding have been long-standing goals to help ensure the continued protection of park resources and a quality visitor experience. The NPS has made a tremendous effort to add transportation improvements and other changes to accommodate the public while protecting park resources. We applaud the park for continuing to address these goals in the draft VAMP. Yet despite these efforts, the likelihood of ever-increasing visitation continues to put Yosemite’s natural beauty and serenity at risk. Yosemite Valley has been called a cathedral and should be treated as one. A reservation system that limits access during peak times and protects park resources is the only solution.
Sincerely,
Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks
Phone: (202) 819-8622
cc: Da*************@np*.gov, Regional Director, Pacific West