March 5, 2026
Mariposa County Planning Department
PO Box 2039
Mariposa, CA 95338
Submitted via email to pl**********@************ty.gov
Dear Mariposa County Planning Department,
On behalf of National Parks Conservation Association, Coalition to Protect America’s National Parks and National Wildlife Federation, we submit the following comments regarding Camp Yosemite LLC’s Formal Housing Development Project Application Nos. PLAN-MIN-2025-00016 and -00017 (filed on November 25, 2025).
Yosemite National Park is facing a crisis driven by over visitation, excessive vehicle traffic and overdevelopment of lodging outside of the park’s boundaries. This has resulted in a range of impacts including hours-long traffic jams at entrance stations and throughout the park, harm to Yosemite’s natural and cultural resources, wildlife and facilities, as well as public safety concerns and deteriorating experiences for park staff and visitors. At Yosemite Superintendent Ray McPadden’s direction, the park also recently eliminated the successful day-use reservation system that in 2024 welcomed over 4 million visitors – the 5th highest in Yosemite’s history – while helping resolve the crisis.
We are concerned that a new 110-unit residential development adjacent to West Yosemite and on the border of Yosemite National Park would exacerbate these impacts while also causing harm to local communities and tribes who own properties next to the proposed development site. Based on the evidence we have reviewed, we do not believe that California’s builder’s remedy should be utilized to force through this development.
I. California’s builder’s remedy does not apply to commercial short-term rentals or other transient lodging developments.
One of our top concerns is that the applicant’s proposed development is not actually meant to address the very real affordable housing shortage in the region. Rather, we are worried that the so-called “Camp Yosemite” development is a trojan horse scheme to develop a large new short-term rental or other transient lodging development just on the border of Yosemite, which will impact the park in a myriad of ways.
The owners of Camp Yosemite LLC are attempting to use California’s builder’s remedy provisions to push through approval of the development and allow the proposed parcels to be rezoned for higher density residential use. If this development is in fact any way seeking to provide transient lodging, then California’s builder’s remedy simply does not apply. According to 65589.5(h)(2)(a) and 65589.5(h)(2)(b)(i)(I)-(II) of California’s Government Code, the builder’s remedy that the applicants are pursuing is applicable to “residential units only” or to mixed-use developments where “[a]t least two-thirds of the new or converted square footage is designated for residential use [and] [n]o portion of the project is designated for use as a hotel, motel, bed and breakfast inn, or other transient lodging.” We are not aware of and seek clarification on how the County, through its consideration of this application, intends to guarantee that none of the proposed units would be utilized for unauthorized transient lodging.
II. Mariposa County should disapprove of this development if it will have an adverse impact on public health or safety that cannot be sufficiently mitigated
In the event the applicant can prove without doubt, and the County can verify without doubt, that the proposed development would not violate the builder’s remedy provisions related to non-residential lodging uses, it is important for planning staff to realize this does not mean the County has to approve the application. While the builder’s remedy requires counties to approve of housing developments that meet that statutes requirements, section 65589.5(d)(2) of the California Government Code allows local agencies to deny such developments if they “would have a specific, adverse impact upon the public health or safety, and there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact without rendering the development unaffordable to low- and moderate-income households or rendering the development of the emergency shelter financially infeasible.”
We believe based on public documents we have reviewed and feedback received from local community members that this project as proposed could result in numerous adverse impacts on public health and safety and there are likely no feasible mitigation measures that can be put in place to address those harms.
We trust that a full California Environmental Quality Act (CEQA) Environmental Impact Report (EIR) will be conducted to analyze the various environmental and public health and safety impacts of this project. In conducting an EIR and/or any other permitting requirements for Camp Yosemite, we request that the county ensure that the following potential impacts are fully analyzed and clarify whether they can be effectively mitigated.
a. Increased wildfire threats
Because of its location directly in the wildland urban interface in a region that faces significant wildfire threats, construction and occupation of this proposed development could substantially increase local wildfire risks – jeopardizing local communities and Yosemite National Park. In the wake of nearby wildfires such as the Furgeson and Rim fires, we are concerned by specific aspects of the proposal that could heighten localized wildfire risks and threaten public safety. For instance, fire risks could be exacerbated by the proposed density of the housing units, limited requirements for setbacks, as well as the project site itself, which is located on steep terrain that is full of excessive amounts of highly flammable biomass and vegetation. Moreover, should a fire occur, emergency response capabilities are extremely limited in the area, and associated response delays would affect the size, severity and danger any potential fire poses to the local community and to Yosemite.
b. Road access and emergency egress
There is only one access road to the development which runs through the Community of Yosemite West and connects directly to highway 41/Wawona Road within Yosemite National Park, which is used by thousands of visitors traveling in and out of Yosemite daily. The National Park Service has been asked many times to allow a second exit to be built for prior hotel projects and it has always been denied. Given the ever-growing threat of natural or human caused wildfires in the region, evacuating additional individuals at the bottom of a winding subdivision road without a secondary egress during an emergency is a significant concern.
c. Water and wastewater
The proposed Camp Yosemite development will require significant new water and wastewater infrastructure to make the project work. According to local community members, because much of the project lies outside the boundaries of Yosemite West, the development is not entitled to access to the community’s water or wastewater infrastructure. Even if the development worked out a way to share this infrastructure, we understand that Yosemite West’s outdated water and wastewater infrastructure is already out of compliance with state laws because it reliant on a single well and the deteriorating wastewater system is at capacity. Given recent climate change driven droughts and uncertainty about the availability of subsurface water, even if access to the current well exists or if future wells could be drilled on the development site, this proposal could overextend the availability of ground and surface water for Yosemite West residents and the surrounding ecosystems.
Under 65589.5(d)(2)(4) of the California’s builder’s remedy statute, jurisdictions can deny a proposed development if it “does not have adequate water or wastewater facilities to serve the project.” Should further investigation prove there to be a lack of adequate local water and wastewater facilities, then Mariposa County must deny the application.
d. Local zoning considerations
65589.5(d)(2)(4) specifies that local jurisdictions can deny a proposal brought under California’s builder’s remedy if “[t]he housing development project or emergency shelter is proposed on land zoned for agriculture or resource preservation that is surrounded on at least two sides by land being used for agricultural or resource preservation purposes.” Based on Mariposa County’s zoning map, it appears that (outside of Yosemite West which is zoned as rural residential), all the land upon which the development would be built and surrounded by is zoned as general forest. Moreover, this development would border nearly 900 acres of land recently transferred to the Southern Sierra Miwok Nation to be used for tribal purposes and conservation We believe this general forest zoning and the land owned by the Southern Sierra Miwok Nation qualifies as agricultural or resource preservation land uses, and thus these surrounding parcels would allow for disapproval by the County. We ask that Mariposa County Planning Department staff provide clarity on whether the parcels surrounding the development on at least two sides are indeed zoned for agricultural or resource preservation purposes. If so, then the county should deny the proposal.
e. Increased traffic
The construction and occupancy of 100 new housing units will undoubtedly lead to significant amounts of new vehicle traffic traveling through Yosemite National Park and Yosemite West. Given the parks significant preexisting issues with excessive vehicular traffic, the substantial number of additional vehicle trips caused by the construction and occupation of this development would lead to even longer lines at park entrance stations and further strain park highways and local Yosemite West roads. This would only be exacerbated during the winter months when snow and ice make vehicle travel even more dangerous.
f. Wildlife
Amid a global biodiversity crisis, Yosemite National Park serves as a refuge for a variety of native wildlife that does not know park boundaries. The Camp Yosemite proposal would deprive the region of crucial wildlife habitat, potentially alter or affect wildlife migration corridors, and could directly threaten numerous plant and animal species including threatened or endangered species, such as the pacific fisher.
g. Noise and light pollution
Construction and occupancy of the Camp Yosemite development will undoubtedly result in additional noise and light pollution affecting local communities, visitors to Yosemite national park, and local wildlife. We are concerned that noise from any additional development will interfere with the peaceful enjoyment of Yosemite while any light pollution will reduce the ability of visitors to perceive the parks beloved dark skies.
h. Watershed concerns
We understand that the watershed overlapping the proposed development site flows into the South Fork of the Merced River, including portions designated as wild and scenic under the U.S. Wild and Scenic Rivers Act. We are concerned that construction and occupancy of the proposed development could result in discharge of pollutants into the South Fork of the Merced affecting the rivers various values.
III. Tribal considerations
As mentioned above, the proposed Camp Yosemite development would directly abut the nearly 900 acres of land recently transferred to the Southern Sierra Miwok Nation. We strongly support the tribe’s stewardship of their ancestral lands and are seriously concerned that this proposed development could interfere with the tribe’s use and enjoyment of their land. Moreover, we are worried that the proposed development could disturb or damage important cultural or archaeological resources that reveal centuries of indigenous inhabitation in the region.
We strongly recommend that the county work closely and consult with the tribe on any CEQA, permitting, and/or other decision-making processes as it relates to this proposal and take all of their comments and objections into consideration when making any determinations on whether to allow this proposal to move forward.
IV. Conclusion
We are deeply concerned about the potential impact of this development on Yosemite National Park and local communities. For the above-mentioned reasons we strongly urge the Mariposa County Planning Department to (1) seriously consider if this application satisfies the criteria for the builder’s remedy process and (2) if it does satisfy the criteria, then fully analyze this application and deny approval if the identified concerns about developing housing in this specific area would trigger conditions would impact public health and safety.
Sincerely,
Mark Rose
Sierra Nevada Senior Program Manager
National Parks Conservation Association
Don Neubacher
Former Yosemite Superintendent and Board Member
Coalition to Protect America’s National Parks
Beth Pratt
Regional Executive Director, California
National Wildlife Federation