Coalition Opposes Reopening Moose-Wilson Road Decision Without Full Public Review

ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW

 

July 8, 2026

 

National Park Service, Grand Teton National Park

 

Subject:  Comment on Revised Draft Programmatic Agreement for the Moose-Wilson Road Comprehensive Management Plan

 

The Coalition to Protect America’s National Parks (Coalition) is comprised of more than 5,000 members, all of whom are retired, former, or current National Park Service (NPS) employees or volunteers who collectively represent more than 50,000 years of national park management and stewardship experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are numerous former employees of Grand Teton National Park, include some who were involved in the previous planning effort.

 

We strongly object to reconsideration of a portion of the Moose-Wilson Road Comprehensive Management Plan and to your method of asking, not for public input on the merits of revisiting a multi-year planning process that engendered strong and varied public opinions, but only for comments on a revised draft programmatic agreement (PA) with the Wyoming State Historic Preservation Office (WYSHPO). This fails to provide the public with any persuasively stated rationale for reopening a decision made a decade ago. To the contrary, the only stated purpose of such reconsideration in the draft PA is to enhance recreational opportunities under recently Executive Order 14314. Such a mandate is not the sole—nor we would argue—primary purpose of national parks. The National Park Service (NPS) Organic Act, established by the U.S. Congress in 1916  (39 Stat 535), mandated the NPS to conserve park scenery, natural and historic objects, and wildlife, while managing them “unimpaired for the enjoyment of future generations.” 

 

The revised draft PA admits that the newly reconsidered alternative, which was rejected in the original 2016 Record of Decision for the Moose-Wilson Corridor, would have an adverse effect on Moose-Wilson Road (documented by the Wyoming WYSHPO as site 48TE1205) and also to the Sawmill Ponds archeological site (48TE498), both of which are eligible for listing in the National Register of Historic Places. The draft PA also admits that additional cultural properties, the LSR Site (48TE1959) and Grey Owl Sites (48TE1961), although yet unevaluated for the National Register, would be adversely affected by the proposed action, which would realign 1.8 miles of the Moose-Wilson Road and construct a separated multi-use pathway along the road.

 

The draft PA appropriately does not yet propose final mitigating measures while awaiting completion of consultation with the WYSHPO, with other consulting parties, and with eleven American Indian tribes listed in the PA. However, the draft PA does imply that the NPS believes resolution to an adverse effect could be to prepare, record, and archive Historic American Landscapes Survey documentation of the sites. This essentially would document destruction of a historic landscape and prehistoric archeological sites for the purposes of building and constructing a pathway for a comparatively small number of persons, whether non-resident visitors or, we would suggest, primarily residents of the area in and near Jackson Hole.

 

NPS’ longstanding practice under Section 106 has been to avoid or minimize adverse effects on historic properties. The original 2016 agency decision did not select analyzed alternative B, “primarily because the proposed realignment of the Moose-Wilson Road would result in significant and irreversible adverse impacts on archeological resources…” and “a substantial loss of the historic character and cultural integrity of the road corridor.” Alternative D was similarly not selected for numerous reasons, the first of which mentioned in the previous ROD was “because it would have the same significant adverse impacts on archeological resources, historic character, and cultural landscape integrity as alternative B.”

 

Such admitted serious consequences for the cultural resources of Grand Teton National Park deserve, at the very least, not just consultation with tribes, the WYSHPO, and other parties interested in historic properties, but with the broader public that was and has continued to be engaged in planning and management of the Moose-Wilson corridor. We believe that, if the NPS is determined to pursue reconsideration of a portion of the 2016 ROD, their admission of direct adverse effects on known cultural resources warrants full reconsideration under the National Environmental Policy Act (NEPA) through preparation of a new environmental impact statement, with associated public scoping and a comment period of at least forty-five days as required under the law.

 

Thank you for considering our input on this important issue.

 

Sincerely,

 

 

 

 

Cheryl A. Schreier
Chair of the Executive Council
Coalition to Protect America’s National Parks
Email: Ed****@********ps.org
Mail: 2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Web: www.protectnps.org
Phone: (202) 819-8622