Joint Letter to Superintendent Lewis of Yellowstone from Conservation Organizations

National Parks Conservation Association • Coalition of National Park Service Retirees
Greater Yellowstone Coalition· The Wilderness Society
Winter Wildlands Alliance • Natural Resources Defense Council

September 30,2009

Superintendent Suzanne Lewis
P.O. Box 168
Yellowstone National Park
Wyoming 82190

Dear Superintendent Lewis:

On behalf of our two million collective members, we write to thank the more than 400 scientists
and managers who have given the American people a concise and valuable new window into the
health of Yellowstone National Park. The Superintendent's 2008 Report on Natural Resource
Vital Signs, made available to the public earlier this month, contains many pages of important
information about the welfare, and in some cases the prognosis, of resources of Yellowstone
National Park. Reading it, we were reminded of a statement in the 1999 State of the Park report:
"Will Yellowstone remain at risk? Only if the American public ceases to care, if budgetary
needs are not met, or if the many county, state, and federal jurisdictions whose decisions
affect Yellowstone do not recognize and act upon our collective interest in safeguarding
essential resources beyond the park's boundary - resources without which the park itself
will be tragically diminished. "

We believe the majority of this new report describing the Park's "vital signs" will help the
American people continue, more knowledgably, to care about Yellowstone's health. Thank
you for publishing it.

We recognize the purpose of the Superintendent's 2008 Report is to present monitoring data.
But obviously the larger aim of the National Park Service's Natural Resource Challenge, the
impetus behind this report, is to present monitoring data that enhances the public's
understanding and park managers' understanding of resource health, thereby illuminating
what management choices, over time, may help sustain or restore particular resources. As
Robert Stanton, then Director of the National Park Service, stated when he announced the
Natural Resource Challenge in 1999:

"The information that we can gather is not idle facts and curious statistics, it is the
underlying substance that will allow us to make informed decisions and take informed
actions in the parks and to inspire similar decisions and actions outside the parks. "

We are concerned that the report's most expansive discussion, "Effects of Oversnow Vehicles
on Resources," provides the public an incomplete picture of winter use in Yellowstone. The
report omits the clear and consistent conclusions of the National Park Service obtained in over
a decade of scientific analysis and the important fact that these conclusions have been independently verified by the Environmental Protection Agency. These are:

• Even strictly-limited snowmobile use would result in readily avoidable adverse
impacts to Yellowstone's air, soundscapes and wildlife; and

• Among the many alternatives studied to provide continuing motorized oversnow
access to Yellowstone's interior, the least impacting to the Park's resources and the
health of employees and visitors, is access with best-available-technology
snowcoaches and an end to snowmobile use within the park.

Eight former directors of the National Park Service cautioned in 2007 that when a long-term
policy is finally adopted to govern motorized oversnow access, the basis of the decision will
either strengthen or weaken the role of science in managing America's national parks, and
reaffirm or cast doubt on whether conservation remains the National Park Service's
predominant duty.

In light of this, we are concerned by what the Superintendent's 2008 Report includes and
omits:

The report states: In areas "where oversnow vehicles are most concentrated, " levels of
carbon monoxide and fine particulate matter in Yellowstone's air have not exceeded federal
or state air quality standards.

The report does not state: The National Park Service is required by its Organic Act and the
Clean Air Act to provide much stronger protection of Yellowstone's air than merely avoiding
violating federal and state standards that were designed largely to ensure that residents of
urban areas do not get sick from breathing city air. The obligation of Yellowstone's managers
is rather to "seek to perpetuate the best possible air quality in parks." This higher bar has led
the National Park Service and the EP A to conclude repeatedly that replacing snowmobile use
with access by best-available-technology snowcoaches would best safeguard Yellowstone's
air.

The report states: Fewer snowmobiles, required technological improvements and use of
commercial guides has, "reduced sound levels and the percent of time that snowmobiles are
audible. "

The report does not state: Despite these changes and with a daily average of fewer than 250
snowmobiles in the park, monitoring has found machine noise largely caused by snowmobiles
present at some locations in Yellowstone for over half of many visiting days, exceeding the
park's protective thresholds. Computer modeling successfully anticipated that these noise
problems would persist even with far fewer snowmobiles. Largely because of this, the
National Park Service and the EPA have consistently determined that replacing snowmobiles
with best-available-technology snowcoaches would provide the fewest adverse impacts to
Yellowstone's winter soundscape while providing full public access to the park's interior.

The report states: Maximum sound levels "frequently" spiked above 70 decibels at Madison
Junction and "93% of the spikes were from snowcoaches."

The report does not state: On an average winter day, a variety of historic and modern
snowcoaches make dozens of passes through Madison Junction. When the National Park
Service monitored for "loud sound events" at Madison in the 2007-2008 winter season, it
recorded an average of2 to 3 per day. These exceedances totaled "less than 1 minute per day"
and involved, 94 percent of the time, snowcoaches owned by the National Park Service and
operated under contract by Xanterra. NPS has been working with Xanterra to retrofit or
replace these vehicles and the conversions are on track to be completed by 2011.

The report states: Between 2003 and 2008, researchers assessed how species of wildlife
reacted when they encountered snowmobiles or snowcoaches. The incidence of animals
moving location, "were higher for snowcoaches than snowmobiles. "

The report does not state: During the time period discussed, there was a significant
reduction in the number of motorized oversnow vehicles traveling through the park. The
number of snowmobiles, each transporting one or sometimes two visitors, declined
dramatically, while the number of snowcoaches, each transporting an average of eight
visitors, increased. Wildlife biologists concluded that the net reduction in overall traffic was
highly beneficial to Yellowstone's wildlife. Indeed, their top recommendation to park
managers, to ensure the future fitness of animals existing in Yellowstone's harsh winters, was
to cap the reduced traffic levels or reduce them further.

In the conclusion of the Superintendent's 2008 Report, you have noted: "This report is
intended to be an annual document that will evolve based on user feedback and evaluation as
our monitoring program continues to develop." We appreciate this wonderful commitment
and are grateful for the opportunity to provide, as our foremost feedback to your "first
generation product," the following suggestion:

When the park develops monitoring data atop an enormous body of verified science-as
certainly is the case with "Effects of Overs now Vehicles on Resources" where since 1998 the
National Park Service has conducted three environmental impact studies and each study's
methodologies and results have been reviewed and corroborated by another federal agency-
the public ought to receive the benefit of this larger context, particularly when the addition of
larger conclusions can help ensure that the monitoring data is understood accurately.
We believe omission of such context in this one section of the 2008 report, given how much
misinformation and uncertainty has swirled around the issue of managing winter use in
Yellowstone, is a missed opportunity for a document that serves a high public service. To put
a fine point on what we believe is the resulting injury to the public:

The American people have not yet received the change in management in Yellowstone that
two federal agencies identified in 2000, 2003, 2004 and 2007 would provide opportunities for
winter visitors to enjoy the core of the park while maximally protecting its air, soundscapes
and wildlife. We believe that including this information in the 2008 report would have made
for a stronger, more accurate and enlightening report.

Thank you for considering our concerns and suggestions and thank you once again for the
hard work and dedication that went into producing this valuable and welcome report.

Sincerely,

Kristen Brengel
Director, Legislative & Government Affairs
National Parks Conservation Association

Bill Wade
Chair, Executive Council
Coalition of National Park Service Retirees

Charles M. Clusen
Director, National Parks Project
Natural Resources Defense Council

Mike Clark
Executive Director
Greater Yellowstone Coalition

Mark Menlove
Executive Director
Winter Wildlands Alliance

Bob Ekey
Northern Rockies Regional Director
The Wilderness Society

cc:
Jon Jarvis, Director, National Parks Service
Mike Snyder, Intermountain Regional Director, National Park Service
Will Shafroth, Deputy Assistant Secretary for Fish, Wildlife and Parks
Thomas Strickland, Interior Assistant Secretary for Fish, Wildlife and Parks