Executive Council:

·          Robert Arnberger

·          Don Castleberry

·          Maureen Finnerty

·          Denny Huffman

·          Abby Miller

·          Jerry Rogers

·          Rick Smith

·          Bill Wade

Voices of Experience – Advocating Protection of America’s National Parks  

December 4, 2006  

The Honorable Donna Christensen

1510 Longworth House Office Building

Washington, DC 20515 

Dear Representative Christensen:
 
We are writing to share our deep concern about pending amendments in both houses of Congress that relate to Yellowstone National Park. The riders offered by Senator Burns and Representative Pombo ignore repeated scientific findings of the National Park Service and the Environmental Protection Agency and would force a radical departure from NPS’ overarching duty to conserve the national parks. By mandating a continuation of snowmobile use, the riders prescribe a future in our country’s oldest national park that would include levels of air and noise pollution and disturbance of wildlife that NPS has determined are readily avoidable by providing full public access to Yellowstone with snowcoaches rather than snowmobiles. The riders’ greater impacts to Yellowstone contradict what the American public has said by overwhelming margins that it wants.  

The Coalition of National Park Service Retirees urges you to block these attempts to substitute appropriations riders for scientific research and monitoring, and public preference because they would:
 

Undermine the 2006 NPS Management Policies recently adopted with strong bipartisan and public support
The 2006 NPS Management Policies were widely applauded as a reaffirmation of NPS’ fundamental obligation to preserve the national parks for current and future generations. The policies explicitly state:  

·        NPS managers must always seek ways to avoid, or to minimize to the greatest degree practicable, adverse impacts on park resources and values. 

·        ...the Service will seek to perpetuate the best possible air quality in parks...  

·        The National Park Service will preserve, to the greatest extent possible, the natural soundscapes of parks. 

·        Where such use is necessary and appropriate, the least impacting equipment, vehicles, and transportation systems should be used. 

·        Congress, recognizing that the enjoyment by future generations of the national parks can be ensured only if the superb quality of park resources and values is left unimpaired, has provided that when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant. This is how courts have consistently interpreted the Organic Act. 

None of these policies would be upheld under the Burns and Pombo riders.  Particularly in the context of  America’s first national park and with scientific conclusions verified through multiple studies at enormous taxpayer expense, adopting such riders would set a dangerous precedent that NPS’ policies can be ignored or suspended whenever it suits a political agenda.

Undercut America’s highest standards for air quality
Yellowstone is a Class 1 airshed, a designation Congress created as a gold standard of national air quality. NPS studies show that allowing 720 snowmobiles per day in Yellowstone as the Pombo and Burns riders mandate would result in significantly greater pollution of Yellowstone’s air than the Park has seen during the past three winters and significantly more air pollution than providing winter access to Yellowstone by snowcoach. The same study shows the primary reason for Yellowstone’s improved air quality has been the sharp reduction in the number of snowmobiles in the park to an average of 250 per day.
 

The riders would reverse the progress currently benefiting the health and enjoyment of Yellowstone’s winter visitors and degrade air quality within this Class 1 airshed—directly contravening direction given to NPS by Congress. Worse, the riders would establish a precedent that Congress’ commitment to maintaining the cleanest, healthiest air possible in certain areas of the country is expendable even in the crown jewel of America’s national parks.   

Exacerbate snowmobile noise that is already violating Yellowstone’s standards

The recently adopted Management Policies direct NPS not to allow activities whose impacts would interfere with “the atmosphere of peace and tranquility, or the natural soundscape maintained in wilderness and natural, historic, or commemorative locations within the park.” NPS studies demonstrated that snowmobile noise has exceeded Yellowstone’s standards in the last three winters even as the number of snowmobiles entering the park has declined and converted entirely to the 4-stroke machines highly touted by the snowmobile industry as “cleaner and quieter.”  

NPS says these impacts, occurring with an average of 250 snowmobiles in the park each day, fall into the category of “major adverse effects,” interfering with visitor enjoyment and affecting those areas most accessible by the vast majority of park visitors. At the 720 snowmobiles per day mandated in the Pombo and Burns riders, snowmobile noise would exceed Yellowstone’s standards by even greater margins.  
 
Disregard the overwhelming majority of public sentiment
Since 1998, NPS has repeatedly asked the public to comment on a range of alternatives for winter use in Yellowstone. In record numbers and by margins consistently greater than 4-to-1, citizens have urged NPS to phase out the use of snowmobiles in the park in favor of increasing the use of the more environmentally-friendly snowcoaches.
 

Ignore the more protective and less costly winter access to YellowstoneThe National Park Service has repeatedly determined that new-generation snowcoaches have significantly less impact on Yellowstone’s environment than snowmobiles, preserving unique natural resources and providing access to the park’s popular attractions with much less motorized traffic. This reduction in traffic not only improves conditions for visitors, it also lifts a significant burden from Yellowstone’s winter-stressed animals that move on or near its roads. Yellowstone’s visitors are increasingly choosing to enter and enjoy the park by snowcoach; over the last five years, demand has doubled the number of snowcoach operators in the gateway communities around the park.   

We ask for your leadership in ensuring that Yellowstone’s highly positive transition is not reversed by the Burns or Pombo amendments, which defy NPS’ legal responsibilities, conclusive scientific findings, and the unprecedented tide of public insistence that standards not be lowered in our first national park. For all these reasons, we ask you to ensure that no riders are attached to any budget bills.  

Sincerely yours,

J. W. “Bill” Wade

Chair, Executive Council 

The Coalition of National Park Service Retirees (CNPSR) consists of 550 members, all former employees of the National Park Service. Together, they represent more than 16,500 years of stewardship of America’s most precious natural and cultural resources. CNPSR members continue to devote their experience and integrity to building support for needed solutions in the national parks. The Coalition includes five former NPS directors or deputy directors; 24 former regional directors or deputy regional directors; 31 former associate or assistant directors at the national or regional level; 68 former division chiefs at the national or regional level; and 142 former park superintendents or assistant superintendents.