Set out below are the Access Fund's Yosemite VIP comments. Please feel
free to distribute or comment. There is an executive summary and statement
of the unique needs of climbers at the beginning, if you don't care to wade
through the 17 pages of the full text.
Superintendent Stanley Albright
Yosemite National Park
P.O. Box 577
Yosemite National Park, CA 95389
Attention: VIP Planning
Dear Superintendent Albright:
Comments on the Valley Implementation Plan
This contains the comments of The Access Fund on the Draft
Yosemite Valley Implementation Plan and Supplemental Environmental Impact
Statement ("the VIP"). The Access Fund is a national non-profit
organization of climbers dedicated to preserving the climbing environment
and maintaining climbers' access to climbing resources. The Access Fund
publishes low-impact educational materials for climbers, funds climbing
impact mitigation projects, acquires land containing climbing resources,
participates in the development of land management plans affecting
climbing, and contributes to the formulation of policies concerning
climbing by federal and state land management agencies.
EXECUTIVE SUMMARY
The Access Fund is concerned that the VIP does not
adequately consider the particular needs of special user groups, including
climbers. Climbers have unique patterns of visitation and use in the
Valley, and these give rise to particular needs. For example, climbers
tend to spend more time in the Valley than members of most other user
groups; climbers' use is more dispersed throughout the Valley, with
climbers using areas in the western part of the Valley seldom frequented by
others; climbers often begin ascents before sunrise and finish after
sunset; and climbers pursue their sport into the off-season, and even into
the winter. Climbers spend much of their time right at the edge of the
Valley's wilderness, where the noise and crowding of the Valley floor have
a particularly negative effect on the wilderness experience many climbers
seek on Valley walls. Finally, climbers enjoy a special camaraderie and
society in the Valley, one that is centered on Camp 4.
Climbers' unique access needs in the Valley include the
need for off-season and off-hour auto and parking access to climbing
approaches in the East Valley when the regional transportation service and
shuttle service will not be available; the need for continued auto and
parking access to climbing destinations in the West Valley that will not be
served by a shuttle; the need for access to the Camp 4 campground without
advance reservations; and the ability to access climbing approaches in the
East Valley that are remote from popular tourist attractions when access to
these tourist attractions has been curtailed because their carrying
capacities have been reached. Many of climbers' needs have already been
identified in the draft Yosemite Climbing Management Plan. This plan
remains in draft form and should be adopted as part of the overall planning
process for the Valley.
As a conservation organization, we support the central goal
of the VIP, which is to reduce automobile use in the Valley. However, we
believe that the transportation and parking portion of the VIP has not been
sufficiently well thought out. It focuses narrowly on the peak season/peak
hour visitor who enters and exits the park from the same direction,
ignoring off-season and off-hour visitation patterns and the needs of
visitors to the Valley who plan to enter and exit the park in different
directions. Consequently, we do not believe that the transportation and
parking scheme in the VIP is either realistic or workable, at least at the
present stage of development. In regard to the transportation components
of the VIP, we recommend that the NPS adopt Alternative IV, the Minimum
Requirements alternative, pending further progress in developing the
Regional Transportation System and a more balanced and in-depth
consideration of how to meet the transportation needs of all Valley
visitors.
Since the VIP will provide the NPS with the means to impose
limitations on day use visitation to the East Valley, while eliminating
much of the parking which formed the basis for the present limitations on
day use visitation, the VIP should clearly present the basis for either
continuing the present limitation on day use or establishing any new
limitations on day use visitation to the East Valley and analyze the
environmental impacts on the recreation experience, including climbing, of
doing so.
We also believe that the number of campsites in the Valley
should be retained at levels prescribed in the 1980 GMP, not reduced, with
additional walk-in campsites developed to achieve GMP levels, and that any
further reductions in Valley overnight accommodations should come from
developed lodging, not campsites; that RV access to scarce Valley campsites
should be limited to provide for greater access by tent campers; that a new
picnic ground should be developed at Ahwahnee Row to mitigate the loss of
other picnic grounds under the VIP; that auto access to the East Valley by
lodging guests should be restricted to the same extent as auto access by
day users; and that more asphalt roadways should be removed from the East
Valley than the VIP calls for.
I.THE UNIQUE ACCESS NEEDS OF CLIMBERS AND OTHER USER GROUPS SHOULD BE
ADDRESSED IN THE VIP.
Climbers are one of a number of user groups with special
patterns of visitation and special access needs. One of the great
weaknesses of the VIP, and particularly of its transportation and parking
components, is the failure to consider the use patterns and access needs of
such particular user groups. These include backpackers, equestrians,
cyclists, photographers, and weekenders of all types. The particular use
patterns of climbers are described below, followed by a discussion of the
particular needs of climbers as they relate to the VIP.
Climbers visit and use the Valley in ways unlike any other
user group that we are aware of. For one thing, individual climbers tend
to spend a lot of time in the Valley. Many climbers stay in the Valley for
extended periods. Others, typically weekender climbers, return to the
Valley repeatedly over the course of a season, often for years on end. As
a consequence, climbers tend to develop a keen awareness of the Valley
environment and of those aspects of the Valley infrastructure and services
that do and do not work for them.
Climbers use of the Valley is much more dispersed than that
of most other visitor groups. Most day use visitors will stay on the
Valley floor or take one of the trails to the Valley's principal water
features, while most backpackers use only a few Valley trailheads. Yet
climbers use the entire Valley, from Parkline Slabs in the west to Mount
Watkins and Half Dome in the east. In fact, relatively few climbs are
accessed by the Valley trails most popular with tourists--those leading to
Upper and Lower Yosemite Falls, Mirror Lake, and Vernal and Nevada Falls.
Most climbing in the eastern end of the Valley takes place on the walls on
the north side of the Valley between the Ahwahnee Hotel and El Capitan, at
Glacier Point Apron, and at the Cathedral Rocks, places little visited by
others.
Climbers also tend to keep longer hours than other types of
visitors. The Valley's many long climbing routes mean that climbers often
must start climbing in the early hours of the morning and descend in the
late hours of the night. Many long free climbs or big wall aid climbs
require climbing teams to make an "alpine start" well before sunrise in
order to summit or to reach a bivouac ledge before nightfall. Many long
climbs also necessarily involve a descent after dark and a return to the
trailhead late at night.
Climbers enjoy a longer season in the Valley relative to
many other types of visitors. Because of the Valley's low elevation and
the fact that many of the more popular climbs are on walls that face south,
climbing is possible year-round in the Valley, although little climbing
takes place in the months of December, January and February. Nevertheless,
climbing in the Valley is popular in many "off-season" months, particularly
since many climbers find the peak summer season too hot and too crowded for
their taste.
Because climbing tends to take place at the very border of
wilderness, many climbers also experience a continual sense of frustration
at the inability to have a wilderness experience in the Valley. Climbers
in the Valley lead a particularly dichotomous existence, spending most of
their days on the Valley's walls, where many seek a wilderness
experience--and are held to wilderness standards of conduct by the
NPS--only to return at days' end to the mechanized, urbanized, and often
crowded world of the Valley floor. Many climbers find the noise of
vehicles--particularly buses, motorcycles, and the loud-speaker Valley
tour--which reach even the most remote walls, the inability to camp
overnight in an environment remote from Valley development, and the whipsaw
effect on their sensibilities of the daily transition from Valley walls to
the Valley floor, substantially reduces their ability to appreciate the
natural qualities of the Valley. Backpackers, by contrast, typically pass
out of the heavily impacted area of the Valley within a few hours, while
day hikers, who may have an experience similar to that of climbers, are
unlikely to spend many days in the Valley.
Climbers, like the enthusiasts of any sport, enjoy the
companionship and camaraderie of their own kind. The bond between members
of a climbing team is strengthened by the fact that each relies on the
other for his very survival in the climbing environment. A climber is by
definition a person both willing to entrust his personal safety to another
and willing to assume responsibility for another's safety. Knowing this
about each other strengthens the sense of camaraderie that climbers
naturally share. In Yosemite Valley, this natural camaraderie among
climbers is enhanced by the shared enjoyment of one of the world's great
climbing areas. This sense of camaraderie is part of the climbing
experience in Yosemite and is best reflected in the society of Camp 4, the
Valley's traditional climbers' campground, where climbers (and other
campers) can find a campsite without an advance reservation, and where,
because campers are packed in six to a campsite without regard for group
size or identity, there exists the ever present possibility for new
friendships and associations. Thus, the society of climbers and the
"scene" at Camp 4 are very real parts of the climbing experience in
Yosemite Valley.
We now turn to the particular needs of climbers as they are
affected by the VIP.
A.Climbers' auto access to the West Valley should be preserved and enhanced.
Under the VIP, climbers should continue to have automobile
and parking access at West Valley climbing sites. The Proposed Alternative
envisions a regional transportation system that would intercept
Valley-bound day use visitors, transfer them from their cars to buses,
transport them to Taft Toe, and then transfer them to the Valley Tour or
Valley Shuttle. VIP at 43; See also Appendix D: Summary of the
Transportation Study. This scheme appears intended to address the majority
of day use visitors to the Valley, who will be headed to the popular
tourist attractions at the Valley's eastern end.
Many day use climbers will probably prefer to avoid this
cumbersome system and climb at West Valley sites, however. We predict that
one effect of implementing the VIP will be increased day use by climbers of
climbing areas west of the East Valley Checkpoint at Taft Toe. Many
climbers without Valley campground reservations (or day use reservations,
if a day use reservation system is implemented) will prefer to climb at
locations west of the East Valley Checkpoint rather than take the trouble
to pack their gear for a whole day, leave their car at an out of Valley
intercept point or at Taft Toe, and wait for a shuttle to take them into
the East Valley. Consequently, climber parking at west Valley climbing
sites should be retained and, if necessary, expanded.
This particularly applies at El Capitan, since it is
outside the day use vehicle restriction area, and it has popular short
climbs in addition to its well-known overnight big wall routes. The
Proposed Alternative would redesign the parking area facing El Capitan
along North Side Drive to provide areas for day use parking and to
accommodate a turnout for the Valley tour. See Valley View and Valley
Circulation Maps; see also VIP at 40, stating that vista points and picnic
areas will be built along the Old Big Oak Flat Road for viewing climbers on
El Capitan.
No mention is made in the VIP of climbers' need for
both day use and overnight parking while climbing on El Capitan, however.
(But note that the need for climber parking at El Capitan is acknowledged
in Appendix D, Summary of the Transportation Study, at 277.) The VIP
should be revised to explicitly state that the existing day use and
overnight parking for climbers on El Capitan on North Side Drive will be
retained.
B.Off-hour and off-season auto access to the East Valley and adequate East
Valley trailhead parking should be provided.
We are also concerned that climbers continue to have
off-hour and off-season access to and around the East Valley for very early
morning ascents or very late night descents from Valley walls, particularly
at major formations such as Sentinel Rock, Half Dome, Washington Column,
and Mount Watkins. We think it unlikely that either the regional
transportation system or the Valley shuttle would be operating with any
regularity at these small hours of the night, particularly in the
off-season, and the VIP does not explain what provision will be made for
climbers and others wishing to enter or move around the East Valley at such
times.
Climbers who approach the park in the middle of the night
should not have to wait until daybreak at an out-of-park transfer station
for a bus to arrive to take them to the Valley. Similarly, climbers
arriving at the Valley checkpoint in the early morning should not have to
wait for the shuttle to begin running so they can reach their trailhead.
Rather, they should be able to proceed directly to their trailhead if the
regional transportation system and the shuttle are not operating. This is
likely to be a common situation for climbers arriving late Friday night for
a weekend of big wall climbing. Also, climbers descending to the Valley
floor late at night, possibly with enormous haul bags, should not have to
wait till the morning shuttle or have to hike several miles along a road to
the Taft Toe parking lot to find their car and leave the Valley; they
should be able to return to their car at their trailhead.
Given the likelihood that it will not be economical to
operate the regional transportation system in the off-season or during
off-hours, or to operate the Valley shuttle during off-hours, auto access
to the Valley under the VIP should follow the pattern established at
Devil's Postpile National Monument, in which use of the shuttle is required
during normal daylight hours in the peak season, while auto access is
permitted at all other times. In this way, climbers and others needing to
park at trailheads or climbing approaches can schedule their arrival at a
time when the shuttle is not operating or at least when its use is not
mandatory. This would also mean that adequate parking should be retained
at East Valley trailheads and other appropriate locations.
C.Access restrictions designed to protect Valley tourist attractions should
be trailhead-specific.
With implementation of the VIP, traffic and parking
congestion will no longer be the primary focus of concern regarding the
impacts of day use visitation in the East Valley. Attention will shift to
the carrying capacity of the East Valley's major attractions, particularly
the Upper and Lower Yosemite Falls trails, the Vernal and Nevada falls
trails, and the Mirror Lake trail. The VIP indicates that visitation has
already reached the levels prescribed for these areas in the GMP.
As discussed in more detail below, we believe that any new
day use restrictions should be fully clarified and their impacts on the
recreational experience fully analyzed. We also suggest that any system of
day use limitations or reservations that the NPS imposes to prevent overuse
of the most popular Valley tourist resources be trailhead-specific, rather
than Valley-wide, so that climbers and others willing to visit less heavily
impacted resources will be able to do so. If instead, restrictions on
day-use are imposed on a Valley-wide basis, then climbers and others who do
not intend to visit the heavily-impacted tourist areas will be needlessly
barred from reaching their destinations.
D.Camp 4 must be kept available on a non-reservation basis.
Camp 4 currently operates on a non-reservation basis and
must continue to do so under the VIP. The thrust of the VIP is to separate
visitors to the East Valley into two categories: day use visitors and
overnight visitors with reservations. Under the Proposed Alternative,
these two categories of visitors will be processed separately at the East
Valley checkpoint, with those having reservation allowed to proceed in
their vehicles to their campground or lodging. VIP at 39, 41.
The VIP does not propose to convert Camp 4 to a
reservation-only campground, like all other Valley campgrounds.
Nevertheless, we believe that implementing the VIP will lead the NPS to
consider doing so to simplify the processing of visitors at the East Valley
checkpoint. It is essential, however, that Camp 4 be retained as a
non-reservation, space-available campground, as it has traditionally been.
This makes it available to the young and young at heart, who prefer to
travel more spontaneously than others, and to campers and climbers from
other parts of the country or from other countries, who should not be
expected to make reservations far in advance to accommodate the
uncertainties of long travel itineraries. This may mean that the
allocation of Camp 4 sites would have to be handled from the East Valley
Checkpoint. In any case, Camp 4 should continue to accommodate the needs
of these special populations, as mandated by the General Management Plan.
See GMP at 23.
Conversely, converting Camp 4 to a reservation-only
campground, like all the other Valley campgrounds, would tend to convert it
into a family-oriented campground catering to those with the time, leisure
and foresight to make camping reservations months in advance. Few of these
people are likely to be the young or climbers, and the society of climbers
for which Camp 4 has long been famous, and which is a vital component of
the climbing experience in the Valley, would be irretrievably lost.
E.The NPS should adopt the draft Yosemite Climbing Management Plan
as part of the overall planning process of which the VIP is a part.
Because climbers are a sizeable and distinct user group,
the NPS initiated a process to develop a management plan specifically to
address the impacts of climbing on the Valley environment, the particular
needs of climbers as a group, and the impacts of Valley visitation and
development on the climbing experience. While considerable NPS staff and
climber time has been devoted to the development of this plan, it remains
in draft form and has not been adopted by the NPS. We feel strongly that
with the development of the Lodge Plan and now the VIP, it is time for the
NPS to finalize the Yosemite Climbing Management Plan and integrate it into
the planning process for Yosemite Valley.
II.THE VIP'S TRANSPORTATION AND PARKING PROPOSALS ARE INADEQUATE TO ADDRESS
THE FULL RANGE OF VISITOR NEEDS.
Two central premises of the Preferred Alternative are that
if a regional transportation system can be developed to serve the Valley,
such a system would make a parking lot at Taft Toe unnecessary, VIP at 43,
and that with either development of a regional transportation system or a
parking lot at Taft Toe, substantially all existing day-use parking in the
East Valley (some 2,300 spaces) could safely be eliminated, VIP at 41.
Both of these assumptions are groundless; we believe that some day use
parking will be required at both the Taft Toe and the East Valley in order
for the transportation scheme proposed in the VIP to work. The assumptions
in the VIP appear to be based on a very narrow vision of how people visit
Yosemite, a vision limited to the peak season, peak-hour, single point of
origin and return excursion day visitor. This vision fails to consider the
full pattern of day use visitation, or the realistic needs of all East
Valley visitors, including off-season and off-hour visitors, visitors
planning to proceed to other destinations in or out of the park after
visiting the Valley, and visitors who are not one-time tourists, all
categories that will frequently include climbers.
The VIP completely ignores the wide variation in day use
visitation between the six-month peak season and the remainder of the year.
Nowhere in the VIP is there any consideration of the questionable economic
feasibility of operating a regional transportation system to serve Yosemite
in the winter, when system patronage would doubtless be very low,
particularly on weekdays. If a regional transportation system were
developed but was found to be uneconomical for serving off-season use, as
seems very likely, the NPS would have to either build the Taft Toe parking
lot or allow visitors continued direct access to day use parking in the
East Valley. Hence, the mere existence of a regional transportation system
that is successful at serving peak season use does not automatically
preclude the need for a parking lot at Taft Toe or continued day use
parking in the East Valley to serve off-season use.
The same holds true for off-hour use. While a regional
transportation system might be effective at serving peak hour day use, it
seems doubtful that it could economically serve visitors wishing to access
the East Valley late at night or early in the morning. Such visitors would
include climbers and backpackers travelling to approaches or trailheads in
the East Valley, particularly on Friday nights. They should not have to
wait until daybreak at an out of park transportation staging area to take
the regional transportation system into the Valley. They should be able to
drive directly to either Taft Toe or to their trailhead in the East Valley,
depending on the availability of the Valley shuttle at the time they
arrive. Hence, if the regional transportation system does not effectively
serve off-hour visitors, it will not obviate the need for in-Valley parking
to serve them, both at Taft Toe and in the East Valley.
There are also very real questions as to the ability of a
regional transportation system to serve park visitors that the VIP should
acknowledge. The transportation study summarized in Appendix D of the VIP
raised serious concerns as to the amount of day use automobile traffic that
could successfully be intercepted outside the park. As noted in the VIP,
almost 60% of visitors enter and leave the park via different entrance
stations. VIP, Appendix D at 269. Only 21% enter and exit through the
same station. Id. Thus, visitors planning to enter the park at Wawona,
visit the Valley and exit through Tuolumne Meadows, and who are compelled
to use the regional transportation system, would have to cover the mileage
between Wawona and the Valley three times. And after returning to Wawona
on the regional transportation system, they might feel compelled to take
local overnight lodging rather than face the daunting task of driving to
the Valley again on their way to Tuolumne Meadows over a route they had
already traversed twice that day. It seems very likely that compelling a
significant percentage of Valley visitors to travel three times over a
route that they would otherwise have traversed only once, in circumstances
that could require them to pay for overnight lodging for the privilege of
doing so, will generate vociferous opposition. In the face of such
opposition, the NPS might well invite through-park visitors to park at Taft
Toe instead. If so, this is yet a third circumstance in which the mere
existence of a functioning regional transportation system would not obviate
the need for parking at Taft Toe.
Even though the VIP does not propose to implement a
regional transportation system, if the VIP is to have any meaning or
integrity as a transportation planning document, it must give adequate
consideration to how such a system would serve Valley visitors and be
integrated with the transportation and parking system the NPS proposes for
the Valley. Otherwise, the VIP simply misleads its readers into believing
that the Taft Toe parking lot need never be built, or that auto access to
the East Valley or day use parking there can be eliminated without
substantial dislocations to current patterns of visitation that are certain
to generate public protest.
Because the description and functional analysis of the
transportation and parking elements in the VIP are so glaringly incomplete,
we believe that the NPS should adopt the transportation components of
Alternative IV, the Minimum Requirements alternative, for the time being,
until further progress is made in implementing the Regional Transportation
System and more detailed consideration can be given to how to serve the
realistic needs of all Valley visitors at all times and seasons of the
year. We also think that the implementation of the transportation and
parking portions of the VIP should be as flexible as possible, with parking
retained in the East Valley for off-season and off-hour use until it is
clear whether the transportation system and shuttle are able successfully
to handle the full range of visitor needs.
III.THE VIP SHOULD CLARIFY THE BASIS FOR, AND THE ENVIRONMENTAL IMPACTS OF,
ANY NEW LIMITATIONS ON THE NUMBER OF DAY USERS TO THE EAST VALLEY.
The VIP establishes the means for the NPS to control the
numbers of day use visitors to the East Valley. Once the East Valley
Checkpoint is in operation, it will be a relatively simple matter for the
NPS to monitor the number of day use visitors who have passed through, note
when a prescribed number has been reached, and shut off access to the East
Valley to all subsequent day use visitors, who would then be diverted to
other park destinations.
A maximum number of day use visitors for the Valley has
already been established by the 1980 General Management Plan ("GMP") for
Yosemite. This number is 10,530 people. GMP at 17, VIP at 9. This figure
was derived primarily from the number of Valley parking spaces available
for day use visitors, although consideration was given to tour bus visitors
as well. See GMP at 15.
The VIP notes that it does not plan to change this number.
VIP at 6. Hence, under the VIP, the maximum number of day use visitors
allowed into the Valley (or at least into the East Valley) would remain at
10,530. This number is already frequently reached or exceeded in the
summer. VIP at 6, Appendix D at 268. In recent years, the NPS has closed
off access to the park on certain summer weekends as a consequence. VIP at
6.
The problem with enforcing the GMP day use limits under the
VIP is that the basis for the GMP day use limits will no longer exist under
the VIP. The VIP plans to eliminate all, or at least nearly all, day use
parking in the East Valley. See VIP at 41. In doing so, it will also
eliminate the rationale for the day use visitor maximum of 10,530 people
established in the GMP.
If the Park Service expects to enforce the old GMP
numerical limitations on day use in the East Valley after day use parking
has been eliminated in the East Valley and before a day use reservation
system is in place, as the VIP indicates, or if the NPS anticipates
establishing new day use limitations, then in either case the basis for
these limitations should be clearly set forth in the VIP and the
environmental effects of imposing these limitations, including the effects
on the recreational experience of all types of users, including climbers,
should be analyzed in the VIP.
IV.THE NUMBER OF CAMPSITES SHOULD BE RETAINED AT LEVELS PRESCRIBED IN THE
GMP AND MORE WALK-IN SITES DEVELOPED.
The 1980 General Management Plan ("GMP") called for the
number of Valley campsites to be reduced from 872 to 756, a reduction of
116 sites, or 14%. GMP at 35, 43. The VIP proposes to further reduce the
total number of campsites from the GMP proposed level of 756 to 675, an
additional reduction of 81 sites, or 11% more than the reduction prescribed
in the GMP. VIP at 30, 45. The combined GMP/VIP reduction in campsites
would thus be 197 sites, or a 23% reduction from 1980 levels.
We support the goal of the 1980 GMP to reduce the numbers
of all types of lodging in the Valley, including campsites, in order to
reduce visitation impacts. However, the VIP's proposed further reduction
in campsites is a very substantial reduction in the number of people who
would otherwise have access to camping in the Valley. Taking the VIP's
180-day camping season, 95% occupancy rate for campsites, and average of
3.8 people per campsite group (see VIP at 165), the additional loss of
these 81 sites would mean that 52,634 people would be denied access to the
Valley each year (81 x 3.8 x 180 x .95 = 52,634). (The VIP erroneously
puts a dollar figure before this number of campers, thereby confusing the
reader. See VIP at 166.) The VIP also miscalculates the loss in revenue
to the NPS from this reduction in campsites as $13,851, using a figure of
$1 per night for camp fees, rather than the correct figure of $15 per
night. See VIP at 165. The actual loss to the NPS in camp fees is
therefore 15 times the amount stated in the VIP, or $207,765. These errors
and oversights should be corrected in the final EIS and the document
recirculated for comment.
The VIP acknowledges this reduction of campsites as a
"significant decrease in the park's lodging capacity," VIP at 165, but
offers absolutely no analysis of the impacts of this decrease on the
recreational experience. See VIP at 162-164. Instead, the VIP simply
notes laconically that "considerable unmet demand for in-park camping would
be anticipated," VIP at 165, and then concludes brightly that "most of the
excluded campers would readily accept local (out of Valley) accommodations
as an acceptable substitute," VIP at 166. As frequent in-Valley campers,
we vociferously disagree with this statement. It blithely overlooks a
number of crucial facts: 1) many out of Valley campgrounds are already full
during the peak season, 2) out of Valley campers would have to rely on the
regional transportation system to get into and out of the Valley, a
substantial expenditure of time and an inconvenience that in-Valley campers
would be able to avoid, 3) out of Valley campers could be barred from
entering the East Valley altogether by a day use limitation or reservation
system; and 4) for climbers contemplating one of the Valley's longer
climbs, considerable inconvenience would be involved in reaching the start
of the climb early and returning late. Certainly from our perspective as
climbers, out-of-Valley camping is a completely unacceptable substitute for
in-Valley camping. It is our unshakable conviction that if in-Valley
overnight accommodations are to be further reduced from GMP levels, these
reductions should come from developed lodging facilities, not from
campsites.
According to the VIP, the purpose of the proposed reduction
in campsites is to remove campsites from areas prone to flooding, reduce
campsite density, and improve circulation. VIP at 45. While these are
worthy goals, no data is presented in the VIP to show that additional
campsites could not be built in the Valley while still achieving these
purposes. In particular, the higher areas of the Medial Moraine between
Tenaya Creek and the Merced River, the area east of the proposed Lamon
Campground, the area surrounding the Tenaya Creek walk-in backpackers camp,
and the area east of the Ahwahnee Hotel are all possible sites for
campground development.
To bring the total number of campsites up to levels
prescribed by the GMP, additional campsites could be designed as walk-in
sites. Under the Preferred Alternative, walk-in sites constitute only 10%
of Valley campsites. Yet, such sites need less space than drive-in sites,
bring the visitor into a closer relationship with park resources, and make
the visitor less dependant on buildings, vehicles, and other forms of
modern technology than any other form of overnight lodging in the Valley.
As such, walk-in camping should be considered the "highest" form of
overnight lodging in the Valley and accorded the highest priority for
overnight accommodations in the VIP.
To work successfully, walk-in campsites must have adequate
parking to accommodate the likely numbers of campers in each site. Under
the Preferred Alternative, however, only 40 parking spaces are provided for
the 30 walk-in sites at the Tenaya Creek Campground, in contrast to the two
parking spaces provided at current tent sites. NPS studies cited in the
VIP indicate that a typical camping group consists of 3.8 people, and most
groups of this size using walk-in sites will be adults who, with all their
gear, will not fit into a single car. Consequently, each walk-in site
should have parking for two cars. Parking for the Tenaya Creek campground
should therefore be increased to 60 spaces.
In addition, since parking for walk-in sites can be located
somewhat apart from the campsites themselves, the parking for walk-in sites
could be located in the flood plain, if necessary, while the sites
themselves are located further away from the rivers. This is how parking
was sited at the Yosemite Lodge under the new Lodge Plan. In sum, the
project description in the VIP should state that new walk-in campsites will
be developed, and the total mix of Valley campgrounds altered to
incorporate more walk-in sites, so that the total number of campgrounds in
the Valley can be maintained at the levels prescribed in the GMP. The VIP
should also clearly state that no reductions in the number of campsites
from GMP levels will be considered except in the context of a comprehensive
review of all types of overnight lodging facilities in the Valley.
V. THE NUMBERS OF RV CAMPSITES SHOULD BE RESTRICTED.
The 1980 General Management Plan proposed to "restrict
self-contained vehicle [recreational vehicle, or RV] camping and separate
tent camping from vehicle camping." GMP at 43. The NPS subsequently
considered this goal of the GMP to be "accomplished" when it designated
Upper River campground as tent-only camping. See NPS, The 1980 GMP: A
Draft Analysis of Accomplishments to Date (1989) at 20. In effect, this
action simply provided tent-only camping in the one campground with the
smallest and most cramped sites, while RV camping was allowed in all other
drive-in campgrounds. For practical purposes, RV camping continued
unrestricted.
The VIP proposes to continue this pattern of unlimited RV
access to campsites. Under Alternatives 2, 3, and 4, there would be 443 RV
sites, 169 tent sites, and 68 walk-in sites in the Valley. VIP at 40,
45-46; See also maps for Alternatives 2-4, Ahwahnee Hotel & Campgrounds.
This means that 67% of Valley camp sites would be accessible to RVs. Given
that RVs never appear to constitute more than 50% of all camp site use in
the Valley, it seems obvious that the VIP proposal would simply continue
the present pattern in which RV's are subject to no meaningful restrictions
on campsite access. This is contrary to the mandate of the GMP.
To bring campsite use under the VIP in line with the
General Management Plan mandate to reduce self-contained vehicle camping,
camp sites available to RVs should be subject to meaningful limitations
under the VIP. There are good reasons for doing so. RVs allow the visitor
to remain almost completely detached from park resources while inside the
vehicle preparing food, eating, sleeping, and attending to personal
hygiene. Given the limited number of Valley campsites, and the fact that
demand for these sites greatly exceeds availability throughout the entire
peak season, preference in access to campsites should be given to those who
come to the park to live as close to park resources as park regulations
allow. Those who choose to use campgrounds as places to park their
moveable lodgings should be accorded a lower priority in access to scarce
Valley campgrounds.
RVs should also be separated from tent campers, since RV
uses tend to conflict with tent camping. Campers tend to resent RVs' great
bulk, the noise of their generators, the hermetically sealed nature of
their living environment, and the intrusion of modern technology, including
electricity and television, into an environment in which tent campers have
deliberately chosen to renounce these conveniences.
The VIP presents an opportunity to correct this problem and
should do so by imposing meaningful limitations on the number of campsites
available to RVs. Thus, we recommend that RVs be limited to the 71
campsites in Lower Pines Campground. This would provide RVs with access to
over 10% of Valley campsites, while at the same time isolating the RV
campground from tent campers.
VI.NEW VALLEY PICNIC GROUNDS SHOULD BE DEVELOPED TO MITIGATE THE LOSS OF
EXISTING PICNIC GROUNDS TO CAMPERS.
The Valley's picnic grounds are valued by climbers and
other campers as places to enjoy quiet breakfasts and dinners away from the
Valley's campgrounds, which can be dark, cold, smoky, crowded and noisy.
The VIP states that under all alternatives, no changes would be made to
existing picnic facilities. VIP at 26, 41, 55, and 64. Yet, the maps for
Alternatives 2-4, Valley Overview, show the picnic grounds at Cathedral,
Sentinel, and El Capitan (Manure Pile Buttress) being restored to natural
conditions. The VIP does not state exactly what is to be restored at these
picnic grounds, and this should be clarified. If in fact these picnic
grounds are to be eliminated, an environmental analysis of the
environmental effects of such action on recreational resources should be
included in the VIP.
The VIP should also describe the substantial reduction in
the use of Valley picnic grounds, and the resultant impacts on the
recreational experience, that is likely to result from the proposed
limitations on auto access and circulation in the Valley. For example,
under Alternatives 2-4, in which North Side Drive is closed to traffic east
of El Capitan, the El Capitan picnic area would be accessible only to
people on bicycles or on foot. This would make it essentially useless for
those seeking an alternative to the campgrounds for cooking breakfast or
dinner, since it would be impossible or at least unfeasible to bring
cooking gear, groceries, coolers, and firewood to this picnic ground.
Nor is the El Capitan picnic area likely to get much
mid-day use by walkers or cyclists. Given the short distances available
for bicycling in the Valley, few cyclists are likely to consider it a
viable lunch destination, and few walkers are likely to choose a site with
tables and barbecue pits simply to eat their sandwiches, particularly when
other sites offer better views, access to water, and a less impacted, more
natural and more private environment. In short, it seems unlikely that
anyone would find much use for this picnic ground, and that under the VIP
it would soon be abandoned. The VIP should note this very real possibility
and consider alternate means to meet the demand for picnic facilities.
Similarly, it seems likely that the Cathedral picnic area
will become an adjunct of the Taft Toe parking lot, presumably a place for
people to cool their tempers while they wait for problems with their
reservations to be worked out or for a cancellation to become available at
one of the lodgings or campgrounds. No one staying at a campground would
choose to go there because the environment would be dominated by the
enormous parking lot and the noise and fumes of traffic on South Side drive.
Sentinel picnic area might remain of some interest to the
camper seeking relief from the campgrounds, but only if the shuttle buses
take the access road into the picnic area itself, so that campers can bring
their coolers, stoves, and cooking gear. Without direct shuttle service,
this picnic ground would have little purpose, because no one would carry
coolers and stoves down the access road if the shuttle bus just stopped on
South Side Drive, and cyclists and day hikers looking for a place to eat a
sandwich have no need for picnic tables and fire pits and are more likely
to disperse themselves along the river and in meadows where the shade is
less deep, the views better, and the environment less impacted.
With the Cathedral and El Capitan picnic grounds
effectively lost to Valley campers seeking alternative locations to enjoy
breakfast or dinner, and access to the Sentinel picnic ground in question,
the VIP should propose the creation of one or more new picnic grounds in
the developed area of the East Valley to mitigate this loss. The
demolition of the concessionaire houses on Ahwahnee Row provides a rare
opportunity for the NPS to create a picnic ground looking out over Ahwahnee
Meadow with spectacular views of Half Dome and early morning sun--two
things that the camper sorely welcomes after a few days in the gloom of the
campgrounds. This location would also be easily accessible to campers by a
short shuttle ride. This location should be developed as a new picnic
grounds to mitigate the loss of El Capitan and Cathedral picnic grounds to
Valley campers.
VII. GUESTS AT OVERNIGHT LODGING SHOULD ARRIVE BY TRANSIT.
Under the Proposed Alternative, all visitors with overnight
lodging or camping reservations would be allowed to drive their vehicles
directly to their place of lodging or to their campsite. VIP at 39. They
would not be allowed to use their vehicles for touring in the Valley,
however, and would be required to use the Valley shuttle for this purpose.
VIP at 40.
It is understandable that campers would need to be able to
drive directly to their campsites, since their vehicles would be filled
with gear and food. There appears to be no reason why lodging guests
should be allowed to drive to their lodgings, however. Most of these
people will be staying for one, two, or three nights and taking their meals
in Valley restaurants, and they can easily carry everything they need in a
few pieces of luggage. Their cars will be useless to them while they are
in the Valley anyway, so there is no reason that their cars could not be
parked at regional transportation stations out of the Valley or at Taft Toe.
The resource benefits of this course of action would be
substantial. The Valley presently accommodates 860 overnight lodging
units. VIP at 18. Assuming that at least one overnight parking space is
allocated for each of these 860 units, then approximately 860 parking
spaces and their access drives could be removed from the East Valley,
resulting in the elimination of 8-10 acres of asphalt. Some overnight
lodging parking may have to be retained for off-season lodgers or off-hour
arrivals. Nevertheless, the restriction on auto use should be extended to
overnight lodgers to the maximum extend feasible.
VIII.MORE ASPHALT SHOULD BE REMOVED FROM THE EASTERN END OF THE VALLEY.
None of the transportation maps in the VIP show the
existing asphalt road to Mirror Lake. The Valley Circulation Maps for both
the No Action Alternative and the Proposed Alternative show only a bike
path crossing Tenaya Creek and then a footpath and equestrian trail
continuing to Mirror Lake. While we agree with this trail configuration,
the VIP should also propose the removal and restoration of the asphalt road
to Mirror Lake.
In addition, all alternatives show a shuttle loop from
Curry Village to Happy Isles that circles around Upper Pines campground and
crosses the Merced twice before returning to Curry Village. Most of this
loop could be eliminated. The shuttle should run to the NPS stables/old
Curry dump, turn around and go to Lamon Orchard, and then turn around and
return to Curry Village. In this way, the remainder of this loop,
including the section of road between the stables/dump and Happy Isles, as
well as the section east of the Merced, including the Happy Isles bridge,
could be removed and this section of roadway restored. Hikers would only
have to walk a few more minutes to get to Happy Isles or Mirror Lake, and
campers in Upper Pines would suffer only minor inconvenience in getting to
the shuttle. The remainder of the shuttle loop east of the Merced River
seems to serve little purpose and could easily be eliminated. This would
also free up more space for new campsites.
The Access Fund appreciates this opportunity to contribute
to the development of the VIP and the planning process for Yosemite Valley.
Please do not hesitate to call me with any questions regarding these
comments on the VIP.
Yours very truly,
Paul Minault
Regional Coordinator
Armando Menocal
amenocal@earthlink.net
(307) 734-6034 (ph/fax)
Box 414
Wilson, WY 83014-0414