bigwalls.net

Letter to RD Caughron from Dick Duane

February 25, 1998

R.D. Caughron

Dear R.D.:

I think we can both agree that Camp 4 in Yosemite Valley is one of the few campgrounds in the world that is, in and of itself, a travel destination. Name a country with a climbing tradition, and I'll guarantee there are people there right now scheming to get to Camp 4 so they can meet their climbing comrades from around the world and tackle the great routes and walls of Yosemite Valley.

By some ironic law of unintended consequences, the promise of the National Park Service (NPS) over the past 17 years to make a visit to the Valley a more fulfilling wilderness experience has resulted in the decision to build five three-story apartment buildings up against Camp 4 and to place lodging in an adjoining bouldering area known as Swan Slab. The end result will be to destroy, not enhance, the ambiance of this treasured park resource.

Tom Frost and other climbers have retained our firm and former Sierra Legal Defense Fund attorney Larry Silver to determine whether a legal challenge might be made to stop or alter these plans. It is our conclusion that the construction project as now conceived, and explained to the public, has not met the requirements of the National Environmental Police Act (NEPA), 42 U.S.C. § 4331 et seq. More particularly, we feel that the Environmental Assessment used to justify these plans in the Draft Concept Development Plan for the Yosemite Lodge Area (1997) inadequately considered the alternatives to putting this construction in the Camp 4/Swan Slab area, and failed to provide a sufficient environmental analysis of the impact of the construction plans.

The following portions of this letter will give you some understanding of how the decision-making process of the National Part Service evolved. If you have the patience to follow the process, I think you'll come to the conclusion, as we have, that the plans for the Camp 4/Swan Slab are truly unnecessary, and not in the interests of climbers, the National Park Service or the park concessionaire.

The Changes Proposed/What's Wrong With Them

Changes now proposed by the NPS that will go a long way toward ruining the integrity of Camp 4. Five apartment buildings, three stories high, that will house 336 employees are going to be built across the area now marked by Northside Drive and up against Camp 4. The parking lot used by the climbers, as much as a meeting spot and hang-out as a place to leave their cars, will be moved south of Northside Drive. Lodging, formerly kept to the south of Northside Drive, in the Yosemite Lodge area, will be moved north into the Swan Slab site.

The park officials have a formal language to discuss these matters. They have a mandate to maintain a "safe, functional, and orderly environment that provides compatible opportunities for resource preservation and enjoyment by visitors and employees." Their goal is to "provide the opportunity for a quality wilderness experience" and to "assist all people in enjoying the natural, cultural and scenic resources."

How can this mandate and this goal be achieved if apartment buildings are constructed by a walk-in campground, and lodging is erected in an undeveloped area used for bouldering by the climbers? Joining employee housing, a walk-in campground and visitor lodging in one small area would subject the land to "incompatible uses." The "integrity" of the campground would be destroyed by the presence of the apartment buildings and hundreds of park employees. The "quality of experience" for the climbers bouldering in the Swan Slab area would be degraded by the presence of permanent lodging. Noise, crowding, visual impairment and distraction, and the loss of space to dream and drift in nature would be the inevitable results of these "incompatible uses."

True, there was a gas station nearby in the past, but the prior existence of a gas station doesn't provide the rationale for further diminishing the experience at Camp 4 by building five three-story apartment buildings in the area, or for erecting lodging by Swan Slab.

Young climbers throughout the world are now saving their money by working odd jobs in order to get to Camp 4. Historic dream space, gypsy-like freedom, and the atmosphere of challenge and endeavor will be sadly dimmed when they arrive if the plans of the Park Service are not reversed.

The Key Factors in Producing These Changes:

The Number of Employees to Be Housed in the Park,

Site Locations Chosen, and the Flood

How did this happen? Since 1980, when the National Park Service issued its General Master Plan (GMP), there has been a promise of bringing back to the Valley a true wilderness experience by reducing the number of employees housed there and by decreasing the number of overnight visitors. Who could have imagined that out of these promises would come an enormous concentration of employees in an area utterly unequipped to absorb them, and a plan to place middle-income lodging in the Swan Slab area where no lodging had ever existed.

I'll try to give you the chronology of documents and events that produced this result. It may help if I first point out three factors that have helped me organize my thoughts. They are as follows:

(1) As you read, keep in mind the National Park Service's process of deciding how many employees actually have to remain housed in the Valley to keep it a functioning park. The higher the number, the more housing you have to build inside the park, and the more difficult it becomes to diminish the negative impact on the wilderness experience of the visitors.

(2) Follow the process of how the Park Service analyzed and dealt with the places where one might put employee housing, both in and out of the park. Curry Village, the Yosemite Village area, the Ahwahnee Inn area, and the Yosemite Lodge Area are the major places already developed within the park which have been used for employee housing. To get an idea as to where those areas are, take a look at the maps at the back of the Draft, Yosemite Valley Implementation Plan/Supplemental Environmental Impact Statement.

(3) Watch how the flood of January 1997 affects the planning process.

Since the handling of these three factors by the NPS did much to produce the problem we face, let me give you some thoughts about them.

1. The Number of Employees Housed in the Park

There have been four possible numbers of employees that have been considered "necessary" to house in the park: 221, 480, 688 and 1,017. The numbers seem to change in various planning documents without any real analysis of the different figures used or of the employees' need to live in the park or of their impact on the Valley wilderness experience. The plan to build housing alongside Camp 4 was made when the NPS was utilizing the 1,000+ figure. The Yosemite Valley Implementation Plan introduces, without much analysis, the possibility that 765 employees will be housed in the park. The smaller the number, the less housing necessary. The less housing needed, the less need to destroy the Camp 4 area.

Where is a discussion of the number of employees necessary to live in the park? What rationale, if any, does NPS give for the escalating numbers? Does it provide justification for any of the numbers it bandies about?

2. The Sites Considered

To the extent that it insists that employees live within the park, the NPS is tempted to use only the three or possibly four already developed areas. (This temptation, however, doesn't explain why they end up sticking apartment dwellings in the relatively undeveloped area abutting Camp 4.)

Irrespective of the number of employees the NPS decides to keep in the park, how did it go about the process of choosing appropriate sites for their housing? It could decide to house employees in the previously developed portions of Curry Village, Yosemite Village, the Ahwahnee, or Yosemite Lodge. There is a particularly good spot available in the old, now empty, maintenance yard in Yosemite Village. The NPS has to make value judgments about where the concentration of employee housing will do the least amount of harm, even if it does choose to use previously developed areas as housing sites. It could even have considered developing other previously undisturbed parts of the park, such as the area along Southside Drive. (This part of the park is frequently in the shade and is the least desirable area to walk in.)

As you review the documents, it may help to determine whether all of the alternatives were considered in dealing with site locations and whether the environmental analysis relating to the choice of sites was properly handled.

3. The Flood

Finally, keep in mind that the flood which occurred in January of 1997 drastically reduced the amount of non-"flood zone" space where the NPS might put employee housing or visitor lodging. (A map of the flood zone from the January 1997 flood is attached for your use.) All of the employee housing in the Yosemite Lodge area was in the flood zone and was damaged. Fifty percent of the visitor lodging in the area was also damaged.

Before the flood, the NPS, almost by a process of osmosis, ended up choosing the Yosemite Lodge area as the place to concentrate employee housing. (You will see this when you review the 1992 and 1997 Yosemite Housing Plans and the Draft Yosemite Valley Implementation Plan/Supplemental Environmental Impact Statement (VIP).) These pre-flood decisions would have had no impact on Camp 4 or Swan Slab, since the housing would have been built to the south of Northside Drive where similar housing/lodging already exists. The failure to re-think this decision after the flood meant that housing and lodging was going to be concentrated in the one area the flood proved to be utterly unfit for such a use. Unless the NPS rethought its decisions regarding the concentration of employee housing and the building of visitor lodging in the Yosemite Lodge area, it was inevitable that it would end up building in the historic Camp 4/Swan Slab area and destroy the ambiance of these areas. The necessary rethinking didn't occur. Since there is at least one excellent previously developed site available in the non-flood zone area at Yosemite Village (the abandoned maintenance yard), the failure to rethink the matter seems inexcusable.

4. Other Factors

Those are the major factors I see that led to this decision. There are others, however. When lodging and/or employee housing is rebuilt, the amount of space needed will depend not only on the number of needed beds, but also on the size of the space allotted to each lodger or employee. The plans of the NPS greatly expanded the construction space set aside for each visitor and employee, and therefore expanded the amount of land that would have to be developed.

Note also that the phrase "flood zone" has prompted a knee- jerk reaction: you can't build in it because there will be a flood. In fact, the Park Service intends to build facilities (e.g., large parking lots, for example) in the flood zone and plans to keep other buildings there that were affected by the flood. If so, why hasn't the NPS also considered building flood-proof employee housing within the flood zone? Architects know how to do this, but no one seems to have considered it.

Chronology

Should you wish to review the actual public documents yourself, it may be helpful to have a chronology of their issuance. You can refer to the chronology when you read the summary of the documents provided in the following portions of the letter.

A Brief Discussion of the Documents

The majority of the documents listed above are available from the National Park Service. I've reviewed the documents to try and follow the chain of decisions that led to the current crisis. You may find the following brief summary of the documents helpful in arriving at your own conclusions about the validity of our position.

1. The General Management Plan (1980)

The General Management Plan (GMP) was passed pursuant to the mandates of the National Park Service Organic Act, 16 U.S.C. § 1

et seq. which required the Park Service to prepare and revise "the General Master Plans . . . for the preservation and use of each unit of the National Park Service." 16 U.S.C. §§ 1a-7b. The statute spells out minimum requirements for these plans and requires federal revision of these plans in a "timely" manner. The implementing regulations for the National Park Act may be found at 36 C.F.R. § 7 et seq.

The 1980 General Plan spelled out the visionary premises that Yosemite Valley had been overdeveloped and that the process must be reversed so that those activities that "take advantage of the park's natural features rather than the man-made facilities or mechanized equipment" could more thoroughly enjoyed. (GMP, p. 15.) It is significant to note the type of experiences that the NPS considered appropriate:

Picnicking along the Merced River or reading in a flowered meadow is relaxing and calm; a Valley scenic tour or historic walk is inspirational and educational; and a three-day climb on El Capitan is exciting and challenging.

(GMP, p. 31). This description, with its reference to the climbing of El Capitan, is significant. It shows that the National Park Service recognized at least eighteen years ago that climbing was one of the central experiences in the Valley for both those participating and those watching.

It's also important to note that Sunnyside campground (Camp 4), was already clearly established as the climbers' gathering spot. With this knowledge, the General Master Plan clearly stated that the campground would be retained. Again this, in my view, is an acknowledgement that the Park Service should be committed to supporting the culture and atmosphere in which climbers live and carry out their efforts.

Enhancing the wilderness experience of the park meant rethinking visitor use and the presence of park and concession buildings. The amount of overnight usage was to be reduced. More specifically, accommodations in the Valley were to be decreased by 268 units.

In 1980, there were about 1,900 employees, of whom about 1,390 were housed in the Valley. Housing in the park was to be provided only for "employees whose jobs regularly required them to live near their worksites" or for other employees "only when there is no viable alternative for securing housing outside the park." (GNP, p. 24, emphasis added.)11111

A housing study to spell out the specifics was promised, but the initial estimates indicated that "a maximum of 480 . . . employees will reside in the Valley. . . ." (GMP, p. 24)

Yosemite Lodge, to the south of Northside Drive, contained 90 employee tent cabins and dormitories for 200 other workers. The employee cabins would be removed and the dorms would be retained. Various visitor lodging facilities also existed to the south of Northside Drive. Some of the visitor lodging would be removed. Thirty-two cabins with bath units, 58 cabins without bath units, and 274 motel units would be retained.

2. The Yosemite Valley Housing Plan, Draft Supplement to the Final Environmental Impact Statement for the General Management Plan and the Concessions Services Plan, Environmental Impact Statement (July/August 1992)

Eleven and one-half years passed after publication of the General Management Plan, and nothing happened to implement it or even to start the decision-making process until the Concessions Services Plan (CSP) and the first Yosemite Valley Housing Plan (VHP or Housing Plan) were issued in July and August of 1992. The CSP didn't say much about employee housing. It did show a shift in lodging development activities to the Yosemite Lodge/Camp 4 area. The CSP projected a reduction in overnight lodging of 15.2 percent, but focusing on the reduction percentage would cause you to miss the impact on the Yosemite Lodge area. The proposed action had the Yosemite Lodge complex as the "primary year-round lodging facility in Yosemite Valley." It had 481 "rooms" in 1980. In the 1992 plan, it would end up with 440 units. There would be a lot of "replacement" cabins and economy cottages built, all with private baths. That meant the replacements would be larger than the structures that previously existed. Still, there was no suggestion that any lodging would be built north of Northside Drive in the Camp 4/Swan Slab area.

The Housing Plan, released at almost the same time as the CSP, gives the first look at NPS thinking on the number of employees that would be kept in the park, and where they might be housed.

There were 1,390 park employees housed in the park when the Housing Plan was released. The VHP devised three different criteria (p. 269) for determining the number of park employees to be housed in the Valley, and projected the need for either 221, 688 or 1,107. The criteria were always based on projections of "disruption of visitor services" rather than on the interference with the visitors' wilderness experience in a park with significant residential development. The 688 figure was based upon a "minimal disruption" of visitor services (i.e., no essential disruption of visitor services, even when there were road closures or commute problems), in contrast with the 1,107 figure that was based on absolutely no disruption of visitor services. The 688 figure therefore seemed quite reasonable, and the old figure of 480 employees housed inside the Valley proposed by the 1980 GMP was going by the wayside.

At the time, the 1,390 employees were housed in tents, houses, apartments and dorms located at either Yosemite Lodge, Yosemite Village (which includes the historic district, Camp 6, Tecoya, Lost Arrow, the Stables), the Ahwahnee area, and Curry Village. Yosemite Lodge had approximately 297 employees housed in its confines, but that included 90 in an area called the Ozone. Its dormitories housed 136 employees.

Four different employee housing "alternatives" were considered by the NPS in its 1992 Housing Plan. The one proposed for action left 664 beds in the Valley, with 952 beds being relocated outside the valley (Foresta, El Portal and other places). A chart (p. 22) shows where the changes would be made, but there isn't a real discussion of why the changes are being made in one site as opposed to another. The end result at Yosemite Lodge would be that the Annex cabins and the "Ozone area" would be eliminated, and the existing Lodge dormitory space would be increased by 81 rooms. (See p. 23 for Yosemite Valley overview of the "proposed action.") Why is the Yosemite Lodge a better place than Curry Village or the Yosemite Village area to concentrate employee dormitories? I don't see the analysis. Doesn't the flood plain make the Lodge area a poor location when compared with Yosemite Village or Curry Village (see flood zone map attached)?

Nor do I see an analysis of why entirely new areas in the Valley might not be considered for placing housing. There certainly are areas along Southside Drive that are less significant to visitors than the areas that have already been impacted by housing.

Whatever you might think of the analysis in the CSP and the 1992 Housing Plan, the following is clear: No one ever suggested putting any type of construction north of Northside Drive, either to lodge visitors or to house employees.

Key Documents and the Flood

The problem with the Camp/Swan Slab area arises out of the decisions related to the building of employee housing and the construction of visitor lodging. One would think that these decisions would have had to wait until the issuance of the VIP, which was released in the fall of 1997. This document would, after all, be the first peek at the comprehensive and integrated approach to be taken by the NPS toward implementing the 17-year-old General Master Plan. It wouldn't be until the VIP that one would actually know how many visitors were going to be in the park on an overnight basis and how the question of transportation was going to be faced. One wouldn't know which buildings were going to be taken out of the Valley. All of these decisions would affect the number of employees needed in the Valley on an overnight basis and affect the location of lodging for visitors.

In fact, the decisions relating to employee housing, and the location of that housing and lodging around Yosemite Lodge, were made before the VIP was even close to being released.

1. The 1996 Amendment to the Housing Plan (Proposal "E")

The first key document, the 1996 Amendment to the 1992 Housing Plan, added a new alternative "E" as the proposed housing action. Nothing in this new employee housing proposal suggested that employee housing be built up against Camp 4 or across Northside Drive. However, the assumptions of this proposal were carried over into the decision-making that did lead to the proposed construction to the north of Northside Drive.

Remember that the 1980 GMP dictated that housing for employees within the park would only be provided for those whose jobs regularly required them to live near their worksites or for those employees for whom there was no viable alternative for securing housing outside the park. The NPS thought that meant a maximum of 480 employees needed to be housed within the park. The 1992 Housing Plan, without explaining why the 480 figure was impractical, designed criteria that suggested either 200+, 600+ or 1,000+ employees housed in the park. It chose a plan based on the 600+ figure.

The new proposed action in the 1996 housing plan, proposal "E," blithely moves to the 1,000+ figure. Why? The analysis is insufficient. Has the NPS justified such a far departure from the dictates of the 1980 GMP regarding the criteria for placing employee housing in the park?

Much of the already developed area within the park was within a potential flood zone. There seems to be no analysis of how that flood possibility affected decisions about whether to house people either outside or inside the park. Some analysis went into choosing outside sites; Foresta and El Portal were the only ones chosen. The NPS now proposed to put 600 new employee beds in El Portal and none in Foresta. Foresta had been chosen as a site for 952 employee beds in the proposal of 1992. People obviously objected in 1992 and a decision was made in 1996 not to place any beds there.

Under the new 1996 housing plan, 1,114 employees would be spread over four concentrated areas (see attached map). The most important thing to note is that the Yosemite Lodge area ends up with removal of some "Ozone" beds and some Annex cabins, but it gets a total of 345 dorm beds to be placed where the old 136-bed dormitory used to be. These are the dorm beds that will be moved up against Camp 4 in a later decision. Where is the analysis as to why the areas chosen for concentrated employee housing were better than other alternatives? Was it merely because there had already been development in those areas at the time? How was the choice made between one developed area and another developed area? All of the concentrated areas designated were potentially flood-zone areas, even before the flood of January 1997. Shouldn't the NPS have considered the potential of a flood on the proposed sites? If it had, it would have made no sense whatsoever to concentrate a new dorm for 345 employees on the old Yosemite Lodge location because the site was obviously in a flood zone.

Since it was already making a choice to put 182 beds at the NPS maintenance area in Yosemite Village, why not make that the concentrated, out-of-the-flood-zone site for all of the employee dorms? (Note that a later decision, announced in the Fall 1997 VIP, leaves the maintenance area utterly free of any housing development!)

None of this analysis seems to have been made but, again, the decisions didn't seem to be of any threat to Camp 4 because absolutely no housing or lodging proposals had been suggested for building in the area adjacent to Camp 4 or in the Swan Slab area.

The Flood and the Draft Yosemite Lodge Area

Development Concept Plan (DCP)

2. The Draft Concept Development Plan (April 1997)

No sooner had the December 1996 Amendment to the Employee Housing Plan (Proposal "E") been published than it was rendered obsolete by the January 1997 flood. The flood was described as the largest in the 80-year period of stream gauge records along the Merced River. It did extensive damage to about 50 percent of the Yosemite Lodge lodging and 100 percent of the permanent concessionaire employee housing at the Lodge area.

In April of 1997, some three to four months after the release of the Housing Plan and three to four months after the flood, the NPS proposed in its Draft Concept Development Plan for the Yosemite Lodge Area that the visitor lodging and employee housing decisions in this portion of the park would be separated from the VIP and finalized immediately to "accelerate flood recovery." Why? Rushing to decide such questions as permanent employee housing based upon the flood emergency seems short-sighted. Temporary housing could easily be made available by way of trailers or by other arrangements.

For the first time, it was now proposed that five three-story dormitories, with enough beds for 336 people, be placed across Northside Drive and up against Camp 4. The only real development that had been in this area had been a gas station which was to be removed. This new footprint would obviously exceed the footprint of the gas station by a considerable margin. Doesn't this decision reflect the failure of the NPS to actually think through the effects of the flood on the previously chosen site locations? Didn't the flood, which showed the paucity of pre-flood planning, present the Park Service with a significant environmental event that would have forced a rethinking of the number of employees that would be housed in the park, the relative benefits of sites outside the park (including Wawona) versus sites inside the park, and the relative benefits of the sites previously chosen within the park?

Assume, for the moment, that the NPS didn't rethink the number of employees who were going to be housed in the park. Wouldn't it have made sense at least to rethink the decision to concentrate employee dormitories in the Yosemite Lodge area, since the lesson derived from the flood was that there was less space in this area than had previously been thought available?

The Ahwahnee Hotel area was not affected by the flood. The flood never reached to the south of Southside Drive along Curry Village. The flood never touched whole sections of Yosemite Village, including the Yosemite Village maintenance area. Aren't any of these sites preferable to the Yosemite Lodge area, if the NPS's criteria for selection included an estimate of available space for construction outside the flood zone that had already suffered from development? If this consideration wasn't part of the NPS's criteria, it should have been.

The same questions might be raised regarding the building of visitor lodging in the Yosemite Lodge area. The desire was to build in a non-flood-zone area. Why continue to concentrate the lodging around the Yosemite Lodge area where there was so little undeveloped space for it in the non-flood zone? Again, none of this was discussed.

The decision was made to build visitor lodging in the Swan Slab area and to build employee housing up against Camp 4, as if there were no room to build south of Northside Drive where development had already occurred. The assumption was that the NPS couldn't rebuild in the flood zone, but consider the construction that is being left in or near the flood zone. The vast majority of the Yosemite Lodge facilities abut the flood zone. Vast parking lots are being built in the flood zone. Couldn't employee housing be built above the parking lots, out of the reach of a flood? No consideration was given to the possibility of building flood- resistant or flood-proof employee housing. Perhaps the reason for this is that the congressional flood appropriation did not allow for rebuilding within the flood zone. But why should the flood appropriation dictate the future of the Yosemite Valley? The flood appropriation is an emergency measure. The money shouldn't be used if its use is going to have a long-term adverse effect on the environment of Yosemite Park.

The 1997 Draft Concept Development Plan for the Yosemite Lodge Area was the first document that ever showed that there was going to be an adverse environmental impact on an area sacred to climbers. Even then, climbers didn't know how threatened their area was because the actual drawings of the proposed lodging facilities were not available. There wasn't even an Environmental Impact Statement (EIS) prepared to accompany the document, despite the fact that the proposed construction was going to impair a previously undeveloped or underdeveloped area. (See U.S. Department of the Interior, National Park Service, Management Policies, Chs. 1:3, 2:7 and 2:8, for helpful definitions of "impairment" and "development zones.")

Assume, for the moment, that an Environmental Impact Statement (EIS) was not required (I have my doubts about that assumption). Under those circumstances, the National Environmental Policy Act (NEPA) requires the National Park Service to issue an Environmental Assessment (EA). 42 CFR §1508.9 has some specific requirements for an adequate Environmental Assessment. The regulations require, among other things, that the document shall include "brief discussions of the need for the proposal, of alternatives as required by section 102(2)(e), of the environmental impacts of the proposed action and alternatives, and a listing of agencies and persons consulted." [Section 102(e) of NEPA refers to the need of agencies to "study, develop and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources ..."]

It is our contention that the Environmental Assessment issued is clearly inadequate in its failure to consider alternatives before dumping housing and lodging in the Camp 4/Swan Slab area. Why should the employee housing be placed up against Camp 4, when other places are readily available in the Valley? Why, for example, couldn't the housing go in the Curry Village Area, the Yosemite Village Area, or the Ahwahnee area? I could go on. The environmental analysis (EA) simply ignores the need to weigh these and other alternatives.

The regulations also require that the National Park Service at least provide sufficient evidence and analysis for determining whether to prepare an Environmental Impact Statement or to make a "finding of no significant impact" (FONSI). It is our contention that the Environmental analysis provided is inadequate. More particularly, we feel that the report's contention that there will be "acreage recovery" in the overall development around Yosemite Lodge area is misleading. We base our thoughts in this matter on Greg Adair's analysis, which will be made available to you if you consider it important.

The objections to the 1997 Draft Concept Development Plan for the Yosemite Lodge Area were quick and unanimous. The Sierra Club pointed out the paucity of discussion of flood-proof architecture, the paucity of analysis regarding the number of employees to be housed within the park, and the complete lack of analysis on the possible alternative sites for concentrating employee housing. It suggested that temporary measures be taken to house the employees while these matters were thought through and analyzed, and suggested that the housing couldn't be separated from the yet-to- be-released VIP. It opposed development north of Northside Drive.

The Yosemite Restoration Trust made similar objections, including an objection to the number of employees to be housed within the park. It demanded that the buildings be kept "as far away as possible from Camp 4." It did not want development in the Swan Slab area.

The American Alpine Club, through Lou Reichardt, specifically objected to the introduction of buildings in the currently undeveloped area northeast of Swan Slab, and suggested that more information regarding architectural designs was absolutely needed.

Architect Brock Wagstaff wanted the site plans reviewed in light of the 1997 flood, and didn't understand the need to rush to judgment on such an important consideration as permanent employee housing merely because a flood had occurred. He suggested creative architectural possibilities that would allow the NPS to still build behind Northside Drive, and even volunteered to assist.

In short, no one was satisfied.

The Yosemite Lodge Comprehensive Design Report

(July 17, 1997)

This report was issued after the comment period on the Draft Concept Plan for the Yosemite Lodge. To meet the objections of the climbing community, the NPS proposed large "buffers" between Swan Slab and the development that was going to occur in the Swan Slab area. Buffers were also to be put up between the employee housing and the Sunnyside campground (Camp 4) and between the employee housing and the visitor lodging. The lodging for visitors was moved slightly. In short, the NPS refused to rethink its decision. "Buffers" are hardly the answer.

The Valley Implementation Plan

In the fall of 1997, the Valley Implementation Plan was released. A quick perusal would suggest that it is irrelevant to us because it treats the April 1997 Draft Concept Plan for the Yosemite Lodge Area as a given. There is, however, at least one gem of information in it. You will recall that the Yosemite Village maintenance area was, in the 1996 Amendment to the Housing Plan (Proposal E"), designated as a replacement housing site for employee dormitories. It would have been a good site, actually, because it was well out of the flood zone and the site had already been developed. Furthermore, the site was next to other developments and not anywhere close to an area that could truly be considered "wilderness."

The VIP announced that the Yosemite Village maintenance area was to undergo some development; however, it is unclear why additional lodging could not be built in Yosemite Village (or for that matter, in the Curry or Ahwahnee village areas). This meant that the previously underdeveloped or undeveloped area around Camp 4 and Swan Slab was going to be the site for five new dormitory buildings, and the previously developed area in Yosemite Village was going to be exempt from any development. That makes no sense. Where is the environmental analysis that weighs the pros and cons of developing the area around Camp 4 and Swan Slab but not developing the area in the Yosemite Village maintenance yard?

Whatever the merits of the analysis might have proven, it seems clear that the implied NPS argument in the April 1997 Draft Concept Plan for the Yosemite Lodge Area that it had no other choice than to build dormitories in the area abutting Camp 4 is simply false.

Conclusion

This letter contains my thoughts regarding the adequacy of the Park's decision-making process in the Camp 4 area. We will be attempting to meet with the Park Service shortly. We will be filing a lawsuit within two weeks. You may circulate this letter to any persons you think might be interested. I would be glad to answer any questions that any climbers may have regarding this matter.

Thank you in advance for assisting us.

All the best,

Richard P. Duane