Dear Superintendent Albright: 21 Feb. 1998
Thank you for this opportunity to comment on the Draft Valley Implementation Plan. The Friends of Yosemite Valley was formed in 1997 with the purpose of promoting respect for and appreciation of Yosemite's natural and wild values. We support continued public access to Yosemite for low income people, the disabled, and wilderness users. We believe that hotels, food service, and commercialism should be removed in favor of camping and a self-managed natural experience of the Park. Our goals are in keeping with the public goals of the G.M.P. We believe these values are at the heart of a democratic public ideal of access and enjoyment of nature found in the Park's enabling legislation.
While we support some individual elements of the Draft VIP we do not believe that it is legally adequate in scope and analysis as developed at this time. Only the Park's primary mission of resource preservation and the public goals of restoring Yosemite valley found in the G.M.P. can serve as the measure for a plan of this breadth and importance. We believe that the VIP, as a plan intended to integrate management decisions for the entire Valley, should coordinate impact analysis and planning across that range in a single E.I.S.; the result should accord with the goals of the G.M.P. as a whole. We believe that the Draft VIP wrongly excludes plans for the Yosemite Lodge Area, Employee Housing, and the El Portal Road, and by such omissions of analysis and planning unduly constrains its range of alternatives for public comment. It is difficult to discuss the VIP in its current form since a range of changes to the east valley are predicated on the presumed failure of a regional transit system, and the proposed creation of a parking/transit facility in an undisturbed area of the west valley, a proposal which we oppose. The Draft VIP is inadequate in its current form as a public proposal for implementing the Park's G.M.P.
The positions of the Friends of Yosemite Valley on the Draft VIP are as follows:
1. Yosemite Lodge:
We do not accept plans for the Yosemite Lodge Area as developed in the Lodge D.C.P.E.A.. The Plan moves the commercial hotel and employee housing complex north of Northside Drive. This would create incompatibility with the enjoyment of the Swan Slabs Area and the historic Camp 4 campground, and is in violation of the goals of the GMP. We believe that the decision to separate Yosemite Lodge lodging and employee housing from interrelated planning for the whole Valley has led to the approval of plans which through expansion to a currently undeveloped area will harm Yosemite's natural values, and significantly restrict access of low to moderate income individuals and families and interpretive programs. The N.P.S. should withdraw plans based on the Yosemite Lodge D.C.P.E.A. from the bidding process until the VIP is approved.
Planning for the Yosemite Lodge Area should be the subject of a full Environmental Impact Statement (EIS). Lodge planning cannot be completed in isolation from related Valley-wide parking proposals, Valley-wide changes in Employee Housing, and related and similar lodging proposals for Curry Village, Yosemite Lodge and plans for the Lower Yosemite Falls Area; these are structurally related proposals with interrelated impacts, analysis, and outcomes. Section 1502.4 (a) of the NEPA regulations (40 C.F.R. 1502.4) stress that the agency, "shall make sure the proposal which is the subject of an E.I.S. is properly defined," referring to the criteria in section 1508 25 and requires that proposals, "which are related to each other closely enough to be, in effect a single course of action shall be evaluated in a single impact statement." Section 1508.25, defining the "scope" of an EIS, advises that actions which are "connected," "cumulative" or "similar" because they, in short, are all related to an identified course of action affecting a particular environment, should be considered in a single EIS. Only the VIP, as the implementing plan and EIS for the Valley-wide portion of the GMP/EIS provides the scope and context for a Lodge EIS compliant with public law.
An EIS is further required for the Lodge area proposal due to significant new environmental conditions created by the 1997 flood. In 1980 the GMP called for the removal of 130 modest lodging units from the Lodge area located in the known flood plain. In 1992, the CSP increased lodging units at Yosemite Lodge over GMP numbers from 365 to 440, all of the replacement units full-service motel-style units; yet the CSP identified neither the size of the new units nor any actual sites to which they would relocate these units. Indeed the CSP is clear that there are no currently undeveloped sites upon which to build lodging in Yosemite Valley, consistent with the GMP/EIS. The CSP stated that, There are no practicable alternative sites in Yosemite Valley for Housekeeping Camp, Pine Cottage, or the Ahwahnee Cottages. Developable space in Yosemite Valley is limited by the extent of the 100-year flood plain, geologic hazards (rock fall zones), meadows and wetlands, sensitive species, and the extent of existing development. No new construction of lodging in undisturbed areas of the valley will be allowed. There are no previously disturbed areas in Yosemite Valley suitable for the construction of replacement lodging that are of adequate size and have sufficient infrastructure available. Because reducing congestion in existing valley developed areas is a goal of the GMP, relocating lodging to other developments is not acceptable." (CSP p 331).
The CSP pointed out that at the time it was proposed (preflood, 1992) there was no location at the Lodge area outside the known flood plain in which to relocate Pine Cottage (a mere 16 units) let alone the 130 additional units proposed in the CSP. Therefore the CSP was mistaken and unjustified in proposing this increase over GMP numbers; CSP maps confirm this. A supplemental EIS must be written whenever a federal agency makes substantial changes in a proposed action that are relevant to environmental concerns addressed in an EIS, or when there are significant new circumstances or information relevant to environmental concerns that have arisen since an EIS was prepared. (40 C.F.R. 1502.9 (c)) The NPS must prepare an EIS which re-evaluates lodging proposals for the Yosemite Lodge as to number, scale, and location in light of significant new environmental conditions created by the 1997 flood. This is also the case for employee housing, discussed separately.
Just as NEPA is clear that Lodge planning must be based on a current EIS, and be put forth in the context of interrelated proposals, the law also insures the public a meaningful role in the planning process. The NPS must provide reasonable alternatives to the proposed action (40 CFR 1502.14). The Lodge DCP EA, however, proposed no reasonable alternative to the proposed action. Since "No Action" does not describe viable and legally compliant mitigation, it is without content as an alternative. A real mitigation strategy for lodging and flood plains would require compliance with the Wild and Scenic Rivers Act, the National Flood Insurance Program (44 CFR 60), a revised and approved Statement for Management, and a revision of the Supplement to the EIS, Statement of Findings, Flood Plains. No Action is not a viable alternative lacking such compliance. At issue is the provision of documented alternative in compliance with NEPA. We strongly support that the Park, on the basis of a complete EIS for the Lodge Area, return to GMP lodging and employee housing numbers as the proper starting point for proposed alternatives for the Lodge area.
We believe that very small, rustic cabins without bath and tent-cabins provide a more resource-related experience of the Park where lodging is required. We oppose the change of lodging type to full-service motel style accommodations, as proposed in the Lodge DCPEA. Hospitality industry standards are an inappropriate basis for planning accommodations in a National Park. This is particular to Yosemite Valley due to spatial constraints. Family style cottages which can be turned into "conference centers" have no place in Yosemite.
Moreover, environmental impact analysis related to changes proposed in 1992 was inadequate. The increased labor demands of year-round motel use and the related labor and employee housing needs remain unknown. Increased maintenance needs for full-service units with bath must be analyzed in terms of the additional numbers of and support services for employees and related impacts. Increased water requirements of additional showers and bathrooms must be analyzed. Impacts on winter and off-season ecosystems, wet trails, wet meadows, and air quality must be analyzed.
Moreover, current drawings for the Yosemite Lodge Area demonstrate that while planning restores 6 acres of riparian adjacent area, new construction will impact 14 currently undisturbed acres. The net consumption of 8 areas of Yosemite Valley by development is a violation of the GMP. There is an evident 40% net increase in roads and parking at the proposed Lodge complex, also inconsistent with the GMP. Increased room sizes are evident from available drawings for the proposed Yosemite Lodge. Construction at the planned scale would cause a quantum price increase, as per the Park's pricing formula for lodging. If similar (CSP-derived) plans for Curry Village take the same course, the Valley would suffer a nearly complete elimination of low-to-moderate priced lodging. This is not acceptable. Yosemite is not a resort. As a public institution, Yosemite National Park must insure that moderate and low income individuals, families, and interpretive programs are not shut out of the Valley due to pricing.
The 1980 GMP is a social contract. It is the result of an unduplicated undertaking in participatory democracy: as such it is the sole legitimate basis for public consent in the Park's planning. The profit making needs of the concession are not an alternative to that contract, and are an improper basis for planning Yosemite's future. It would be wrong for the public gift of flood relief money to be used to hinder the public planning goals of the GMP. Yet the Concession Contract does provide the park with the means to reduce infrastructure in accordance with the GMP and the protection and enhancement of resources as new condition arise (Concession Contract/Hotel Services, Section 12 Terminations) We believe that pursuant to public law, and the broad public support for the democratically achieved General Management Plan of 1980, the Park should not lack guidance in its planning efforts.
We enjoin the National Park Service to fulfill its mission under the Organic Act, its public commitments under the GMP, and its legal requirements under NEPA. The F.O.Y.V. directs the NPS to complete a Valley-wide EIS which includes the Yosemite Lodge Area and which implements the 1980 GMP before any plan is initiated for the Yosemite Lodge Area.
2. Employee Housing:
Many of the members of the Friends of Yosemite Valley were the earliest opponents of the NPS decision to move employee housing next to Camp 4. The proximity of that housing is unacceptable. We are sensitive to the need for decent housing for the employees living in Yosemite Valley. We believe, however, that the attempt to rapidly resolve the temporary housing shortage created by the 1997 flood has, in part, resulted in the proposal of a permanent solution to the temporary problem of in-Valley housing which lacks environmental analysis and NEPA compliance, as discussed in comments on the "Yosemite Lodge Area". Additional impact analysis for the Yosemite Lodge Area planning must include noise and visual impacts of development to the campground, and consideration of Camp 4's important historic character.
The lack of compliance with NEPA at (40CFR 1502.2 (c)) in proposing the Yosemite Lodge site for an expanded employee complex is discussed in paragraph 2 of the section "Yosemite Lodge Area." All new employee housing proposed in the VIP would be located at Yosemite Lodge. Yet employee housing proposals for Yosemite Lodge are based on the assumption, in housing studies between 1992 - 1996, of available land now known to be in the floodplain. NEPA at 40 CFR 1502(c) requires plans to be based on accurate and up-to-date environmental analysis. For employee housing at Yosemite Lodge, as for other aspects of Lodge Area planning, the 1997 flood event created significant new environmental conditions requiring an EIS.
Plans for the Yosemite Lodge employee housing complex outlined in the Lodge DCP EA further lack compliance with NEPA in proposing NO ALTERNATIVE SITES TO THE PREFERRED ALTERNATIVE. Indeed, even sites considered in the 1996 Housing Plan are absent as alternatives in the Lodge DCP EA. The maintenance area site at Yosemite Village (which as recently as Spring 1996 proposed 182 units) is not mentioned in the Lodge DCP, and remains absent from the VIP. The 1996 plan proposes to eliminate 70 bedspaces from the Awahnee Hotel Complex, but without explanation. Housing is moved from Curry Village to the Lodge site. The very narrowing of in-Valley employee housing solutions in this way to a single site precludes compliance with NEPA in failing to provide reasonable alternatives to the proposed action (40 CFR 1502.14).
We oppose increases in food-service and year-round full-service hotel accommodations proposed in the 1992 CSP. Our position is that labor requirements would increase with these proposed changes, and housing and services for employees would necessarily increase based on these proposals. While the NPS has never analyzed such impacts related to CSP proposals, the Park Service did acknowledge that increasing day-use, and planned off-season visitation and lodging increases would require more concession employees to live permanently in the Valley (1992 Housing Plan pp 7-8.) GMP employee numbers were then taken to be obsolete without analysis: this change should be included for analysis in the Valley-wide VIP/EIS.
The Park must provide not only environmental analysis and compliance, and a range of alternatives in locating housing, but a justification and analysis of the need to house employees in excess of GMP numbers on a permanent basis in Yosemite Valley. In this context, we believe that concurrent proposals for a transit system serving Yosemite Valley could significantly affect the assumptions regarding how many employees can live beyond the Valley. These assumptions are found in existing housing plans. Specifically all prior housing studies have assumed a 40-minute commute envelope as the maximum acceptable commute distance for employees commuting in private cars. This assumption is integral to the derivation of all employee-housing numbers. The notion that a commute beyond 40 minutes is too long, taxing, costly and dangerous is based on the assumption of employees driving individual cars. The introduction of scheduled transit to Yosemite should be used by the park as the occasion to revisit the question of available out-of-Valley housing for employees arriving and departing by bus. Available housing at Midpines and Mariposa should be pursued.
The Park has many opportunities to realize the employee housing goals of the GMP through housing solutions beyond Yosemite Valley. We strongly favor the creation of good short-term measures to meet immediate needs until legally acceptable and GMP-compliant permanent solutions are found through public process.
3. Campgrounds:
The Friends of Yosemite Valley support the following related initiatives for camping: The preservation and enhancement of camping in Camp 4 on a space-available basis.
We believe that Camp 4 is eligible to become and should be designated a national historic landmark.
The eastward expansion of Camp 4.
Increased numbers of first-come-first-served campsites Valley-wide.
Retention of at least GMP numbers of campsites and propose an increase in keeping with resource preservation.
An increase in walk-in campsites and a decrease in vehicle campsites.
Consideration for handicapped access to camping.
Decreased access of large-scale RVs to vehicle campgrounds.
Phased elimination of individual campfires from campgrounds.
We believe that camping should be the primary form of overnight accommodation in Yosemite Valley. Appropriate access and visitation are best matched with resource protection through the progressive elimination of service and land intensive hotel development. We propose a reduction in hotel development (as noted in the section 'Yosemite Lodge', above), and in this context the eastward expansion of the Camp 4 campground. We agree with the VIP's concept of "tiered" camping, to better separate car and RV camping from simple walk-in tent camping. We believe that walk-in camping in the most resource-protective mode for overnight stays, and should be emphasized over car camping.
We believe that the proposal to place Camp 4 an the National Register of Historic Places ( Frost and Ament, 1997) corrects the record on Camp 4s eligibility, and is a much more fair measure of the question than the Parks own study (Unrau, 1997). Camp 4 is an historic treasure and deserves NRHP designation. As a matter of good faith, the Park should withdraw plans which harm the campgrounds historic ambiance. Subsequent plans for Camp 4 and the Yosemite Lodge area should finally recognize the historic character and importance of the campground and nearby natural surroundings and bouldering .
The Park should honor its commitment to achieve GMP-compliant numbers of campsites for Yosemite Valley; an increase over GMP numbers should be seriously considered and become a goal of Park planning. In seeking a plan which achieves GMP numbers, we value meadows and wetland areas as more valuable than mixed-conifer forest; we also value undeveloped land over developed land. We propose a more efficient use of existing campground spaces by the elimination of asphalt and a degree of increased density in existing car campgrounds. We propose the continued use of Rivers campgrounds.
We oppose the development of sensitive wetland areas for camping, such as Lamon Meadow, and believe further study is needed of proposals to move camping to undeveloped and possibly sensitive areas at Happy Isles and "Happy Pines" (an inappropriate name).
In order to decrease new impacts to Yosemite Valley while at the same time attaining the number of campsites that the GMP calls for, Upper and Lower River campgrounds should be retained. However, the few sites nearest to the river could be removed in order to protect riparian zones. We feel the Rivers site is far superior for a campground than Lamon Meadow, especially given that the Rivers site is already impacted and has been the site of a campground for decades. We propose a redesigned Rivers campground, which would contain at least 225 "walk-in" campsites. A footbridge could replace the Stoneman Bridge, and the road should be eliminated.
In order to attain full GMP numbers for campsites, a portion of the proposed "Happy Pines" campground could be developed. All Pines campgrounds would be accessible to cars, but only one campground, preferably North Pines, would accommodate RVs.
We propose that a portion of one of the Pines campgrounds include a group campground. A group campground in Yosemite Valley is an important asset for interpretive groups. In addition, we propose that the current Backpackers' campground continue to exist as is, and be expanded.
Walk-in campsites should be the preeminent form of campsite in Yosemite National Park for numerous reasons, including: 1) through walk-in camping, campers most closely experience the resource, the real purpose for visitation to Yosemite, 2) while experiencing Yosemite most intimately, walk-in campers create the least impact on Yosemite's resources due to their minimal use of vehicles and other high-impact incidentals, and 3) walk-in campgrounds accommodate more campers in a smaller area, thereby minimizing the size of campgrounds. Carts should be available to walk-in campers to make transportation of camping gear more convenient. The concessioner could rent other camping equipment, including tents, stoves, sleeping bags, etc. This would allow those campers using public transit to bring less luggage. Just as walk-in campsites should be emphasized, we believe the NPS should recognize the value of space-available camping in Yosemite's camping mix. The ability to visit the Valley spontaneously is important for young people, people who do not work desk jobs with telephones, and people traveling from other countries. Many of the arguments against first-come-first-served campsite availability has been based on inconvenience to Park staff, resulting from conflicts created by people driving to the Valley expecting to find campsites. This situation might be alleviated by having concurrent registration for a greatly enlarged space-available campsite number at transit and entrance stations. Moreover, some campsites could be specifically reserved on the space-available basis for those campers arriving in the Valley by transit.
It is important that the Park increase food storage lockers at parking lots and post information regarding methods of decreasing human conflicts with bears.
4. Parking, Transportation, and Access:
We oppose the potential construction of any new parking and transfer facilities at Taft Toe or the Pohono Quarry in the west end of Yosemite Valley. This is a proposal which would violate the Olmstead line and senselessly and needlessly destroy a wild area of the Valley. We believe that existing parking in the east end of the Valley should be preserved (as in Alternative Four) until such time as a phased introduction of a regional transit system removes the need for such parking.
We believe that the logical place for a transit transfer station is in the already developed Yosemite Village area. In the near term, Camp Six could be retained as a complement to this facility to accommodate peak season parking needs. We support the restoration of the (small) riparian portion of Camp Six, and favor the whole area's restoration when the success of regional transit eliminates the needs for such parking.
We do support the NPS as a participant in the YARTS process. We believe that a voluntary or free or very low-cost transit system instituted for the near term, on a peak season basis, would have a measurable benefit in reducing traffic congestion in the Park. It is important, however, that the Park understands that the success of such a system will hinge on the costs to the user. If it is to be successful, it must be virtually free. This is a reason not to immediately attempt its creation on a year-round basis; funding for a full-time year-round system would soon identify users as a primary source of revenue, something it must by all means avoid doing for its very success. No transit system anywhere in the world runs on fare-box funding. We believe that existing auto entrance fees should be used to partially offset the costs of the YARTS system, or in- park transit, though we disagree with the current costly entrance fee.
We further believe that the Park should work to create a secondary in-park transit system connecting Yosemite Valley to Tuolumne Meadows and Glacier Point on a frequent schedule. Outbound shuttles along these lines should also connect to a Yosemite Village transfer station, and would greatly increase the option of carless travel for: 1) overnight visitors initiating travel within the Park from either end of these travel lines, 2) day-use access to the Valley for through-Park travelers on Highways 120 and 140, who could leave their cars at points along these lines for carless travel to the Valley and later continued through-travel by car. The Badger Pass Shuttle serves as a successful model of how such a system could work. Moreover, it is important that the NPS come to fully understand non-east-Valley recreational use (i.e. west-Valley climbing) in designing a transit alternative for arrival at these locations. We recommend both the retention of roadside and turnout parking for climbers taking cars to these destination, and a "stop request" option on transit and shuttles at areas including, but not limited to: El Capitan, Reed's Pinnacle, the Cookie Cliff, Arch Rock, The Rostrum, etc. Climbers should be able to simply hail a bus for pick-up in either direction at these spots, as well.
Any transit system serving Yosemite Valley must creatively engage solutions to baggage and gear transport and transfer, and become an option for Valley campers. And such a system should be the required means of travel for hotel users in the Valley (with the exception of handicapped visitors) who need little luggage for their stay. Requiring hotel users to take transit to their destination is a reasonable goal in keeping with the Park's mission, given that approximately 1000 parking spaces could be removed from the Valley adjacent to hotels, and given the disproportionate burden on resources which hotel visitation creates in other ways (i.e., employee housing, cars, services, and other hotel service requirements).
We believe that the VIP should identify off-season, and off-hours travel in its discussion of travel patterns. The Park must allow for continued freedom of movement during these times (by car) until a successful transit system becomes a better option for users. The probability that no foreseeable transit system will operate around the clock for twelve months of the year further underscores the need to manage the retention/reduction of east-Valley parking in conjunction with the phased growth of a successful transit system.
The Friends of Yosemite Valley favors a carless society. We look forward to the achievement of a Yosemite which is truly public, truly accessible, and with far fewer cars. At present, the challenge to the Park and the public is to achieve these goals simultaneously. We strongly urge the Park, and the partners in YARTS to do a feasibility study for a light rail system as a solution to transit.
5. Other Valley Issues:
We believe that the Park should further develop plans for the Curry Village area in cooperation with the public prior to seeking approval of the schematic site plan included under the various alternatives of the VIP. The public should be given a clear idea of the actual form development will take before it approves the plans. At issue again is the question of pricing, and the actual extent of proposed development. As a good faith gesture, the park should go on record as intending to replace Curry Village lodging with units of the same (or smaller) size, which will cost the users the same amount of money or less. A commitment of this kind should combine with comparability studies for lodging as a measuring stick for the development of subsequent draft concept plans for the Curry Village area.
We enthusiastically support the creation of the Indian Cultural Center to the west of Camp 4. We recognize the right to ceremonial and traditional use of the park, and the moral and historic right to self-determination for Yosemites native people.
The Friends of Yosemite Valley thank the Park Service for this opportunity to comment on the Draft VIP, and would like to add to this text further comments during the forthcoming supplemental comment period in the Spring of 1998.
Sincerely,
Friends of Yosemite Valley