Comment Needed On Yellowstone Draft Winter Use Plan / Deis

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May 8, 2008

Jack Welch, Volunteer Consultant, BlueRibbon Coalition
- Phone: (303) 279-8436 or Cell (303) 324-7185
- Fax: (303) 279-8214
- Email:
- Webpage:

Date: 06/06/2011



Dear Action Alert Subscribers,

The National Park Service (NPS) has prepared a Draft Winter Use Plan and Draft Environmental Impact Statement (Draft Plan/DEIS) for Yellowstone National Park. The purpose of the Winter Use Plan is to establish a management framework for Yellowstone's unique and valuable winter recreational resources.

This plan will determine whether motorized winter use of the park (including wheeled motor vehicles, snowmobiles, and snowcoaches) is appropriate, and if so, the types, extent, and location of this use. A Winter Use Plan is needed at this time because: the NPS is deciding whether snowmobile use should continue, and if so, under what limits and restrictions. The EIS will evaluate the environmental effects of winter use on air quality and visibility, wildlife, natural soundscapes, employee and visitor health and safety, visitor experience, and socioeconomics.

The public comment period for the Draft Plan/DEIS ends July 18, 2011, and it is extremely important that the National Park Service hear from you.


NOTE: Comments may be submitted through the NPS web site, by mail, hand delivered to park headquarters in Mammoth Hot Springs, WY, or at one of the public meetings or webinars. (See schedule below.) Comments will not be accepted by fax, email, or in any other way than those specified above. Bulk comments in any format (hard copy or electronic) submitted on behalf of others will not be accepted.


Tuesday, June 7, 2011 6:30 - 9:30 p.m. MDT
Holiday Inn, 315 Yellowstone Avenue, West Yellowstone, MT 59758

Wednesday, June 8, 2011 6:30 - 9:30 p.m. MDT
Holiday Inn, 5 Baxter Lane, Bozeman, MT 59715

Tuesday, June 21, 2011 6:30 - 9:30 p.m. MDT
Sheraton on Union, 360 Union Boulevard, Lakewood, CO 80228

Thursday June 23, 2011 6:30 - 9:30 p.m. EDT
DAR Presidents General's Assembly Room, 1776 D Street, N.W., Washington, D.C. 20006

The National Park Service intends to have a final EIS, a Record of Decision, and a final rule guiding winter use in place before the start of the 2011-2012 winter season.

For up-to-date information on the Yellowstone Winter Use Issue, go to our website

For questions and other information, contact Al Nash or Dan Hottle at (307) 344-2015. More info is also available on the web at:

BlueRibbon has formed the Yellowstone Task Force which is made up of state and national snowmobile leaders, the snowmobile industry, commercial tour operators, representatives from the affected gateway communities, and elected official at the county and state level. These groups have reviewed the plan and DEIS, and have suggested comments. Snowmobile enthusiast NEED to comment on the DEIS, and if you have ever been to Yellowstone, we need you to comment regarding your experience.


NOTE: Please be polite and, if possible, make your comment letter as personal as you can.

STEP 1: Click on the following link, which will take you to the NPS Comment webpage.
Read and follow the instructions for completing the Comment Form.

STEP 2: Use the comments suggestions below as a guideline for your comments. Cut and paste is okay, but try to make your comment letter as personal as possible.

STEP 3: Take just a minute to add a bit about where you live, any winter visits you have made to Yellowstone, how often you go, how long you have been riding in the area and/or how important the area is to you.

Once you have completed your comments, click the "Submit" button.

You may also comment by mail to: Yellowstone National Park, Winter Use DEIS, P.O. Box 168, Yellowstone NP, WY 82190.

NOTE: Comments will not be accepted by fax, email, or in any other way than those specified above. Bulk comments in any format (hard copy or electronic) submitted on behalf of others will not be accepted.


*Snowmobiles have been used to access Yellowstone National Park for over 45 years and should continue to provide a special form of Winter transportation.

I understand that when the National Park System was created by Congress there was a dual mandate that the Park Service: "promote" and "provide for the use and enjoyment" of park resources, and "leave [the park resources] unimpaired for the enjoyment of future generations." These are coequal, yet sometimes conflicting, mandates that require the NPS to balance both interests when making management decisions.

The Park Service needs to be more user friendly for both snowmobile and snowcoach operators and visitors. The proposed preferred Alternative 7 is too limiting and more restrictive than in the past. This seems to happen with each new EIS process. What is the true goal of the Park Service for Yellowstone National Park and it's Winter use?

*In the preferred Alternative 7, the number of daily entries into the Park ranges from 110 to 330; these numbers are too low. A range of 400 to 480 would be more reasonable.

The current recommendation of variable limits with a maximum of 330 daily entries is too low. If the Park Service wants to provide opportunity for both commercially guided and non-commercially guided snowmobile access to the Park the range of daily entries should to be increased to between 400 to 480 per day. Per the DEIS this daily entry range shows no adverse effects to the Park resources.

An entry cap creates actual lower daily entry numbers. How does the daily entry cap do this? It is nearly impossible to fill to the last snowmobile when there is a cap. If the cap were 20 per operator for West Yellowstone, as an example in 2010-11 season, and if the fill rate on average was only 77% of the 20 cap or 16 resulting in a loss of 4 entries into the Park, it would appear that the demand for entry into the park was down. However, the reason could be a group of five riders wanted to go together and you had only 4 machines left.

*Non-commercially guided access to the Park needs to be considered. The final alternative with increased daily limits needs a system to allow individuals to become certified non-commercial guides.

Not included in the preferred alternative is non-commercial guiding. Many potential visitors would like to guide their own family and not be forced to pay a commercial guide. The cost of renting snowmobiles, most likely rental of clothing and the cost of a commercial guide, limits the affordability for many families. If you remove the guide fees the family Yellowstone trip becomes more affordable, if the family has BAT machines and clothing it is very cost effective.

Looking back at an earlier final EIS decision for the 2004 season the Park Service had a system including reservations and on line training for non-commercial guided groups. That decision was never given a chance. The reason it never had a chance to work was a court action that enjoined the decision for the 2004 season and forced a special regulation to reopen the Park.

*Limiting daily entry into the Park to before 10:30 am will not work and could provide a negative experience for Park visitors.

I feel this will cause bunching, which could lead to a crowded condition. It causes concentration of snowmobile and snowcoach traffic. It seems that the resources would be protected better by dispersing traffic rather than consolidating it. I would like to be able to enter the Park with a group for a half day trip starting at noon.

If I have to enter the Park before 10:30 am this would limit my options to see the Park. I want to have the option of arriving later that 10:30am: so why inflict one more limitation and reason not to come and visit the Park in winter.

*The variety of use levels concept with a range from 110 to 330 daily entries a day is too difficult for winter visitor to plan their trips.

Snowmobile and snowcoach operators need to be able to select peak-use days and non-peak-use days according to supply and demand, not the National Park Service variety of use levels concept. In addition, the winter visitor would have great difficulty in planning their winter vacation trip to Yellowstone with the variety of use concept.

The variable use limit concept is too restrictive, and it will result in a loss of 5,728 visitor snowmobile machine days compared to last year. I figured last year's limit at 318 and variety of use levels concept of 110 to 330 as proposed in Alternative 7, both at full usage of the available entries; the difference was 5,728 less machines in the Park, therefore a major decrease.


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