For
More Information Contact:
Brandt Mannchen,
Wild Lands Co-Chair
Lone Star Chapter of the Sierra Club
5431 Carew
Houston, Texas 77096
713-664-5962 brandtshnfbt@juno.com
Sierra Club, Lone Star Chapter Comments on Proposed Draft General Management Plan/Environmental Impact Statement for Guadalupe Mountains National Park
June 13, 2008
Mr. John Lujan
Superintendent
Guadalupe Mountains National Park
Draft General Management Plan
400 Pine Springs Canyon Road
Salt Flat, Texas 79847-9400
Dear Superintendent Lujan,
On behalf of the Lone Star Chapter of the Sierra Club (Sierra Club) I am submitting these comments regarding the proposed Draft General Management Plan/Environmental Impact Statement (DGMP/EIS) for Guadalupe Mountains National Park (GMNP or the Guads). The Sierra Club requests a hard copy and CD of the final EIS and Record of Decision when it is complete and has been signed.
The Sierra Club has a long relationship with GMNP. It was the effort to create GMNP that resulted in the creation of the Lone Star Chapter of the Sierra Club. Since that time, over 40 years ago, the Sierra Club and its members have visited GMNP many times and enjoyed its beauty and incomparable radiance while speaking in favor of and acting on behalf of its protection. It is with this history in mind, the love and awe we have for GMNP, and the desire we have to ensure its protection that we provide these comments.
Before we begin our specific comments about the draft GMP/EIS we want to lay out some of our most important concerns.
1) Scenic Vistas – Scenic vistas of the Guads, both from the high and low country, looking outside its boundaries and from outside its boundaries looking in, provide the majestic backdrop to enjoy and visit in a state of humility. It is this magnificent Wilderness quality of GMNP that captures our imagination and must be protected. The focus of GMNP must be as a Wilderness park.
2) Trails – In most of GMNP trails are the way we access this mountain and desert jewel. Trails must remain as primitive and as protected as possible. Unfortunately some trails, like the Guadalupe Peak Trail, need better maintenance. The Kincaid Trail is one that could be kept for hearty hikers who want to go that way. The Old Stage Route and Old Indian Trail could be rock cairned for primitive cross country, low country, use. In the future a trail connecting Carlsbad Caverns National Park, GMNP, Lincoln National Forest, New Mexico state lands, and Bureau of Land Management (BLM) lands should be carefully considered.
3) Horses – Horses should be limited to fewer trails to reduce geological, biological, and ecological degradation and protect the vegetation, soil, and other natural resources while providing a better experience for other uses. The Tejas Trail proper, PX Trail, Cox Tank Trail, and old jeep road on the west side are possible trails that make sense for horseback riding. Currently, 60% of the Guads trails are used by horses. We have been told that horse use is very small in GMNP but there are no figures in the draft GMP/EIS to verify this. A reduction in percentage of trails used by horses (perhaps by 20-50%) would ensure that environmental damage is reduced. Horse concessions should not be allowed as they result in pressure on NPS to allow more damaging horse use. Keep the existing public corrals but do not expand their size.
Something should also be done about the other impacts of horses. For instance, in our recent visit to GMNP, on at least three occasions, when we visited Frijole Ranch and sat under the tree canopy at the picnic tables next to the ranch house, the unmistakable odor of horse manure could be smelled. For a historic location that is heavily visited this is not a good way to introduce visitors to GMNP. In addition, the horse corrals are very close to spring flow and a natural gully. If not carefully managed nutrients from horse manure and urine could be washed by rain into the spring flow and natural gully thus causing non-point source water pollution. These problems should be discussed regarding the impacts of horses on GMNP.
4) Concessions – Any desire for stores and showers should not be the NPS’s business. These are businesses better suited to locate outside the GMNP.
5) Salt Flats and Dunes – Limit the use via group size and numbers of vehicles to protect this unusual and fragile habitat. No through roads and only small primitive parking areas should be allowed. No campsites in or near the dunes. Let private enterprise occur outside GMNP. Limit use to day use, have ranger guided tours, and ensure people stay on whatever trails are used to reduce environmental degradation and damage.
6) McKittrick Canyon and Watershed – The NPS must work with the U.S. Forest Service (FS) to protect the complete watershed of McKittrick Canyon if it is to remain protected and nearly pristine. In reality the essence of GMNP should flow by management into Lincoln National Forest and the rest of the Guadalupe Mountains that exist on FS or BLM lands. Doing this provides for more resilient habitats for plants and animals and helps them adapt as the full effects of climate change are expressed. Keep all development off the entire north rim of North McKittrick Canyon.
7) Wildlife – Allow elk and turkey to remain in GMNP. Remove all aoudad sheep. Develop a carefully crafted non-native invasive plant species plan to reduce exotic plants. This plan must recognize that Wilderness requires that the minimum tool be used with a non-motorized and mechanized hand on the land for non-native invasive plant species control.
8) Wilderness – Much of GMNP is designated Wilderness or qualifies for designation as Wilderness. The maximum landscape that qualifies for Wilderness must be proposed by NPS to the U.S. Congress for designation as Wilderness. Ensure that human effects (no installations and structures) are kept to a minimum. Wilderness management must keep in mind the minimum tool requirement. The key for GMNP is Wilderness appreciation for the fragile ecosystems of this small, beautiful, and unique Wilderness national park. Maintain the park experiences that are already available in the Wilderness park and do not try to make GMNP all things for all visitors. Do not change the Wilderness focus simply due to evolving patterns of public use. Change for the sake of change does not make sense. GMNP is not Yosemite or Grand Canyon National Parks. The management of the Guads as a Wilderness park is right and should be kept that way.
Why the National Park Service Plans and Summary
1) Page v, Why the National Park Service Plans, NPS states “The planning process ensures that decision-makers have adequate information about benefits, costs, and impacts on natural and cultural resources, visitor use and experience, and socioeconomic conditions.” The NPS should remember that the “public” also must have this information. That is what the National Environmental Policy Act (NEPA) and Council on Environmental Quality (CEQ) NEPA implementing regulations requires and why NPS must follow NEPA meticulously. NEPA is the only opportunity for the public to find out about, review, comment on, and understand what is proposed for GMNP, which it owns.
2) Page vii, Summary, Park History and Planning, NPS uses the phrase “interested stakeholders”. NPS must remember that the public is the “owner” of NPS and GMNP and therefore it is the public, not only so-called stakeholders, that must be looked to for review, comment, and understanding of this proposal.
The NPS has expressed a concern about becoming irrelevant to the public. NPS should explain what it means by this and state how this concern has shaped this draft GMP/EIS.
3) Page x, Preferred Alternative and page xii Alternative C, the NPS states “The preferred alternative would have mostly minor, long-term, adverse impacts on most natural resource impact topics, primarily because about 200 acres of currently undeveloped land would be permanently converted to developed park facilities” and “Alternative C would have mostly minor, long-term adverse impacts on most natural resource impact topics, primarily because about 500 acres of currently undeveloped land would be permanently converted to developed park facilities.” The Sierra Club does not consider the loss of 200 or 500 acres of natural habitat with functioning natural ecological processes a “minor” environmental impact especially since much of this area may be appropriate for Wilderness designation.
3) Page x, Preferred Alternative, NPS states “Increased visitation that would result from park improvements would have beneficial impacts on regional economies and community infrastructure.” NPS does not mention at any point about the problem of falling attendance in national parks, the increase in gas prices, and the problem of climate change and its interaction with how people get to and get around GMNP. NPS should thoroughly explore in this draft GMP/EIS these issues including coordinating with private and public entities to bring people via bus and van to GMNP to reduce greenhouse gas emissions, reduce space for vehicles in GMNP and land developed, and reduce energy impacts.
4) Page xi, Alternative B, if Alternative B really has a major adverse impact on visitor use and experience from eliminating camping except in the backcountry and a moderate to major adverse impact on management and administration due to insufficient space then why does this not constitute an impairment? In the past, for other NPS decisions (for example oil/gas activities in Big Thicket National Preserve), it was suggested that up to moderate impacts were not impairment. So if you have a major impact would this not constitute impairment or an unacceptable impact? If it does not then there is no impact that is greater than major and you can never, according to NPS methodology spelled out on pages 218-244, ever reach impairment or unacceptable impacts. This makes no sense.
Chapter1: Introduction
5) Page 9, Plan Review and Public Comment, the NPS states “the NPS planning team will evaluate substantive comments”. The Sierra Club requests that NPS review all comments. How does NPS define a substantive comment? The public and decision-makers should be able to review, comment on, and understand this definition. After all the public is the owner of NPS and without the public’s support NPS would not exist.
6) Page 10, Table 1, Conditions to Be Achieved at Guadalupe Mountains National Park Based on Service-wide Mandates and Policies, Natural Resources: Air Quality, NPS states “Air quality in the park meets national ambient air quality standards for criteria pollutants. Park air quality is maintained or enhanced with no significant deterioration. Nearly unimpaired views of the landscape both within and outside the park are present. Scenic views are substantially unimpaired.” NPS says not one word about the State of Texas (Texas Commission on Environmental Quality – TCEQ) proposing in its regional haze state implementation plan (SIP) that it cannot meet the EPA mandated deadline of 2064 for GMNP.
The TCEQ states that it may meet the regional haze standard by 2081 but that for the next 5 years has proposed that it will do nothing to reduce regional haze. The Sierra Club vigorously disagrees with NPS that it should eliminate air quality from this draft GMP/EIS as an issue topic. The NPS should commit to the public that it will push TCEQ, at the very least, to meet the 2064 mandated deadline for reductions in regional haze and that regional haze emissions will be reduced over the next 5 years.
NPS is required to protect all resources of our National Park System, including air quality. NPS must do a better job and must include air quality as an issue topic in this draft GMP/EIS. Otherwise NPS abdicates its authority and responsibility to ensure the public breathes clean air and can see beautiful natural scenic vistas in GMNP unimpaired. Particulates, which make up the bulk of the air pollutants that obscure the scenic vistas of GMNP, also harm human health. Right now the scenic vistas are indeed impaired and this should be noted and the public and decision-makers given the opportunity to review, comment on, and understand the air quality issue topic in this draft GMP/EIS.
In addition, NPS totally ignores climate change, which is due mostly to the release of carbon dioxide (CO2) air pollution. Climate change is an air pollution problem on an even larger scale than regional haze. Climate change will alter existing ecosystems and make it more difficult for plants and animals to adapt successfully to these changed ecosystems. NPS must address questions like:
1. How will GMNP be affected by climate change?
2. What can be done to create more resilient and resistant habitats and ecosystems?
3. What can GMNP do to reduce CO2 or other greenhouse gas emissions within the park?
4. What can be done to assist plants and animals so they can adapt to climate change?
Climate change is an air pollution issue which threatens the fate of all existing ecosystems in GMNP. Why does NPS remain silent about this issue? Why is this issue not addressed in the draft GMP/EIS?
NPS should prepare and include in this draft GMP/EIS, a climate change ecological resilience and resistance plan. This plan would assess the biological and ecological elements in GMNP and the effects that climate change has had and will have on them. The plan would also assist plants, animals, and ecosystems in adapting to climate change and would require monitoring of changes and mitigation measure effectiveness. The plan would be based on:
1. Protecting existing functioning ecosystems in GMNP.
2. Reducing stressors on the ecosystems in GMNP.
3. Restoring natural functioning ecological processes in GMNP.
4. Using natural recovery in GMNP, in most instances.
5. Acquiring buffers and corridors to expand and ensure connectivity of ecosystems in GMNP.
6. Intervening to manipulate (manage) ecosystems in GMNP only as a last resort.
7) Page 15, Implementation of the Plan, NPS states, “These steps often involve stakeholder consultation”. What about public consultation? It is the public that owns GMNP and it should be consulted.
8) Page 19, Preserve Park Resources, NPS states “Scenic vistas from within and outside the park boundaries are protected from significant intrusions.” What is a significant intrusion? Where are they located outside or inside GMNP? What does NPS propose to do about them? How does NPS propose to alleviate them? How will NPS protect GMNP from “significant intrusions”? What are the solutions? These questions should be answered and this topic discussed in the draft GMP/EIS.
9) Page 19, Ensure Organizational Effectiveness, NPS states “Adequate resources, including infrastructure, staffing, and budget are available to adequately operate, maintain, and protect the park” and then says on Page 15, “It should be understood that the approval of the plan does not guarantee that the funding and staff needed for plan implementation will be available”. What if NPS does not have the money or staff to implement the draft GMP? What has the highest priority for implementation? The Sierra Club supports implementing full natural resource protection elements first before any elements are implemented that deal with development, recreation, or that degrade GMNP’s natural environment.
It is obvious that budgeting for complete implementation of the draft GMP/EIS is necessary for GMNP to be protected. We are aware, for instance, that the fire budget is not large enough to allow for appropriate actions to allow the complete implementation of prescribed fire management plans in GMNP. The fact that there are discussions about conducting more fire activities, including the use of hand held saws in areas with high fuel loadings in Wilderness, but that money is lacking to do this and that personnel are pulled to fight other fires on federal public lands, should be thoroughly discussed in the draft GMP/EIS.
In addition, the NPS must fully explain how such manipulations in Wilderness will protect Wilderness character. Is the preventive control of high fuel loadings in Wilderness allowed under the Wilderness Act? Is the loss or partial loss of a major forest ecosystem in GMNP due to fire considered negative to Wilderness character of GMNP? Since there is no discussion about any proposals (which are shunted to fire management plans) this key, significant, issue (fire in Wilderness) is not discussed in the draft GMP/EIS. The public and decision-makers need this information so they can review, comment on, and understand what NPS proposes to do.
10) Page 19, Ensure Organizational Effectiveness, NPS states “Park stakeholders, partners … contribute to the decision-making process”. It is the public that should be invited to contribute to the decision-making process that guides effective management of GMNP’s resources.
11) Pages 25-26, Private Entities, NPS should clearly state what it intends to do to reduce any potential impacts that Blue Origin, Wallacetown, and two subdivisions on the boundary of GMNP will have on the park. How does NPS plan to address these and similar incompatible development issues in the future in the draft GMP/EIS? What is it specifically in the draft GMP/EIS that will allow NPS to take care of these incompatible uses so that GMNP is protected?
12) Page 32, Facilities and Operations, NPS states “What level of minimum improvement is necessary in wilderness to protect character and provide for resource protection and visitor satisfaction?” Visitor satisfaction should not result in installations or structures being placed in Wilderness which would damage Wilderness character. The Wilderness Act does not allow this. Human improvements are antithetical to Wilderness which is supposed to result in human traces not being noticeable. The Sierra Club is very concerned about this statement and requests that NPS change it to reflect and be in compliance with what the Wilderness Act mandates.
13) Page 32, Pine Spring Canyon, NPS states “There is no sanitary dump station for recreational vehicles and potable water facilities are inadequate for filling the water tanks of recreational vehicles.” Should NPS cater to a type of use in GMNP that generates such a large amount of waste; uses such a large amount of water; and causes such a large amount of climate change emissions? This makes no sense if this draft GMP/EIS is to be called sustainable.
14) Page 35, Eastern Escarpment, the Sierra Club is in favor of either removing unharmed or killing all exotic aoudad sheep from GMNP. These non-native species eat native plants that wildlife need; displace native wildlife; or pass diseases to native wildlife.
15) Pages 37-38, Basin and Range and Western Escarpment/Guadalupe Peak, NPS states Basin and Range resources “are isolated and accessible only with substantial effort” and “Western escarpment geological resources are not accessible for many visitors.” Why is this a problem? Perhaps with the description that NPS has given in other places in the draft GMP/EIS of the importance of these natural resources and the need for their protection that we should leave these geological resources so that few view them and therefore can harm them. After all, there are many other geological resources in the GMNP that are more easily available to visitors. All geological resources do not all have to become easily available to the public. Protection of geological resources must come first before any viewing by the public. These phrases need to be thoroughly discussed.
16) Page 38, Salt Basin Dunes, NPS states “Visitors … but are encouraged to avoid walking on the fragile black crust of the cryptobiotic evaporitic soils.” Encouragement is not enough! Very little is said in the draft GMP/EIS about how NPS will protect cryptogrammic soils of the Salt Basin Dunes within the alternatives proposed. The Sierra Club is very concerned about protecting the Salt Basin Dunes and all of its biological, ecological, and geological resources.
17) Page 43, Air Quality, Topics Dismissed From Further Consideration, as the Sierra Club stated in 6) above, we are against not including air quality as an impact topic in the draft GMP/EIS. Air quality should be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS.
18) Pages 43-44, Conflicts with Land Use Plans, Policies, and Controls, the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. This is particularly true since NPS has outlined on pages 25-26 some of the threats to GMNP that we currently know. This is a huge issue that must be addressed in the draft GMP/EIS. Air pollution is another “private entity” problem that should be included under this issue topic.
19) Pages 45-48, Floodplains and Wetlands, the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS.
On page 46, the Sierra Club recommends that the phrase “or acquiring” be added to the protective elements for wetlands.
20) Page 48, Lightscape Management and page 49, Soundscape Management, the Sierra Club disagrees that these impact topics should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. NPS has already pointed out that development pressures are increasing and therefore in the next 15-20 years there will be more lightscape and soundscape problems. This must be addressed in the draft GMP/EIS so that public and decision-makers can review, comment on, and understand what NPS proposes to do about these impact topics.
21) Pages 50-51, Special Status Species (Threatened and Endangered Species, Species of Concern, and Designated Critical Habitats) and Species Restoration, Exotic Species Control, and Extirpated Species Reintroduction, the Sierra Club disagrees that these impact topics should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. For instance, feral hogs have been found at the very boundary of GMNP, right next to MiKittrick Canyon. NPS needs to be specific on how it will prevent these destructive riparian species before they enter one of the most sensitive habitats in the entire GMNP.
It is NPS’s responsibility to protect special status species, reduce problems with exotics species, restore ecological functions, and reintroduce extirpated species. The way NPS wants to protect these issue topics should be integrated in all alternatives of the draft GMP/EIS so that public and decision-makers can review, comment on, and understand what NPS proposes to do about these impact topics.
22) Pages 51-52, Water Quality and Quantity (Surface and Groundwater), the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. Water is the lifeblood of the desert and high mountain areas. The way that NPS wants to protect water quality and quantity should be in all alternatives of the draft GMP/EIS. What does “would substantially change” mean? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
23) Page 52, Wilderness Resources and Values, the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. This is particularly true since GMNP is a Wilderness national park.
The Sierra Club does not support additional use of dynamite to make trails and does not believe that NPS should focus on “improve safe access to wilderness areas”. NPS should focus on protecting Wilderness character. Wilderness character should not be degraded to make Wilderness safe for visitors. This is what the Wilderness Act requires.
Wilderness is where people enter at their own risk and bow to the risks that Wilderness poses, on Wilderness’ terms. It is a place where humans leave their arrogance at the Wilderness boundary and enter with humility and not with the typical control and manipulation (trammeling) that we do in our human modified and built environment. NPS should not be in the business of de-wilding and de-fanging Wilderness.
More trails are not needed in designated Wilderness in GMNP. NPS calls building new trails in GMNP “long-term beneficial impacts” but the Wilderness Act says that installations and structures are not allowed. Building new trails would result in reduced Wilderness character which is a long-term negative impact and these actions are not beneficial to Wilderness protection and the protection of Wilderness character. The way that NPS will protect Wilderness character should be in all alternatives of the draft GMP/EIS so that public and decision-makers can review, comment on, and understand what NPS proposes to do about these impact topics.
Chapter 2: Alternatives, Including the Preferred Alternative
24) Page 56, Visitor Use Capacity, the NPS states “Rather, user capacity is measured by comparing desired resource and visitor experience conditions to actual conditions and, when an imbalance is noted, employing management practices to return to the desired conditions.” This may be true in instances but for some resources there is no returning to the “desired conditions”. For instance, soil erosion and cryptogrammic crust damage is in essence forever because the process of creating soil and cryptogrammic crusts, especially in desert and or mountain habitats, is extremely slow. The loss of 200 or 500 acres due to construction of built environments means these areas “would be permanently converted to developed park facilities” and would not longer qualify as Wilderness. These are irreversible and irretrievable commitments of resources.
25) Page 56, Visitor Use Capacity, the NPS states “Within GMNP: visitor use capacity planning currently is needed at McKittrick Canyon … The use of this technique may also be appropriate at the Salt Basin Dunes within the 15 to 20 year timeframe of this document.” The Sierra Club supports and urges NPS to be proactive and not wait until unacceptable visitor use occurs and damage is done before setting capacity limits. This is particularly important for the Salt Basin Dunes since easily damaged natural resources like cryptogrammic crusts can be permanently damaged or the damage can be such and the time taken for recovery is so long that there are irreversible and irretrievable degradation and destruction. NPS should be proactive for the protection of all GMNP resources.
26) Page 57, Management of Wilderness, the Sierra Club requests that we be placed on the list to be notified about any wilderness study for future designation of Wilderness and any proposal to change the Wilderness management plan.
The Sierra Club is very concerned about NPS’s treatment of Wilderness management and designation and the Wilderness Eligibility Assessment in Appendix D. There is no discussion or mention that previously the NPS conducted a Wilderness Suitability Assessment that was approved by the Director of the NPS and sent to the Department of the Interior (Assistant Secretary of the Interior for Fish Wildlife, and Parks) and was delayed and then rejected over a period of years, along with other similar studies for other units of the National Park System. Enclosed are materials detailing this illegal action and our letter of protest of February 7, 2004. The public does not know that a previous Wilderness Suitability Assessment was conducted by reading the draft GMP/EIS. Why?
The previous Wilderness Suitability Assessment found that there were 38,134 acres of land suitable for Wilderness designation. However, the NPS now states there are only 35,484 acres suitable for Wilderness designation. This is a difference of 2,650 acres. The draft GMP/EIS never discusses why there is a difference between the two analyses. What areas that were found to be suitable for Wilderness in the earlier study have been found not to be suitable by the study that is in Appendix D? Why have the 2,650 acres been disqualified for Wilderness? What criteria were used? The public and decision-makers must be able to review, comment on, and understand what NPS proposes to do about Wilderness. See Attachment 1.
NPS must also clearly show in all alternatives of the draft GMP/EIS why backcountry zone designation “would protect these lands (Wilderness eligibility lands) from incompatible development and inappropriate use”. There is no description of the uses allowed in backcountry zones and how these zones differ from designated Wilderness areas.
27) Page 57, Management Zones for the General Management Plan and page 62, Developing Management Concepts, “Alternative A, the no action/continue current management alternative, does not include the use of management zones, and also may not meet all park management goals … Alternative A does not necessarily meet all of the goals and objectives that are critical if the National Park Service is to consider the general management plan successful”.
How does not meeting “park management goals” equate with “impairment” in GMNP? It is not clear to the public when not meeting goals affects “impairment”. In addition, if not meeting all park management goals is not an impairment (notice it says goals and objectives that are “critical”) how important is meeting those goals? The NPS never says and never is as specific as it should be so the public and decision-makers can review, comment on, and understand the proposal.
28) Page 58, Designated Wilderness, NPS states “The park’s wilderness management plan would be updated to include specific indicators and standards to achieve wilderness management objectives”. What are the Wilderness management objectives? Why have these indicators and standards not been developed before now? When will the update process occur? The Sierra Club requests that its name be placed on the list to be notified about this process so we can participate.
29) Page 58, Designated Wilderness, the NPS states “the resource, such as removing invasive plants or rehabilitating damaged areas”. Throughout the draft GMP/EIS there is no thorough discussion about how invasive plants or animals will be removed or killed in Wilderness. In addition, NPS does not discuss how it will manage Wilderness so that its actions protect Wilderness character. Doing so is key if Wilderness is to be protected. Without such specific discussion and language in the draft GMP/EIS the public and decision-makers cannot review, comment on, and understand how Wilderness character will be protected via Wilderness management.
For instance, on page 59, Table 3: GMNP Management Zones for the Action Alternatives, NPS states “Significant cultural resources could be present and, as appropriate, are stabilized and preserved”. NPS uses words like stabilized, preserved, and rehabilitated in relation to cultural resources but does not define these terms for the public and decision-makers so they can be reviewed, commented on, and understood in relation to the protection of Wilderness character via Wilderness management.
The Sierra Club is concerned that NPS may attempt to justify actions in Wilderness for cultural resources that degrade Wilderness character. There is very clear and specific case law (copies included) which does not allow the requirements of the National Historic Preservation Act to trump the requirements of the Wilderness Act (protection of Wilderness character). The attached decisions include Wilderness Watch and PEER versus NPS, DOI, etc., June 28, 2005, dealing with Cumberland Island National Seashore Wilderness; Olympic Park Associates, Wilderness Watch, and PEER versus NPS and DOI, July 29, 2005, dealing with Olympic National Park Wilderness; and High Sierra Hikers Associations et al, versus United States Forest Service, June 8, 2006, dealing with the Emigrant Wilderness Area. See Attachment 2.
The Sierra Club requests that NPS discuss in detail its proposal to allow actions in Wilderness on behalf of cultural resource protection and how this affects Wilderness character and will adhere to the Wilderness Act and protection of Wilderness character.
30) Page 60, Frontcountry, NPS states “improving trail delineation or hardening trails”. The Sierra Club prefers that trails not be hardened. If hardening is needed perhaps that is a sign that the trail should not go through the area that needs to be hardened or that the carrying capacity of the trail has been exceeded and must be reduced to ensure that natural resources are protected.
31) Page 61, Motorized Scenic Corridor, NPS mentions “the development of social trails”. NPS does not state where social trails currently exist, what NPS has done about these “social trails”, what resource damage has occurred, whether the trails have been obliterated, what visitor use caused the “social trails”, etc.
In our recent visit to GMNP, the Sierra Club saw social trails at Manzanita Spring, on the Smith Spring Trail, and at the Butterfield Stage historic site. These social trails should either be restored to native ecosystem or incorporated as part of the official trail system and protected with appropriate mitigation measures. NPS needs to fully address this issue and its importance and how this draft GMP/EIS will deter the creation of “social trails” or mitigate their use and damage.
32) Page 62, Developing Management Concepts, NPS states “The NPS’s preferred alternative would incorporate “the best” elements of Alternative B and Alternative C … seeks a balance between providing enhanced visitor opportunities and increasing exposure to wilderness.” The Sierra Club suggests that NPS is biased on behalf of the Preferred Alternative.
NPS uses words that are meant to sway public opinion like “best” and “balance” as if the other alternatives also do not provide “best” and “balance”. For instance, since almost all of the United States is not Wilderness and many natural lands have been destroyed or heavily degraded does not Alternative B provide balance by protecting more Wilderness or Wilderness-like lands than any other alternative and help provide some additional balance to the loss of 90% or greater of most wild-land ecosystems? Is this not the “best” alternative for protecting Wilderness, natural resources, and human visitation to natural landscapes? It depends on how you look at the alternative and what words are used. The Sierra Club urges the NPS to be unbiased in its use of words when describing alternatives. NEPA and CEQ regulations require this.
33) Page 64, Annual Costs and Staffing, the Sierra Club is opposed to the reduction in personnel at GMNP. We believe additional resource protection, law enforcement, and interpretation employees are needed to ensure that the natural resources of GMNP are fully protected. The Sierra Club does not support a core employee population of 34 people since this is a loss and downgrading in needed personnel numbers from 40 in 2006.
The Sierra Club is aware that the Bush Administration has attempted to privatize and shrink the federal employee population which protects public resources (“The Commons”) and we have opposed these efforts. We do not support privatization of jobs in the NPS since a person who works for the public, a public servant, is more likely to value natural resources because they are not told to make money like someone who works for a concessionaire or private company whose purpose is to make money. The Sierra Club likes public servants in the NPS because we believe they can do the best job and have the interest of the “People” in their hearts.
34) Pages 67-78, Alternative A: No Action/Continue Current Management, the Sierra Club does not support Alternative A. This is because more protection of natural resources, including naturally functioning ecosystems, is provided in Alternative B.
On page 71, the Sierra Club notes a wording bias by NPS against Alternative A. NPS states “Currently, all cultural interpretive exhibits are housed at a location separate from the visitor center that is only open part of the time”. This is where this description should stop since it is only supposed to be a description of the alternative. However, NPS biases the description of Alternative A so that the public will favor the Preferred Alternative when it says “This limits the ability of visitors to see the cultural exhibits and learn about the history of the area. Building a new headquarters would provide additional space in the visitor center for the cultural exhibits”. This text should be found only in Chapter 4: Environmental Consequences since this is a perceived environmental problem; is considered to be analysis; and should be disclosed at the time the alternatives are compared not when they are simply described.
The Sierra Club makes the same criticism about biasing against and for alternatives with the language on page 71 which says “A new facility would allow for all museum items to be kept in the park and stored in one place with appropriate environmental controls.” This is analysis and rightfully belongs in Chapter 4 where alternatives are compared and not when they are simply described. The same can be said for several more statements on page 71. NPS must not bias this draft GMP/EIS because this violates NEPA and the NEPA implementing regulations of the CEQ.
On Page 72, McKittrick Canyon, the Sierra Club supports removal of the electric power line in McKittrick Canyon. The Sierra Club also recommends that the current McKittrick Canyon nature trail interpretive signs be reviewed. The lettering used is green and is hard to read in direct sunlight. Darker lettering may make reading of the interpretive signs easier.
On Page 74, Management of Exotic Species, NPS does not state how Wilderness character will be protected when exotic species are killed. The public and decision-makers need this information so they can review, comment on, and understand Alternative A.
On Page 75, Management of Research Natural Areas, the NPS should show where these areas are, tell how many acres they cover, and state what the purpose is of each one. The public and decision-makers need this information so they can review, comment on, and understand Alternative A.
On Pages 75-76, Historic Structures and Landscapes, NPS uses words like preserved and stabilized but does not provide a definition and explanation about what these words mean. This is particularly important in Wilderness (Hunter Line Cabin) where Wilderness character must be protected when conducting any historic work. The public and decision-makers need this information so they can review, comment on, and understand Alternative A.
On Page 77, Hiking Trails, Trailheads, and Horse Use, NPS states that “Horseback riding would continue to be allowed on some of the park’s interior trails”. The word “some” is misleading. According to the Sierra Club’s calculation, using the Trails Unlimited Map mileage of GMNP, about 47.7 miles of the 82 total miles of hiking trails allow horses on them, which is over 50% of the trails (58.2%). Page 191 of the draft GMP/EIS states “About 60 percent of the trails are open to horses”. This is more than “some” trails allowed for horse use.
On Page 77, Park Operations, the NPS states “There would not be any commercial services planning”. The Sierra Club supports no commercial services planning because GMNP can be both hiked and ridden by horses without commercial services. This is done currently and has been done very successfully for many years. There is no need for commercial services planning. The primitive, Wilderness, quality of GMNP, which is a small national park, should be kept, protected, husbanded because it is rare to find these days. People need to enter Wilderness or Wilderness-like areas (backcountry) with humility and on Wilderness’s terms and not ours, which often means reliance on mechanized means and modern gadgets instead of our primitive skills and instincts. Wilderness is for solitude, quiet, contemplation, enjoyment of natural sounds, and peace for the soul. There are so few places like this anymore. The Sierra Club does not want to see GMNP loved to death. As NPS states on page 90, “Visitors to Guadalupe Mountains would be given opportunities to have a true wilderness experience at a self-sufficiency level … Through direct experience, visitors would be able to gain a first-hand understanding of wilderness values”.
On Page 78, Boundary Adjustment, the Sierra Club supports including the two parcels of NPS owned land in the boundaries of GMNP. We also support acquiring more land to provide protection the view-shed, to protect geological, biological, and ecological resources, and to buffer GMNP from incompatible uses and provide migration corridors for plants and animals due to climate change. NPS should discuss opportunities for land acquisition including the 10,000 acres of land that is adjacent to McKittrick Canyon that has recently gone on the market for $1,000/acre.
42) Pages 79-93, Preferred Alternative, the Sierra Club does not support the Preferred Alternative because it is less protective of Wilderness; encourages more recreational activities than necessary; and causes more environmental damage.
On page 79, Concept, NPS states “Cultural resources, including historic structures, would be stabilized and or preserved or rehabilitated and protected from impacts”. NPS uses words like preserved, stabilized, protected, and rehabilitated but does not provide a definition and explanation about what these words mean. This is particularly important in Wilderness (Hunter Line Cabin for example) where Wilderness character must be protected when conducting any historic work. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 79, Concept, NPS states “surrounding the new Salt Basin Dunes staging area … an expanded staging area at Williams Ranch”. What is a staging area? Oftentimes in the draft GMP/EIS NPS mentions parking areas or similar areas but then does not state how many and what type of vehicles can use these areas and does not state how large these areas are. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 80, Visitor Center Area, the NPS states “For example, video technology could be used to present trips in park’s wilderness areas for those unable to access it directly.” The Sierra Club understands that NPS is not thinking of installing cameras in Wilderness for visitor enjoyment. This would be illegal because cameras and associated equipment are installations or structures and are not necessary for the management of Wilderness and will negatively affect Wilderness character. NPS should explain what “video technology” is and ensure it does not include putting installations and structures in Wilderness. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 83, New Campground, NPS talks about a new campground, but does not state how many acres it would be. The Sierra Club recommends that each picnic table in GMNP have a shade roof on it. Since GMNP has very high temperatures for many months a year; the sunlight is so intense; and since little shade is available for visitors the options at GMNP are limited to not staying at GMNP for long periods of time or of crowding areas where shade is available (Visitor Center, Frijole Ranch, McKittrick Canyon Visitor Center). A simple shade roof would make it easier for people to protect themselves from the sun and heat.
The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative. The Sierra Club favors campgrounds being run by NPS and not a “concessionaire”. Public servants make better protectors of the public “Commons”. The Sierra Club also does not support any proposal for a horseback riding concessionaire. People can bring their own horses and ride in GMNP. This is a small park that cannot withstand a lot of use. A concessionaire wants to make money and will push NPS for more use than should occur which will lead to more resource degradation.
On page 83, Administration Facilities, NPS talks about new administration facilities but does not state how many acres they would cover. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 84, Frijole Ranch, Facilities and Activities, the Sierra Club does not support continued dredging of Manzanita Spring so the pond would continue to exist. We prefer that the pond slowly silt in and become a natural wetland like it once was before it was altered by humans.
On page 85, McKittrick Canyon, Facilities and Activities, the Sierra Club supports removal of the electric power line. What does NPS mean when it says “This could include the use of information technology and audiovisual systems to maximize the visitor educational experience”. The Sierra Club understands that NPS is not thinking of installing cameras in Wilderness for visitor enjoyment. This would be illegal because cameras and associated equipment are installations or structures and are not necessary for the management of Wilderness and will negatively affect Wilderness character. NPS should explain what “video technology” is and ensure it does not include putting installations and structures in Wilderness. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 85, Dog Canyon, Facilities and Activities, NPS states it wants to put in another group campsite. How large will that campsite be and how many people will be allowed to camp in it? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 86, Salt Basin Dunes, Management Zoning, Facilities and Activities, NPS talks about zoning the area north of the existing road as frontcountry and states “Staging and access for the Salt Basin Dunes area would be improved over time to provide enhanced use as a visitor destination for day use”. How many acres would the frontcountry zone and the visitor day use area be? What is the nature of the improvements mentioned? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 86, Williams Ranch, Management Zoning, Facilities and Activities, How many acres would the frontcountry zone and the visitor day use area be? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 87, Ship-on-the-Desert, how many acres would the administrative campground be? How many acres would the frontcountry zone and the visitor day use area be? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 87, PX Well, how many acres would the new trailhead and small parking lot be? How long are the two trails? Does it make sense to allow horse use in a fragile area with cryptogrammic crusts and where exotic plants can be spread easily by horse manure? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 87, Guadalupe Pass Trailhead area, how many acres will the enlarged parking area be? How many and what type of vehicles could be parked here? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative. v
On page 88, Wilderness, are primitive sanitary facilities really needed in Wilderness? NPS needs to give more information about this issue. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 88, Management of Human Disturbed Ecosystems, what does “aggressive control of exotic plants” mean? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative. v
On page 88, Management of Exotic Species, the Sierra Club supports the total removal or killing of aoudad sheep because they compete with native species for food and shelter. What exotic plants specifically does NPS want to eradicate? What are “more strict control measures”? What is “aggressive management action” mean? What native plants will be planted and where will they be planted? How will Wilderness character be protected with regard to these proposed actions? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 89, Management of Research Natural Areas, what other areas may be designated as Research Natural Areas; where are they; and how many acres are they? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 89, Cultural Resources, NPS talks about preservation, stabilization, and rehabilitation of significant resources. Are any of these resources in Wilderness? Where and what are the other discovery sites? What restoration will be allowed in Wilderness? What is the NPS definition of restoration? How is it described? How will Wilderness character be protected? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 91, Interpretive and Educational Outreach Programs and Media, NPS states “New audiovisual technology would present park themes information, and values … and audiovisual systems to maximize the visitor educational experience … Computer-based audiovisual media would provide enhanced opportunities for those who do not actually explore the park … Video technology would simulate trips in park’s wilderness areas for those unable to access it directly … Interactive media … and other technology would be enhanced to more effectively interpret park resources and values”.
The Sierra Club understands that NPS is not thinking of installing cameras in Wilderness for visitor enjoyment. This would be illegal because cameras and associated equipment are installations or structures and are not necessary for the management of Wilderness and will negatively affect Wilderness character. NPS should explain what “video technology” is and ensure it does not include putting installations and structures in Wilderness. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 91, Interpretive and Educational Outreach Programs and Media, the Sierra Club supports expansion of outreach to local communities and educational groups, including El Paso and Juarez.
On page 92, Circulation and Parking, the Sierra Club does not believe that the ranch road trace from the Salt Basin Dunes parking area several miles north and east to PX Well needs to be improved. How large will the gravel surfaced parking lot be at the PX Well trailhead? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 92, Hiking Trails Trailheads, and Horse Use, NPS states “the NPS may add to the park’s trail inventory by mapping hiking trails along abandoned trails and road traces on the park’s west side”. How many trails is NPS referring to? How long are these trails? What would be their environmental impacts? Where are they located specifically? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On pages 92-93, Park Operations, are sanitation facilities really needed in Wilderness? If so where and why? The Sierra Club does not support a commercial service plan and does not support commercial horse operations at Frijole Ranch and Dog Canyon and commercial campground operation at Pine Springs or Frijole Ranch. The Sierra Club visited Dog Canyon and appreciated its remote and isolated location and the minimal facilities available. We also found the NPS ranger on duty very helpful and friendly.
Already horses are causing unacceptable damage to geological resources (fossils), user conflicts, eroded trails, and exotic plant species introductions. More horse use will only exacerbate these problems. The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
On page 93, Boundary Adjustment, the Sierra Club supports the boundary adjustment as well as additional acquisitions for GMNP.
On page 93, Costs, the Sierra Club does not support reducing the number of employees at GMNP from 40 in 2006 to 34. NPS has fallen in line with the Bush Administration’s siren call of a smaller federal work force when GMNP needs more people to protect the public’s natural resources. The Sierra Club does not believe that temporary and seasonal staff can pick up the slack in place of permanent full-time employees. We understand, for instance, that there are, many cultural and archeological resource sites throughout GMNP that have not be surveyed in many years. This and other needed natural resource protection and interpretation work must be funded and must have the personnel to carry out these actions. By not doing so NPS runs GMNP in a penny-wise and pound-foolish way.
What is the “landscape rehabilitation work” that is referred to here? The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative.
43) Pages 94-103, Alternative B, the Sierra Club supports Alternative B with the following changes:
1) Wilderness eligibility and designation for 38,134 acres instead of the proposed 35,487 acres.
2) Reduction in, but not elimination of, horse use (day use only) on trails in GMNP by some percentage (perhaps 20-50%) to reduce environmental impacts on geological, biological, and ecological resources and conflicts with hikers. If horseback riding is a relatively small amount of use certainly there is not the need for 60% of the trails to be designated for horse use. No removal of public corrals and no horse concession.
3) Proposed boundary adjustment and acquisition of additional lands (by fee title acquisition or conservation easement) in Patterson Hills, Salt Basin and Flats, Guadalupe Pass area, McKittrick Canyon area, Delaware Mountains, Guadalupe Escarpment, and other sensitive areas to protect the GMNP view-shed; acquire important geological and ecological areas; and to buffer GMNP from present and future development pressures and to allow plants and animals to adjust to changes caused by climate change.
4) Employment of at least 40 people and reject the downgrading of employee numbers to a core of 34.
5) Aggressive push by NPS to get state and federal officials to address the deterioration of scenic views due to regional haze air pollution sooner than the mandated 2064 deadline. Air Quality as an “impact topic” should not be dismissed from further consideration in all alternatives of the draft GMP/EIS and should be fully analyzed, assessed, and evaluated for all alternatives.
6) Retention and possible expansion of the Pine Springs tent camping area and the movement of the RV camping area so it is separated from the Pine Springs tent camping area.
7) Support the treatment of Conflicts with Land Use Plans, Policies, and Controls; Floodplains; Wetlands; Lightscape Management; Soundscape Management; Special Status Species (Threatened and Endangered Species, Species of Concern, and Designated Critical Habitats); Species Restoration, Exotic Species Control, and Extirpated Species Reintroduction; Water Quality and Quantity; and Wilderness Resources and Values as “impact topics” with full environmental analysis, evaluation, and assessment for all alternatives in all alternatives of the draft GMP/EIS.
8) New consolidated park headquarters and office complex and cultural museum and storage south of U.S. Highway 62/180 close to the maintenance area.
9) Full implementation of the Wilderness Act and protection of wilderness character versus protection of human installations and structures and other human actions in wilderness management.
10) Provision of a shuttle system for trails to reduce driving and parking impacts.
On page 94, Concept, NPS states “Visitor use levels would be actively managed”. NPS must explain what it means by “actively managed”. The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 94, Concept, NPS uses words like stabilized, preserved, or rehabilitated for cultural resources. NPS must explain what these words and this system of cultural resources protection means. NPS must discuss what cultural resources activities will be allowed in Wilderness and how Wilderness character will be protected. The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 94, Concept and page 102 Hiking Trails, Trailheads, and Horse Use, NPS states the park’s trail inventory could be expanded by mapping old ranch trails and road traces”. Where are these? What is their length? What would be the environmental impacts of doing this? The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 99, Management of Exotic Species, the Sierra Club supports removal or killing of all aoudad sheep due to their negative impacts on native wildlife and plants. NPS must explain what “eradicating all species of exotic plants throughout the park” and “more strict control measures” and “native plant re-vegetation” mean. How will Wilderness character be protected with regard to management of exotic species? The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On pages 99-100, Management of Research Natural Areas, where will these possible Research Natural Area’s be; how many acres will each one cover; and what is the purpose of setting aside each one? The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 100, Cultural Resources, NPS uses words like stabilized, preserved, or rehabilitated for cultural resources. NPS must explain what these words and this system of cultural resources protection means. NPS must discuss what cultural resources activities will be allowed in Wilderness and how Wilderness character will be protected. The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 101, Visitor Education, Interpretation, and Orientation, NPS uses the phrase “enhanced resource restoration”. What does this mean and how will it be implemented? The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 101, Interpretive and Educational Outreach Programs and Media, NPS uses the phrases “information technology and audiovisual systems”; “audiovisual media”; “video technology”; and Interactive media, the park’s Internet site, and other technology”. What do these phrases mean?
The Sierra Club understands that NPS is not thinking of installing cameras in Wilderness for visitor enjoyment. This would be illegal because cameras and associated equipment are installations or structures and are not necessary for the management of Wilderness and will negatively affect Wilderness character. NPS should explain what “video technology” is and ensure it does not include putting installations and structures in Wilderness. The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 102, Park Operations, are sanitation facilities needed in Wilderness? What criteria will be used to decide this? How will Wilderness character be protected? The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
On page 102, Boundary Adjustment, the Sierra Club supports the boundary adjustment and the acquisition of more lands to protect GMNP.
On page 103, Costs, the Sierra Club does not support the reduction of full-time employees from 40 to 34. The Sierra Club supports NPS hiring more full-time employees for law enforcement, resource protection, and interpretation.
44) Pages 104-117, Alternative C, the Sierra Club opposes Alternative C because it emphasizes too much development (at least the loss of 500 acres of potential Wilderness).
For instance, the Sierra Club does not support an expanded corral area south of Frijole Ranch; dredging of Manzanita Spring; extended hours in McKittrick Canyon after dark; improved access to a seep on the McKittrick Nature Trail; construction of bridges across McKittrick Canyon; overnight use of the Pratt Cabin; restrooms and potable water system at Pratt Cabin; concessionaire operations for camping and horse facilities; improving the Meadow Nature Trail; new picnic area at Dog Canyon; new trail between Manzanita Ridge between the Tejas and Bush Mountain Trails; upgrading of recreational vehicle camping facilities; expanded corral for commercial packers or a horse concession in Dog Canyon; the large development proposed for the Salt Basin Dunes; a road from Williams Ranch to the west boundary of the park; the commercialization via corporate partnerships of the expansion of the Ship-on-the-Desert facilities; additional trails in Wilderness; etc.
On page 104, Concept, where will the new trails that NPS mentions be? What is their length? What would be the environmental impacts of doing this? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
On page 111, Management of Human Disturbed Ecosystems and Exotic Species, the Sierra Club supports removing or killing all aoudad sheep. What does “aggressive exotic plan control”; “eradicating target species of exotic plants throughout the park (which species are targeted)”; and “aggressive monitoring and mitigation measures” mean? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
On page 111, Management of Wetland and Aquatic Environments, what does “The trail at Smith Spring would be improved” mean? The Sierra Club found the trail to Smith Spring in good condition and not in need of improvement. The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
On page 111, Management of Research Natural Areas, what are the RNA’s that are being referred to? How many are they? Where are they located? How many acres is each one? What are the environmental impacts of visitors using these areas? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
On page 112, Historic Structures and Landscapes, NPS talks about preservation, stabilization, and rehabilitation of significant resources. How will NPS ensure that historic structure activities adhere to the overarching Wilderness Act requirements and prohibitions? How will Wilderness character be protected? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
On page 113, Visitor Experience, NPS proposes degrading Wilderness so “More visitors would be able to develop an understanding and experience of solitude because of the improved ease of access to some currently more remote areas of the park”. Wilderness needs to be visited on its terms not ours. We are not supposed to provide “ease of access”. NPS in essence proposes the degrade Wilderness to educate people to respect Wilderness. NPS teaches the wrong lesson. How will Wilderness character and abiding by the Wilderness Act be accomplished in this way? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
On pages 113-114, Visitor Access, the Sierra Club does not support “increased horse use” and “Overnight horse use” because this will result in more user conflicts; more destruction of geological features; more biological and ecological damage (like introduction of exotic plants); and more soil erosion and sedimentation.
On pages 114-115, Hiking Trails, Trailheads, and Horse Use, the Sierra Club is concerned that NPS does not state what the environmental impacts will be of each of the proposed trails; what are the impacts on Wilderness character; and what are the impacts of implementation on the Wilderness Act. Some of the trails NPS talks about are not identified, their length not stated, and their location not provided. The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
The Sierra Club agrees that shuttle system makes sense in GMNP. The Sierra Club does not support a horse concession in GMNP including Frijole Ranch and Dog Canyon.
On pages 116-117, Costs, the Sierra Club supports the employment of additional full-time employees in GMNP for law enforcement, resource protection, and interpretation.
45) Page 118, Implementation, NPS states “The park would prioritize implementation to focus on visitor experience and safety, resource protection …”. Resource protection should be prioritized and implemented first over any other goal. What does this statement mean? The public and decision-makers need this information so they can review, comment on, and understand its proposal.
46) Page 118, Implementation, the Sierra Club is very concerned about NPS’s constant reference to concessions and other privatization type operations. For instance NPS states “To fully implement the general management plan, the National Park Service, would consider other mechanisms, including partnerships and providing some visitor serves through a concession operation … Concession operations would be considered for actions determined to be necessary and appropriate commercial visitor services and would be implemented in accordance with a commercial services plan”. It is obvious, from the efforts of the Bush Administration, that this means privatizing the public “Commons” via corporate control of public resources. The Sierra Club is very concerned about this and recommends no concession operations because they are not needed at GMNP.
47) Page 119, Mitigative Measures, NPS does not tell what the “compliance monitoring program” is for mitigation measures. The public and decision-makers need this information so they can review, comment on, and understand its proposal.
48) Page 120, Soils, NPS states “Monitor for visitor impacts”. What monitoring is this? What will be implemented? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
49) Page 120, Plant Communities and Vegetation, NPS states “Monitor areas used by visitors”. What monitoring is this? What will be implemented? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
50) Page 120, Water Resources, NPS states “Work to minimize erosion from trails”. How will this be done? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
51) Page 120, Wetlands, NPS states “Improve trails through wetland areas to minimize impacts on vegetation”. How will this be done? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
52) Page 123, Noise Abatement, NPS states “minimize objectionable noise, and exploring opportunity to reduce the sounds of human caused noise”. How will this be done? What is “objectionable noise”? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
53) Page 123, Sustainable Design and Aesthetics, why does NPS require sustainable projects “whenever practicable” when it requires protection of cultural resources “to the greatest extent possible”? Why should sustainability be less important than the protection of cultural resources? The public and decision-makers need this information so they can review, comment on, and understand Alternative C.
54) Page 124, Future Studies and Implementation Plans, the Sierra Club does not support preparation of a commercial services plan. It is not needed for a small, Wilderness oriented park like GMNP.
55) Page 124, Alternative B, NPS should define restoration and state what the restoration plan would be. The public and decision-makers need this information so they can review, comment on, and understand Alternative B.
56) Pages 126-127, Environmentally Preferred Alternative and Table 5, Alternative B has been low-balled by NPS since it met criteria 3 and 5 yet NPS says it does not. What does “the widest range of beneficial uses of the environment” mean? What does “achieving a balance between population and resource use” mean? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
57) Page 128, Alternatives or Actions Considered But Dismissed From Detailed Evaluation, NPS states “Protect air quality – Although the park is classified as a Class 1 air quality management area, the park staff has limited ability to address air pollution that drifts to the park from regional sources, particularly pollution sources in Mexico”. NPS does have a lot of authority to review permits, to urge EPA and TCEQ to do their jobs, to work with Mexico to reduce air pollution. NPS should not play helpless since it is the public’s park and air resources that suffer. The public deserves better. Air quality should be an issue topic in the draft GMP/EIS and not cast aside because NPS says it is helpless to do anything.
58) Page 129, Alternatives or Actions Considered But Dismissed From Detailed Evaluation, the Sierra Club agrees that motor vehicle access to the high country; mountain bike use on trails; selling or leasing portions of park lands; the tram to Guadalupe Mountain; and road from Williams Ranch to the west; are inappropriate in GMNP.
59) Pages 131-138, Table 6, Features of the Alternatives, NPS must define “aggressive management” for exotic species”; “Eradicate target invasive species” (what species); “more strict prevention measures”; “More aggressively protect water quality and quantity”; “Stabilize and preserve”; “site restoration”; and other similar phrases. The public and decision-makers need this information so they can review, comment on, and understand the proposal.
60) Pages 139-143, Table 7, Summary of Impacts, Alternative B, NPS states “The elimination of the hammering action of horseshoes on fossil deposits in trails would have a long-term, beneficial impact”. Why is NPS proposing in the Preferred Alternative to continue to allow this “hammering action of horseshoes” at the present levels? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
On page 144, Alternative B, removal of cultural structures so they can be protected is a positive and not adverse effect. On page 145, allowing Manzanita Spring to fill naturally is not an adverse impact on the cultural landscape because it is what the settlers found when they first arrived. On page 147, closing the road to the Salt Basin Dunes parking area has a positive impact environmentally and would require people to enter Wilderness on its own terms and not theirs. On page 148, Alternative B, NPS has shown no documentation that there would be “increased demand for commercial camping and other overnight lodging”. Park maintenance should be lower and beneficially affected by Alternative B because there will be fewer facilities and horse and frontcountry camping use would be eliminated. So how does NPS come up with a “Moderate, long-term, adverse impacts” on maintenance? This makes no sense. The public and decision-makers need this information so they can review, comment on, and understand the proposal.
Chapter 3: Affected Environment
61) Page 157, Soils, NPS states “Many human activities are incompatible with the presence and well being of cryptobiotic soils … Burial can mean death because crustal organisms need light to photosynthesis … Under ideal circumstances, a thin veneer of cryptobiotic soils may return in five to seven years, but in some disturbed areas … a recovery period of 50 years or more”. For this reason why has NPS not been specific about how it will protect these soils in the draft GMP/EIS? Why is horse use allowed where these soils exist? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
62) Page 163, Chihuahuan Semi-desert Grassland, NPS states “With the cessation of livestock grazing, these grasslands are recovering and expanding”. Where are these areas? How does NPS propose protecting them from the impacts of horses and other uses? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
63) Page 189, Visitor Understanding and Experience, NPS states “In descending order, the five most desired experiences in this park are seeing wilderness and scenery, hiking, viewing nature, seeing wildlife, and experiencing solitude or quiet.” For this reason NPS should focus its efforts on drafting an appropriate GMP/EIS that protects these desired experiences. It appears that Alternative B better protects these experiences than any other alternative and at the same time protects the natural environment the best.
64) Page 203, Park Operations, Facilities, and Equipment and page 206, Park Budget, NPS says that in 2006 there were 40 full-time staff positions. The Sierra Club does not support cutting this to 34 positions. This is pennywise and pound foolish action. We need more law enforcement, resource protection, and interpretation employees, not less.
65) Page 205, Park Budget, NPS states “Fees have averaged $88,300 over the past four years, and revenues beyond the cost of collection are used for special projects”. How much for each year since 2002 have revenues exceeded the cost of collection? What total amount of money each year are we talking about? What projects have been funded? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
Chapter 4: Environmental Consequences
66) Page 213, Introduction, NPS uses the word “feasible”. What does this word mean in the context it has been used? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
67) Page 213, Introduction, pages 216-217, Decision-Making to Avoid Impairment or Unacceptable Impacts on Resources of Guadalupe Mountains National Park; and pages 218-226, Methods for Analyzing Impacts, NPS states “Because of the general, conceptual nature of the actions described in the alternatives, their impacts can only be analyzed in general, qualitative terms. Thus, this environmental impact statement should be considered a programmatic analysis.”
The Sierra Club has seen other programmatic EISs that provide more quantitative detail than this one. For instance, the Minerals Management Service is able to quantify, at least partially, what the impacts will be for lease sales for oil/gas activities in the Western, Central, and Eastern Gulf of Mexico.
A dictionary usage of words or phrases will not suffice to provide the public with a clear picture of what the intensity, significance, and context of environmental impacts are. This draft GMP/EIS, by using qualitative and un- or ill-defined words and phrases (negligible, minor, moderate, and major and the undefined phrases in their definitions), ensures that the public and decision-makers cannot compare alternatives because they cannot see now NPS judged them. In other words, an all or mostly qualitative assessment, analysis, and evaluation of environmental impacts is not sufficient to deal with the clearly articulated CEQ NEPA implementing regulations, Section 1502.14, that the EIS “should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision-maker and the public”.
Quantitative assessment, analysis, and evaluation are necessary to ensure that alternatives and environmental impacts are clearly defined, compared, and shown in the EIS. As stated in the CEQ NEPA implementing regulations, Section 1500.1(b), Purpose, “NEPA procedures must insure that environmental information is available to public officials and citizens … The information must be of high quality. Accurate scientific analysis … are essential to implementing NEPA”.
As stated in Section 1501.2(b), “Identify environmental effects and values in adequate detail so they can be compared to economic and technical analyses.”
As stated in Section 1502.8, “which will be based upon the analysis and supporting data from the natural and social sciences and the environmental design arts.”
As stated in Section 1502.18(b), about the Appendix, “Normally consist of material which substantiates any analysis fundamental to the impact statement”.
As stated in Section 1502.24, “Agencies shall insure the professional integrity, of the discussions and analyses … They shall identify any methodologies used and shall make explicit reference by footnote to the scientific and other sources relied upon for conclusions in the statement.”
Most of the analysis that NPS has conducted for this EIS is “best professional judgment”. “Best professional judgment” is where a group of people, using their experience, decide what is important. This level of assessment, analyses, and evaluation for environmental impacts and alternatives is an insufficient foundation upon which to base the draft GMP/EIS and its conclusions.
The qualitative description of phrases used for environmental impacts or the protectiveness of an alternative does not provide the public with the degree of comparison required by the CEQ’s mandatory NEPA implementing regulations. These regulations state, in Section 1502.14, Alternatives including the proposed action, that, “This section is the heart of the EIS … it should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision-maker and the public … Devote substantial treatment to each alternative in detail … so that reviewers may evaluate their comparative merits.”
The CEQ also states, in Section 1502.16 and (d), Environmental Consequences, that, “This section forms the scientific and analytic basis for the comparisons … The environmental effects of alternatives including the proposed action the comparisons under Section 1502.14 will be based on this discussion.”
It is key for NPS to clearly compare and make apparent the distinctiveness of each alternative and its impacts or protectiveness. This is not accomplished when words like “small” or “substantially” are used instead of quantitative information or more detailed and clear descriptions of qualitative information. The Sierra Club requests that NPS clarify and detail clearly the comparative differences between each alternative and define clearly what the words or phrases used mean including the words or phrases used in their definition.
In addition, the phrase “best professional judgment” is not defined in the EIS. NPS must define what “best professional judgment” means so that the public can review, comment on, and understand what NPS is referring to. Decision-makers also need to know this information. The qualitative description of phrases used to describe environmental impacts or the protectiveness of an alternative does not provide the public with the degree of comparison required by the CEQ as outlined above.
The use of “best professional judgment” (page 218) is not a substitute when quantitative information is available to show what impacts are or could be. This is the concern that the Sierra Club has when NPS develops and uses the “impact threshold definitions”. This methodology is based on “best professional judgment” but the public is not told what this phrase means. The interaction of the “impact threshold definitions” with the requirement in Section 1502.22 of the CEQ’s NEPA implementing regulations must be discussed in detail in this EIS and where information is missing and the NPS cannot obtain due to money or time then Section 1502.22 must be implemented as required by CEQ.
Section 1502.22, requires that when evaluating reasonably foreseeable significant adverse effects on the human environment that incomplete or unavailable information be plainly stated as lacking in the EIS. This section requires that if the costs of obtaining this information are “not exorbitant” then the agency must include the information in the EIS.
Finally, this section requires that if the information cannot be obtained due to exorbitant costs that the agency must:
1. State the information is incomplete or unavailable;
2. State the relevance of this information to evaluating the significant adverse impacts;
3. Summarize the credible scientific evidence;
4. Then provide the agency’s evaluation of impacts based upon theoretical approaches or research methods generally accepted in the scientific community.
In the EIS the use of “best professional judgment” is the theoretical approach or research method that is generally accepted in the scientific community that NPS uses to assess the environmental impacts in this EIS for GMNP. On pages 218-219, NPS states “In the absence of quantitative data, best professional judgment was used to identify impacts … Analysis of natural resources was base don research, knowledge of park resources, and the best professional judgment … For this document, the planning team qualitatively evaluated the impact intensity for natural resources”. Therefore NPS must give a thorough discussion of the use of this evaluation method in place of using quantitative data for the impact issue that is being discussed and use Section 1502.22 of CEQ NEPA implementing regulations where quantitative data is not available.
NPS cannot substitute “best professional judgment” for gathering existing quantitative data that it does have or gathering quantitative data that does not cost an exorbitant amount to collect for this EIS. The Sierra Club opposes the use of “best professional judgment” in lieu of using existing or not exorbitantly costly acquired quantitative data. The Sierra Club requests that NPS clarify and detail clearly the comparative differences between each alternative and define clearly what the words or phrases used mean.
This EIS should be an attempt by the NPS to implement the recent court ruling in favor of the Sierra Club and against the NPS about assessment of impacts and the methodology used, from impairment and NEPA perspectives, which was deemed inadequate, arbitrary, and capricious. By United States District Judge John D. Bates, then it has failed. The judge’s decision stated, in part, in Sierra Club v. Mainella the following:
“Because NPS’s impairment analysis served as its NEPA analysis, the flaws in the impairment analysis also apply to the environmental assessment. Those shortcomings are, first, NPS’s lack of explanation as to how it reached its conclusions, typically simply describing the impacts followed by a conclusion that the impact was not an impairment or, in the case of NEPA, that it was not “significant”; and second, the use of the descriptors “negligible”, “minor”, “moderate”, and “major” that are largely undefined or are defined in a manner that includes few objective bounds … nowhere explained the basis for its conclusion that potentially “moderate” impacts could not be significant under NEPA … There is no basis in the administrative record for accepting NPS’s conclusion that even a “minor” impact is not significant under NEPA, because there are no determinate criteria offered for distinguishing a “minor” impact from a “moderate” or “major” impact other than NPS’s conclusory say-so … the scoping regulations still require the agency to explain why they {dismissed issues} will not have a significant effect on the human environment … Thus, the EA must provide a realistic evaluation of the total impacts and cannot isolate a proposed project, viewing it in a vacuum … In short, NPS’s three findings of no significant impact are, the court concludes, arbitrary and capricious for many of the same reasons as are the impairment determinations. In each decision, NPS has failed to take a “hard look” at impacts on the Preserve from adjacent surface activities, as evidenced by the lack of explanations supporting its conclusions and, in particular, its methodology of describing impacts using conclusory labels and then setting forth a bare conclusion without explanation as to the significance of an impact. NPS also failed to provide an adequate cumulative impacts analysis that included the other oil and gas operations in the Gore Baygall Unit … However, NPS’s ultimate conclusions that the drilling activities would not result in impairment of park resources and values under the Organic Act, or a significant impact on the human environment under NEPA, are not supported by reasoned explanations, and hence are arbitrary and capricious and an abuse of discretion.”
It does not appear that the NPS has quantified in the EIS’s assessment many of the impacts and the methodology has not removed the “conclusory statements” that Judge Bates ruled against. Judge Bates states in his decision that the descriptors “negligible”, “minor”, “moderate”, and “major” are largely undefined or are defined in a manner that includes few objective bounds. These descriptors remain largely undefined and with few objective bounds. In addition, the NPS still does not explain the basis for its conclusion that potentially “moderate” impacts could not be significant under NEPA.
The Sierra Club is unable to find the complete analysis, assessment, and evaluation of “unacceptable impacts”, except for a brief description on pages 216-217 of the EIS. NPS states “The impact threshold at which impairment occurs is not always readily apparent. Therefore, the National Park Service manages to avoid impacts that fall short of impairment, but are still not acceptable” and then lists some qualitative and non-specific criteria for unacceptable impacts. For example, “impede the attainment of the park’s desired future conditions”; “unreasonably interfere with”; “create an unsafe or unhealthful environment”; and diminish opportunities for current or future generations”. What do these words and phrases mean? The public and decision-makers need this information clearly stated and transparently presented so that it can be reviewed, commented on, and understood in relation to the environmental impacts of the proposal.
Therefore, the following words or phrases (including the criteria themselves – negligible, minor, moderate, and major), are not defined, inadequately defined, or are un-quantified, and must be defined and quantified so that the public and decision-makers can review, comment on, and understand the proposal:
1) Soils, Pages 219
a. Negligible – “lower levels of detection” and “would be slight”
b. Minor – “would be small”; “relatively simple”; “likely to be successful”
c. Moderate – “readily apparent:; “would likely be long-term”; “relatively wide area”; “would likely be successful”
d. Major – “readily apparent”; “would substantially change”; “over a large area”; “would be needed and extensive”; “success could not be assured”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
2) Plant communities and Vegetation, Page 219
a. Negligible – “some individual native plants”; “could be affected”; “native species populations”; “small scale”
b. Minor – “would affect some individual native plants”; “relatively minor portion”; “could be required”; “would be effective”
c. Moderate – “some individual native plants”; “affect a sizeable segment”; “relatively large area”; “could be extensive”; “would likely be successful”
d. Major – “considerable effect on native plant populations”; relatively large area”; “would be required and extensive”; “success of the mitigation measures would not be assured”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
3) Wildlife, Page 220
a. Negligible – “would be well within natural fluctuations”
b. Minor – “would not be expected to be outside the natural range of variability”; “not be expected to have any effects”; “would be simple and successful”
c. Moderate – “particularly vulnerable life-stages”; “occasional basis”; “outside the natural range of variability”; “would be extensive and likely successful”
d. Major – “outside the natural range of variability”; key ecosystem processes”; “might be disrupted”; might affect the viability of at least some native species populations”; extensive mitigation measures”; “success would not be assured”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
4) Geologic Resources, Pages 220-221
a. Negligible – “could result in a change”; lowest level of detection”
b. Minor – “could result in a detectable change”; “Would be slight and local”; Mitigation might be used”; “would be relatively simple”; “likely successful”
c. Moderate – “clearly detectable change”; “would affect a substantial area”; “would likely be successful”
d. Major – “substantial alternation”; “would be highly noticeable”; “would affect a large area”; “would be necessary and extensive”; “success could not be guaranteed”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
5) Paleontological Resources, Pages 221-222
a. Negligible – “disturbance would be negligible”; “would be nearly indiscernible”; “would be minimal”
b. Minor – “a few fossils”; “might be lost”; “would be a low probability”; Volume of bedrock disturbance would be low”; “nearly indiscernible”; “would be minimal”
c. Moderate – “A number of fossils”; might be lost”; “moderate probability”; “would be large”; “would be small”; “some fossils”
d. Major – Many fossils”; “could be lost”; “high probability”; High fossil richness”; volume of bedrock disturbance would be large”; “probably would be lost”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
6) Ethnographic Resources, Page 223
a. Negligible – “barely perceptible”
b. Minor – “would be slight but noticeable”; “would neither appreciably alter”
c. Moderate – “would be apparent”; “would facilitate traditional access”
d. Major – “would alter resource conditions”; “greatly affect traditional access”; “survival of a group’s practices and/or beliefs would be jeopardized”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
7) Museum Collections Pages 223-224
a. Negligible – “barely measurable”; “with no perceptible consequences”
b. Minor – “would affect the integrity of a few items”
c. Moderate – “would affect the integrity of many items”
d. Major – “would affect the integrity of most items”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
8) Visitor Experience and Understanding, Page 224
a. Negligible – “would not be detectable”; “not be any noticeable change”
b. Minor – “small but detectable”; ”not appreciably alter”
c. Moderate – Some changes”; “would be readily apparent”; “would be substantially altered”; Most visitors”; “Visitor satisfaction would change”
d. Major – “Changes in multiple critical characteristics”; “would be readily apparent”; “Most visitors”; “likely express a strong opinion”; “would be considerably altered”; “would result in substantial changes”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
9) The Socioeconomic Environment, Pages 224-225
a. Negligible – “would be detectable only through indirect means”; “would result in no discernible effect”
b. Minor – “would be detectable but localized in geographic extent or size of population”; “would not be expected to alter”
c. Moderate – “would be readily detectable”; “across a broad geographic area”; “could have an appreciable effect”
d. Major – “would be readily apparent”; “affect a substantial segment of the population”; “likely have a noticeable influence”; “temporary in nature”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
10) Park Operations, Facilities, and Equipment, Pages 225-226
a. Negligible – “below detectable levels”; “would not have an appreciable effect”;
b. Minor – “would not have an appreciable effect”
c. Moderate – “would be readily apparent”; “would result in a substantial change”; “manner noticeable to staff and the public”
d. Major – “would be readily apparent”; “would result in a substantial change”; “in a manner noticeable to staff and the public”; “would be markedly different”; “have a permanent effect”
e. Other phrases: “likely to have negligible effects”; “reach reasonable conclusions”
1. What do these phrases mean in the context cited in the text and quantitatively?
2. Is the uncertainly great or small?
3. What is the probability, risk, potential, and likelihood of these events happening?
If the information that these questions ask cannot be obtained then Section 1502.22 of CEQ NEPA implementing regulations must be implemented. The public and decision-makers need to know this information so they can review, comment on, and understand the proposal.
Because of the NPS’s failure to define quantitatively (using non-quantitative terms like negligible, minor, moderate, and major) the environmental impacts (including cumulative environmental impacts) of all alternatives for the draft GMNP GMP/EIS on pages 227-284, for the issue topics of Natural Resources (Soils, Plant Communities and Vegetation, Wildlife, Geological Resources, Paleontological Resources); Cultural Resources (Archeological Resources, Historic Structures, Cultural Landscapes, Ethnographic Resources, Museum Collections); Visitor Experience and Understanding (Access, Activities and Destinations, and Scenic Views; Interpretation, Education, and Orientation); The Socioeconomic Environment (Regional Economic and Demographic Conditions and Housing and Community Infrastructure); and Park Operations, Facilities, and Equipment (Management and Administration, Employee Housing, and Maintenance); The Relationship Between Local Short-Term Uses of the Environment and the Maintenance and Enhancement of Long-Term Productivity; Any Irreversible or Irretrievable Commitments of Resources Which Would be Involved Should the Alternative be Implemented; and Any Adverse Impacts Which Cannot be Avoided Should the Action be Implemented, this draft GMP/EIS has not followed the CEQ NEPA implementing regulations including Section 1502.22. The public and decision-makers need this information so they can review, comment on, and understand the proposal.
68) Page 213, Cumulative Impacts and Projects That Make Up the Cumulative Impact Scenario, what does “reasonably foreseeable future” mean? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
69) Page 214, Subdivision Development, NPS should determine if it can buy the proposed subdivisions on the west side of GMNP in the Salt Basin and on the south boundary, east of Patterson Hills. It is very important to avoid hemming in and prevent any incompatible use next to GMNP.
70) Page 214, Mining and Drilling, NPS should ensure that it does all it can to keep drilling from Otero Mesa and Crow Flats so the vistas and ecological integrity of GMNP is kept intact.
71) Page 214, Water Exports, how is NPS going to address protecting aquifers in the GMNP area? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
72) Pages 214-215, Aircraft Overflights, what will NPS do to reduce aircraft over-flight noise? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
73) Page 215, Lincoln National Forest, New Mexico, what logging, road building, mineral extraction, and prescribed burning does Lincoln National Forest do in the greater GMNP ecosystem? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
74) Pages 227-228, Alternative A: No Action, Soils, what do “small areas”; “relatively small area” mean? The public and decision-makers need this information so they can review, comment on, and understand the proposal.
75) Page 227, Alternative A: No Action, Soils, NPS states “Trails were constructed to minimize impacts on soils by concentrating hikers on a maintained surface”. What does “maintained surface” mean? Why does NPS ignore horses since they cause more soil and vegetation damage? Horses also need to remain on the trail surface to reduce environmental damage.
76) Page 229, Plant Communities and Vegetation and page 231, Wildlife and page 233, Geological Resources, NPS states “Lands outside the park boundary that are considered critical to protecting important park related resources, including habitat for important species of plants, might be acquired from willing sellers or though donation, or could be protected through agreements or easements.” NPS should state which lands are most important to protect. The recent proposal to sell 10,000 acres near McKittrick Canyon should be mentioned as a priority area for acquisition.
NPS should make a statement in this draft GMP/EIS to commit to long-term land preservation, protection, conservation, and restoration of these lands outside the park boundary. The public needs a list of these lands and a map where they are located. The public and decision-makers need this information so they can review, comment on, and understand this proposal.
77) Page 229, Plant Communities and Vegetation, NPS states “The irrigation of shade trees and lawns … would continue to cause the growth of unnaturally lush vegetation and would allow exotic species to flourish”. What does the NPS plan to do to control or reduce this exotic plant species growth. The public and decision-makers need this information so they can review, comment on, and understand this proposal.
78) Page 230, Plant Communities and Vegetation, what does “very small increment” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
79) Page 230, Wildlife, NPS states “Development would continue to occupy less than 1,000 acres or a little more than 1 percent of the 86,416 acres in the park”. Why is the destruction of 1,000 acres of natural area or Wilderness quality area considered acceptable and why is this considered to be a relatively small environmental impact? After all, for cumulative impacts this is a large loss of wildlife habitat in GMNP. The public and decision-makers need this information so they can review, comment on, and understand this proposal.
80) Page 230, Wildlife, what does “many wildlife species” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
81) Page 231, Wildlife, what does “relatively low incidence of collisions” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
82) Page 231, Wildlife, Cumulative Effects, what does “would contribute only very slightly” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
83) Page 232, Wildlife, Conclusion, what does “would be very small” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
84) Page 232, Geological Resources, what does “intensity would be minor because of the small areas involved” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
85) Page 232, Geological Resources, NPS states “Currently, the number of permits issued each year is low”. How many permits of what type are issued each year? What are the environmental impacts of issuing permits for this activity? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
86) Page 233, Geological Resources, Cumulative Impacts, what does “would contribute only very slightly” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
87) Page 233, Geological Resources, Conclusion, what does “these effects would be very small” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
88) Page 235, Paleontological Resources, Cumulative Impacts, what does “would contribute only very slightly” mean? What are the impacts for surface resources from 0-50 feet below the surface? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
89) Page 235, Paleontological Resources, Conclusion, what does “effects would be very small” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
90) Page 235, Archeological Resources, what does “few if any adverse effects would be anticipated” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
91) Page 235, Archeological Resources, what does “would be avoided to the greatest extent possible” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
92) Page 236, Archeological Resources, Cumulative Impacts, what does “would be avoided to the greatest extent possible”; “would contribute only minimally to the adverse effects”; “would be a very small component” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
93) Page 236, Archeological Resources, Conclusion, what does “Few if any adverse effects” and “effects would be very small” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
94) Pages 236-237, Historic Structures, what do “Monitoring the carrying capacity of historic structures”; “few if any adverse effects would be anticipated”; “would result in few if any adverse effects”; “would be very small”; “Few if any adverse effects”; “contribution to these effects would be very small” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
95) Page 237, Cultural Landscapes, NPS states “in accordance with standards and guidelines”. NPS must explain what these “standards and guidelines” are. The public and decision-makers need this information so they can review, comment on, and understand this proposal.
96) Page 238, Cultural Landscapes, Conclusion, what does “would contribute a very small increment” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
97) Page 240, Access, NPS states “Horseback riding is allowed on some trails. It is more than “some trails” that horseback riding is allowed on. From the Trails Illustrated map it appears that horseback riding is allowed on the Tejas Trail, Mountain Trail, Bush Mountain Trail, Marcus Trail, Foothills Trail, Guadalupe Peak Trail, Salt Basin Overlook Trail, El Capitan Trail, and McKittrick Canyon Trail. According to the Sierra Club’s calculation, using the Trails Unlimited Map mileage of GMNP, about 47.7 miles of the 82 total miles of hiking trails allow horses on them, which is over 50% of the trails (58.2%). This is more than “some” trails allowed for horse use. Page 191 states that 60% of the trails are used for horseback riding. The public and decision-makers need this information so they can review, comment on, and understand this proposal.
98) Page 240 Activities and Destinations, what does “A small increase in use” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
99) Page 241, Scenic Views, how long is the electric line that will be removed from McKittrick Creek? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
100) Page 241, Scenic Views, Cumulative Impacts, what does “the continued protection of scenic views is substantial” mean? This seems like a strange statement since NPS has previously in this draft GMP/EIS stated that air quality, which obscures scenic views, is not an issue topic and NPS cannot do much about. The public and decision-makers need this information so they can review, comment on, and understand this proposal.
101) Page 241, Scenic Views, Conclusion, what does “would have generally adverse impacts” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
102) Page 243, Housing and Community Infrastructure, what does “minimally increased demand” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
103) Page 243, Housing and Community Infrastructure, Cumulative Effects, what does “effects would be very small” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
104) Page 243, Housing and Community Infrastructure, Conclusion, what does “contribution to these effects would be very small” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
105) Page 243, Housing and Community Infrastructure, Cumulative Effects, NPS states “Increases in residential development, … could result in increased visitation levels at the park and require additional management efforts along those park boundaries … could require a reallocation of staff, decreasing their availability in other areas of the park” and then says on page 243, Management and Administration “Through core operations, the park management is streamlining the organization … would hire more seasonal and term position rather than using full-time staff for these activities” and on page 244, Maintenance, states “the potential of increasing visitation, the park staff could be presented with increasing challenges in carrying out the park’s maintenance requirements”.
These quotes are contradictory. While park visitation may increase and cause the need for more people, NPS is cutting its staff from 40 to 34. There is no way that seasonal employees can do the same quality work and the same amount of work as full-time employees. This is penny wise and pound foolish thinking. NPS pays seasonal employees very poor salaries. Seasonal employees are only around for a few months and cannot learn the needs and resources of GMNP in the same manner as full-time employees.
But what happens if the opposite occurs? Due to high gasoline prices fewer people come to GMNP. The figures shown on page 190, Table 8, Recreational Visitation in 2000-2008, document a decline from a high of 222,307 in 2001 to 174,157 in 2006. This is before gasoline prices rose astronomically to almost $4/gallon right now. The forecast is for further rises in gasoline prices and for these increases in price to remain high. Why does NPS not talk about this and how it will affect GMNP? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
106) Page 244, Maintenance, Cumulative Impacts, what informal trails are NPS talking about? How many of these trails are likely to be made and where? What are their environmental impacts? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
107) Page 244, Maintenance, Cumulative Impacts, what does “effects would be slight” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
108) Page 244, Maintenance, Conclusion, what does “contribution would be slight” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
109) Pages 244-245, The Relationship Between Local Short-Term Uses of the Environment and the Maintenance and Enhancement of Long-Term Productivity, what does “sustainable action” mean? Why is Alternative A, a “sustainable action”? NPS does not explain. What criteria is NPS using to judge an alternative’s sustainability? What are the local short-term uses that this draft GMP/EIS proposes? What is the maintenance and enhancement of long-term productivity that NPS compares to short-term uses and that this draft GMP/EIS provides? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
110) Page 245, Any Irreversible or Irretrievable Commitments of Resources Which Would be Involved Should the Alternative Be Implemented, NPS ignores that what NEPA says has to be in this section of the EIS. NPS states “Alternative A would not involve the irreversible or irretrievable commitment of resources”. This is an untrue statement. Alternative A, with the actions currently underway at the Frijole Ranch and the existing 1,000 acres of Wilderness-like area that has been developed has irreversible and irretrievable commitments of resources.
Where is the acknowledgment that energy will be used, air pollution generated, soil eroded, sediment will go into streams, loss of solitude, loss of quiet, loss of hearing natural sounds, trampling of vegetation will occur, materials will be used, existing acres of what once were Wilderness quality natural area will remain developed areas, actions currently underway at the Frijole Ranch complex will cause a loss of Wilderness quality lands? Where is the discussion about the loss of 1,000 acres of natural ecologically functioning ecosystems in the past? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
111) Page 245, Any Adverse Impacts Which Cannot Be Avoided Should the Action Be Implemented, NPS remains totally quiet about what these “adverse impacts” are in this part of the draft GMP/EIS. A few adverse impacts the Sierra Club can think of include destruction or degradation of fossils by horses, soil erosion and sedimentation by horses and hikers, vegetation trampling by horses and hikers, existing acres of what once were Wilderness quality natural area will remain developed areas, continuing reductions or obscuring of scenic vistas by air pollution, etc. Why has NPS ignored these impacts and not stated them here in the EIS? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
112) Page 246, Preferred Alternative, Natural Resources, Soils, NPS states “Actions of the preferred alternative would disturb about 200 acres of soil through the park”. This statement is incomplete. The 200 acres of disturbed soil, or plant communities and vegetation, etc., must be added to the 1,000 acres already disturbed to give a true picture of the total impacts that have and will be done due to this proposed alternative. The loss of an additional 200 acres is a 20% increase in the loss of soils. The public and decision-makers need this information so they can review, comment on, and understand this proposal.
113) Page 246, Preferred Alternative, Natural Resources, Soils, Conclusion, what does “would contribute a very small increment” mean? The public and decision-makers need this information so they can review, comment on, and understand this proposal.
114) Page 247, Plant Communities and Vegetation, Cumulative Effects and page 248, Conclusion, what does “would contribute a very small increment” mean? The public and decision-makers need this informati
