**Summary**

# Yellowstone and Grand Tetons National Parks Winter Use Plan

**NPS Meeting with Governmental Cooperating Agencies**

Friday, December 8, 2006, 9 am -- 2 pm

Cody Holiday Inn at Buffalo Bill Village, Cody, WY

1)  **Purpose for Meeting**

The objectives and the desired outcomes of the meeting as described in
the draft Agenda were accepted without further discussion.

***Substantive Outcomes Desired***

1)  NPS answers cooperator questions to clarify information in the
    review draft.

2)  NPS explains how the alternatives meet the purpose and need --
    toward the decision to be made on extent of public recreational
    access to parks during winter.

3)  Cooperators ready to deliver governmental comment letters to NPS
    by12-22-06 to improve the Draft EIS that NPS will publish for the
    60-day public review and comment period later this winter.

***Relational Outcomes Desired***

4)  Dialog between and among the governmental agencies.

5)  Investment in increasingly collaborative working relationships for
    the long haul.

***Procedural Outcomes Desired***

6)  Continued clarity and honesty about who has what kind of influence
    in the winter use decision and implementation steps and schedule \--
    Shared understanding of long history and current situation in all
    three branches of government.

7)  Meet/exceed project information sharing and participation goals.

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2)  **Results of the Meeting and/or Next Steps**

-   A draft of a summary of this meeting will be distributed to CAs
    before noon Friday December 15.

-   The date for submission by CAs to NPS of written comments on the
    preliminary version of the DEIS is **postponed until close of
    business on Friday, January 5 2007.**

-   In the period from January to mid-March, NPS will adjust, edit, and
    print the DEIS document.

-   Probably in late March the formal public review of the DEIS will
    start. This could last somewhat longer than 60 days. NPS will also
    issue a Proposed Rule for public comment.

-   Final EIS expected to be published by mid/late Oct 2007, for the
    normal 30-day waiting period.

-   The NPS will carry out any necessary additional analysis or
    re-analysis.

-   In mid-November the Record of Decision (ROD) will be signed and the
    final regulation will be published. There will be a 30-day waiting
    period for implementation of the Final Regulations in time for the
    winter season.

3)  **Questions and Comments on Identified Topics of Interest**

    a.  **East Entrance**

The proposal to cease grooming and avalanche control on Sylvan Pass was
described.

**Question**: Closure of Sylvan Pass to OSV to increase safety and
security will still allow dangerous activity by skiers who can use the
pass. ***Answer**: The pass will be treated like most of the
backcountry: open to non-motorized travel at your own risk.*

**Q**: Can't the pass be open to OSVs on the same "at your own risk"
basis? ***A**: Various alternatives treat this differently so NPS can
look at different ways of addressing Sylvan Pass.*

**Q**: Can the NPS include "open Sylvan Pass" in the preferred
alternative? ***A**: NPS wants to explore what would enable them to
operate Sylvan Pass safely.*

**Q**: If NPS doesn't groom the East. Entrance during the winter, won't
this increase the effort to plow it in the Spring, and delay opening for
the summer season? This would impact Cody's summer business. ***A:**
Grooming the East Entrance makes the road harder to plow in the spring,
because the snow is compacted. So, not grooming will make the spring
plowing easier and will not delay the opening.*

**Q**. If snow in the avalanche chutes is not managed in Sylvan Pass
during winter, what do we have to do in the Spring? ***A**: The snow in
the chutes will release naturally throughout the winter. Before plowing
in the spring, the avalanche chutes will be emptied.*

**Q**: Will there be Administrative use of Sylvan Pass? ***A**: In
Alternative 1 the Pass would be closed to all administrative use except
search and rescue etc.*

**Q**: What can NPS do to keep the East Entrance open for OSVs? ***A**:
NPS hopes the CAs will identify opportunities as they review the
information in the preliminary DEIS document.*

**Q**. CAs may need additional time to discuss this issue with State
Government to see how we can find funding and support to help us keep
the East Entrance open to OSVs, taking account of avalanche safety.
***A**: NPS will take CA comments at any time and is looking for
opportunities to discuss this.*

**Q**: What is the possibility of plowing the eight mile unplowed
section of the Beartooth Highway? ***A**: That road is not the
responsibility of NPS, it would be up to Wyoming and Montana and the
U.S. Forest Service.*

b.  **CDST -- Continental Divide Snowmobile Trail**

The management and use of the CDST in Grand Teton and the Parkway were
described. The CDST enters from the East on Route 287 and turns North up
to Flagg Ranch. There are some safety concerns about proximity of CDST
to the road because it runs along the road shoulder or encroaches on the
road. It takes until mid-January to establish the trail on this route.
Consideration of management of this trail is informed by the low usage
of the route by snowmobiles. NPS must judge where to spending its
budgets and consider the CDST in the context of the whole park. The
former usage level of 30-35 snowmobiles per day is not considered a
bench-mark for this purpose.

> **Q**: What about the approach coming in from Idaho where snowmobiles
> need to have BAT for a short stretch? ***A**: The current rule is that
> snowmobiles coming from the East are not subject to BAT until reaching
> Moran junction. But the 25 miles up to the Grassy Lake Road junction
> at Flagg Ranch do have a BAT requirement. The NPS is considering a
> shuttle service to allow people to make the whole trip. The Shuttle
> would run from Moran to Flagg Ranch .*
>
> **Comment**: Such a shuttle wouldn't accomplish much because users
> wouldn't be able to go west on the CDST. In a situation where Grassy
> Lake Road was open to 2-strokes but CDST wasn't, it might make sense
> for a shuttle service. Teton County urges NPS to find a way for this
> not to become cumbersome because it may become a greater deterrent to
> snowmobile use on the CDST.

**Q**: What's the reason for allowing non-BAT on the short stretch after
entering the Park from the East on Route 287? ***A**: NPS treats this
like other areas where there is adjacent private land, and allows
non-BAT snowmobiles.*

c.  **Jackson Lake**

**Q**: The Teton County Commission unanimously supports snow planes on
the lake and considers it a great cultural aspect of the valley. Is
there a mechanism to revisit this decision to prevent snow planes from
using the lake, or is this question closed? ***A**: NPS is not
reconsidering the use of Snow Planes in this planning process. In 2000
NPS found that the sound of Snow Planes is unacceptable, and violates
the Organic Act. The Court has not yet given a decision on this issue.
At present NPS permits the use of snowmobiles to provide access to the
Lake.*

d.  **Guiding**

**Q** What are the definitions of the categories of "Guiding"? ***A**:
Commercial Guiding means that a company is contracted with NPS to
provide guided snowmobiling. Unguided refers to private/personal
operators of snowmobiles who are all members of the same party, and who
attend a short orientation session and then enter the park. This is
similar to the arrangements for back-country access in summer.
Non-commercially guided means that one member of the group is the
non-commercial guide, who has attended a more extensive training program
lasting 2-3 hours, and is then responsible for the group.*

> **Comment:** Preparation for non-guided access could be done on-line
> without having to come in and spend part of the day in an orientation.

**Comment:** What about a state safety course? Unguided groups could
also present a certification from a snowmobile association or a state
agency. Some state safety licenses last for lifetime, not just a winter.

**Q**: Please explain the reason for the timing of snowmobile entry
before 10 a.m. in the "Unguided" Alternative 5? ***A**: NPS looked at
this concept to provide a longer period of natural quiet during the
day.*

> **Q**: The size of guided groups in Alternatives 4&5 is 11 per guide.
> Other Alternatives have smaller and larger groups. What determined
> these group sizes? ***A**: Scoping comments suggested the value of
> smaller groups, because one guide may not be able to manage a larger
> group. We included different Alternatives (e.g. 7 per guide or 15 per
> two guides) to be able to compare and contrast different
> alternatives.*
>
> **Q**: Is there no access on snowmobiles when temperatures are --25
> Fahrenheit. ***A**: That is NPS administrative practice. This is close
> to a prohibition. It is a NPS personnel guideline enforced
> administratively so that Park employees don't go out below --25 F. NPS
> has requested guides and outfitters to consider this as a
> recommendation for them. Most of them have their own guidelines, so
> NPS has asked for feed-back about this.*

**Q**: Winter use management has done much to discourage people from
riding in the park. On factor of this discouragement is the cost of
renting a machine and then paying additional fees for a guide. This
affects local riders especially, although tourists from far away may be
able to pay that much. Non-commercially guided entry allows locals to
get into the park. We want an outcome that allows non-commercially
guided access for snowmobiles. This winter use plan makes winter use an
elitist experience, except that Snowcoaches provides a less expensive
alternative to visitors. ***A**: Yellowstone has never been an
inexpensive place to visit. NPS has included some alternatives using
plowing to provide less expensive access (wheeled vehicles are cheaper
than OSVs). See, for example, Alternative 6.*

e.  **Best Available Technology (BAT)**

**Q**: What is the rationale for analyzing Improved BAT at this point?
***A**: NPS expects technology to improve over time. Even some of the
current BAT-compliant models are significantly better than others. So
NPS explored the impact of requiring Improved BAT on snowcoaches. NPS
did not do the same thing for snowmobiles because it knows that the
technology of snowcoaches will improve significantly so it makes sense
to examine the effect of this on snowcoaches. NPS welcomes suggestions
and definitive language to facilitate this.*

> **Q**: What proportion of the snowcoach fleet is BAT compliant?
> ***A**: About one third or one fourth of the fleet.*
>
> **Q**: What snowcoach standard was use in Modeling? ***A**: NPS
> followed the quality of the best fourth or third of the fleet.*

**Q**: Better environmental standards are being required of snowmobile
engines. What happens when BAT is no longer good technology for normal
snowmobile use? If BAT is superseded by other technology, or if
manufacturers stopped building BAT machines, what would we be able to
use in the Parks?. ***A**: BAT has been very important in improving air
quality and soundscapes. NPS has met with manufacturers to discuss this.
All four major snowmobile manufacturers produce machines that meet NPS's
BAT requirements. NPS believes that they'll continue to produce machines
that meet NPS requirements. They're also interested in meeting the EPA
requirements, and expect to do that. NPS will maintain this dialog with
the manufacturer.*

f.  **Adaptive Management**

**Q**: There is a table describing the Draft Adaptive Management Plan in
the preliminary DEIS. Will this be included in the Draft document?
***A**: The intention of NPS is to include discussion of the adaptive
mgmt plan in the winter use plan.*

> **Q**: If the preferred Alternative is adopted and the East Entrance
> is closed to OSVs, does the adaptive management process provide
> opportunities to re-open the East Entrance? ***A**: The adaptive
> management program would not address issues like the East Entrance,
> but NPS's intent is for this to be a long-term plan. However, NPS is
> always ready to re-look at things. If new information appeared or
> something different occurred, of course NPS would look at this issue
> again. Willingness to revisit such issues is balanced by NPS's
> awareness that uncertainty about future winter management has severe
> impacts on the gateway communities. Fortitude to stand behind the
> Winter Use Plan will affect the level of this certainty.*
>
> **Q**. Page A42 of Appendix E shows a big change of direction in park
> management. In the third paragraph it says "excedence of these
> thresholds would be unacceptable etc." In the 2003 ROD, the adaptive
> management thresholds were defined as impacts being unacceptable. This
> appears to be changed. ***A**: Adaptive Management Thresholds don't
> represent a definition of acceptability or unacceptability. They were
> and are intended to provide management with guidance as to the
> significance of what is going on out there for the purpose of
> determining what is acceptable or unacceptable. An adaptive management
> threshold would indicate to a manager that it might be time to make a
> change, or perhaps not. These thresholds are draft thresholds, and NPS
> will take a close look at them recognizing that adjustments may be
> necessary. NPS needs to be consistent in its language and welcomes
> suggestions.*
>
> **Q**: Can the NPS expand concept of Adaptive Management: to allow
> flexibility in the granting of access? ***A**: NPS does have contracts
> with concessioners that allow flexibility to NPS. However, NPS
> recognizes the need to provide predictability to concessioners and,
> for example, time-lags for implementation of changes. Most of the
> abrupt changes made by NPS regarding winter use have been
> court-ordered.*
>
> **Q**: Although the Organic Act does not protect the interests of
> snowmobile outfitters, this is an important part of the enjoyment of
> the park. So what way is there to make outfitters whole so that they
> can engage in their work effectively? ***A**: Following the
> development of a Winter Use Plan under NEPA, NPS will follow a process
> to put the business opportunities out to bid. NPS tries to ensure that
> winter use management decisions have the best chance of being
> implemented from a business perspective.*
>
> **Q**: The Adaptive management in Alternative 5 talks of 6-12 months
> of consultation. Can this consultation be built into the adaptive
> management process? ***A**: No, this would be built into the
> contracts, and contractors would decide how to allow visitors to
> visit.*

g.  **Xanterrra**

**Q**: What will these Alternatives do to businesses like Xanterra's
Snow Lodge? ***A**: In winter Xanterra only operates two facilities for
a very limited time: Mammoth, and Snow Lodge from December to March.
This business is a loss leader for them. NPS requires them to stay open,
and they are able to sustain this loss because they make enough profit
in the summer. Alternatives will affect Xanterra and they will make
adjustments to their operations. In some alternatives Xanterra would
probably not have an Old Faithful operation.*

h.  **Alternatives**

**Q**: What's the rationale for changing the environmentally preferred
alternative from last time? ***A**: The Environmentally Preferred
Alternative 3b is different from the prior one. NPS looked at the
results from modeling and analysis and concluded that 3b had the least
environmental impacts. Alternative 3b isn't a "No Access" alternative.
There is wheeled access in parts, and access to the back country would
stay open but without OSV access. NPS welcomes your thoughts on this
issue.*

> **Q**: Explain the division of Alternative 1 into different
> sub-alternatives. ***A**: In the modeling process NPS asked its
> technicians to look at different variations and to reflect the
> modeling analysis in the alternatives.*
>
> **Q**: Will NPS be able to do blending and amending of the existing
> alternatives before preparing the DEIS? ***A**: Yes NPS can do that
> during this process.*
>
> **Q**: What are the Desired Conditions? NPS describes desired future
> conditions of the park. But the wording has been changed in this
> cooperator draft of the DEIS. Desired Conditions need to crosswalk
> with new NPS management policies. At the moment they fall short of the
> management policies. ***A***: *We believe the desired conditions are
> consistent between documents, but please provide us your comments and
> thoughts.*

i.  **Bison Study**

**Q**: If the bison study requires closing some routes, what is
proposed? ***A**: The proposed experimental closures would affect access
from Mammoth to Old Faithful, and from West Yellowstone to Norris. NPS
is developing some scientific parameters to conduct some studies to show
any relationship between changes on the ground and impact on Bison. NPS
is not ready now to do this -- it does not have the monitoring in place
nor the questions in place to do this study. The basic question is "If
the Bison can't go through the Gibbon River Canyon on the road, will
they not go through the canyon at all?" This topic is in front of the DC
district court now.*

**Q**: What about the impact of plowing on bison? ***A**: NPS
acknowledges that plowed roads may be a sort of trap for wildlife, so it
would need to provide wildlife escape routes from plowed roads.*

j.  **Schedule of the Planning Process**

> **Q** Can CAs have an extension to January 22 to prepare written
> comments on the preliminary version of the DEIS? ***A**: In order to
> have the ROD signed in December 2007, NPS has designed its schedule by
> backtracking from that date to the present. That is how NPS determined
> its December 22, 2006 deadline. Postponing until January 22 would lose
> a whole month, and jeopardize timeliness of the ROD. The period up to
> December 22 is not the only opportunity to suggest comments. There is
> still the public comment period starting in March, and there are also
> the oral comments presented today. NPS does encourage you to include
> any oral comments made today in your written comment letters. NPS has
> arranged for a contractor to visit on January 8 to incorporate written
> comments into the DEIS. So the NPS schedule will not be set back by
> postponing the deadline for your written comments to Friday, January 5
> and NPS agrees to postpone the deadline for written comments to that
> date.*

**Q**: We want extra time to prepare input for the NPS especially
regarding the East Entrance. Our concern is that if our comments are
delivered after the deadline they will be ignored. ***A**: NPS will take
your comments at any time.*

> **Q**: Will NPS personnel be accessible over the holidays? ***A**:
> Denice Swanke will be in her office over the holiday period and John
> Sacklin will be in town.*

k.  **Other**

> **Q**: Does the Rule Making process provide the same opportunities for
> public comments and amendments to the draft as the EIS process.
> ***A**: The Rule Making process is different, but NPS does need public
> input to the Rule Making process and the Rule Making needs to track
> well with NEPA.*
>
> **Q**: If there is litigation following the ROD, what will happen?
> ***A**: It would depend on the court. If NPS doesn't reach a decision,
> and the legislation sunsets, there will be no winter use.*

**Q**: Why are natural soundscapes given more importance in winter use
than summer use? ***A** NPS gives attention to soundscape in summer too.
This is a Winter Plan so the focus of these discussions is now on
winter.*

l.  **Written Comments**

The following written comments were read and accepted by NPS for
consideration after the meeting:

**Comment: Recent Trends -- Bridger -- Teton National Forest, second to
last paragraph, page 75**: First, there is reference to "Table 29" which
more likely should be a reference to Table 27? Second, the last sentence
in this paragraph states the "use is up," which appears to be inaccurate
when looking at the data in the accompanying tables. Use should more
appropriately be characterized as "flat" versus "up." Table 27 which
pertains to the CDST-Togwotee and Gros Ventre areas, presents a total
for 1998-99 of 351 and the total for 2003-2004 (the last year) of 348 --
with every other year in between at or below these beginning and ending
totals. Use is flat, not up. Table 28 for the Grey's River area presents
a similar scenario. If you discount the anomaly of 1993-94 used in this
table, numbers for 1994-95 (9,200) through 2004-2005 (9,230) are
consistently flat and average 9,142 over the period. This conclusion
should be corrected.

**Comment: Table 27, Page 76 -- Bridger-Teton NF Trailheads**: It is
unclear what the numbers in this table are supposed to represent. Are
they numbers of autos, number of snowmobiles, number of snowmobilers, or
something else? Please add either narrative or explanation in the
heading to clarify.

**Comment: Recent Trends Conclusion, bottom of page 77**: The conclusion
statement in the last two sentences at the bottom of this page stops
short of portraying the full summary picture. To fully summarize this
section it seems that language should be added to clarify that, even
though snowcoach visitation numbers have increased by about 68%, the
accompanying 68% decrease in snowmobile visitation equates to an overall
winter visitation decrease in Yellowstone of nearly 54%. This overall
decrease in winter visitation also equates to a nearly \$900,000 per
season net loss to the Park Service from Park entrance revenue. This
information doesn't appear to be quantified in this document. Similarly,
language on page 128 regarding Winter Visitation Data should be
clarified to more fully reflect this change.

**4) Parting Comments:**

-   We expect to be able to meet again before the ROD although we
    recognize this will be very difficult to arrange.

-   This is the best meeting I've had in fifteen years of doing this.

-   This has been great. A good exchange and not so much anger over what
    are important issues.

-   We recognize that this is all about our shared concern for
    Yellowstone National Park.

**5) Present:** (those who signed the sign-in sheet. A few others came
and went during the meeting. Our apologies where we couldn't be sure of
spelling.)

  ----------- ----------- ------------------------------------ ----------------
  **NAME**                **INTEREST/ORGANIZATION/LOCATION**   **Cooperating
                                                               Agency signator
                                                               of information
                                                               sharing MOU?**

  Baker       Lane        NPS Yellowstone                      

  Buline      Pam         U.S. Senator Craig Thomas            

  Burson      Shan        NPS Grand Teton                      

  Catton      Jon         Independent conservationist,         
                          Bozeman, MT                          

  Chandler    Nedra       Cadence facilitation team            

  Cook        Jeff        Idaho Parks and Recreation           

  Davis       Troy        NPS Yellowstone                      

  Davison     Burnie      U.S. Forest Service, Shoshone        Yes, here for
                          National Forest                      Becki Heath of
                                                               the Gallatin

  Dewar       Nicholas    Cadence facilitation team            

  Flanderka   Mary        Governor's Planning Office, WY       

  French      Tim         Park County Commission, Cody, WY     yes

  Goeddeke    Heather     NPS Environmental Quality Division   

  Hill        Greg        Wyoming State Snowmobile Assn        

  Hill        Brad        Wyoming State Trails                 

  Holstein    Jim         Yellowstone Tour Guide               

  Howell      Bill        citizen                              

  Jorgenson   Larry       Teton County Commission, Jackson     yes
                          Hole, WY                             

  Jourdain    Christine   American Council of Snowmobiles      
                          Associations                         

  Keck        John        National Park Service, Cheyenne, WY  

  King        Jackie      U.S. Representative Barbara Cubin    
  ----------- ----------- ------------------------------------ ----------------

  ------------- --------- -------- ------------------------------------ ----------------------------------- ----------------
  **NAME**                         **INTEREST/ORGANIZATION/LOCATION**                                       **Cooperating
                                                                                                            Agency signator
                                                                                                            of information
                                                                                                            sharing MOU?**

  Lewis         Suzanne            National Park Service, Yellowstone                                       
                                   National Park                                                            

  Manning       Teri               Wyoming State Trails Council                                             

  McCray        David              Two Top Snowmobile Rental Inc.                                           

  McCreary      Karen              U.S. Senator Mike Enzi                                                   

  McNamara      Amy                Greater Yellowstone Coalition,                                           
                                   Bozeman, MT                                                              

  Mitchell      Sandra             Idaho State Snowmobile Assn                                              

  Murdock       Bill               Gallatin County Commission, Bozeman,                                     yes
                                   MT                                                                       

  Peacock       Bruce              NPS Environmental Quality Division                                       

  Pollock       Gary               National Park Service, Grand Teton                                       yes
                                   National Park                                                            

  Raap          Kim                Trails Work Consulting                                                   

  Ray           John               NPS Air Resources Division                                               

  Rumpke        Thomas             Attorney General's Office, Wyoming                                       

  Sacklin       John               National Park Service, Yellowstone                                       yes
                                   National Park                                                            

  Scott                   Mary                                          National Park Service, Grand Teton  
                                                                        National Park                       

  Solberg       Terry              Individual user of public lands                                          

  Stevens       Tim                National Parks Conservation                                              
                                   Association                                                              

  Stevenson     Temple             Office of the Governor, Wyoming                                          yes

  Strobel       Phil               EPA Region VIII, Denver, CO                                              yes

  Swanke        Denice             National Park Service, Yellowstone                                       

  Tripe         Amy                Casper Star Tribune                                                      

  Turke         Paul               Moore, Smith Buxion Turke/Blue                                           
                                   Ribbon                                                                   

  VandePolder   Debbie             NPS Yellowstone                                                          

  Vaughan       Doyle              Wyoming State Committee person,                                          
                                   Teton County                                                             

  Vecellio      Gary               Idaho Fish and Game                                                      

  Wade          Bill               Coalition of National Park Service                                       
                                   Retirees                                                                 

  Walker        Bob                Montana Fish Wildlife and Parks                                          Yes, here for
                                                                                                            Pat Flowers

  Welch         Jack               Blue Ribbon Coalition                                                    

  Wilgus        Carl               Idaho Department of Commerce and                                         yes
                                   Labor                                                                    
  ------------- --------- -------- ------------------------------------ ----------------------------------- ----------------

\*END\*