WINTER USE PLANS

FINAL ENVIRONMENTAL IMPACT STATEMENT

VOLUME III

PART I

for the

Yellowstone and

Grand Teton National Parks

and

John D. Rockefeller, Jr.,

Memorial Parkway

U.S. Department of the Interior

National Park Service

CONTENTS

Introduction to Volume III................................................................................................................................i

Part I. Representative Government, Cooperator, Organization, and Individual Comments and Responses

U.S. Congress

Senator Craig Thomas................................................................................................................................I-1

Representative Rick Hill............................................................................................................................I-3

Representative Bruce Vento and others.....................................................................................................I-7

Federal Agencies

USDA Forest Service...............................................................................................................................I-11

United States Environmental Protection Agency ....................................................................................I-19

American Indian Tribes

Confederated Salish and Kootenai Tribes of the Flathead Nation...........................................................I-24

States

State of Idaho, Governor Dirk Kempthorne ............................................................................................I-28

State of Montana, Governor Marc Racicot..............................................................................................I-33

State of Wyoming, Governor Jim Geringer.............................................................................................I-74

Wyoming State Representative, Charles P. Childers.............................................................................I-108

Counties

Fremont County Parks, Recreation, Waterways Commission...............................................................I-112

Gallatin County, MT..............................................................................................................................I-114

Gallatin County Commissioner, Bill Murdock......................................................................................I-120

Park County Commisioners, MT...........................................................................................................I-123

Park County Commissioners, WY.........................................................................................................I-125

Teton County, WY.................................................................................................................................I-129

Paul Kruse, Representative of Cooperating Counties............................................................................I-334

Organizations

Alliance for the Wild Rockies................................................................................................................I-133

Biodiversity Legal Foundation ..............................................................................................................I-142

Blue Ribbon Coalition ...........................................................................................................................I-148

Bluewater Network ................................................................................................................................I-153

The Ecology Center, Inc. .......................................................................................................................I-161

The Fund For Animals Inc.....................................................................................................................I-164

The Greater Yellowstone Coalition .......................................................................................................I-169

Jackson Hole Conservation Alliance .....................................................................................................I-202

Moore Smith Buxton & Turcke, Chartered ...........................................................................................I-205

National Parks and Conservation Association.......................................................................................I-226

National Wildlife Federation .................................................................................................................I-229

InterTribal Bison Cooperative ...............................................................................................................I-233

Predator Conservation Alliance .............................................................................................................I-236

Schubert & Associates...........................................................................................................................I-241

Sierra Club Recreation Issues Committee .............................................................................................I-285

Yellowstone Ecosystem Task Force of the Sierra Club.........................................................................I-289

Yellowstone National Park Lodges .......................................................................................................I-298

Individuals

Don Bachman.........................................................................................................................................I-300

William J. Barmore, Jr...........................................................................................................................I-305

Walt Farmer ...........................................................................................................................................I-316

Jim Gerber..............................................................................................................................................I-319

Paul Hoffman.........................................................................................................................................I-324

David C. Jones and Debra Callahan ......................................................................................................I-330

Dr. Mary Meagher .................................................................................................................................I-348

Rick Meis...............................................................................................................................................I-350

John Mundinger .....................................................................................................................................I-355

John Spahr..............................................................................................................................................I-366

Melissa Stringham .................................................................................................................................I-372

Michael J. Yochim.................................................................................................................................I-375
Comment Documents by Type

Total form letters

87%

Individual letter

5%

Telephone 

comment sheet

1%

Comment sheet

1% Public meeting 

comment

1%

Email

5%

Documents by Source

All other

1%

Public at

large

99%

Executive Summary

his is a summary of the public

comments received for the Winter

Use Plans/Draft Environmental

Impact Statement (DEIS) for the

Yellowstone and Grand Teton National

Parks and John D. Rockefeller, Jr.,

Memorial Parkway. The NPS received

comments from across the United

States, Canada, and as far away as

Germany, Saudi Arabia, and Japan.

Most comments came from Rocky

Mountain and Northwest States.

The NPS received about 46,500

documents commenting on the DEIS—

6,300 unique documents and 40,200

form documents.

The unique documents contain over

19,700 comments. Most documents (87

percent) were form documents from

individuals.

The remaining documents were from

telephone calls, NPS comment sheets,

e-mail, and public meeting

transcriptions.

Commentors included businesses,

private and non-profit organizations,

local, state, tribal, and federal

government agencies, and the public at

large, which constituted 99 percent of

the total commentors.

T
Alternative Preference

Citizens' 

Solution

45%

Revised E

(all versions)

44%

No preference

6%

Natural 

Regulation

4%

Other*

1%

ive new alternatives were

submitted by non-profit

organizations or government

agencies outside the NPS—

• The “Natural Regulation

Alternative” submitted by the

Fund for Animals

• The “Citizen’s Solution” submitted

by the Greater Yellowstone

Coalition, et al.

• The Jackson Hole Conservation

Alliance Proposal

• The State of Montana’s

alternative

• Several versions of a “Revised E”

alternative with minor differences

submitted by the Cooperating

Counties and the Blue Ribbon

Coalition.

From the total number of documents

reviewed, 1 percent or about 500

documents expressed a preference for

an alternative proposed by the NPS in

the DEIS. An additional 93 percent or

about 43,100 documents expressed

support for 1 of the 5 alternatives listed

above.

*Includes all NPS alternatives and State of Montana and Jackson Hole Conservation Alliance alternatives.

F
PART I 

REPRESENTATIVE GOVERNMENT, COOPERATOR, ORGANIZATION,

AND INDIVIDUAL COMMENTS AND RESPONSES
I-1

COMMENTS U.S. Congress
RESPONSE U.S. Congress

I-2

SENATOR CRAIG THOMAS, U.S. CONGRESS

Re: Based on DEIS, NPS has not adequately listened to the concerns of cooperating agencies. In the process of reviewing and commenting on the DEIS, an

inordinate amount of focus has been placed upon the designation of alternative B as the preferred alternative. This has colored the response, and the

relationship between lead and cooperating agencies. Clearly, cooperating agencies are concerned about this designation because of the perceived impacts of

plowing the road from West Yellowstone to Old Faithful for wheeled vehicle access. Since the NPS has indicated it is leaning heavily toward DEIS

alternative G instead of alternative B, it appears that a disproportionate amount of time was spent on alternative B and its consequences. NPS is investigating

a full range of alternatives in the DEIS. Various features of each of these alternatives may be mixed and matched in the eventual decision. NPS feels that

much of the criticism of the EIS, per se, is misdirected because the concern is really about the decision yet to be made. NPS wishes to perform a legal and fair

analysis of impacts, limited by the time available under the court settlement. The cooperators have been included, and their input has been considered and

documented in the DEIS. NPS respectfully submits that the cooperators feel they have not been listened to because of the decision they think NPS is going to

make, not the adequacy of the EIS.

Re: The preferred alternative does not adequately address the issues facing the parks and the concerns of the local communities. Please see previous response.

Considering the types and amounts of winter recreation use and the impacts that are at issue (i.e. sound, air pollution, health and safety, effects on other

visitors, and damage to wildlife), alternative B is a possible approach to addressing some of the issues. At the time of DEIS’ publication, it appeared to be the

best approach to the Park Service, as presented on pages 38-39.

CEQ Regulations do not stipulate the rationale for selecting a preferred alternative in an EIS. It stipulates that in a final EIS, a preferred alternative must be

identified. The statement of preference for one or more alternatives in a DEIS is discretionary, depending upon whether the agency has a preference at that

point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded by the public as extremely tenuous. This is because an EIS is

to serve as a means of assessing impacts of proposed agency actions “rather than justifying decisions already made” (§1502.2(g)). The FEIS preferred

alternative may be viewed more as a “precursor” decision, which will only become final in a Record of Decision that expresses the rationale for the choice. In

any case, it is clear that merely the expression of a preferred alternative, by itself, can in no way invalidate the entire EIS analysis. The decision maker can

select any of the proffered alternatives in a Final EIS through consideration of a variety of factors, including but not limited to environmental impacts. The

selected alternative does not have to be the most environmentally preferable alternative, which must also be revealed in the decision document.

Re: NPS should develop a final plan that protects wildlife, mitigates impacts and allows access for a range of winter recreation experiences. This comment

goes to the decision to be made, not to the adequacy of the EIS or the range of alternatives considered. However, the statement is essentially how NPS views

the purpose and need for action, and how it constructed the range of alternatives. Under NEPA (see previous response), a decision is not made until it is made

in a record of decision based on a final EIS. The decision maker must consider the full range of alternatives available in the EIS and carefully weigh all the

possible impacts against the agency mandate, regulations, executive orders and policies. The alternatives presented and analyzed in the DEIS include actions

supported by cooperating agencies, mostly identified as Revised Alternative E, and features of other alternatives.
I-3

COMMENTS U.S. Congress
I-4

COMMENTS U.S. Congress
RESPONSES U.S. Congress

I-5

REPRESENTATIVE RICK HILL, U.S. CONGRESS

Page 1. Re: Affected states and surrounding counties. There is a desire on the part of NPS to cooperate. The effectiveness of the process used in this EIS

relative to cooperating agencies is subject to debate, especially given the short time frames. Early on, NPS intended to invite the three states surrounding the

parks to participate as cooperating agencies in developing the EIS. NPS believed the states could provide information on impacts to natural resources and

local and regional economies. Without consulting with NPS, CEQ opined to a Wyoming Senator that counties also should act as cooperating agencies in this

process. Thus NPS was faced with working with nine cooperating agencies, several of which had never before participated in a NEPA process as cooperators.

Due to the schedule set by the settlement agreement, NPS had little time to work with cooperating agencies on what was expected of them in that role. This

includes disagreements about the nature of special expertise in the NEPA process, and the burden of the cooperator in providing it. As a result, the

cooperators often acted as though the relationship was one where the NPS was to provide information to them, instead of the reverse. NPS notes that Mr. Paul

Kruse, designated representative for cooperating counties, states in his letter that the counties provided detailed socio-economic analysis and that NPS

allegedly ignored the input. It is clear that roles and expectations in the process were, and are, not well understood, despite the cooperating agreements that

were negotiated and signed.

NPS has considered or used all information provided by cooperating agencies. The characterization of the socioeconomic environment specifically cites

information from the cooperators or their consultants. It may not have been clear in the DEIS how all the information was used, so the final EIS will cite all

cooperating agency materials. On pages 298 through 315, the DEIS discloses the impacts of each alternative on adjacent lands in the cooperating agencies’

own terms.

The cooperating counties attested in the agreements that they would provide special expertise in the areas of social and economic analysis. This analysis was

to be applied to the range of alternatives, not just the preferred. The designation of a preferred alternative in a DEIS is peripheral to the process, since the final

decision must choose from the full range of alternatives presented in the EIS, with their consequences (§1502.14(e) and §1505.2(b)). Cooperating agencies

had information about the range of alternatives, including the eventual preferred alternative, with time in which to develop economic analyses sufficient for

this programmatic assessment. NPS reiterates that the inexperience of cooperators in performing such a NEPA analysis, along with the short time frame,

unfortunately led to the current state of affairs.

Page 2. Re: Economic assessment using 17 counties. It was the judgment of the economic consultant used by NPS that the 3-state area and the 17-county area

were sufficient to answer the question about impacts on the regional economy. Considering the issues raised by local governments, NPS agrees it is

appropriate to focus on the 5-county area containing gateway communities to the parks. The economic model will be re-run on this level. Input-output

models that are available for performing this type of analysis are appropriate only for economies at the county and regional levels. Impacts on communities is

within the purview of the state and local cooperating agencies and their stated special expertise. By and large, none of the cooperators provided specific

effects on communities for each alternative. Most focused only on the effects of the plowed road from West Yellowstone to Old Faithful in preferred

alternative B insofar as it would affect West Yellowstone. This is only one part of one alternative, whereas the eventual decision must consider the full range

of effects for all alternatives.

Page 2. Re: Purpose and need. This comment reflects the sentiment from a number of snowmobile interest groups that there is really no problem with the

current use in the 3 park units. There are identified gaps between existing conditions and desired conditions, and they form the basis for the purpose and need

for action. The underlying purpose (§1502.13), or goal to be achieved as stated at the scoping stage is to provide a full range of quality winter experiences

offered in appropriate settings and having no significant adverse impacts on park values. This purpose is represented by the desired condition shown on page

3 of the DEIS. The underlying need (§1502.13) is defined by the existing conditions expressed on page 4, with detailed expansion in Chapter III, Affected

Environment. Despite the complexities introduced by multiple goals and multiple issues, the alternatives in Chapter II represent possible actions that meet the

underlying purpose and need. The range of alternatives is sensitive to the need for people, businesses and local governments to adapt to change. Most
RESPONSES U.S. Congress

I-6

REPRESENTATIVE RICK HILL, U.S. CONGRESS

alternatives do not represent wholesale, abrupt changes, and some features of some alternatives do not apply for seven or eight years. Adaptive management,

as expressed in alternative E represents a programmatic status quo, except that focused study over time may result in management changes.

The commenter states that the treatment of existing versus desired condition, and issues pertaining thereto, are peripheral. NPS and many people who

commented during the scoping process and on the DEIS disagree with this assessment of the issues.

Page 2. Re: Effects on business community and local government. See response above. This statement is a reaction to a portion of the preferred alternative.

Not all alternatives, nor pieces of preferred alternatives would impact all local businesses in all gateway communities. As a side note, NPS must be sensitive

to the effects of management on local communities. However, when there is an identified conflict between local economies and the protection of park values,

park values must be emphasized.

Page 2. Re: The Park Service’s lip service to cooperation. The premise for “cooperation” as stated in the purpose and need section is that implementing or

achieving desired conditions of a program is facilitated by both NPS and local government, communities and user groups. This cooperation is to be

distinguished from the series of statements regarding desired condition of parklands and opportunities for use of those lands. The premise for “cooperation” in

regard to the involvement of cooperating agencies in this EIS is that those agencies have the responsibility to provide data concurrent with their identified

special expertise (§1501.6 (b) and §1508.26). To state that the measure of cooperation is for NPS to select an alternative that the cooperating agencies or local

governments (and businesses) like is beyond NPS understanding of cooperation in either context.

NPS has been clear about its decision-making authority throughout the process. The cooperating agencies have concurred that the final decision lies with the

park service. CEQ Regulations do not stipulate the rationale for selecting a preferred alternative in an EIS. It stipulates that in a final EIS, a preferred

alternative must be identified. The statement of preference for one or more alternatives in a DEIS is discretionary, depending upon whether the agency has a

preference at that point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded as extremely tenuous, and it is not a factor by

which the validity of an EIS is gauged. Therefore, NPS disagrees that the document is flawed. NPS has identified the purpose and need for action, has

developed a full range of alternatives to address the need and the public’s issues, and has disclosed the effects of those alternatives all in accordance with the

CEQ regulations for an EIS.

Page 3. Re: Objection to alternative B. Under CEQ regulations, NPS is not required to justify the designation of a preferred alternative. It is required to

explain the rationale for an alternative that is eventually selected and announced in a record of decision following the publication of an FEIS.

Expressions of support and opposition relate to the decision that the commenter would like to see NPS make. The general response to such comments is that

the commenter’s opinions will be considered in making the final decision, but there is nothing in those opinions that substantively would alter the range of

alternative features to be evaluated in the Final EIS. To illustrate, if the features not supported were to be deleted from the range of alternatives then the

analysis would be left only with features that the commenter agrees with. If only the actions that are liked by the commenter remain, then there is effectively

only one alternative.

Page 3. Re: Support for Revised Alternative E. Revised Alternative E comes from cooperating agencies and the Blue Ribbon Coalition in a variety of forms.

The essentials of Revised Alternative E, all versions considered, are not significantly different from alternative E as presented in the DEIS, especially

considering the programmatic nature of the proposed action. See the matrix comparison of Revised Alternative E versus the features analyzed in the range of

alternatives. This may be found in FEIS Chapter I in the section “Alternatives Suggested During the Public Comment Period.” All alternatives in the DEIS

meet the purpose and need for action to a greater or lesser degree.
I-7

COMMENTS U.S. Congress
I-8

COMMENTS U.S. Congress
I-9

COMMENTS U.S. Congress
RESPONSES U.S. Congress

I-10

REPRESENTATIVE BRUCE VENTO AND OTHERS, U.S. CONGRESS

Page 1. Re: Concern about excessive snowmobile use relative to preservation of natural heritage. This concern is reflected in the purpose and need for action

articulated in the DEIS.

Page 2. Re. Examination of impacts, and support of snowmobile regulation. The purpose of the DEIS, and the FEIS to be published, is to evaluate the impacts

of snowmobiles and other forms of winter use and access. NPS might argue that the establishment of this use appeared to be in concert with park service

mandates and policies at the time. In retrospect, and considering the amount of use that exists today, it is more than timely for this analysis to be undertaken.

The range of choices for winter use, the impact mitigation that is available, and the disclosure of effects in the FEIS will be factored against laws, executive

orders and policies to arrive at the decision.
I-11

COMMENTS Federal Agencies
I-19

COMMENTS Federal Agencies
I-20

COMMENTS Federal Agencies
I-21

COMMENTS Federal Agencies
RESPONSES Federal Agencies

I-22

U.S. EPA

Page 1. Re: Limiting off-trail nonmotorized or OHV use. Impacts analyzed in the DEIS will be indexed to road segments and vehicle-miles traveled on those

segments, assuming there is a cause-effect relationship that can be demonstrated in that fashion. Natural sound and air quality are two resources for which the

relationship exists; further modeling is being done in both areas. Given a demonstrated impact for certain alternatives, mitigation will be applied in the form

of interim recreation limits – pending the completion of capacity studies that are features of all alternatives.

Page 1. Re: Significant environmental and human health impacts. Identified, immediate human health impacts clearly call for corrective action on the part of a

park superintendent. This can be accomplished without any additional analysis. Cumulative impacts or impacts that take a long time to develop must be

addressed in this and any programmatic plan. In terms of environmental impacts, NPS seeks through this analysis to determine the magnitude, extent, and

duration of impacts and assess whether or not they are adverse in light of park mandates. NPS views this comment as an affirmation that levels of impact can

be constrained by setting limits in alternatives, and further that NPS has the authority to implement such limits for the protection of park values and resources.

Page 2. Re: Compliance with NAAQS in CO. Please see previous response, “Limiting off-trail nonmotorized or OHV use.” This analysis will focus impacts

by alternative more in terms of location and intensity, compared to that in the DEIS. It will allow NPS to display where and under what circumstances the risk

of violating standards exists. For two alternatives, B and E, this will put more of a perspective on adaptive management, and for all alternatives mitigation

needs become clearer. With mitigation, including interim limits on vehicle numbers, the range of alternatives will overall appear more viable.

Page 2. Re: Section 169(A)(a)(1) of the Clean Air Act. Comment affirms NPS assertion, as part of the purpose and need for action, that it has an affirmative

responsibility to protect air quality related values in national parks. Apart from the issue of air quality standards, which both EPA and the States play a role in,

air quality is a park value that must be managed and protected.

Page 2. Re: Protection of Class I air quality. NPS agrees that if a use is determined to violate state or federal standards or impair resource values, NPS must

act.

Page 2. Adaptive management procedures and monitoring as they apply to various alternatives will be defined better in the FEIS. NPS intends that sufficient

detail will be included to allow for the articulation of related needs in the eventual decision document.

Page 2. Re: Adaptive management and costly NEPA process. Since the EIS and plan are programmatic in nature, implementation is likely to involve further

NEPA. It should be noted that short-term measures for addressing impacts are available to NPS under its regulations (e.g. 36 CFR 1.5 and 2.18), using

minimal NEPA. Longer-term measures such as setting carrying capacities will require more extensive analysis and public involvement. To address impacts

that may occur before capacities can be determined, interim limits on use will be considered as mitigation.

Page 2. Re: Alternatives A-F not compliant with EO 11644. Using a more comprehensive analysis of effects, as indicated in earlier responses, an appropriate

basis for mitigating alternatives’ impacts will be evident in the FEIS. Mitigation choices will be available for the decision-maker to resolve possible

noncompliance with mandates and executive orders. Since alternative G appears to meet such needs based on the DEIS effects analysis, it represents a target

for designing mitigation in other alternatives.

Page 3. Re: EO. As stated in earlier responses, corrective (mitigation) measures will be applied within the range of alternatives – predicated on impact levels

associated with alternative G. Such measures will be facilitated by additional data and analysis to be disclosed in the FEIS.

Page 3. Re: Last paragraph. NPS welcomes further coordination with EPA.

Page 4. Re: Impacts identified from current OHV emissions. Interim carrying capacities and other identified mitigation measures will be available as choices

for the decision-maker to address this need.
RESPONSES Federal Agencies

I-23

U.S. EPA

Page 4. Re: Adaptive management. NPS appreciates the guidance on improving the EIS relative to adaptive management. NPS will provide more detail on

the process as it applies to two alternatives. The FEIS will address decision points, public involvement, NEPA applications, and potential management

actions. Adaptive management offers a programmatic process for management to address issues in the absence of absolute site-specific data and hard

thresholds. It is also a process that could be used to develop thresholds. This will be explained in the FEIS.

Re: EPA’s suggestion that thresholds should be set in the EIS. The EIS conforms to CEQ regulations that require disclosure of the magnitude, extent and

duration of direct, indirect and cumulative impacts. Though the setting of standards or thresholds of impact might be desirable, they might also be regarded as

arbitrary without a far more exhaustive analysis. Some thresholds are imposed through limitations on sound or pollution emissions as a feature of an

alternative. With reduced impacts in such alternatives, coupled with mitigation, it is reasonable to conclude generally (programmatically) whether or not an

impact would be beneficial, adverse, unmeasureable, negligible, minor, or major. These disclosures set the stage for a decision-maker to judge the impact in

light of mandates, executive orders, regulations and policies. In other words, it is left to the decision to find the significance of impacts –in context and

intensity – in the absence of hard standards and incontrovertible data.

Page 4. Re: Adaptive management, Point 4.There is no mechanism whereby the FEIS can make such assurances. Costs accrue to each alternative in the range

– and all are available for consideration of the decision maker. A decision could be based in part on cost, subject to the judgement that funds would not be

available for implementation. This would need to be explained in the rationale. On the other hand, a programmatic decision can provide the basis for future

funding requests – it is not practical to assure that funding is available for programs that will take place over the next 5 to 15 years.

Page 5. Re: Water quality. NPS has additional information available for the FEIS relating to snowpacks, water quality and aquatic resources. Needs for

additional monitoring programs or studies will be indicated.
I-24

COMMENTS American Indian Tribes
I-25

COMMENTS American Indian Tribes
RESPONSES American Indian Tribes

I-26

THE CONFEDERATED SALISH AND KOOTENAI TRIBES OF THE FLATHEAD NATION

Page 1. Re: Flawed consultation process. The National Park Service is committed to recognizing the past and present existence of American Indians in the

region and the traces of their use as an important part of the cultural environment to be preserved and interpreted. Throughout the planning process the

National Park Service invited American Indian tribes traditionally affiliated with the greater Yellowstone area (Blackfeet, Crow, Nez Perce, Northern

Arapahoe, Northern Cheyenne, Confederated Salish and Kootenai, Shoshone-Bannock, Shoshone-Eastern Band, Assiniboine & Sioux, Cheyenne River Sioux,

Crow Creek Sioux, Flandreau Santee Sioux, Gros Ventre & Assiniboine, Kiowa Tribe of Oklahoma, Lower Brule Sioux, Oglala Sioux, Rosebud Sioux,

Sisseton-Wahpeton Sioux, Spirit Lake Sioux, Standing Rock Sioux, and the Yankton Sioux) to consult, as well as to participate in a general tribal consultation

meetings. One such meeting was held at Yellowstone National Park on May 20, 1999, during which the Winter Use Plan/Environmental Impact Statement

was discussed. Winter use was discussed at prior meetings, and at a subsequent meeting on April 26, 2000. The National Park Service will continue to

consult with representatives of affiliated tribes as actions resulting from this plan are implemented, to insure that their interests and concerns are adequately

addressed, as well as to develop and accomplish its future programs in a way that respects the beliefs, traditions, and other cultural values of the American

Indian tribes who have ancestral ties to the area.

Page 1. Re: Increasing winter use is not consistent with NPS goals and mandates. There has been no legal finding through environmental analysis that

motorized use adversely impacts park resources. The DEIS expresses the need to deal with the impacts of winter use, including motorized access, while

continuing to provide opportunities in accordance with NPS mandates. Alternatives developed to meet this need all address issues regarding winter use. Over

time, they are all intended to find a level of use (recreation capacity) consistent with resource needs and other visitors. If the variety of winter uses are found

to have unacceptable impacts, management actions will be undertaken to eliminate or mitigate them. The FEIS will provide greater detail on the amounts of

motorized use that might result from each alternative, as well as any needed mitigation.

Page 2. Re: Bison. The fundamental purpose of an EIS is to disclose impacts of a proposed action and alternatives to it. The possible impacts on bison for

each alternative are disclosed in the DEIS.

Page 2. Re: Moose and other ungulates. The impacts on moose and other ungulates are disclosed in the DEIS. The possible impacts on wildlife expressed in

the Final EIS will be considered before a final decision is made.

Page 2. Re: Proposed road plowing. NPS is required to evaluate the impacts of existing winter recreation use on park resources. NPS cannot do this and

eliminate the concept of plowing from the EIS.

Page 2. Re: Canada lynx and wolverines. The impacts of winter use on lynx and wolverines are evaluated using the best available data for the park units.

Note that for a programmatic EIS and plan, information does not need to be exhaustive nor reported in voluminous detail. Where additional information may

be needed subsequent to the decision process, NPS will indicate a need for monitoring or programmed study.

Page 2. Re: Use and wildlife impacts. These impacts are reflected in the DEIS, pages 165-70, and in each subsequent alternative analysis.

Page 2. Re: Night use and wildlife impacts. Prohibition of snowmobile use during late night hours, from 11 P.M. to 5 A.M. and from sunset to sunrise, are

features of various alternatives in the DEIS. These choices will be available to the decision maker through alternatives in the FEIS.

Page 2. Re: Number of users and use. Implementation of a recreation carrying capacity study is a requirement that would apply to all alternatives (page 23 in

the DEIS). The FEIS will provide mitigation in some alternatives in the form of interim limits on motorized use.

Page 2. Re: Mass transit opportunities. Alternative G would increase mass-transit opportunities, as would alternative B using the plowed road access from

West Yellowstone to Old Faithful.

Page 3. Re: Emission impacts on air quality. The direct, indirect and cumulative impacts of snowmobile emissions are disclosed in the DEIS by alternative.

These analyses will be updated in the FEIS due to the completion of additional studies since the DEIS was published.

Page 3. Re: Impact of emissions on air quality and food and medicinal plants as cultural resources. As stated in the discussion of air quality monitoring on

page 109, “[a]ir pollutants (primarily from nitrogen and sulfur) may be deposited on terrestrial and aquatic resources through rain, snow, cloudwater, dryfall

and gases and may affect resources such as vegetation and water chemistry.” While the visible impacts (haze and odor) of snowmobile emissions upon air
RESPONSES American Indian Tribes

I-27

THE CONFEDERATED SALISH AND KOOTENAI TRIBES OF THE FLATHEAD NATION

quality are usually short-term, depending upon the location and such environmental factors as wind, the long-term impacts of air pollutants on the environment

and human health are less well known. Studies are underway to ascertain and understand such long-term impacts. The studies will help identify the long-term

impacts of air pollutants on the parks’ resources, such as vegetation, and provide insight into how the traditional use of such resources by American Indians

would also be impacted The DEIS dismisses impacts on vegetation on pages 81-82. NPS will consider this issue further and provide adequate discussion in

the FEIS.

Page 3. Re: Continued study of winter use impacts. As a result of the FEIS and the decision, additional monitoring, adaptive management procedures (if

selected), and research needs will be identified.

Page 3. Re: Inadequate range of alternatives. “The primary purpose of an environmental impact statement is to serve as an action-forcing devise to insure that

the policies and goals defined in the Act [NEPA] are infused into the ongoing programs and actions of the Federal Government (§1502.1).” “The range of

alternatives discussed in an [EIS] shall encompass those to be considered by the ultimate agency decision maker (§1502.2 (e)).” The purpose and need for

action described in the DEIS is sufficiently broad to act as an action forcing tool. It is within the discretion of the decision maker to set the scope of analysis.

Considering that motorized use in the Parks is an existing use, not a proposed use, it is logical to frame the purpose and need in terms that would include that

use and facilitate an incremental investigation of the impacts of that use. To do otherwise would result in a narrow scope of analysis. The settlement

agreement that resulted in a need to develop this EIS requires a comprehensive evaluation of winter recreation use – the presumption that only nonmotorized

use should be considered in light of policy, law, regulation and existing use, is not appropriate.

NPS takes this opportunity to further address the complexity of alternative formulation in this effort. Many suggestions for alternatives or alternative features

were made in the thousands of comments received. A great deal of criticism was leveled at the current range of alternatives because people did not like the

way features were “mixed.” At the same time, many people focused on features of alternatives that they liked, and features to which they were opposed. It is

clear that for such complex issues there could be an infinite number of possible alternatives. CEQ states that in such instances, the agency need only consider

a reasonable number of examples that cover the full spectrum of possible alternatives that meet the purpose and need (Question 1b, CEQ 40 Most-Asked

Questions). What constitutes a reasonable range depends on the nature of the proposal and the facts in each case, where the proposal is at the discretion of the

agency.

The final selected alternative that is to be documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS. Such

mixing can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside the range of

alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the record of decision, along with the

rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail. This material needs to be explained in a new

FEIS section on the decision to be made.
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Page 1. Re: NPS Policy. NPS has been clear about its decision-making authority throughout the process. The cooperating agencies have concurred that the

final decision lies with the park service. CEQ Regulations do not stipulate the rationale for selecting a preferred alternative in an EIS. It stipulates that in a

final EIS, a preferred alternative must be identified. The statement of preference for one or more alternatives in a DEIS is discretionary, depending upon

whether the agency has a preference at that point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded by the public as

extremely tenuous. This is because an EIS is to serve as a means of assessing impacts of proposed agency actions “rather than justifying decisions already

made” (§1502.2(g)). The FEIS preferred alternative may be viewed more as a “precursor” decision, which will only become final in a Record of Decision that

expresses the rationale for the choice. In any case, it is clear that merely the expression of a preferred alternative, by itself, does not invalidate the EIS analysis.

The decision-maker can select any of the options provided in a Final EIS by weighing the effects analysis alongside law, policy and regulation.

Page 1. Re: Visitor use and access. Alternative B responds to issues and resource needs associated with the current management situation. As with the other

alternatives, there are consequences associated with it that are disclosed in the EIS. Other alternatives in the EIS provide for continued snowmobile access from

West Yellowstone. All alternatives remain available in the range of choices for the final decision.

Page 2. Re: Eliminating snowmobile access at West Yellowstone. As with the other alternatives, there are consequences associated with it that are disclosed in

the EIS. This alternative will remain in the range of choices available to the decision maker.

Page 2. Re: Plowing displacing snowmobilers to the North, South, or East Entrances. On the one hand, cooperating agencies have expressed the notion that

some alternative features, e.g. plowing the road from West Yellowstone, will devastate local communities because snowmobilers will no longer come. On the

other hand, they express the notion that snowmobiles will be displaced to adjacent lands outside the national parks. These notions are inconsistent. In

responding to legitimate concerns about both topics – economic impacts and impacts on adjacent lands – NPS will develop scenarios of how management

changes might affect use. NPS wishes to note that this is an exercise covered in CEQ regulations (§1502.22(b)(4)), wherein a theoretical approach may be

taken to evaluate impacts that are reasonably foreseeable.

Page 2. Re: Potential increased daily visitation to Old Faithful under alternative B. Commenter is concerned about devastating the local economy (at West

Yellowstone), yet implies that day use originating from West Yellowstone will overrun Old Faithful. In alternative B, NPS illustrates that plowing the road

from West Yellowstone to Old Faithful can provide opportunities for the same number of people that presently use the route using snowmobile and snowcoach

access. This is evaluated in the DEIS on pages 217-218, partly in response to the pre-DEIS issue that plowing the road could not allow access for the current

number of visitors.

Pages 2-3. Re: Visitor experience impacts under alternative B. The DEIS discloses the visitor experience and access impacts of alternative B, pages 217-223.

Page 3. Re: Air quality under alternative B. Industry has not been highly responsive to the environmental issues relating to 2-stroke engines. NPS feels it is

possible for industry to develop and implement suitable technology for cleaner and quieter machines, especially if it has 8 or 9 years to do it. EPA and NPS are

concerned about allowing this amount of time for snowmobiles to operate and continue producing at pollution current levels. The use of less polluting fuels

and oils is a feature of several alternatives. Pre-paid passes have been implemented as an interim measure to protect the health of park employees and visitors

at the gate. However, not all people avail themselves of this service, and much is given up in the way of necessary visitor contacts when people use the service.

Page 3. Re: The EPA is currently developing emission standards for all off-road engines, including snowmobiles. EPA indicates that NPS should proceed

with alternative features that are designed to improve air quality to the extent that it is expected in national parks. EPA notes that it is within NPS authority to

manage air resources, and that in fact NPS has the affirmative responsibility to do so under the Clean Air Act.

Page 3. Re: Sound. Sound that is emitted by current snowmachines is an issue, in terms of its impacts on the natural soundscape and on other visitors. Clearly,

one alternative to the current situation is to reduce the allowable sound produced by snowmachines. Industry plays a role in that it is technologically possible to

reduce snowmobile sound.

Page 3. Re: Sound analysis. NPS will improve its analysis of sound for the FEIS, including sounds emitted by other forms of transport.

Page 3. Re: Additional moguling makes a trail more difficult to travel and poses an increased risk for snowmobile accidents. Changes in use will be evaluated
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more thoroughly in the FEIS, by virtue of a reasonably foreseeable impact analysis for each alternative.

Pages 3-4. Re: Safety concerns about the plowed road section in alternative B. NPS is aware of inherent risks associated with winter driving either on plowed

or groomed routes. This rationale would apply to every road or groomed route in the GYA. Safety concerns and potential impacts of alternative B are

discussed on page 203 of the DEIS. There would be sections having relatively high berms, but in our judgment there would be no significant difference from a

visual and safety standpoint between this road segment and the road between Colter Bay and Flagg Ranch or other plowed roads in the GYA. Plowing the road

will not increase “serious disease issues” associated with bison. In alternative B, most new or “nontraditional” users of a plowed route would access Old

Faithful by mass transit vehicle, not by personal transportation.

Page 4. Re: Economic impact. Economic analysis is being updated for the FEIS, including the use of the economic impact model for the 5-county area

surrounding the parks, as requested by the cooperating agencies.

Page 4. Re: Plowing and sanding costs. The cost of all alternatives, relative to the cost of current management was disclosed in the DEIS, Appendix F.

Page 4. Re: Impacts of alternative B on wildlife. The effects of Alternative B, including impacts of plowed and groomed surfaces on wildlife, are disclosed in

the DEIS pages 208-214.

Page 4. Re: Impacts of sanding road surfaces. Sand removal for this purpose is a standard practice for routes that are plowed.

Page 4. Re: Adaptive management. Adaptive management is an alternative feature that will be in the range of choices for the decision maker. Commenter’s

note that plans must be adaptable for changing conditions is correct. That is in part why NPS engaged in an EIS process to produce a “programmatic” plan,

rather than a project level, site-specific plan. The decision maker will consider all FEIS alternatives and their effects on local economies, visitor experience,

and natural resources before making a decision. The consideration of these factors, and the rationale for selecting an alternative will be explained in the record

of decision.
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Page 1. Re: Introduction and background. The NPS disagrees that there is a “lack of a clear management relationship between the GYA and the parks in the

DEIS. The desired conditions for winter use described in the DEIS, for the three national park units closely follow the winter use goals as outlined in the Winter

Visitor Use Management: A Multi Agency Assessment (GYCC 1999 p.2). Because the scope of the DEIS is park specific and does not include the entire Greater

Yellowstone Area (GYA), the desired conditions identified in that document should reflect that change in scope. In addition, the DEIS (as required by NEPA)

underwent a separate specific scoping effort which identified issues and concerns specific to the 3 park units. It should also be noted that while the Winter

Visitor Use Management: A Multi Agency Assessment (GYCC 1999) provides useful information and direction on winter use in the GYA, it is not a decision

document and no NEPA analysis was performed. Despite the differences inherent in the two processes the DEIS presents a very clear relationship between

parks and surrounding lands. The national forests of the Greater Yellowstone Area; the states of Montana, Idaho and Wyoming; and the five counties

surrounding the 3 parks have been granted cooperating agency status. The cooperating agencies have participated in formulating the alternatives (see Appendix

A, Volume II of the DEIS) and have provided an analysis of the effects of those alternatives on lands within their jurisdiction. That analysis can be found in the

Effects on Adjacent Lands section of the DEIS on pages 298-309. The comments were also printed in their entirety in Appendix I, Volume II of the DEIS.

These sections of the document will be updated as the national forests and other cooperating agencies further refine their analysis.

Page 1. Re: Analysis of off-road vehicles. Executive Order 11646 (as amended by EO 11989) defines off-road vehicles as “any motorized vehicle designed for

or capable of cross-country travel on or immediately over land, water, sand, snow, marsh, swampland or other natural terrain” (see DEIS, Appendix C). The

effects of snowmobile and snowcoach use on the travel corridors of the parks are disclosed for all alternatives including the no action alternative in Chapter 4

Environmental Consequences of the DEIS. The effects of other off-road wheeled vehicles, (as defined by EO 11646), were not analyzed in the DEIS because

regulations require that in national parks off-road vehicles must operate only on routes specifically designated for their use. Except for snowmobiles, no such

designations exist in the 3 park units (36 CFR 4.10).

Page 2. Re: Preferred alternative. An EIS is not, per se, a scientific analysis. It is intended to disclose environmental effects over a range of alternatives, in

which the analyses must demonstrate scientific integrity by disclosing methods and making explicit references to sources used (40 CFR 1502.24). The DEIS

does this. CEQ regulations also allow for incomplete or unavailable information, by describing procedures that are to be followed in these instances

(§1502.22). Any identified gaps in the FEIS will follow the requisite procedures. Also, there is no requirement in CEQ regulations (§1502.14) to justify a

preferred alternative, just to name one or more alternatives as preferred in the DEIS if there is a preference. The agency must express a preferred alternative in a

Final EIS. The effects of the alternatives on park values such as air quality, natural soundscapes, and visitor experience have been analyzed in the DEIS on

pages 157–327.

Page 2 Re: Page 7, Facility Issues. The scope of the Winter Use Plan DEIS for Yellowstone and Grand Teton National Parks and the John D. Rockefeller, Jr.,

Memorial Parkway is limited to an examination of a range of alternatives and the associated impacts of winter visitor use (see §1500.4). Activities that occur in

the summer, are outside the scope of the DEIS except where their impacts are additive to those occurring in the winter. The effects of those types of actions are

considered cumulative (§1508.25(c)) and are disclosed in the DEIS on pages 319-327.

Page 2 Re: Desired conditions. The reference to snowmobile sound and emission levels on page 4 is a typographical error. The bullet should read “Oversnow

vehicle sound and emission levels are reduced to protect public and employee health and safety, enhance visitor experience and protect natural resources.”

Page 2 Re: Page 4, Existing conditions. Visitors to the national parks generally come because they are seeking a certain type of experience. Because the basis

of any visitor experience is empirical a visitors comment on that experience is often expressed as an opinion.

Page 2. Re: Desired condition. The statements outlined under the Desired Condition heading of the DEIS are described as issues and concerns that are

unresolved, that is, there is some contention as to whether the concern is valid or not. Alternatives were formulated in order to provide clear definition of these

issues. The effects of these alternatives and the degree to which they achieve the desired condition are assessed in the environmental consequences section of

the DEIS. It is appropriate to express these unresolved issues or areas of disagreement, (including professional opinion) as a facet of the existing condition.

Indeed, these areas of disagreement are one of the primary indicators that a comparative analysis is required in order to meet the desired condition. This will be

clarified in the FEIS.
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Page 2. Re: Concern for groomed road access. As noted in the DEIS several surveys have indicated that existing winter users expressed strong support for

maintaining groomed trails in the parks. The State of Montana also notes correctly that users responding to this survey are not the only indicators for meeting

the desired condition that should be used. Under the no action alternative approximately 184 miles of road are groomed. Under alternative B (preferred

alternative) 154 miles of road would be groomed, a reduction of 15%. The NPS disagrees that the concern for groomed road surfaces is not addressed or is

contradictory to the preferred alternative.

Page 2. Re: Sewage treatment capacity. Recently Yellowstone has completed an environmental assessment on a sewage treatment facility at Old Faithful.

Because these facility issues are site-specific year round concerns they are typically addressed in separate implementation level environmental assessments (see

1508.18(B).

Page 3. Re: State of Montana’s special expertise. The text describing the special expertise of the State of Montana will be edited to include air and water

quality.

Page 3. Alternative B would provide for visitor access from West Entrance to Old Faithful via mass transit shuttle busses, which would reduce the number of

vehicle miles traveled from West Yellowstone by nearly 80 % (see DEIS page 202). Because the transit system would be operating under permit from the NPS

these busses can be required to fuel their vehicles outside the park if a fuel shortage should arise in the park. The same is true for alternative G. Efforts were

made in each alternative to rely on surrounding gateway communities for support services.

Page 3. Re: Air quality. This section will be clarified in the FEIS.

Page 3. Re: Air quality. This section will be clarified in the FEIS.

Page 3. Re: Air quality. Additional air quality modeling for CO for all alternatives will be included in the FEIS.

Page 3. A clarification as to the cause of bison removals will be made in the FEIS.

Page 4. Re: Summer/Winter use comparisons. The scope of the Winter Use Plan DEIS for Yellowstone and Grand Teton National Parks and the John D.

Rockefeller, Jr., Memorial Parkway is limited to an examination of a range of alternatives and the associated impacts of winter visitor use (see §1500.4).

Activities that occur in the summer, are outside the scope of the DEIS except where their impacts are additive to those occurring in the winter. The effects of

those types of actions are considered cumulative (§1508.25(c)) and are disclosed in the DEIS on pages 319-327.

A description of winter facilities is provided on page 140-141. CEQ regulations encourage the authors of NEPA documents to reduce excessive paperwork by

emphasizing portions of the environmental impact statement that are useful to decision makers and the public and reducing emphasis on background material

(See § 1500.4 (f)). It is unclear from the comment how an additional discussion of changes in fees and changes to summer travel corridors (other than that

provided in the introduction and affected environment) would further define a winter use issue, help to clarify the analysis or provide useful information to the

decision maker.

Page 4 Re: EIS process. Recently Yellowstone has completed an environmental assessment on a sewage treatment facility at Old Faithful. Because these

facility issues are site-specific year round concerns they are typically addressed in separate implementation level environmental assessments (see 1508.18(B).

Page 4. Re: Scope of the plan and EIS. The stated purpose and need for action defines the desired conditions for winter use for the 3 park units. The scope of

the winter use planning effort identified in the DEIS was limited for practical reasons to the 3 park units. Since the alternatives are formulated to respond to the

purpose and need, they necessarily exclude those lands outside the jurisdiction of the NPS (§1502.14(c). Although CEQ regulations allow an agency to

consider an alternative that includes actions outside its jurisdiction this was considered to be impractical, in this case, for the following reasons. In response to a

lawsuit filed by The Fund For Animals and others in 1997 the NPS agreed to prepare a comprehensive EIS, pursuant to NEPA, addressing a full range of

alternatives for all types of winter visitor use, including snowmobiling and trail grooming, in the parks and considering the effects of those alternatives on the

parks’ environments. The agreement also specified a completion date of the FEIS ofSeptember 1, 2000. In order to provide meaningful analysis for the public

and decision-makers within the agreed upon timeframe it was essential that the scope of the document be limited to the specifications of the settlement

agreement.
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Page 4. Re: Management zones. The management prescriptions describe the potential range of desired resource conditions and visitor experiences. These

prescriptions are not comparative, that is they are not intended to define the differences between existing and desired conditions. They are intended to describe

the desired condition for that zone. Therefore, to describe air quality as good to excellent is appropriate. In response to your comment these terms will be

further defined in the FEIS. In addition to the park’s responsibilities under the Clean Air Act, clean air is a park value that is highly regarded by park visitors.

It would not be appropriate to identify a parameter of “the maximum allowed by law (approaching exceeding NAAQS standards)” as the desired condition for

any zone within the parks.

Page 4. Re: Management zones. Please see the previous response. The management zone describes the parameters that will guide the future management for

that zone. The purpose of the management zones is to ensure a diversity of appropriate visitor experiences and to help set up carrying capacity decisions. If, as

you suggest, park visitors along these roadways are exposed to a high level of bus exhaust, the NPS agrees that the park visitor may not experience a “sense of

being in a natural environment”. Consequently, park mangers might pursue visitor management actions (i.e. park passes, reservations, use limits etc.) to ensure

that the identified desired resource conditions for those zones are met. The purpose of the management prescriptions will be further clarified in the FEIS and a

description of carrying capacity studies will be incorporated.

Page 5. Re: Scientific studies and monitoring. Published studies and monitoring reports should as a matter of course be available to the public. For obvious

reasons, this information should not be subjected to a political process in advance of their publication. There are policies and protocols already in place to

ensure appropriate scientific review. If future studies or monitoring indicate the need for management action, NPS will follow the requirements already set in

law (such as NEPA), regulation and policy. At that time, the scientific basis for an action can be scrutinized and criticized by any interested parties.

Page 5. The standards for visitor experience and resource condition for each zone described in each alternative are outlined on Table 2 in the DEIS. On page 25

of the DEIS under Actions and Assumptions Common to all Alternatives the text states that further studies will be necessary to set indicators and further define

the standards for achieving the desired visitor experience and resource condition and that if necessary the parks will implement techniques such as reservations,

permits and differential fees. This process will be further clarified in the FEIS. (The State of Montana has not been sent a protocol for determining indicators

and carrying capacities for the 3 parks because it has not yet been developed.)

Page 5. Re: Cooperating agencies and review of modeling and other information. The NPS disagrees that the State of Montana has not received data, and other

information relating to the proposed action and its alternatives in the DEIS. The planning record will show that studies that have been prepared by the NPS for

the DEIS and that relate to the cooperating agencies areas of expertise were sent to each of the cooperating agencies for their review. In some cases the NPS

funded state designated peer reviewers to review the models and surveys utilized in the analysis.

Page 5. Re: EPA emission standards. The suggestion to use EPA standards for vehicles entering the park in alternative G will be incorporated into the

alternative. The suggestion to utilize the EPA method of emission testing (mass of pollutant per unit of power) under alternative G has merit. The alternative

feature will be edited in the FEIS. Peak day information will be included in the environmental consequences section for alternative G in the FEIS.

Page 5. Re: Numbers of snowcoaches. This clarification will be added to the description of the environmental consequences of this alternative

Page 5-6. Re: Rationale for the preferred alternative. The preferred alternative is not a decision but is the agency’s preferred course of action at the time a draft

or final EIS is released. The purpose of identifying the preferred alternative is so that agencies and the public can understand the lead agency’s orientation

(§1502.14(e)).

Page 6. Re: Public access to the parks. The preferred alternative identified in the DEIS does not ignore the “overwhelming public preference on access to the

park” and at the time of the writing of the DEIS appeared to be the most responsive to the criteria stated on page 38-39. All roads identified as open to

motorized travel under the no-action alternative are open under the preferred alternative. The preferred alternative also adds an additional 6 miles of motorized

access and 10 miles of groomed non-motorized access. The preferred alternative identifies 154 miles of groomed snow road, only 30 miles less than the noaction alternative. As identified on page 218 capacity levels at the Old Faithful area would remain the same as in no action. The preferred alternative adds the

ability to access Old Faithful via a plowed road, as well as via an oversnow road, thus increasing opportunities for different types of access. Partly in response
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to the overall non-support of plowing this section of road, the NPS expresses a new preferred alternative in the FEIS which allows for oversnow access

throughout the park by snowcoach.

Page 6. Re: Mandated topics. §1502.16(e) requires that an EIS include a discussion of the energy requirements and the conservation potential of various

alternatives and mitigation proposals. The NPS is unaware of a mandate that does not allow the decision-maker to select an alternative that uses more energy

than the no-action alternative. Alternative B proposes mass transit on the road sections from West Entrance to Old Faithful. These sections currently receive

the most use during the winter. Given current use this alternative reduces the number of vehicle miles traveled by a factor of 8, it is unclear how alternative B

would increase the amount of energy used over alternative A. The NPS will review the commenters concerns that energy consumption would be substantially

greater under one alternative than another and will make appropriate changes to the FEIS.

Page 6. The dispersal of exotic species is a problem that accrues to year-round use in the national parks. On the whole, the portion of this problem to be

attributed to winter use is very small – considering that the major dispersal agent is the use of horses from park trailheads and trailheads on adjacent public

lands. The Park Service’s judgment is that this is not a significant issue worthy of study in this EIS.

Page 7-8. Re: Regional economy. The information provided will be considered in revising the economic assessment.

Re: Recreation sector and park visitors. The information provided will be considered in revising the economic assessment.

Re: Nonmarket values. Editorial changes regarding nonmarket values will be made in the FEIS

Re: Air quality and public health. Editorial changes will be made to clarify the issues of ambient air quality standards and personal exposure levels value in the

FEIS

Page 9 Re: Air quality and public health. Editorial changes will be made that describe snowcoach emissions in the FEIS.

Page 9 Re: Air quality and public health. Editorial changes will be made that clarify the methods used for measuring ambient air quality standards on Montana.

Page 9 Re: Air quality and public health. Editorial changes will be made that clarify the methods used for measuring ambient air quality standards on Montana.

Clarification will be made in the DEIS

Page 9 Re: Air quality and public health. Editorial changes will be made that clarify the air quality analysis. Additional work is being accomplished on air

quality and public health and appropriate changes will be incorporated into the FEIS.

Pages 9-11. Re: Air quality and public health. Additional work is being accomplished on air quality and public health and appropriate changes will be

incorporated into the FEIS.

Page 11. Re: Public Safety. NPS acknowledges that snowmobile traffic sharing a road surface with wheeled vehicles is a potentially hazardous situation. Your

comment does not indicate how alternative B would cause this problem to increase. The NPS will review and if appropriate disclose this effect in the adjacent

lands section of the FEIS.

Page 11. Re: Air quality and public health. The text of the FEIS will be edited to reflect the additional source of pollutants.

Page 11-12. Re: Air quality. Additional work is being accomplished on air quality and appropriate changes will be incorporated into the FEIS.

Page 12 Re: Bison. The FEIS will include additional information on the brucellosis issue. The term “perceived risk” was removed.

Page 13 Re: Comment noted. A correction will be made in the FEIS.

Page 13 Re: Bison management actions. Comment will be incorporated in the FEIS.

Page 13. Re: Untested Meagher theory. The bison analysis will be reviewed and updated as necessary. In an effort to better understand the relationship of

bison movements and the use of the winter groomed road system, managers have instituted studies that address this issue. While groomed roads may have

contributed to the redistribution of bison within park boundaries (Meagher 1997), it appears that bison tend to use waterways and off-road trails for much of

their travel on the west side of the park (Bjornlie and Garrott 1998), and that much of their movement toward park boundaries may occur on such routes.

Monitoring of bison movements in the Hayden Valley and Mammoth to Gibbon Falls sections of the park has found that less than 12% of bison movements

occurred on the groomed road surface (Kurz et al. 1998, 1999). However, groomed roads may have allowed larger numbers of bison to exist in the park than in

the absence of groomed roads, by allowing access to otherwise unavailable foraging areas, and westward redistribution early in the winter may predispose some
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bison to exit the park (Meagher 1997). Therefore closing of groomed roads could have the effect of reducing population size and shifting distribution back to

patterns observed before grooming, thereby possibly reducing the magnitude of bison movements outside park boundaries. Conversely, bison are highly social

and appear to retain and pass along knowledge through generations (Meagher 1985), so it is possible that closing groomed roads may not impact bison

movements and distribution. Research is currently being conducted to better understand the relationship between road grooming and bison movement and

distribution patterns.

Page 13. Re: NAS Review of Brucellosis. Comment noted. Reference to the NAS report will be made in the FEIS.

Page 13. Re: Aune 1981. Aune’s work is cited in Chapter 4 “Environmental Consequences” Much of his work did demonstrate that recreation impacts

wildlife.

Page 14. Citation from Aune will be incorporated into the FEIS.

Page 14. A correction will be made in the FEIS regarding lynx distribution.

Page 14-15. Re: Assumptions and methods. Additional work is being accomplished on air quality and appropriate changes will be incorporated into the FEIS.

Page 15. Re: West Entrance relocation. This suggestion will be incorporated as a mitigation measure into alternative E.

Page 16. Re: Public Safety Assumptions and Methodologies. The effect on visitor safety of different types of winter users, primarily skiers and snowmobilers

sharing the same road surface was identified during public scoping. The identified concern is a result of the great difference in the rate of speed of these

different user groups: one slow and one fast. If you separate two user groups you will eliminate the danger that a collision between them will occur. The

assumption stated on page 162 is valid.

Page 16. Re: Public Safety Assumptions and Methodologies. This assumption has not been utilized to indicate a level of effect in the preferred alternative. The

effects of an increase in winter use on lands outside the 3 park units are discussed on pages 298-315. The USFS is revising the analysis of winter visitor

displacement and that information will be incorporated into the FEIS.

Page 16 Re: MTBE. Additional work is being accomplished on water resources and appropriate changes will be incorporated into the FEIS.

Page 16 Re: Nitrate. Additional work is being accomplished on water resources and appropriate changes will be incorporated into the FEIS.

Page 16 Re: EPA regulations. Additional work is being accomplished on air quality and appropriate changes will be incorporated into the FEIS.

Page 17 Re: Ethanol fuels. This feature is in the range of alternative features analyzed, and will continue to be an option for management.

Page 17 Re: Pre-paid passes. Pre-paid passes are available in West Yellowstone. Should the need arise at other gates for the same reasons, the service could be

expanded. The rationale for this measure – mitigating pollution impacts on visitors and employees – has a cost associated with it. Opportunities for necessary

NPS-visitor contact at the gate are lost. Suggesting that all visitors forego an important safety element of the park experience, so that their snowmobiles will be

less polluting is clearly not in compliance with 36CFR 2.18. The regulation states that snowmobiles are prohibited except where designated and only when

their use is consistent with the park’s natural, cultural, scenic and aesthetic values, safety considerations and will not disturb wildlife or damage park resources.

In this case, mitigating an effect on park values and resources by completely eliminating an important information and safety resource for park visitors is

illogical. Voluntary compliance with this management option is reasonable, but only for those visitors who wish to utilize it.

Page 17 Re: NAAQS violations. Additional work is being accomplished on air quality and appropriate changes will be incorporated into the FEIS.

Page 17 Re: Public Health. This information will be included in the FEIS.

Page 17 Re: Public Health. This information will be included in the FEIS

Page 17-18. Re: Water Resources. Additional work is being accomplished on water resources and appropriate changes will be incorporated into the FEIS.

Page 18 Re: Biodegradable lubricants. This feature is in the range of alternative features analyzed, and will continue to be an option for management.

Page 18-19. Re: Air Quality. Additional work is being accomplished on air quality and appropriate changes will be incorporated into the FEIS

Page 19. Re: Lynx abundance. The statement regarding lynx abundance will be revised in the FEIS.

Page 19. GYA regional economy. NPS has set the context for the decision to be made at the level of the GYA region. This is entirely appropriate – witness the

comments of all cooperating agencies that this is a regional concern, not just a community concern. Comments about the rationale for the preferred alternative
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are taken out of context, and are given too much weight; the rationale for the preferred alternative does not set the scope of analysis. NEPA (CEQ Regulations)

does not make stipulations about the rationale for selecting a preferred alternative in an EIS; in fact there is no requirement for stating the rationale in an EIS. It

stipulates that in a final EIS, a preferred alternative must be identified. The statement of preference for one or more alternatives in a draft EIS is discretionary,

depending upon whether the agency has a preference at that point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded by

the public as extremely tenuous. This is because an EIS is to serve as a means of assessing impacts of proposed agency actions “rather than justifying decisions

already made” (§1502.2(g)). The FEIS preferred alternative may be viewed more as a “precursor” decision, which will only become final in a Record of

Decision that expresses the rationale for the choice. In any case, it is clear that merely the expression of a preferred alternative, by itself, can in no way

invalidate the entire EIS analysis. The decision-maker can select any of the offered alternatives in a Final EIS through consideration of a variety of factors,

including but not limited to environmental impacts. The selected alternative does not have to be the most environmentally preferable alternative, which must

also be revealed in the decision document.

Page 20. Re: Alternative B’s major impact. It appears too much emphasis is placed on support or justification for a course of action or decision. See discussion

on disclosure of a preferred alternative, above. Under the CEQ regulations, the requirement in an EIS is to provide a range of reasonable alternatives that

clearly define the issues, and to fully evaluate and disclose the possible effects of those alternatives. The DEIS meets this requirement, while acknowledging

that the commenter disagrees about many of the impacts disclosed. In general, the expressions of opposition relate to the decision that the commenter would

like to see NPS make, based on myriad disagreements about the effects disclosed in the DEIS. The general response to such comments is that the commenter’s

opinions will be considered in making the final decision, but that there is nothing in those opinions that substantively would alter the range of alternative

features to be evaluated in the Final EIS. For example, if the features that are not supported were to be deleted from the range of alternatives then the analysis

would be left only with features that the commenter likes or agrees with. If only the actions that are liked by the commenter remain, then there is effectively

only one alternative. Therefore, expressions of support or objection will not be responded to, in general, by changes in alternative features – they will be

responded to when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision. People who

commented in this fashion are asked to consider that there is a very clear separation between alternatives legitimately considered in an analysis and the

expression of a preferred alternative or the decision to be made.

Page 20. In part due to the low public support for one feature of alternative B, plowing the road from West Yellowstone to Old Faithful, NPS will change its

FEIS preference to alternative G.

Pages 20-21. Re: Plowed road proposal. The commenter perceives the rationale incorrectly. The stated purpose of plowing the road (DEIS, page 28) is to

“improve affordable access” – not , as this and other commenters state, to “provide affordable access for minority and low-income people.” A thorough reading

of the EIS would reveal that a required impact topic in an EIS is to evaluate the effects of a proposed action on socially or economically disadvantaged

populations (DEIS, page 80). These populations are characterized on page 90 in the DEIS, and the effects on those populations are disclosed in the

socioeconomic section for each alternative (DEIS, pp 176, 199, 224, 245, 260, 274, 288). We disagree that this analysis is “extremely flawed”; the stated

impacts on socially or economically disadvantaged populations are not used as “justification” for plowing in alternative B. The rationale for preferring

alternative B may be found on page 39.

Page 22. Re: Public safety outside the parks. NPS is concerned about public safety outside the parks. As an example, Grand Teton National Park personnel

respond to winter accidents involving snowmobiles, et al, on Togwotee Pass. NPS asked all cooperating agencies to provide assessments of impacts on adjacent

lands and jurisdictions. These assessments are disclosed in the DEIS on pages 298-315. In particular, for Montana, this point is made on page 311. It appears

that the situation involving travel from West Yellowstone to Big Sky and Taylor Fork, and return, is hazardous regardless of any management decision by NPS.

Page 23. Re: Tunnel effect of plowed roads on bison. Pages 182 and 208-09 in the DEIS discuss the impact of snow berms on ungulates. Although the DEIS

does not use the term “tunnel effect” it does discuss the negative impact associated with snow berms along the plowed road corridor, and suggests mitigation (p.

209). NPS and the commenter disagree on whether or not a tunnel effect would result from plowing. In many other areas within and near the three park units,

roads are plowed and no tunnel effect exists.
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P. 23. Re: Mitigation measures for snow berms. Page 209 in the DEIS discusses creating turnouts in the snow berms for wildlife to exit the road corridor.

P. 23. Re: NAS report. The FEIS will incorporate the findings of the NAS report.

P. 23. Re: Effects of groomed trails on bison energetics. The bison analysis will be reviewed and updated as necessary. In an effort to better understand the

relationship of bison movements and the use of the winter groomed road system, managers have instituted studies that address this issue. While groomed roads

may have contributed to the redistribution of bison within park boundaries (Meagher 1997), it appears that bison tend to use waterways and off-road trails for

much of their travel on the west side of the park (Bjornlie and Garrott 1998), and that much of their movement toward park boundaries may occur on such

routes. Monitoring of bison movements in the Hayden Valley and Mammoth to Gibbon Falls sections of the park has found that less than 12% of bison

movements occurred on the groomed road surface (Kurz et al. 1998, 1999). However, groomed roads may have allowed larger numbers of bison to exist in the

park than in the absence of groomed roads, by allowing access to otherwise unavailable foraging areas, and westward redistribution early in the winter may

predispose some bison to exit the park (Meagher 1997). Therefore closing of groomed roads could have the effect of reducing population size and shifting

distribution back to patterns observed before grooming, thereby possibly reducing the magnitude of bison movements outside park boundaries. Conversely,

bison are highly social and appear to retain and pass along knowledge through generations (Meagher 1985), so it is possible that closing groomed roads may not

impact bison movements and distribution. Research is currently being conducted to better understand the relationship between road grooming and bison

movement and distribution patterns.

P. 23. Re: Energetic value of walking on groomed roads. If the issue is the effect of groomed surfaces on the energy balance of individual animals, as is the

intent of the DEIS discussion, then groomed surfaces by themselves allow animals to save energy. This is why they use the surfaces, and it is apparently to

their benefit. The DEIS also makes the point that recreation use of groomed surfaces contributes to stress and energy expenditures by animals. The larger issue

– given the balance of energy savings vs. energy loss – is if and to what extent these circumstances constitute an impairment of park values. The total picture –

groomed routes, type and amount of use, stressful periods for wildlife, availability of forage – needs to be considered in the final decision. The goal of natural

regulation applies to whole populations, not individuals, and must factor in the presence of people.

P. 24. Re: Bison movement from Tower to Mammoth and from 7-mile Bridge to West. The FEIS will include some of the information cited in Aune et al 1997.

P. 24. Re: Effects of nonmotorized use on ungulates. The statement regarding the effects of nonmotorized use on ungulates will be revised in the FEIS.

Page 25. Re: Effects on public health. Modeling of air quality impacts, including consideration of Montana’s estimates, will be incorporated into the FEIS.

Additional air dispersion modeling for CO for all alternatives will be included in the FEIS.

Page 25. Re: Water Resources. Additional work is being accomplished on water resources and appropriate changes will be incorporated into the FEIS.

Page 25-26. Re: Air quality. Modeling of air quality impacts, including consideration of Montana’s estimates, will be incorporated into the FEIS. Although

alternative C (as well as alternative D) proposes selling 10 percent ethanol fuel and synthetic low emissions lubricants in the park, this does not ensure that all

snowmobiles would operate on these products.

Pages 27-28. Effects on national forests were provided by USFS personnel. This section will be adjusted in accordance with USFS comments on the DEIS.

Page 29. Re: Effects on states. NPS will incorporate the suggested information into the FEIS.

Page 29. Re: Relationship between local short-term uses and long-term productivity. In order for the suggested impacts on lands far beyond park boundaries to

be assessed, it would first be necessary for the states to provide an assessment of the current impacts of snowmobiling, or other winter uses, on those lands.

NPS cannot be expected to perform this analysis without some assistance from Montana. The NPS is not aware whether such needed assessment information is

available from the state of Montana.

Page 29. In order for the suggested impacts on lands far beyond park boundaries to be disclosed, it would first be necessary for the states to provide an

assessment of the current impacts of snowmobiling, or other winter uses, on those lands. NPS cannot perform this analysis without assistance or information

from Montana. The NPS is not aware whether such needed assessment information is available from the state of Montana. NPS has the impression from this
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series of comments (i.e., short-term vs long-term, cumulative effects) that Montana, as well as lands in other states, is at or approaching a threshold of

snowmobile use. This conclusion is drawn from the implication that any changes in snowmobile use in the parks could distribute unwanted additional use to

adjacent lands and have important negative effects. It is also at odds with the suggestion that closing portions of the parks to snowmobiling would have the

negative effects on local communities – if people will still come to those communities to snowmobile and place local resources at risk. Such inconsistencies

and the unavailability of data, make it difficult to respond effectively to the comment.

Pages 30-31. Potential cumulative impacts on national forest lands are discussed on pages 326-327 of the DEIS. NPS believes the cumulative effects analysis

is sufficient to provide information for the decision to be made. Any additional input received from cooperating agencies, in accordance with their special

expertise, before the preparation of the FEIS will be incorporated into it.

P. 31. Re: Threatened and Endangered Species. Potential cumulative impacts to T&E species associated with winter recreation will be more fully discussed in

the FEIS. Again, input from cooperators is necessary for the NPS to formulate a comprehensive analysis on areas of concern outside the parks.

P. 32. Re: Species of Special Concern. Potential cumulative impacts to species of concern associated with winter recreation will be more fully discussed in the

FEIS. Again, input from cooperators is necessary for the NPS to formulate a comprehensive analysis on areas of concern outside the parks.

Page 32. Appendices. Clarifications on indicated pages will be made in the FEIS.

Attachment to letter: Montana’s Proposed Preferred Alternative. Montana’s proposal is not significantly different from alternative E as presented in the DEIS,

especially considering the programmatic nature of the proposed action. Features proposed by Montana are for the most part considered within the range of

DEIS alternatives, and will continue to be available for selection by the decision maker following publication of the FEIS. Other recommended features are

more site-specific than programmatic, or have been dismissed with rationale. See the matrix comparison of Revised Alternative E, which resembles Montana’s

alternative, versus the features analyzed in the DEIS. All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree. For any

alternative that incorporates an adaptive management process as its chief feature, the Final EIS will be modified to include more explanation of that process and

its resource focus.
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Cover letter. Re: Non-support of proposed alternative and support of proposed alternative. See the following two responses, below.

Page 1. Re: Concerns. The EIS analysis is aimed at developing a programmatic plan (§1508.18(b)(2) and (3)) for winter use. For concerns relating to gaps in

information, it should be noted that there is no burden to develop site-specific information to support a programmatic planning document. Without further

information, we are unable to address general concerns as to what is meant by inadequate science. An EIS is not, per se, a scientific analysis. It is intended to

disclose environmental effects over a range of alternatives, in which the analyses must demonstrate scientific integrity by disclosing methods and making

explicit references to sources used (40 CFR 1502.24). The DEIS does this. CEQ regulations also allow for incomplete or unavailable information, by

describing procedures that are to be following in these instances (§1502.22). Any identified gaps in the FEIS will follow the requisite procedures. Also, there

is no requirement in CEQ regulations (§1502.14) to justify a preferred alternative. The requirement is to identify one or more alternatives as preferred in the

DEIS if there is a preference. The agency must express a preferred alternative in a Final EIS.

Page 1. Re: Support for Revised Alternative E. See above response. Comments place a great deal of emphasis on support or justification for a course of action

or decision. Under the CEQ regulations, the requirement in an EIS is to provide a range of reasonable alternatives that clearly define the issues, and to fully

evaluate and disclose the possible effects of those alternatives. The DEIS meets this requirement. Comments of support or nonsupport go to the decision to be

made; they do not affect the range alternatives considered.

Page 2. Re: Revised Alternative E. Revised Alternative E comes from cooperating agencies and the Blue Ribbon Coalition in a variety of forms. The

essentials of Revised Alternative E, all versions considered, are not significantly different from alternative E as presented in the DEIS, especially considering

the programmatic nature of the proposed action. See the matrix comparison of Revised Alternative E versus the features analyzed in the range of alternatives.

All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree. For any alternative that incorporates adaptive management as its

chief feature, the Final EIS will be modified to include more explanation of that process and its resource focus.

Page 2. Re: Revised Alternative E. All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree. It is unrealistic to expect all

alternatives in an EIS to meet all desired conditions expressed in the purpose and need for action equally well. Such a set of alternatives would likely have no

significant differences among them.

Page 2. Re: Revised Alternative E. The DEIS purpose and need for action, desired condition, is explicit along these lines.

Page 4. Re: Advisory committee feature. The suggestion about the procedural aspects of an advisory committee very nearly replicates wording in DEIS

alternative E. [NOTE: commenter states that the comments from pages 3-9 in the letter express support for proposed actions. However, much of the dialogue

talks to features of alternatives that the commenter feels are not “justified”. Pages 10-19 address features that are opposed by the commenter, which to a degree

are duplicative of the opposition expressed in pages 3-9. In general, the tenor of these expressions of support and opposition appear to relate to the decision that

the commenter would like to see NPS make. The commenter’s opinions will be considered in making the final decision, but there is nothing in those opinions

that substantively would alter the range of alternative features to be evaluated in the Final EIS. For example, if the features that are not supported were to be

deleted from the range of alternatives then the analysis would be left only with features that the commenter agrees with. If only the actions that are supported

by the commenter remain, then there is effectively only one alternative. Accordingly, the commenter concludes that there is only one alternative that warrants

consideration, and that is Revised Alternative E (pages 20-28 in the comment letter). From the NEPA standpoint, the analysis cannot be limited in this fashion.

Therefore, expressions of support or objection will not be responded to, in general, by changes in alternative features – they will be responded to when the

decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision. There is a very clear separation

between alternatives legitimately considered in an analysis and the expression of a preferred alternative or the decision to be made.
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STATE OF WYOMING

Page 4. Re: Enforce current sound standards. This suggested feature is analyzed in the “no action” alternative, A. As an aside, the final selected alternative

that is documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS. Such mixing can occur as long as the

mixed features are consistent with one another, and as long as the effects of such an alternative would not fall outside the range of effects disclosed in the EIS.

Page 4. Re: Natural Quiet Assumptions. The 78 dB full throttle level refers to the test procedure in 36 CFR 2.18. In 1995, passages of individual snowmobiles

under constant speed cruise conditions were measured at a distance of 50 feet at Flagg Ranch. Levels ranged from 68 dB at 10 mph to 75 dB at 30 and 40 mph.

In 1996, levels of 75-77 dB were measured at speeds up to 55 mph in controlled tests near Jenny Lake of GTNP The revisions to the DEIS will use levels

typical of cruise conditions in the impact assessment. Additional work is being accomplished on the sound analysis, and needed changes will be incorporated in

the FEIS.

Page 5. Re. Alternative fuel sales. This suggested feature will be considered. In consideration of the sensitivity to regulation and the time it may take for

support industries to catch up, it may make more sense to encourage voluntary compliance with this provision until two years have passed. The cooperating

agencies’ support of such an approach is appreciated.

Page 5. Re: Late night closure. This section will be clarified in the FEIS.

Page 5. Re: Late night closure. Support of night time closure is acknowledged. This feature is in the range of alternative features analyzed, and will continue

to be an option for management.

Page 5. Re: Late night closure. Support of 10 P.M. to 6 A.M. closure is acknowledged. This feature is in the range of alternative features analyzed, and will

continue to be an option for management.

Page 6. Re: Nighttime Speed Limit. Support of 35 mph nighttime speed limit is acknowledged. This feature is in the range of alternative features analyzed,

and will continue to be an option for management.

Page 6. Re: Information Programs Partnerships with communities would necessarily be part of any alternative to be considered. NPS views this as a standard

practice to help implement management actions. Communities and organizations need to be accessible and supportive in order to implement partnership

strategies.

Page 6. Re: Additional Plowing – YNP. Partly in response to the overall non-support of plowing the road, NPS expresses a new preferred alternative in the

Final EIS. This alternative would provide oversnow motorized access from West Yellowstone to Old Faithful, and allow visitors to experience the Grand Loop

by snowcoach.

Page 7. Re: Winter access to YNP. The alternative features being objected to and the activities being supported remain as choices within the range of

alternatives being evaluated in response to the purpose and need for action. The objections to the NPS preferred alternative are noted. See earlier response to

this letter in regard to page 4 “Advisory committee.”

Page 7. Re: Length of Winter Season. All features considered in the range of alternatives are justifiable from an analysis standpoint. They all respond to

various issues developed during scoping, or they represent a possible approach to an issue that is being contrasted with a possible approach considered in

another alternative.

Page 8. Re: Use on Jackson Lake. All features considered in the range of alternatives are justifiable from an analysis standpoint. They all respond to various

issues developed during scoping, or they represent a possible approach to an issue that is being contrasted with a possible approach considered in another

alternative. Again, there is undue attention on the preference indicated in the DEIS, or the decision to be made.

Page 9. Re: Moving the CDST. See earlier response to this letter in regard to page 4 “Advisory committee.” Though this feature is not part of the new

preferred alternative, it remains as a feature in the range of alternatives.
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Page 9. Re: Widened Highway CDST. This reference is not inappropriate for two reasons: similar circumstances exist in the proximity of highway vehicle

traffic to snowmobile use, and GTNP responds to medical emergencies involving snowmobile use on Togwotee Pass.

Page 9. Re: Use on Grassy Lake Road. See earlier response to this letter in regard to page 4 “Advisory committee.” Should motorized oversnow use on Grassy

Lake Road be allowed in the eventual decision, the suggested activities could be implemented thereafter. They do not require analysis in this programmatic EIS

and plan.

Page 10. Re: NPS sound and emissions standards. NPS has the responsibility to protect park resources and values. Given the issue that partly drives this EIS -

-that snowmobile emissions impair air quality -- it is necessary to consider alternatives that both reduce and eliminate the impairment. In regard to the

assertion that NPS should defer to EPA, implying that such an alternative feature should not be considered, CEQ regulations allow the lead agency to evaluate

reasonable alternatives that are not within its jurisdiction (§1502.14[c]).

Page 10. Re: Air Resources Division air quality report. This generalization ignores most of the referenced report and any number of other efforts that are

correct and accurate. The report is now correct and final, and is available for use as a reference in the winter use EIS analysis.

Page 10. Re: Air Resources Division air quality report. Criticism stemming from the release of the draft summary ARD report and its content is beyond the

scope of this EIS analysis and requires no response. The report, so far as the alleged faulty information, was not a part of the Draft EIS. The fact that the

cooperators disagree with how the report was publicized and distributed does not affect the air resources analysis in the EIS.

Page 11. Re: Snowmobile sound levels. (basically same comment as on page 4) The 78 dB full throttle level refers to the test procedure in 36 CFR 2.18. In

1995, passages of individual snowmobiles under constant speed cruise conditions were measured at a distance of 50 feet at Flagg Ranch. Levels ranged from

68 dB at 10 mph to 75 dB at 30 and 40 mph. In 1996, levels of 75-77 dB were measured at speeds up to 55 mph in controlled tests near Jenny Lake of GTNP

The revisions to the DEIS will use levels typical of cruise conditions in the impact assessment. Additional work is being accomplished on the sound analysis,

and needed changes will be incorporated in the FEIS.

Page 11. Re: Personal Access. Please see the purpose and need section in the DEIS and the FEIS. Personal access may be reflected in the statements of

desired condition, but personal access by snowmobile is not a right or a guarantee. The NPS mandate, as stated in the purpose and need section, places personal

enjoyment and freedom of access in a subordinate role to protection of park values so they are unimpaired for future generations.

Page 11. Re: Commenter Motivation. It is not material for the EIS range of alternatives to speculate about the unstated motivations of any group of

commenters. NPS notes that there may be many people who do not visit the Parks because of current use by snowmobiles.

Page 12. Re: Oversnow Transportation Choice. This comment is a reference to statements made in the DEIS that apparently the commenter agrees with. The

inference is that since people choose to come in these numbers, they would not choose to experience the Park in any other fashion. The commenter seems to

further infer that because this is so, and because the economies have thrived on this demand, then freedom and economic well being in the gateway

communities should have priority over any impacts that this use may cause. NPS disagrees with these inferences. Please see earlier response to this letter in

regard to page 11 “Personal Access.”

Page 12. Re: Personal Access. The “personal access” issue is not taken lightly. All alternatives but one in the EIS allow the use of snowmobiles in varying

degrees and places, depending upon the alternative concept. The impact of each alternative on visitor experience is disclosed, including impacts on snowmobile

users as a group. The difficulty is that personal access via snowmobile, considering present commercial technology and usage, causes a variety of impacts on

park resources, values and other visitors. Please see the purpose and need section in the DEIS and the FEIS. Personal access may be reflected in the statements

of desired condition, but personal access by snowmobile is not a right or a guarantee. The NPS mandate, as stated in the purpose and need section, places

personal enjoyment and freedom of access in a subordinate role to protection of park values so they are unimpaired for future generations.
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Page 13. Re: Socioeconomics. The FEIS will report economic impacts following another review of the input from the cooperating agencies. As in the DEIS,

all assumptions made in the analysis will be disclosed. According to the CEQ regulations, §1503.3(b), commenting agencies that criticize an analysis

methodology should describe an alternative methodology and why it prefers it. The commenter, in this instance describes an alternative methodology, but does

not specifically indicate what is incorrect about the agency method – other than it arrives at a different answer. If there is a significant difference of opinion, as

there may be in this case, then the remedy provided in CEQ regulations is to report both opinions in order to meet the disclosure requirement. This approach

was taken in the DEIS by reporting the results of NPS studies and the reports from each cooperating agency. Efforts will be made in the FEIS to enhance this

comparison.

Page 13. Re: Shuttle Bus Cost. Subsidized access, should it be necessary, would be a consideration if this alternative were to be selected in the decision.

Page 13. Re: Plowing Roads. The stated purpose of plowing the road (DEIS, page 28) is to “improve affordable access” – not, as the commenter states, to

“provide affordable access for minority and low-income people”. The DEIS explains that a required impact topic in an EIS is to evaluate the effects of a

proposed action on socially or economically disadvantaged populations (DEIS, page 80). These populations are characterized on page 90 in the DEIS, and the

effects on them are disclosed in the socioeconomic section for each alternative (DEIS, pp 176, 199, 224, 245, 260, 274, 288). NPS disagrees that this analysis

is “extremely flawed”; the stated impacts on socially or economically disadvantaged populations are not used as “justification” for plowing in alternative B.

The rationale for preferring alternative B may be found on page 39.

Page 14. Re: Plowing Roads. This comment restates the disclosure of effects present in the DEIS. Many commenters refer to any disclosure of an impact as

“admitting” something. Readers should understand that it is the purpose of an EIS to disclose the possible effects of a proposed action and alternatives to it,

and that references to the “justification” for a preferred alternative is an entirely different issue relating to the decision to be made. Please see earlier response

to this letter in regard to page 4 “Advisory Committee.”

Page 14. Re: Access and available space. Please see earlier response to this letter in regard to page 4 “Advisory Committee.” Any expression of available

space versus visitation in the DEIS will be clarified in the Final EIS.

Page 15. Re: Shuttle Bus Experience. This comment restates the disclosure of effects present in the DEIS. Many commenters refer to any disclosure of an

impact as “admitting” something. Readers should understand that it is the purpose of an EIS to disclose the possible effects of a proposed action and

alternatives to it, and that references to the “justification” for a preferred alternative is an entirely different issue. NPS has persisted in describing “noise” from

snowmobiles as “sound” at the request of cooperating agencies. It should be noted that many interested parties commented during scoping and during the DEIS

review that snowmobiles produce unwanted noise. The section on impacts of human winter use activities on the natural soundscape will be further developed

in the FEIS.

Page 15. Re: Construction and Operation Costs in Vol. II. Regarding the allegation that NPS has inflated costs to justify the preferred alternative: the FEIS

preferred alternative will not be alternative B. Therefore, the point is academic. The cost analysis will be reviewed and clarified, if necessary, in the FEIS.

Page 15. Re: Plowing Roads. It is conceivable that the desired effect of an alternative action would not be achieved, or that it would have adverse

consequences associated with it. It is the purpose of an EIS analysis to evaluate an action and disclose such things. The DEIS analysis will be reviewed and

altered if necessary.

Page 16. Re: Converting oversnow route to mass transit. It is conceivable that the desired effect of an alternative action would not be achieved, or that it would

have adverse consequences associated with it. It is the purpose of an EIS analysis to evaluate an action and disclose such things. The DEIS analysis will be

reviewed and clarified if necessary.

Page 16. Re: Eliminating access from East Entrance. This comment restates the disclosure of effects present in the DEIS, pages 255-256.
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Page 16. Re: Public Safety and Avalanches. The analysis will be reviewed and supplemented with additional information if necessary.

Page 16. Re: Access and available space. Please see earlier response to this letter in regard to page 4 “Advisory Committee.”

Page 17. In terms of use, the effect is minimal. NPS acknowledges that such a change could impact local businesses, particularly those catering to the

snowmobile visitor immediately outside the park. NPS is also aware that other opportunities for winter visitors exist on the Shoshone National Forest,

including a downhill ski area, groomed cross-country ski trails and many opportunities for backcountry activities. In recent years, winter marketing priorities

outside the east entrance have favored snowmobile users. Please see earlier response to this letter in regard to page 13 “Socioeconomics”.

Page 17. Re: East Entrance. This comment is speculative. No further response is necessary.

Page 17. Re: Use of military ordinance. This administrative procedure is always available to park managers, to be implemented as conditions arise. See

previous response, above.

Page 17. Re: Access and available space. The FEIS will report economic impacts following another review of the input from the cooperating agencies. As in

the DEIS, all assumptions made in the analysis will be disclosed. According to the CEQ regulations, §1503.3(b), commenting agencies that criticize an analysis

methodology should describe an alternative methodology and why it prefers it. The commenter, in this instance describes an alternative methodology, but does

not specifically indicate what is incorrect about the agency method – other than it arrives at a different answer. If there is a significant difference of opinion, as

there may be in this case, then the remedy provided in CEQ regulations is to report both opinions in order to meet the disclosure requirement. This approach

was taken in the DEIS by reporting the results of NPS studies and the reports from each cooperating agency. Efforts will be made in the FEIS to enhance this

comparison.

Page 18. Re: Socioeconomics. This comment is speculative. No further response is necessary.

Page 18. Re: Proposed closures. Please see the purpose and need section in the DEIS and the FEIS. Personal access may be reflected in the statements of

desired condition, but personal access by snowmobile is not a right or a guarantee. The NPS mandate, as stated in the purpose and need section, places personal

enjoyment and freedom of access in a subordinate role to protection of park values so they are unimpaired for future generations.

Please see earlier response to page 12 “Oversnow Transportation,” page 11 “Personal Access,” and page 12 “Personal Access.” See also NPS mandates and

purpose and need for action in Chapter I of the FEIS. Alternative F was developed to address wildlife issues specifically. One consequence of the alternative,

as disclosed in the DEIS, is that there would be no access to those areas. To object to this feature, and others, is to object to having a range of alternatives that

sharply define the issues (§1502.14).

Page 18. Re: Snow plowing changes. Please see earlier response to this letter in regard to page 4 “Advisory Committee.”

Page 18. Re: Snow plowing changes. This statement of effects is speculative. Other facilities operate effectively using oversnow transport. Should Flagg

Ranch become an oversnow destination, NPS feels that it could adapt and take advantage of a new set of opportunities for winter recreation experiences.

Page 18. Re: Snow plowing changes. As is the case with nearly any other alternative feature, there would be consequences associated with not plowing the

road from Colter Bay to Flagg Ranch. It is interesting to contrast the commenter’s criticism of this feature with its criticism of plowing the road from West

Yellowstone to Old Faithful in alternatives B and C. The contrast presents a contradiction, from which NPS concludes the only acceptable form of access in the

state’s opinion is that represented by the status quo. Please see earlier response to this letter in regard to page 4 “Advisory Committee.”

Page 19. Re: Elimination of the CDST. Please see earlier response to this letter in regard to page 4 “Advisory Committee.” NPS acknowledges the importance

of the CDST to Wyoming and Idaho.

Page 19. Re: Elimination of the motorized winter use on Jackson Lake. If ice fishing is the premier reason for using snowmobiles or snowplanes on Jackson

Lake, there are other modes of access for this purpose. Please see earlier response to this letter in regard to page 4 “Advisory Committee.”
RESPONSES States

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STATE OF WYOMING

Page 22. Re: Bio-based fuel sales. This comment is similar to an earlier point made on page 5 of the letter. The suggestion for immediate implementation of a

synthetic oil and bio-fuel requirement is tempting. In consideration of the average visitor and of support industries, it may make more sense to encourage

voluntary compliance with this provision until two years have passed. In the past, people have reacted strongly to a perception of “heavy handed regulation” on

the part of federal agencies. The cooperating agencies’ support of such an approach is appreciated. [Note: this letter presents a “Revised Alternative E” for

consideration on pages 20-28. Features of this alternative were for the most part analyzed throughout the range of alternatives in the DEIS. Please refer to the

matrix which illustrates where the features of Revised E are evaluated in the DEIS. The matrix can be found in Chapter I of the FEIS under Alternatives

Suggested During the Public Comment Period.]

Page 22. Re: Interim carrying capacity. NPS is encouraged by support from the cooperating agencies on establishing a recreation carrying capacity. In

practice, setting a carrying capacity is a highly complex and potentially divisive exercise. NPS managers decided there was not sufficient time available in the

settlement time frame to devote to this type of analysis. More explanation of the carrying capacity issue will be included in the FEIS. NPS will provide

analysis in the alternatives mitigation to look at interim limitations on use, one of which will be at the seven year average level.

Page 23. Re: Alternatives C, D and G conceptually include the opening of such facilities to one degree or another. A reference to other plans and

environmental analysis on page 17 of the DEIS includes commercial services plans for both parks. Since these plans were in process, the decision was made

not to include analysis of facilities being addressed elsewhere.

Page 23. Re: Educational video Partnerships with communities would necessarily be part of any alternative to be considered. NPS views this as a standard

practice to help implement management actions. Communities, organizations and NPS need to be mutually accessible and supportive in order to implement

partnership strategies such as the suggested video. As an implementation detail, no further response to this comment will be made.

Page 24. Re: Educational Video. Both NPS and concessionaires employ ongoing safety programs, snowmobile user certification or training. Regardless, such

programs should be enhanced, improved and implemented to eradicate preventable accidents.

Page 25. Re: Scientific studies and monitoring: published studies and monitoring reports should as a matter of course be available to the public. This

information should not be subjected to a political process in advance of their publication. There are policies and protocols already in place to ensure

appropriate scientific review. If future studies or monitoring indicate the need for management action, NPS will follow the requirements already set in law

(such as NEPA), regulation and policy. At that time, the scientific basis for an action can be scrutinized and criticized by any interested parties.

Page 25. Re: Continue existing plowed road access in YNP. This is a feature of alternatives A, D, E, F and G.

Page 25. Re: Expanded nonmotorized routes away from motorized routes, served by shuttle service. This suggestion is programmatically compatible with all

alternatives, and could be implemented without further significant environmental review (as a function of the Winter Use EIS and the decision resulting from

it). Whether solitude can actually be achieved by this separation depends upon site characteristics and the degree to which motorized use sounds travel in the

area.

Page 25. Re: Restricting nonmotorized uses to designated trails. This is a feature of DEIS alternatives B, D and E. The preferred alternative in the FEIS will

incorporate this measure.

Page 25. Re: Congestion and visual concerns at Old Faithful. This suggestion may be useful in site-specific implementation of any of the alternatives retaining

snowmobile use at Old Faithful. It is not a key programmatic feature; i.e. it does not require an EIS analysis for approval – it could be done now.

Page 26. Re: Prepaid passes requirement at West Yellowstone– prepaid passes for other entrances. Pre-paid passes are available in West Yellowstone. Should

the need arise at other entrances for the same reasons, the service could be expanded. The rationale for this measure – mitigating pollution impacts on visitors

and employees – has a cost associated with it. Opportunities for necessary NPS-visitor contact at the entrance are lost. Suggesting that all visitors forego an

important safety element of the park experience, so that their snowmobiles will be less polluting is clearly not in compliance with 36CFR 2.18. The regulation

states that snowmobiles are prohibited except where designated and only when their use is consistent with the park’s natural, cultural, scenic and aesthetic

values, safety considerations and will not disturb wildlife or damage park resources. In this case, mitigating an effect on park values and resources by
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STATE OF WYOMING

completely eliminating an important information and safety resource for park visitors is illogical. Voluntary compliance with this management option is

reasonable, but only for those visitors who wish to utilize it.

Page 27. Re: Improve grooming on the Grassy Lake Road and permit commercial outfitters. These measures do not require a programmatic EIS. They could

be considered at any time.

Page 28. Re: Removal of snowmobiles from Teton Park Road. The effects of this are disclosed in visitor use and access and visitor experience for alternatives

B, D, E, F and G in the DEIS.

Page 29. Re: Comments re: GTNP. 1.) Close the Elk Ranch Reservoir-Spread Creek area to public use from December 15 to April 30. According to park

policy, the Buffalo Fork River floodplain and Uhl Hill are currently closed to public entry in the winter. The area between Spread Creek and Wolff Ridge is

open to nonmotorized uses only. Mitigation in alternative F closes Wolff Ridge. 2.) Restrict nonmotorized travel in the Ditch Creek area to designated routes

only. The commenter does not state which segment of Ditch Creek is of concern. NPS assumes it is the area east of the Antelope Flats Road to the Teton

Science School. The effects of human activities on wildlife in this area are largely anecdotal and their magnitude and frequency unknown. NPS does not agree

that they warrant use restrictions at this time. Instead, several alternatives in the FEIS call for implementation of an adaptive management strategy that would

allow for closures to be enacted in the future should additional information become available. 3.) Close Blacktail Butte to public use from December 15 to

April 30. Mitigation in alternative F closes Blacktail Butte. 4.) Close Prospector Mountain and Mt. Hunt to backcountry skiing to protect bighorn sheep. This

is a feature of alternative D. 5.) Close the trail from Lost Creek to Antelope Flats to snowmobiles. This feature is included in alternatives D, E, F, G and the

new preferred alternative restricts access to nonmotorized use only.

Page 30. Re: Aquatic resources. Please see earlier response to this letter in regard to page 4 “Advisory Committee.”

Page 30. Re: Editorial changes. Editorial changes regarding Aquatic Resources will be made in the Final EIS.

Page 30. Re: Editorial changes. Editorial changes regarding Reptiles and Amphibians will be made in the Final EIS.

Pages 31-36. Re: Air quality. [Note: pages 31-36 of the state’s letter consist of comments from WY DEQ, Air Quality Division] References to standard

exceedances will be removed where non-reference methods were used.

The statement about the Class I area will be revised.

FEIS will clarify references to compliance with National Ambient Air Quality Standards for carbon monoxide.

Page 108, Table 14 – FEIS will clarify status of PM2.5 standard.

Page 109, 4th paragraph – FEIS will clarify data methods.

Page 109, last paragraph – Available data will be reviewed for applicability.

Page 161, 4th paragraph, Page 164, 3rd paragraph, Page 165, 1st paragraph, Page 181 – FEIS will clarify references to compliance with National Ambient Air

Quality Standards.

Page 164, 3rd paragraph – Any cited “problems” will be clarified.

Page 182, 1st paragraph, Page 202, Page 208, Page 246, Page 275 - FEIS will clarify references to compliance with National Ambient Air Quality Standards.

Page 231, Page 278 – Class I statement will be revised.

Page 263 – “Adverse impact” is defined in Table 34, page 158. No specific monitoring is identified to date.

These comments are both technical and editorial in nature. All comments are being reviewed and the content of the FEIS will reflect them as needed.
RESPONSES States

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STATE OF WYOMING

Pages 37-45. Re: Socioeconomic impacts. [Note: pages 37-45 of the state’s letter consist of comments from David Taylor, UW economist] The primary

difference between the state’s analysis and that detailed in the DEIS lies in the underlying estimates of baseline visitation to the parks and in the estimates of

reduction to baseline use under alternative management options. The DEIS estimate of baseline trips adjusts recorded entries to the parks by an estimate of reentries (25% in our analysis). The state’s analysis assumes all entries are separate trips from home. The DEIS analysis uses survey responses of current winter

visitors to estimate the decrease in the number of trips under alternative management actions. The state’s analysis assumes that nocurrent park snowmobile

users will return to the GYA under the changed management. Finally, the DEIS analysis recognizes that only visitation changes by those visitors to the GYA

who reside outside of the GYA are relevant to estimation of GYA impacts. The analysis by the state assumes that all current park snowmobilers are from

outside the GYA. The use of these differing assumptions of baseline use, and changes to use, lead to the widely varying estimates of changes in local area

expenditures. Because of the significant differences in the two analyses, both are presented in the DEIS.

The FEIS will report economic impacts following another review of the input from the cooperating agencies. As in the DEIS, all assumptions made in the

analysis will be disclosed. According to the CEQ regulations, §1503.3(b), commenting agencies that criticize an analysis methodology should describe an

alternative methodology and why it prefers it. The commenter, in this instance describes an alternative methodology, but does not specifically indicate what is

incorrect about the agency method – other than it arrives at a different answer. If there is a significant difference of opinion, as there may be in this case, then

the remedy provided in CEQ regulations is to report both opinions in order to meet the disclosure requirement. This approach was taken in the DEIS by

reporting the results of NPS studies and the reports from each cooperating agency. Efforts will be made in the FEIS to enhance this comparison.

The economic impact analysis has been revised with expenditures now based on the actual group indicating they would decrease (or increase) their number of

trips in response to policy changes. As the comment correctly notes, most of the trip decreases are for snowmobilers, who tend to have high trip expenditures

second only to snowcoach riders (Littlejohn, 1996). The analysis has also been revised from a 17-county impact region to a 5-county region to provide a

quantitative measure of the change in the area most impacted. The DEIS acknowledges that winter visitation is important to surrounding communities and

notes that, for example alternative B, (at p. 198) "would have a major negative impact on the West Yellowstone winter economy." The comment on "defacto"

poverty provides new information that will be included in the FEIS Chapter III.

Page 38. Re: Socioeconomic impacts. NPS has not disregarded the state’s information. According to the CEQ regulations, §1503.3(b), commenting agencies

that criticize an analysis methodology should describe an alternative methodology and why it prefers it. The commenter, in this instance describes an

alternative methodology, but does not specifically indicate what is incorrect about the agency method – other than it arrives at a different answer. If there is a

significant difference of opinion, as there may be in this case, then the remedy provided in CEQ regulations (§1502.9(a)) is to report both opinions in order to

meet the disclosure requirement. This approach was taken in the DEIS by reporting the results of NPS studies and the reports from each cooperating agency.

Page 83 of the DEIS makes reference to the use of source information provided by the cooperators, all of which is presented in DEIS Appendix A. The

characterization of the socioeconomic environment specifically cites information from the cooperators or their consultants, such as Dr. Taylor. On pages 298

through 315, the DEIS discloses the impacts of each alternative on adjacent lands in the cooperating agencies’ own terms. Given this, NPS disagrees that the

input from the cooperating agencies has been disregarded.

Pages 46-47. Re: Comments from Wyoming Business Council. [These pages of the state’s letter consist of comments from the Wyoming Business Council]

Many earlier responses are relevant to the comments in this section: e.g. responses on scientific adequacy, programmatic EISs, remedies in CEQ regulations for

unavailable or inadequate information, and economic impacts. Economic studies have been conducted and the results provided to the cooperators that clearly

and appropriately provide adequate information related to the DEIS alternatives, and analysis of the economic impacts of those alternatives. Also, these studies

provide appropriate and adequate information that addresses the winter season and what is spent by winter vacationers As a side note, the CEQ regulations
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STATE OF WYOMING

 define special expertise (the basis for state and county cooperating agency status) as “statutory responsibility, agency mission, or related program experience”

§1508.26. NPS agrees that there is a need to work cooperatively (regardless of the NEPA context for “cooperating”) to develop and use relevant information in

park management.

Page 48. Re: Groomed roads and wildlife. This information is presented in the DEIS (page 166, et al.) reflecting a broader look at Bjornlie and Garrot.

Page 49. Re: Snowmobile use and water quality. As suggested, the analysis of impacts on snowpack and water quality will be reviewed and updated in the

FEIS with respect to information that is now available. The cited report was not available to the study team for inclusion in the DEIS.
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COMMENTS States
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COMMENTS States
RESPONSES States

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REPRESENTATIVE PAT CHILDERS, WYOMING STATE LEGISLATURE

Page 1. Re: NPS not carefully considering NEPA regulations, and “utilizing a flawed air quality study in the NEPA analysis.” CEQ regulations have been

followed scrupulously, as the planning record will show. There is no requirement in CEQ regulations (§1502.14) to justify a preferred alternative, just to name

one or more alternatives as preferred in the DEIS if there is a preference. The purpose of identifying the preferred alternative is so agencies and the public can

understand the lead agency’s orientation (§1502.14(e)). The commenter should note that a final decision has not yet been made in consideration of the full

range of alternatives in an FEIS. Comments about the rationale for or against the preferred alternative are given too much weight at the expense of the range of

alternatives. The rationale for the preferred alternative does not set the scope of analysis. NEPA (CEQ Regulations) does not make stipulations about the

rationale for selecting a preferred alternative in an EIS; in fact there is no requirement for stating the rationale in an EIS. It stipulates that in a final EIS, a

preferred alternative must be identified. The statement of preference for one or more alternatives in a draft EIS is discretionary, depending upon whether the

agency has a preference at that point (§1502.14(e)).

Therefore, the identification of a preferred alternative in a DEIS should be regarded by the public as extremely tenuous. This is because an EIS is to serve as a

means of assessing impacts of proposed agency actions “rather than justifying decisions already made” (§1502.2(g)). The FEIS preferred alternative may be

viewed more as a “precursor” decision, which will only become final in a Record of Decision that expresses the rationale for the choice. In any case, it is clear

that merely the expression of a preferred alternative, by itself, can in no way invalidate the entire EIS analysis. The decision-maker can select any of the

alternatives in a Final EIS through consideration of a variety of factors, including but not limited to environmental impacts. Regarding the air quality study:

criticism stemming from the release of the summary ARD report and its content is beyond the scope of this EIS analysis and requires no response. The report,

so far as the alleged faulty information, was not a part of the Draft EIS or the EIS process.

Page 1. Re: Need to use “Scientific” data and “Significant” impacts in the analysis. First, no decision has yet been made therefore it is not ripe to question

whether or not a decision was “informed.” Second, the cooperating agencies cannot be a party to making the decision. That responsibility lies exclusively with

NPS.

The EIS analysis is aimed at developing a programmatic plan (§1508.18(b)(2) and (3)) for winter use. For concerns relating to “science”, it should be noted

that there is no burden to develop site specific information to support a programmatic planning document. Without further information, we are unable to

address inferences about use of “sound science.” An EIS is not, per se, a scientific analysis. It is intended to disclose environmental effects over a range of

alternatives, in which the analyses must demonstrate scientific integrity by disclosing methods and making explicit references to sources used (40 CFR

1502.24). The DEIS does this. CEQ regulations also allow for incomplete or unavailable information, by describing procedures that are to be following in

these instances (§1502.22). Any identified gaps in the FEIS will follow the requisite procedures. Also, there is no requirement in CEQ regulations (§1502.14)

to justify a preferred alternative. The requirement is to identify one or more alternatives as preferred in the DEIS if there is a preference. The agency must

express a preferred alternative in a Final EIS.

Page 1. Re: Support for Revised Alternative E proposed by counties and State of Wyoming. Revised Alternative E comes from cooperating agencies and the

Blue Ribbon Coalition in a variety of forms. The essentials of Revised Alternative E, all versions considered, are not significantly different from alternative E

as presented in the DEIS, especially considering the programmatic nature of the proposed action. See the matrix comparison of Revised E versus the features

analyzed in the range of alternatives. In general, the tenor of these expressions of support and opposition appear to relate to the decision that the commenter

would like to see NPS make. The commenter’s opinions will be considered in making the final decision, but there is nothing in those opinions that

substantively would alter the range of alternative features to be evaluated in the Final EIS.
RESPONSES States

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REPRESENTATIVE PAT CHILDERS, WYOMING STATE LEGISLATURE

Page 2. Re: Air Resources Division air quality study: criticism stemming from the release of the summary ARD report and its content is beyond the scope of

this EIS analysis and requires no response. The report, so far as the alleged faulty information, was not a part of the Draft EIS or the EIS process.

Page 2. Re: Wyoming DEQ should have been included on the interagency team. As a matter of fact, Wyoming DEQ personnel have been involved since before

the EIS was undertaken in planning and implementation of air studies in YNP, along with the State of Montana. Montana DEQ people have been actively

involved in the EIS process. The agreement NPS signed with the State of Wyoming indicates that Wyoming DEQ similarly has special expertise and will

provide information on impacts to air and water quality. Unlike Montana, that department was not actively involved and no input was received from them prior

to publishing the DEIS. DEQ involvement was limited to criticism of the DEIS in the State’s comment letter. NPS is responding to that criticism elsewhere.

Re: Wyoming primacy. Wyoming does not have primacy over NPS managed lands. Wyoming is the regulatory authority for some aspects of the Clean Air

Act, delegated to it by US EPA. Given the documented impacts on air quality from snowmobiles, it would seem that DEQ might be interested in the possible

levels of pollution from the standpoint of NAAQS standards relating to human health, especially in a national park in Wyoming. DEQ has had opportunities to

be involved in the dialogue along these lines. Despite the regulatory aspects of air quality, the commenter should note that the federal land manager, NPS in

this case, has explicit authority over resources and their management on public lands in their jurisdiction. This includes air and air quality related values. NPS

has the assertive responsibility under the CAA to protect air quality (and related values) in Class I airsheds. It has the authority to undertake management

actions intended to meet that need, as an entirely separate issue from NAAQS standards and state regulatory processes.

Page 2. Re: DEQ offer of participation. The state claimed special expertise in air and water quality and agreed to provide that expertise as a cooperating

agency. It would be incumbent on the state to fund any such efforts within the purview of the agreement (§1501.6(b)(5)). NPS would welcome Wyoming

DEQ’s participation in future air quality studies.
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COMMENTS Counties
RESPONSES Counties

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FREMONT COUNTY, IDAHO (See also responses to Paul Kruse, Representative of Cooperating Counties)

Page 1. Re: Direct violation of the “Organic Law”. The NPS and its basic mandate are authorized under the NPS Organic Act (16 USC 1,2-4) and the General

Authorities Act (16 USC 1a through 1a-8):

 “The Service thus established shall promote and regulate the use of the Federal areas known as National Parks...by such means and measures as to conform to

the fundamental purposes of the said Parks...which purpose is to conserve the scenery and the natural and historic objects and the wildlife therein and to

provide for the enjoyment of same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”

An EIS is necessary to evaluate alternative choices for plans while revealing the possible environmental impacts of activities that may be included in the plan.

All alternatives presented in the EIS meet the purpose and need for action. The purpose and need for action in an environmental impact statement (EIS) is a brief

statement specifying the underlying purpose and need to which the agency is responding in proposing the alternatives, including the proposed action. The need

to develop a plan through an EIS is indicated by the difference between overall desired condition and the conditions that presently exist. The desired condition

reflects the parks’ mandates, and is articulated in the EIS as series of general objectives. The final plan will be designed to move the existing condition toward

the desired condition.

The effects of all the alternative actions on natural resources, public health and safety, socioeconomics, adjacent lands and visitor access and experience are

analyzed in the EIS, Chapter IV, Environmental Consequences.

Page 1. Re: Support for revised alternative E. Comments place a great deal of emphasis on support or justification for a course of action or decision. Under the

CEQ regulations, the requirement in an EIS is to provide a range of reasonable alternatives that clearly define the issues, and to fully evaluate and disclose the

possible effects of those alternatives. The DEIS meets this requirement. Comments of support or nonsupport go to the decision to be made; they do not affect

the range of alternatives considered.
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COMMENTS Counties
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COMMENTS Counties
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COMMENTS Counties
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COMMENTS Counties
RESPONSES Counties

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GALLATIN COUNTY, MONTANA (See also responses to Paul Kruse, Representative of Cooperating Counties)

Page 1. There is no requirement in CEQ regulations (§1502.14) to justify a preferred alternative, just to name one or more alternatives as preferred in the DEIS

if there is a preference. The purpose of identifying the preferred alternative is so agencies and the public can understand the lead agency’s orientation

(§1502.14(e)). The entire comment letter is a criticism of the preferred alternative, and as this comment indicates, the purpose is to convince the NPS to “select

a different proposed action.” In fact NPS will indicate a new preference in the FEIS, which technically addresses this point.

NPS acknowledges the commenter feels there isn’t sufficient support for selecting the preferred alternative, and that there is disagreement on the nature and

level of impacts. The commenter should note that a final decision has not yet been made in consideration of the full range of alternatives in an FEIS.

Comments about the rationale for or against the preferred alternative are given too much weight at the expense of the range of alternatives. The rationale for

the preferred alternative does not set the scope of analysis. NEPA (CEQ Regulations) does not make stipulations about the rationale for selecting a preferred

alternative in an EIS; in fact there is no requirement for stating the rationale in an EIS. It stipulates that in a final EIS, a preferred alternative must be identified.

The statement of preference for one or more alternatives in a draft EIS is discretionary, depending upon whether the agency has a preference at that point

(§1502.14(e)).

Therefore, the identification of a preferred alternative in a DEIS should be regarded by the public as extremely tenuous. This is because an EIS is to serve as a

means of assessing impacts of proposed agency actions “rather than justifying decisions already made” (§1502.2(g)). The FEIS preferred alternative may be

viewed more as a “precursor” decision, which will only become final in a Record of Decision that expresses the rationale for the choice. In any case, it is clear

that merely the expression of a preferred alternative, by itself, can in no way invalidate the entire EIS analysis. The decision maker can select any of the

alternatives in a Final EIS through consideration of a variety of factors, including but not limited to environmental impacts.

The bulk of the comments in this letter express why alternative B is not acceptable to the writer, using much of the impacts disclosure in the DEIS. We reiterate

the purpose of an EIS – to disclose impacts of the proposed action and alternatives to it. NPS will respond directly to any other comments that refute the

analysis in general. Where the County’s assessment of impacts disagrees with that of the NPS, both viewpoints will be represented – as in the DEIS. Though

the County’s strong objection to alternative B may be persuasive in the final decision (see above), there is no information presented in this letter that would

alter the essential features of that alternative or remove it from consideration.

A final note is that the comments in this letter have been directed at the preliminary draft EIS that was provided to cooperating agencies for comment before

publication of the DEIS. The DEIS was adjusted to respond to substantive comments from the cooperators. Therefore, page references in the letter and some

of the content does not actually apply to the DEIS.

Page 2. NPS affirms its statement that this impact is negligible, considering the regional economy. The DEIS states on page 198 that a $12.4 million loss in a

$12.7 billion economy is negligible, especially as this is a worst-case scenario. It is likely that some visitors would continue to come to the GYA in the winter,

and it is likely that others would choose to take advantage of a different type of experience. The DEIS goes on to state that despite the negligible loss in a

regional economy, the impact would be felt mostly in small communities surrounding the parks. The same information is conveyed in the DEIS in relation to

the 3-state regional economy. NPS is responding to cooperating agencies that feel that the economic analysis on 17 counties dilutes the effects for counties that

are most immediately affected. NPS will determine and report on the projected impacts for the 5-county area.
RESPONSES Counties

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GALLATIN COUNTY, MONTANA (See also responses to Paul Kruse, Representative of Cooperating Counties)

Page 2. In many other respects, the commenter might be appreciative of a dispassionate analysis. The cooperators are nearly unanimous in requesting NPS

ignore the emotional content on wildlife, air, water and other “protection” issues and rely instead on “good science.” NPS has a more optimistic view about the

business community in general and, as stated, feels that it will find ways to adapt and profit from its proximity to public lands. NPS also notes from hearings

and other comments that some of that community does not agree with the commission nor support NPS in addressing critical resource issues.

Page 3. Re: Preferred alternative. Partly in response to the overall non-support of plowing the road, NPS expresses a new preferred alternative in the Final EIS.

This alternative would provide oversnow motorized access from West Yellowstone to Old Faithful, and allow visitors to experience the park by snowcoach.

Page 3. Re: Alternative B, affordable winter visitation. The stated purpose of plowing the road (DEIS, page 28) is to “improve affordable access.” A thorough

reading of the EIS would reveal that a required impact topic in an EIS is to evaluate the effects of a proposed action on socially or economically disadvantaged

populations (DEIS, page 80). These populations are characterized on page 90 in the DEIS, and the effects on those populations are disclosed in the

socioeconomic section for each alternative (DEIS, pp 176, 199, 224, 245, 260, 274, 288). The stated impacts on socially or economically disadvantaged

populations are not used as “justification” for plowing in alternative B, although there would certainly be some economic and environmental justice in doing so.

Page 3. Re: Visitor experience. The commenter is encouraged to separate the criteria for selecting an alternative from the process of disclosing impacts for all

alternatives. The decision criteria, or factors considered by the decision maker in making his or her choice, will be explained at the time a legal decision is

made. Comments arguing about the rationale for the preferred alternative in the DEIS are most applicable to the decision that has yet to be made. Directly to

the point of this comment, the new preferred alternative in the FEIS would limit winter visitors, would allow oversnow machine travel, and would eliminate

noise and pollution from snowmobiles. Alternative B does the same, except that it would allow snowmobiles in the parks – except from West Yellowstone.

Page 4. Re: Natural quiet. The sound analysis will be more comprehensive for all alternatives in the FEIS.

Page 5. Re: Chronic harassment of wildlife. In part to address the issue of impacts from humans on wildlife, a carrying capacity study for visitor use will be

completed in a timely manner after the Record of Decision (regardless of which alternative is decided upon) and the FEIS will set interim visitor use levels.

More explanation of the carrying capacity issue will be included in the FEIS.

Page 5. Re: Potential for impacts. Impacts discussed in the section titled Unavoidable Adverse Impacts (DEIS page 317) are drawn from the explanation of

assumptions and detailed analysis of alternatives in Chapter IV of the DEIS. NPS feels there is adequate support for the statement in question.

Page 5. Re: Cumulative impact analysis. The EIS and Plan are of a programmatic nature. It has been NPS’ expressed intent from the beginning of the process

to prepare a programmatic Plan (§1508.18(b)(2) and (3)). This would be the purpose of preparing a “comprehensive EIS.” There should have been no illusions

that a plan of this magnitude would be based upon detailed, site-specific data in order to make every decision possible relating to winter use. This

programmatic approach is acceptable under the law. Such documents make decisions and allocations at a general level and defer many specific project

decisions (implementing the plan) to a later date. Some site-specific decisions will require additional NEPA analysis and a new decision that is “tiered”

(§1508.28) to, or supported by, the programmatic plan. For these analyses, the assessment of cumulative impacts must be done in accordance with the CEQ

regulations.

Page 5. Re: Snowmobile emissions. The emissions analysis will be more comprehensive for all alternatives in the FEIS.

Page 6. Re: Water quality. The analysis of emissions impacts on snowpacks, water quality and aquatic resources will be updated in the FEIS using information

not available for the DEIS.

Page 6. Re: Park infrastructure. Costs associated with winter use alternatives may be found in DEIS Appendix F (Vol. II).

Page 6. Re: Park improvements. As the commenter points out, there are impacts associated with the preferred alternative in the DEIS. There are impacts

disclosed for all alternatives, as is the nature and purpose of an EIS. The commenter misses the point of the process and confuses the eventual decision with

disclosure of impacts through the range of alternatives.
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COMMENTS Counties
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COMMENTS Counties
RESPONSES Counties

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GALLATIN COUNTY, MONTANA–COMMISSIONER BILL MURDOCK

(See also Responses to Paul Kruse, Representative of Cooperating Counties)

Re: Reference to letter of June 30, 1999 spelling out concerns relating to Preferred Alternative B. See responses to letter from Gallatin County.
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COMMENTS Counties
RESPONSES Counties

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PARK COUNTY, MONTANA (See also responses to Paul Kruse, Representative of Cooperating Counties)

Cover letter. Re: Flawed NPS process. There is a desire on the part of NPS to cooperate. The effectiveness of the process used in this EIS relative to

cooperating agencies is subject to debate, especially given the short time frames. Early on, NPS intended to invite the three states surrounding the parks to

participate as cooperating agencies in developing the EIS. NPS believed the states could provide information on impacts to natural resources and local and

regional economies. Without consulting with NPS, CEQ opined to a Wyoming Senator that counties also should act as cooperating agencies in this process.

Thus NPS was faced with working with seven cooperating agencies, several of which had never before participated in a NEPA process as cooperators. Due to

the schedule set by the settlement agreement, NPS had little time to work with cooperating agencies on what was expected of them in that role. This includes

disagreements about the nature of special expertise in the NEPA process, and the burden of the cooperator in providing it. As a result, the cooperators often

acted as though the relationship was one where the NPS was to provide information to them, instead of the reverse. NPS regrets the way that this relationship

has evolved, owing in large part to the short time frame for environmental analysis. NPS notes that Mr. Paul Kruse, designated representative for cooperating

counties, states in his letter that the counties provided detailed socio-economic analysis and that NPS ignored the input. This is definitely not the case. It is

clear that roles and expectations in the process were, and are, not well understood, despite the cooperating agreements that were negotiated and signed.

Attachment to cover letter, County survey. NPS acknowledges receipt of the survey and will refer to it as appropriate in the FEIS.
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PARK COUNTY, WYOMING (See also responses to Paul Kruse, Representative of Cooperating Counties)

Cover letter. Re: Requests for extension and cooperating agency relationships. There is a desire on the part of NPS to cooperate. The effectiveness of the

process used in this EIS relative to cooperating agencies is subject to debate, especially given the short time frames. Early on, NPS intended to invite the three

states surrounding the parks to participate as cooperating agencies in developing the EIS. NPS believed the states could provide information on impacts to

natural resources and local and regional economies. Without consulting with NPS, CEQ opined to a Wyoming Senator that counties also should act as

cooperating agencies in this process. Thus, NPS was faced with working with nine cooperating agencies, several of which had never before participated in a

NEPA process as cooperators. Due to the schedule set by the settlement agreement, NPS had little time to work with cooperating agencies on what was

expected of them in that role. This includes disagreements about the nature of special expertise in the NEPA process, and the burden of the cooperator in

providing it. As a result, the cooperators often acted as though the relationship was one where the NPS was to provide information to them, instead of the

reverse. It is clear that roles and expectations in the process were, and are, not well understood, despite the cooperating agreements that were negotiated and

signed. NPS notes that Mr. Paul Kruse, designated representative for cooperating counties, states in his letter that the counties provided detailed socioeconomic analysis and that NPS allegedly ignored the input. All input was considered and included in the document as appropriate.

Attachment to cover letter, 2 pages of questions. A number of the questions that are asked do not appear to be germane to the EIS being written or the decision

to be made, although clearly they are of interest to Park County. The commenter does not indicate why or how these questions might affect the key issues or

the decision to be made. The EIS and plan is of a programmatic nature dealing with winter use. The alternatives are therefore programmatic – “alternatives for

plans which guide or prescribe alternative uses of federal resources, upon which future agency actions will be based.” (§1508.18(b)(2)) Considering the nature

of the decision to be made, NPS is unclear why information regarding current NPS employment, where employees live, how employees commute, past funding

for programs, etc., are important pieces of information. None of these items affect the decision to be made. Questions that have some bearing on the EIS or the

NEPA process specific to this action are answered.

Page 1, Question 1. Re: Economic Data. Economic analysis methods and relevant citations may be found on pages 159-161 of the DEIS. All documentation

for this analysis is to be found in the planning record for the EIS.

Page 1, Question 2. Re: Housing and lodging capacities. This information is provided on pages 140-141 in the DEIS. Demand trends for housing and lodging

are in the purview of the concession planning efforts. NPS is concerned first about the nature of winter recreation impacts on natural resources – this is the

limiting factor, not availability of lodging.

Page 1, Questions 3-6. Re: Employee data. As explained above, these questions do not appear to be germane to the issues being evaluated and the decision to

be made.

Page 1, Question 7. Re: Sewage spills. Sewage spills occurring in YNP may have affected water quality at specific times and places. NPS asks, how does this

affect a programmatic analysis of the types and levels of winter recreation use in the three park units? How should it affect a decision on the types and levels of

winter use to be managed? Wastewater facilities and the recognized shortcomings associated with them are the subject of another, separate project outside the

scope of a winter use plan.

Page 1, Question 8. Re: Groundwater monitoring. The DEIS does not specifically identify potential impacts on groundwater as a concern. Hence, this is not

evaluated. Of greater concern is the amount of emission and leaked substances deposited in the snowpack for direct infusion into runoff and surface water

systems. Data collected over time on immediate impacts to surface water and associated aquatic values may or may not lead to concern about groundwater

resources.
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Page 1, Questions 9-10. Re: Air and water monitoring. Current, past and future funding for monitoring does not appear to be an issue germane to the analysis.

Certainly the need to monitor such resources must be a topic discussed in the record of decision (§1505.2(c)). The decision represents a commitment to

perform any necessary monitoring and mitigation of disclosed impacts, as well as a firm basis for future funding requests. It may be inferred that, given a

decision, if funding is not received to implement monitoring or mitigation associated with the decision then the source of the impact should be discontinued.

Page 1, Question 11. Re: Formal agreements for the study and protection of Yellowstone’s natural and cultural resources. This question is much broader than

the issues evaluated in the winter use EIS. NPS is unclear about how this information relates to the analysis or the decision to be made. The information

requested could be obtained through other sources, but again, NPS concludes this is not relevant to the analysis at hand.

Page 2, Question 12. Re: Park revenues. NPS cannot determine the context for this question or how it relates to the decision to be made.

Page 2, Question 13. Re: Visitor use. Winter visitor use statistics are presented in the DEIS on pages 143-149. NPS is uncertain about the commenter’s use of

the word “baseline”, and what information is really being asked for. The DEIS provides annual data for the various uses since the winter of 1992-3 to illustrate

the amount of use received and the latest trends in use. It is the current use, or the current average use that represents the baseline for analysis in the DEIS – i.e.

alternative A, the no action alternative. How current use levels might be affected is the subject for impact analysis in each of the other alternatives.

Page 2, Question 14. Re: Disabled access. It is clear that the law requires reasonable efforts be made to allow for accessibility. The commenter appears to

infer, as in other comment letters, that access via snowmobile is somehow more disabled user friendly than buses or snowcoaches might be. NPS disagrees

with this assessment, and feels that the DEIS alternative B places no more of a burden on disabled users than presently exists. NPS envisions that for many

potential disabled visitors, mass transit access is far more viable than that offered by snowmobile.

Page 2, Question 15. Re: Effects of preferred alternative on the surrounding counties. NPS had hoped to receive this information from Park County, and from

the other cooperating agencies as a function of the agreement signed by all parties. Park County agreed in writing to provide this information – see cooperating

agency agreement, Section VI, Cooperating Agency Responsibilities, subpart d): “Providing to the lead agency documented information on possible conflicts

between the EIS’ proposed and alternative actions and the objectives of current approved land use plans, policies and controls within the cooperating agency’s

jurisdiction.” NPS will include such information in the FEIS should it be forthcoming.

Page 2, Question 16. Re: Effects of preferred alternative on surrounding private lands. Private lands would seem to be in the jurisdiction of States and

Counties. Therefore, as in the previous question, any impacts on private lands might more appropriately be identified within the special expertise and

jurisdiction of those government entities. Since there were no issues identified during scoping and no potential impacts identified by either the park service, the

cooperating agencies, or the general public relative to private lands and winter use, there is nothing to disclose in this area. The FEIS shall state this, in the

absence of additional information.
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Page 1. Re: Teton county does not support any alternatives as currently packaged. NPS takes this opportunity to address the complexity of alternative

formulation in this effort. Many suggestions for alternatives or alternative features were made in the thousands of comments received. A great deal of criticism

was leveled at the current range of alternatives because people did not like the way features were “mixed.” At the same time, many people focused on features

of alternatives that they liked, and features to which they were opposed. It is clear that for such complex issues there could be an infinite number of possible

alternatives. CEQ states that in such instances, the agency need only consider a reasonable number of examples that cover the full spectrum of possible

alternatives that meet the purpose and need (Question 1b, CEQ 40 Most-Asked Questions). What constitutes a reasonable range depends on the nature of the

proposal and the facts in each case, where the proposal is at the discretion of the agency.

The final selected alternative that is to be documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS. Such

mixing can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside the range of

alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the record of decision, along with the

rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail. This material will be explained in a new FEIS

section on the decision to be made.

Page 1. Re: Support for Revised Alternative E. Revised Alternative E comes from cooperating agencies and the Blue Ribbon Coalition in a variety of forms.

The essentials of Revised Alternative E, all versions considered, are not significantly different from alternative E as presented in the DEIS, especially

considering the programmatic nature of the proposed action. See the matrix comparison of Revised Alternative E versus the features analyzed in the range of

alternatives. All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree.

Page 1. Re: Support creating an advisory committee. NPS appreciates expressions of support for various alternative features, as well as legitimate criticisms.

Generally, expressions of support or objection will not be responded to by changes in alternative features. They will be responded to when the decision criteria

are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision. People who commented in this fashion are asked to

consider that there is a very clear separation between alternatives legitimately considered in an analysis and the expression of a preferred alternative or the

decision to be made.

Page 2. Re: Consistency between regional National Parks. NPS agrees with the need for consistent management. Essentially, this is the purpose for performing

a joint EIS with integrated alternatives. If management practices differ between the 3 park units as a result of the decision, it is incumbent on NPS to provide

sufficient rationale for the difference.

Page 2. Re: Bio-based fuel requirement not enough. NPS agrees that, regardless of the eventual decision, any allowable motorized use (including

administrative use) should incorporate the “cleanest” technologies and fuel sources. Appropriate provisions are built into the alternatives for such direction.

Page 2. Re: Against plowing road from West Yellowstone to Old Faithful. NPS appreciates expressions of support for various alternative features, as well as

legitimate criticisms. Generally, expressions of support or objection will not be responded to by changes in alternative features. They will be responded to

when the decision criteria are developed, and accordingly, when the rationale for the eventual decision is presented in the Record of Decision.

Pages 2-3. Re: Not adequate analysis of Teton County Impacts. NPS is and has been open to information about the effects of all alternatives on adjacent lands.

The impacts mentioned in this comment, i.e. potential increased use of YNP south entrance and impacts to national forest lands, are disclosed and discussed in

the DEIS for all alternatives. NPS feels the discussions are sufficient, but would welcome any further specific statements of impact provided by the cooperating

agencies.
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Page 3. Re: Safety concerns about the plowed road section in alternative B. NPS is aware of inherent risks associated with winter driving either on plowed or

groomed routes. This rationale would apply to every road or groomed route in the GYA. Safety concerns and potential impacts of alternative B are discussed

on page 203 of the DEIS. NPS disagrees that plowed road access from West Yellowstone to Old Faithful would result in a snow tunnel. There would be

sections having relatively high berms, but in our judgment there would be no significant difference from a visual and safety standpoint between this road

segment and the road between Colter Bay and Flagg Ranch. What makes the Colter to Flagg hazardous in this context is the co-location of the road and the

CDST. The latter situation is addressed in different (alternative) ways – construct a separate route (alternative B), widen the highway corridor (alternatives C

and D), do not plow north of Colter and put the CDST on the groomed road (alternative E), provide a CDST shuttle service to Flagg (alternatives E/F), and

remove both vehicular and snowmobile traffic in favor of oversnow mass transit from Colter Bay (alternative G). Similar options are presented for the West

Yellowstone to Old Faithful route across the range of alternatives, all of which are analyzed from the standpoint of safety.

Page 3. Re: NPS should be responsible for ensuring science is accurate. Recreation carrying capacity studies would be implemented under any alternative. The

FEIS will reflect interim carrying capacities in some alternatives to mitigate the identified impacts. Most alternatives indicate when implementation would

occur. It can be assumed that implementation includes the setting of use capacities. The FEIS will clarify this point.

Page 3. NPS agrees.

Page 4. Re: Future transit coordination. NPS agrees that it is important to coordinate the implementation of any project or program with local government and

adjacent land management jurisdictions. Grand Teton National Park is presently embarking on a transportation planning effort for that very purpose –

coordination with Teton County – outside the scope of the winter use plan. Clearly all efforts will need to be consistent in terms of management.

Page 4. Re: Groomed nordic skiing option. NPS reiterates the programmatic nature of the winter use plan and EIS (§1508.18(b)(2) and (3)). While we agree

that no alternative proposes a large grooming program for nonmotorized uses, the choice is nonetheless available to the decision maker. In any alternative with

an emphasis on nonmotorized recreation, the grooming of some trails may not be entirely inconsistent with the programmatic intent of the plan.

This programmatic approach is acceptable under the law. Such documents make decisions and allocations at a general level and defer many specific project

decisions (implementing the plan) to a later date. Some site-specific decisions will require additional NEPA analysis and a new decision that is “tiered”

(§1508.28) to, or supported by, the programmatic plan. Through additional NEPA, programmatic plans can also be amended.
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Cover letter. Re: DEIS’ Focus on pollution levels. The EIS must evaluate and disclose the effects of the alternatives for winter recreation use on water quality.

The larger picture is in fact disclosed in the DEIS in the cumulative impacts analysis (page 321), which mentions other sources of impact including sewage

effluents. The DEIS states that snowmobile emissions would appear to only add a very small increment of pollution to other more significant water quality

impacts. Disclosure of the direct and indirect effects of winter use, and their additive effect on cumulative sources of impact is done in accordance with CEQ

regulations (§1508.7 and §1508.8). The issue of water and sewage facilities is being handled in a different forum, and any analysis specific to this issue is

beyond the scope of the winter use EIS.

Cover letter. Re: If NPS implements an adaptive approach. Processes associated with adaptive management will be provided in the FEIS: definitions,

administrative actions, study methods, management actions, and NEPA requirements.

Cover letter. Re: Preference for alternative B. NEPA (CEQ Regulations) does not stipulate the rationale for selecting a preferred alternative in an EIS. It

stipulates that in a final EIS, a preferred alternative must be identified. The statement of preference for one or more alternatives in a draft EIS is discretionary,

depending upon whether the agency has a preference at that point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded by

the public as extremely tenuous. This is because an EIS is to serve as a means of assessing impacts of proposed agency actions “rather than justifying

decisions already made” (§1502.2(g)). The FEIS preferred alternative may be viewed more as a “precursor” decision, which will only become final in a

Record of Decision that expresses the rationale for the choice. In any case, it is clear that merely the expression of a preferred alternative, by itself, can in no

way invalidate the entire EIS analysis. The decision maker can select any of the alternatives in a Final EIS through consideration of a variety of factors,

including but not limited to environmental impacts.

Cover letter. Re: Cooperating Counties Revised Alternative E. NPS feels that the Revised Alternative E is not significantly different from alternative E

analyzed in the DEIS, in terms of any environmental effects that might be disclosed for each. Cooperating agencies’ preference goes more to the decision to

be made than to substantive reasons for changing the range of alternatives or the analysis. The decision maker is responsible for considering the opinions and

preferences of the cooperating agencies.

Re: Attachment to cover letter listing the “flaws and positives” of alternative B. This listing is a mix of features that occur in one or more alternatives (to

which the commenter is both pro and con), and perceived weaknesses in the analysis that applies to more than just alternative B. Also, the bulleted statements

are not clearly stated to the degree that NPS can respond effectively.

Re: Attachment to cover letter spelling out cooperating counties’ Revised Alternative E. Revised Alternative E comes from cooperating agencies and the Blue

Ribbon Coalition in a variety of forms. The essentials of Revised Alternative E, all versions considered, are not significantly different from alternative E as

presented in the DEIS, especially considering the programmatic nature of the proposed action (§1508.18(b)(2)). Some features of Revised Alternative E are

present elsewhere in the range of alternatives considered. See the matrix comparison of Revised Alternative E versus the features analyzed in the range of

alternatives.

NPS takes this opportunity to further address the complexity of alternative formulation in this effort. Many suggestions for alternatives or alternative features

were made in the thousands of comments received. A great deal of criticism was leveled at the current range of alternatives because people did not like the

way features were “mixed.” At the same time, many people focused on features of alternatives that they liked, and features to which they were opposed. It is

clear that for such complex issues there could be an infinite number of possible alternatives. CEQ states that in such instances, the agency need only consider

a reasonable number of examples that cover the full spectrum of possible alternatives that meet the purpose and need (Question 1b, CEQ 40 Most-Asked

Questions). What constitutes a reasonable range depends on the nature of the proposal and the facts in each case, where the proposal is at the discretion of the

agency.

The final selected alternative that is to be documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS. Such
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mixing can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside the range of

alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the record of decision, along with the

rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail. This material is explained in a new FEIS section

on the decision to be made.

Page 1. Re: Difference between existing and desired condition. It is the nature of the decision that may not be well understood. It has been NPS’ intent from

the beginning of the process to prepare a programmatic plan (§1508.18(b)(2) and (3)). This would be the purpose of preparing a “comprehensive EIS.” There

should have been no illusions that a plan of this magnitude would be based upon detailed, site-specific data in order to make every decision possible relating to

winter use. This programmatic approach is acceptable under the law, in the way that NEPA is the vehicle for producing NPS General Management Plans and

USFS Forest Plans, and amendments thereto. An expression of general goals and objectives (purpose), and a general description of existing conditions (need)

is entirely appropriate for this level of analysis. Though the alternatives are designed to respond in different ways to the purpose and need for action, NPS will

improve the linkage between alternative concepts and objectives.

Page 1. Re: Socioeconomic Effects. There are several reference in the CEQ regulations applying to socio-economic analysis. There are several major reasons

for this. First, the scoping process as conducted under §1501.7 inevitably raises the social and economic effects of a proposed action. In many instances,

these are regarded as significant issues. Second, the impacts must be considered in the context of society as a whole, the affected region, the affected interests,

and the locality (§1508.27(a)). Third, the intensity of impacts on the quality of the human environment must be gauged (§1508.27(b)), where “human

environment” is to be viewed comprehensively (§1508.14). Effects (direct, indirect and cumulative) are defined as including both economic and social

impacts (§1508.8). However, there is nothing in the regulations that stipulates the weight which must be put on these effects in the decision process.

Pages 2-4. Full identification and discussion of existing socio-economic authorities, etc. Thank you for correcting this citation, which should read (p. 159

DEIS): "Economic and Environmental Principles and Guidelines for Water and Related Land Resources Implementation Studies (U.S. Department of Interior,

1983). This reference has previously been used by the DEIS authors to guide benefit-cost type of analysis. The citation is not necessary in the context of the

current document and will be deleted. Most of the analysis relies on the winter survey report, which has been peer reviewed and was finalized in early May

2000.

Page 4. Pages 83-93 Re: affected social and economic environments. The NPS is not aware of definitive information about the degree to which winter

industry growth has occurred in response to federal policy However, the NPS does not feel this would be an especially relevant disclosure. Growth in winter

use industries and increased use was not entirely at the behest of the federal government. Communities willingly engaged in these activities, and marketed

them accordingly while NPS found supportive policies. The relevant frame of reference is, as indicated in the purpose and need for action, to determine the

level of use that may occur without adversely affecting park resources.

Page 5. Re: Commenter on page 3 indicates that counties were not allowed to provide specific socio-economic analysis on each alternative, but that they

provided general economic effects for each county which NPS “failed to utilize.” On page 5, commenter states that the counties each submitted detailed

analysis of specific economic effects, and that the counties urge NPS to incorporate this information into the EIS.

NPS did not fail to use information provided by the cooperating counties. Information provided by the counties was made available to the Park Service’s

economics consultant. According to the CEQ regulations, §1503.3(b), commenting agencies that criticize an analysis methodology should describe an

alternative methodology and why it prefers it. The commenter, in this instance refers to counties’ economic analyses, but does not specifically indicate what is

incorrect about the agency method – other than it arrives at a different answer. If there is a significant difference of opinion, as there may be in this case, then

the remedy provided in CEQ regulations (§1502.9(a)) is to report both opinions in order to meet the disclosure requirement. This approach was taken in the

DEIS by reporting the results of NPS studies and the reports from each cooperating agency. Page 83 of the DEIS makes reference to the use of source

information provided by the cooperators, all of which is presented in DEIS Appendix A. The characterization of the socioeconomic environment specifically

cites information from the cooperators where applicable. On pages 298 through 315, the DEIS discloses the impacts of each alternative on adjacent lands in
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the cooperating agencies’ own terms. Given this, NPS disagrees that the input from the cooperating agencies was not incorporated.

Page 5 Re: Threat of degradation of streams. The EIS must evaluate and disclose the effects of the alternatives for winter recreation use on water quality. The

larger picture is in fact disclosed in the DEIS in the cumulative impacts analysis (page 321), which mentions other sources of impact including sewage

effluents. The DEIS states that snowmobile emissions would appear to only add a very small increment of pollution to other more significant water quality

impacts. Disclosure of the direct and indirect effects of winter use, and their additive effect on cumulative sources of impact is done in accordance with CEQ

regulations (§1508.7 and §1508.8). The issue of water and sewage facilities is being handled in a different forum, and any analysis specific to this issue is

beyond the scope of the winter use EIS.

Page 6. Adaptive management remains a choice in the range of alternatives. NPS will continue to work with State and Local governments regardless of the

alternative that may be selected. NPS cannot share its responsibility to make decisions on winter use in the parks.

Page 7. Re: Lack of scientific information. Concerns are noted. The EIS analysis is aimed at developing a programmatic plan (§1508.18(b)(2) and (3)) for

winter use. If the concern relates to lack of site-specific information, it should also be noted that there is no burden to develop site-specific information to

support a programmatic planning document. Without further information, we are unable to address general concerns as to what is meant by inadequate

science. An EIS is not, per se, a scientific analysis. It is intended to disclose environmental effects over a range of alternatives, in which the analyses must

demonstrate scientific integrity by disclosing methods and making explicit references to sources used (40 CFR 1502.24). The DEIS does this. CEQ

regulations also allow for incomplete or unavailable information, by describing procedures that are to be following in these instances (§1502.22). Any

identified gaps in the FEIS will follow the requisite procedures.

Page 8. The establishment of an interim visitor carrying capacity is a function of the decision to be made. To help facilitate the decision, setting a seven-year

average cap will be considered as mitigation for one or more alternatives.

Page 8. Re: Wildlife carrying capacity. Work accomplished by biologists on defining the wildlife affected environment and the effects of winter use on it are

cognizant of the carrying capacity issue. Such determinations include many factors other than those associated with winter use. For this reason, NPS holds to

its determination that setting, or determining, carrying capacities is beyond the scope of this effort. Steps are being taken to make the winter use EIS analysis

as consistent as possible with that of the Bison EIS. NPS will clarify this issue as much as possible in the final document.

Page 8. Re: Dispersal of activities. Colter Bay is considered as a staging area for snowmobiling and snowcoaches in alternative D, and for snowcoaches in

alternative G. These alternatives in effect provide the opportunity for visits to Flagg Ranch as an oversnow experience. Yellowstone NP increases day use

facilities in several alternatives, but it is deferring consideration of additional wintertime, overnight facilities pending the concession plan. The draft

concessions plan for Yellowstone National Park is currently being written and will be available for public review in 2001.

Page 9. The suggestion of expanding nonmotorized opportunities away from main motorized routes, serviced by skier shuttles, is consistent with both current

management and other alternatives.

Page 9. Re: 1998-99 Winter Survey. Winter recreation use figures are being updated to include the current year. The assessment of visitor use and access

will use the best available information from surveys and other data sources.

Page 9. Re: Ideas considered but not included. Presuming the commenter refers to Appendix A, Volume II, NPS feels that the rationale given in that section

is sufficient to explain why the options were not viable or appropriate for this EIS.

Page 10. Re: Draft Report. Comment reviewed by economics consultant. Method is explained in the final report and the FEIS.

Page 10. Re: Specificity. Presuming the commenter refers to Appendix A, Volume II; NPS feels that the rationale given in that section is sufficient to explain

why the options were not viable or appropriate for this EIS.

Page 10. Omissions and Research Gaps: Point 1. The report by Dr. Taylor is listed at the beginning of the appendix among other reports and data submitted

for review and incorporation by the cooperating agencies. Dr. Taylor’s report, and the other information, was used by NPS’ economic consultant in the
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preparation of the socio-economic analyses.

Omissions and Research Gaps: Point 2. The cooperating agencies have to date identified no conflicts between any of the alternatives evaluated and any

provisions of land use plans for state or private lands (if such plans exist). Similarly, none of the counties have identified specific conflicts between any of the

alternatives and any current or existing county plans. This would be a function of the special expertise of state and local governments, and NPS would

welcome this information cited as necessary to relevant portions of plans.

Omissions and Research Gaps: Point 3. Cooperating agencies are discussed on page 9 of the DEIS. At the end of this short section, a reference is made to the

agreements to be found in Appendix I. The table of contents for Volume II indicates that Appendix I contains these agreements. The information is present

and locatable. NPS will consider elaborating on the cooperating agency provisions of the CEQ regulations in the body of the document.

Omissions and Research Gaps: Point 4. NPS fails to see the point. Subnivian fauna were dismissed as an impact topic, page 81 of the DEIS.

Omissions and Research Gaps: Point 5. The DEIS discloses impacts, if any, on geothermal areas. It is not clear what is being referred to.

Omissions and Research Gaps: Point 6. Additional information is available from recently completed visitor surveys subsequent to the publication of the DEIS.

The FEIS will incorporate it.

Omissions and Research Gaps: Point 7. For programmatic analyses information need not be exhaustive, and decisions can be made where data is uncertain.

Certainly it would be reasonable to pursue focused monitoring along these lines where the uncertainty may be critical to a decision.

Omissions and Research Gaps: Point 8. NPS agrees.

Omissions and Research Gaps: Point 9. The ARD report and events surrounding its release had nothing to do with the DEIS or the process used in writing air

impacts analysis.

Page 12 Re: Analysis. The comment refers to background information for cultural resources located in Appendix C. Analysis of cultural resource impacts

occurs in the body of the DEIS.
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Page 1 and 2. Re: It is clear that the preferred alternative will not address the most pressing issues. All alternatives in the DEIS meet the purpose

and need for action to a greater or lesser degree. An identified gap between existing conditions and desired conditions form the basis for the purpose

and need for action. This purpose is represented by the desired condition shown on page 3 of the DEIS. The underlying need (§1502. 13) is defined

by the existing conditions expressed on page 4. Despite the complexities introduced by multiple goals and multiple issues, all alternatives represent

possible actions that meet the underlying purpose and need. A decision maker may set the scope of analysis and the decision to be made within the

constraints of those dictates.

Page 2. Re: Based on air quality impacts alone, snowmobiling is not consistent with the park’s management objectives. The impacts in question

are not on their face indisputable, and it is the function of an EIS to focus the issues by addressing those impacts as well as possible. Where

management that serves the enjoyment of the people steps over a line in respect to resource preservation, the action to be taken is clear. It is that

line, or threshold, that is not often clear. It is up to the decision maker to weight the available data and make the determination of what exactly

constitutes impairment. Additional air quality analyses and modeling, formerly unavailable for inclusion in the DEIS, will be included in the FEIS.

Page 2. Re: Conflicting statements in the DEIS, lack of hard data and gaps in the data, so NPS should err on the conservative side when adopting a

preferred alternative. An EIS is not, per se, a scientific analysis. It is intended to disclose environmental effects over a range of alternatives, in

which the analyses must demonstrate scientific integrity by disclosing methods and making explicit references to sources used (40 CFR 1502. 24).

The DEIS does this. CEQ regulations also allow for incomplete or unavailable information, by describing procedures that are to be following in

these instances (§1502.22). Any identified gaps in the FEIS will follow the requisite procedures.

Page 2. Re: Flawed alternatives – measures that protect resources, increase public safety and interpretation opportunities should be included in all

alternatives. It is within the discretion of the decision maker to set the range of alternatives to be considered. The final selected alternative that is

to be documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS. Such mixing can occur as long

as the mixed features are consistent with one another, and as long as the effects of such an alternative would not fall outside the range of effects

disclosed in the EIS. If the features that the commenter did not support were to be deleted from the range of alternatives, then the analysis would be

left only with features that the commenter likes or agrees with. If only the actions that are liked by the commenter remain, then there is effectively

only one alternative, or a set of alternatives that are not significantly different. There is a very clear separation between alternatives legitimately

considered in an analysis and the expression of a preferred alternative or the decision to be made.

Many suggestions for alternatives or alternative features were made in the thousands of comments received. A great deal of criticism was leveled at

the current range of alternatives because people did not like the way features were “mixed.” It is clear that for such complex issues there could be

an infinite number of possible alternatives. CEQ states that in such instances, the agency need only consider a reasonable number of examples that

cover the full spectrum of possible alternatives that meet the purpose and need (Question 1b, CEQ 40 Most-Asked Questions). What constitutes a

reasonable range depends on the nature of the proposal and the facts in each case, where the proposal is at the discretion of the agency. Under the

CEQ regulations, the requirement in an EIS is to provide a range of reasonable alternatives that clearly define the issues, and to fully evaluate and

disclose the possible effects of those alternatives. The DEIS meets this requirement.

Page 3. Re: Features of the preferred alternative may adversely affect wildlife. The analysis in the DEIS discloses the impacts to wildlife

associated with the preferred alternative. The determination as to whether or not these impacts constitute an impairment or derogation of park values

(wildlife, in this case) is made by the decision maker when formulating the Record of Decision.

Page 4. Re: Animals will be trapped by snow berms. The DEIS discusses the impacts associated with snow berms along the plowed road corridor,

and suggests mitigation (p. 209). NPS and the commenter disagree on whether or not a so called tunnel effect would result from plowing. In many

other areas within and outside the 3 park units, roads are plowed and no tunnel effect exists.
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Page 4. Re: Preferred alternative does not identify the risk of vehicle-animal collisions under alternative B although there is an admittedly

ineffectual mitigation measure proposed. The DEIS discusses vehicle-animal collisions on page 209 for the preferred alternative. See response

below.

Page 4. Re: Revise travel restrictions under the preferred alternative to the period from sunset to sunrise. This suggestion is within the range of

alternatives that the decision maker may choose among. Please see response, “Page 2. Re: Flawed alternatives...” for a discussion of “mixing”

alternative features.

Page 4. Re: Impacts associated with warming huts are not analyzed. Impacts associated with warming huts are discussed for each alternative

under the heading “Presence and use of winter supporting facilities”.

Page 4. Re: Shorten the winter season under the preferred alternative to protect grizzlies coming out of hibernation. This suggestion is a feature of

alternative F and is therefore within the range of alternatives that the decision maker may choose among. A discussion of the impacts of winter use

on grizzlies during the pre and post denning periods is included in the biological assessment and will be incorporated into the FEIS.

Page 5. Re: Effects on bison as an ethnographic resource – NPS needs a better plan for managing bison rather than lethal control. The NPS is

working to ensure that the Winter Use Plan and the Bison Management EIS/Plan are coordinated and that analyses are parallel and consistent in

regard to the effects of winter use on bison. The Bison Management EIS/Plan addresses the issue of bison removals.

Page 5. Re: Address the effects of road grooming on bison migration patterns. In an effort to better understand the relationship of bison movements

and the use of the winter groomed road system, managers have instituted studies that address this issue. While groomed roads may have contributed

to the redistribution of bison within park boundaries (Meagher 1997), it appears that bison tend to use waterways and off-road trails for much of their

travel on the west side of the park (Bjornlie and Garrott 1998), and that much of their movement toward park boundaries may occur on such routes.

Monitoring of bison movements in the Hayden Valley and Mammoth to Gibbon Falls sections of the park has found that less than 12% of bison

movements occurred on the groomed road surface (Kurz et al. 1998, 1999). However, groomed roads may have allowed larger numbers of bison to

exist in the park than in the absence of groomed roads, by allowing access to otherwise unavailable foraging areas, and westward redistribution early

in the winter may predispose some bison to exit the park (Meagher 1997). Therefore, closing of groomed roads could have the effect of reducing

population size and shifting distribution back to patterns observed before grooming, thereby possibly reducing the magnitude of bison movements

outside park boundaries. Conversely, bison are highly social and appear to retain and pass along knowledge through generations, so it is possible that

closing groomed roads may not impact bison movements and distribution (Meagher 1985). Research is currently being conducted to better understand

the relationship between road grooming and bison movement and distribution patterns.

Page 5. Re: The adopted alternative should protect bighorn sheep. Alternative G identified in the FEIS will include restrictions on backcountry

travel in bighorn sheep areas.

Page 6. Re: Analyze lynx population and habitat needs. The biological assessment contains a lengthy discussion and analysis of lynx. This

information will be included in the FEIS as well.

Page 6. Re: Include mitigation to protect eagles. The biological assessment contains a lengthy discussion and analysis of bald eagles. This

information will be included in the FEIS as well.

Page 6. Re: Adequately address impacts to wildlife species, especially effects of fragmentation. There will be an expanded species of concern and

bison discussion in the FEIS. Habitat fragmentation is discussed, by alternative, as a possible outcome of plowing and grooming roads. CEQ

regulations do not require exhaustive and voluminous discussion (§1500.4(f)). The amount of detail to be included in an EIS should be that level

which is relevant to the decision to be made, and the NPS believes it has adequately met this requirement.
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Page 6. Re: Analyze the effects of noise on wildlife. Because quantifying the effects of non-natural sound on animals in the wild (as opposed to a

controlled laboratory setting) is extremely difficult, NPS believes that analyzing the effects of machine noise on ambient sound levels is a legitimate

substitute and can be used to infer effects on wildlife. NPS also believes that the effects of noise on wildlife are inherently included in the overall

effects of snowmobiles on wildlife in terms of disturbance. Nonetheless, a review of the impacts of noise on wildlife will be included in the FEIS.

Page 6. Re: Address impacts of air pollution on flora and fauna. The evaluation of pollution impacts by alternative is presented in the environmental

consequences section of the DEIS. This analysis will be enhanced in the FEIS using results from air quality and modeling.

Page 6. Re: Effects of sand on sedimentation of waterways should be addressed. There is a greater amount of final study information available to the

NPS for inclusion in the FEIS than was available prior to the publication of the draft. Water and aquatic resources sections will be updated in

accordance with this data.

Page 7. Re: Effects of emissions on water quality should be addressed. The DEIS discusses this issue under the effects on water resources for each

alternative and in the environmental consequences section. Additional information has become available (Ingersoll, Effects of Snowmobile Use on

Snowpack Chemistry in Yellowstone National Park, 1998) since publication of the DEIS, and will be incorporated into the final document.

Page 7. Re: How did NPS determine that new warming huts would only cause minor impacts to wildlife? See pages 169-170 for a description of the

methods used to assess impacts on wildlife. The effects of warming huts on lynx are assessed in the biological assessment; this discussion will be

incorporated into the FEIS. Warming huts are expected to cause minor impacts because they will be located in the front-country at trailheads where

visitor use already occurs. Site-specific analyses will be conducted before any construction begins, and the public will have the opportunity to

comment.

Page 7. Re: A full analysis of impacts to geothermal areas is necessary, including site specific EIS. The EIS analysis is aimed at developing a

programmatic plan for winter use (§1508. 18 (b)(2). There is no burden to develop site-specific information to support a programmatic planning

document.

Page 7. Re: The DEIS “admits” that plowed roads cause impacts yet proposes additional plowed roads in the preferred alternative. Many comments

restate the disclosure of effects present in the DEIS. Some commenters refer to any disclosure of an impact as NPS’ “admitting” that an action would

cause harm. Readers should understand that it is the purpose of an EIS to disclose the possible effects of a proposed action and alternatives to it.

References in comments to the “justification” for a preferred alternative is an entirely different issue relating to the decision to be made. Comments

expressing opposition or support for an alternative feature are not responded to by changing an alternative or a preference.

Page 8. Re: Close the CDST because the impacts on wildlife are too great. The commenter’s opinions will be considered in making the final

decision, but that there is nothing in those opinions that substantively would alter the range of alternative features to be evaluated in the Final EIS. It

will be up to the decision maker to weigh the available data, evaluate the possible impacts of each alternative, and decide if park resources, including

wildlife, are impaired. The impacts in question are not on their face indisputable, and it is the function of an EIS to focus the issues by addressing

those impacts as well as possible. The new preferred alternative eliminates snowmobiling in the parks.

Page 8. Re: Snowmobiles violate closed areas and cause adverse impacts. Occasionally snowmobiles leave the groomed surface and travel alongside

the road or enter closed areas. These violations are cited by NPS rangers. NPS does not regard this as a usual occurrence, but recognizes the

potential for adverse impacts.

Page 8. Re: Off-road impacts need to be analyzed because of the above mentioned violations. See previous response.

Page 9. Re: Socioeconomic impact analysis on pages 87-89 is not adequately supported with hard data and is too generic. NPS disagrees. The

analysis is sufficient for producing a programmatic plan, which is general in nature. There is a considerable amount of data invoked in this analysis.
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Page 9. Re: The socioeconomic analysis does not adequately differentiate winter from summer recreation expenditures, nor does it take into account

expenditures due to other attractions. The discussion of the existing condition focuses explicitly on winter visitation. Tables five and six are presented

as a context, considering the total economy, for comparing economic impacts associated with winter use in the various alternatives.

Page 9. Re: The projected losses under the preferred alternative do not take into account other economic opportunities such as an increase in other

types of visitors. This is true. The economic analysis is conservative in that it shows small and negligible economic impacts over the regional

economy and the 17-county economy, even if other types of visitors do not choose to come. If other types of visitors come, the various economies are

only improved.

Page 9. Re: Visitor use survey was biased, visitor use should not drive the EIS process. The surveys do not drive the process – they represent

information available to assess impacts. As this survey information is reported or cited in the DEIS, the limitations of the survey are made evident.

Additional survey information is now available for the FEIS, and those data will similarly be accompanied by assumptions and survey limitations.

The data is used to report impacts, primarily those involving visitor experience and social and economic environments. This is entirely appropriate

under NEPA. The final strategy, or decision, is based on selection criteria used by the decision maker, which are disclosed in the record of decision

through discussion of “preferences among alternatives based on relevant factors including economic and technical considerations and agency statutory

missions” (§1505. 2(b)).

Page 9. Re: Support for the Citizen’s Solution. Expressions of support or objection to specific alternatives or alternative features will be responded to

when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision.
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Page 2.Re: EIS as a long-term planning document and ongoing winter use studies. Studies monitoring and data collection relative to winter use are and will be

ongoing in the park units. By this EIS and the eventual decision, NPS does not foreclose on any necessary management actions for park protection that might

be precipitated in the future.

Page 2. Re: Preliminary list of EIS alternatives. “The primary purpose of an environmental impact statement is to serve as an action-forcing devise to insure

that the policies and goals defined in the Act [NEPA] are infused into the ongoing programs and actions of the Federal Government (§1502.1).” “The range of

alternatives discussed in an [EIS] shall encompass those to be considered by the ultimate agency decision maker (§1502.2 (e)).” The purpose and need for

action described in the DEIS is sufficiently broad to act as an action-forcing tool. It is within the discretion of the decision maker to set the scope of analysis.

Considering that motorized use in the Parks is an existing use, not a proposed use, it is logical to frame the purpose and need in terms that would include that

use and facilitate an incremental investigation of the impacts of that use. To do otherwise would result in a narrow scope of analysis and one viable alternative

relative to motorized use. The settlement agreement that resulted in a need to develop this EIS requires a comprehensive evaluation of winter recreation use.

The presumption that only nonmotorized use should be considered in light of policy, law, regulation and existing use, is not appropriate. NPS disagrees that all

alternatives represent the status quo, and that there is overwhelming evidence that certain activities adversely affect the resources to a degree that their

preservation is not ensured.

Page 2. Re: Statutory and regulatory mandates and their application to snowmobile use. Sufficient documentation on this point is in the DEIS.

Page 2. Re: Involvement of cooperating agencies. The intent of granting cooperating agency status was in the spirit of cooperation and coordination consistent

with NEPA, FACA and APA. The content of the document has been affected, but NPS disagrees that the analysis has been. The document incorporates

material from the cooperating agencies, which is reported as a matter of full disclosure even though the results disagree with NPS analysis. Letters from the

cooperators and the signed agreements between NPS and cooperators were included in the DEIS, Volume II. These items relate to content. As to inappropriate

influence, one need only review media reports, comment letters or other correspondence from the cooperators to obtain their assessment of how they were

involved and how influential they feel they have been in the process.

Page 3. Re: Trail closures during winter 1999-2000. A comment about what NPS should have done in the winter of 1999-2000 is moot at this time.

Page 3. Re: Additional studies that NPS should initiate during the winter of 1999-2000. Additional data collection has been undertaken with respect to sound.

Additional air quality models have been run. Information is available on snowpack chemistry that was not usable in the DEIS.

Page 3. Re: Impacts on wildlife species. The impacts on all potentially affected species are disclosed in the DEIS.

Page 3. Re: Impacts on air quality. The impacts of snowmobiles on air quality are disclosed in the DEIS.

Page 4. Re: The parks should set the standard for clean air, clean water, serenity, and solitude. The function of various provisions in the range of alternatives is

to set limits on impacts, and to set standards/objectives for management in identified zones within the parks.

Page 4. Re: Impacts due to snowmobile use. These impacts are disclosed in the DEIS.

Page 4. Re: Impacts on bison due to trail grooming. Impacts on bison have been evaluated and disclosed in the DEIS. Mary Meagher’s work was available

for use in the DEIS, and it is cited appropriately.

Page 5. Re: Impacts on grizzly bears. Impacts on grizzly bears have been evaluated and disclosed in the DEIS.
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Page 5. Re: NPS fails to consider an alternative that would ban snowmobiles, snowcoaches, and trail grooming.

“The primary purpose of an environmental impact statement is to serve as an action-forcing devise to insure that the policies and goals defined in the Act

[NEPA] are infused into the ongoing programs and actions of the Federal Government (§1502.1).” “The range of alternatives discussed in an [EIS] shall

encompass those to be considered by the ultimate agency decision maker (§1502.2(e)).” The purpose and need for action described in the DEIS is sufficiently

broad to act as an action-forcing tool. It is within the discretion of the decision maker to set the scope of analysis. Considering that motorized use in the Parks

is an existing use, not a proposed use, it is logical to frame the purpose and need in terms that would include that use and facilitate an incremental investigation

of the impacts of that use. To do otherwise would result in a narrow scope of analysis and one viable alternative relative to motorized use. The settlement

agreement that resulted in a need to develop this EIS requires a comprehensive evaluation of winter recreation use – the presumption that only nonmotorized

use should be considered in light of policy, law, regulation and existing use, is not appropriate. NPS disagrees that all alternatives represent the status quo, and

that there is overwhelming evidence that certain activities adversely affect the resources to a degree that their preservation is not ensured.

The detriment of actions on park resources is not determined until the requisite environmental analysis determines it to be so. That is the function of an

incremental analysis facilitated by the alternatives in this EIS. The decision to be made will weigh the effects analysis and make a determination about the

extent of allowable activities in light of park mandates, executive orders, regulations and policies.

Page 6. Re: Snowmobiling and trail grooming clearly violate legal standards. There is nothing in literature that conclusively demonstrates that the resources of

the 3 park units have exceeded an “impairment standard.” There are a great number of inferences drawn from general studies, or studies that were undertaken

elsewhere. Results are extrapolated to the 3 park units, where conditions or circumstances are not demonstrated in the literature to be applicable. There is very

little in the literature to provide a solid basis for determining at what point a potential impact becomes an adverse effect on park resources. This is contrary to

the commenter’s apparent assumption that “impairment standards” are self-evident and agreeable to all. It is the function of the EIS to disclose the extent,

magnitude and duration of impacts within the park units to the degree necessary for programmatic planning. NPS maintains that the standard of impairment

can be a function of the criteria used by a decision maker in the record of decision, considering impacts disclosed in the EIS.

Page 6. Re: Requirement of a new alternative. NPS disagrees that a new alternative is required. BDF predicates this assertion on a disagreement about the

purpose and need for action. CEQ regulations require a range of alternatives sufficient to meet the purpose and need for action (§1502.13). The purpose and

need for action is discretionary to the agency and the decision maker (§1500.4(g) and §1501.7(a)(2)) to set the scope of analysis. It is clear the commenter

disagrees with the purpose and need. If the court settlement carried as much weight as the commenter feels, it seems there would be no need to actually

perform an environmental analysis.

Page 6. Re: Local economic pump priming vs. national concerns. The commenter is undoubtedly aware that the consideration of social and economic impacts

is routinely done in any environmental analysis. There are several major reasons for this. First, the scoping process as conducted under §1501.7 inevitably

raises the social and economic effects of a proposed action. In many instances, these are regarded as significant issues. Second, the impacts must be considered

in the context of society as a whole, the affected region, the affected interests, and the locality (§1508.27(a)). Third, the intensity of impacts on the quality of

the human environment must be gauged (§1508.27(b)), where “human environment” is to be viewed comprehensively (§1508.14). Effects (direct, indirect and

cumulative) are defined as including both economic and social impacts (§1508.8). As disclosed in the EIS economic impacts on a regional level are negligible,

and it is our assessment that the business community would adapt to such changes that might accrue to any of the alternatives.

Page 7. Re: Additional legal issues. Sufficient documentation relative to NPS mandates, executive orders, regulations and policy may be found in the DEIS.

The final decision must be consistent with this guidance.
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Page 1. Re: Information provided by cooperators. The commenter is invited to review Appendix A, Consultation and Coordination in the DEIS. This section

documents that a large percentage of the suggestions from the cooperating agencies were incorporated into the range of alternatives presented in the DEIS.

Development of the preferred alternative is within the purview of the NPS. The NPS is not obliged to incorporate in the preferred alternative the preferences

that might be indicated by the cooperating agencies. Many suggestions for alternatives or alternative features were made in the thousands of comments

received. A great deal of criticism was leveled at the current range of alternatives because people did not like the way features were “mixed.” The final

selected alternative that is to be documented in a Record of Decision may mix features from the range of alternatives evaluated in the final EIS. Such mixing

can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside the range of

alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the Record of Decision, along with the

rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail.

Page 2. Re: Air Quality Summary Report. Criticism stemming from the release of the draft summary ARD report and its content is beyond the scope of this

EIS analysis and requires no response. The content of the report, so far as the alleged faulty information, was not a part of the Draft EIS. The fact that the

cooperators disagree with how the document was publicized and distributed does not affect the air resources analysis in the EIS.

Page 2. Re: Preferred alternative rationale. This comment restates the disclosure of effects present in the DEIS. Many commenters refer to any disclosure of

an impact as “admitting” something. Readers should understand that it is the purpose of an EIS to disclose the possible effects of a proposed action and

alternatives to it, and that references to the “justification” for a preferred alternative is an entirely different issue relating to the decision to be made.

Page 2. Re: Costs of road plowing. A disclosure of the costs associated with road plowing can be found in Volume II, Appendix F, Construction and

Operating Costs. The costs of both the existing road plowing and road grooming for snowmobiles are in the end absorbed by the taxpayer. Alternative B

proposes no subsidy for a park visitor to ride the mass transit bus to Old Faithful. The cost estimated for that service, as identified on page 29 of the DEIS, is

$20 to $25, not $10 to $20.

Page 2. Re: Affordable access. The stated purpose of plowing the road (DEIS, page 28) is to “improve affordable access” – not , as the commenter states, to

“provide affordable access for minority and low-income people”. A thorough reading of the EIS would reveal that a required impact topic in an EIS is to

evaluate the effects of a proposed action on socially or economically disadvantaged populations (DEIS, page 80). We disagree that this analysis is used as

“justification” for plowing in alternative B. The preferred alternative addressed the issue of affordability because it was raised as a concern during the public

scoping process. The cost of entering the park during the winter via snowcoach or snowmobile is much higher than entering the park by bus or auto. The

intent was to provide an alternative that would be more affordable. As you note in your letter, subsidizing the use of one particular user group is unfair to the

taxpayer and excludes others from enjoying their national parks. Alternative B was intended to address these issues by providing access to the park interior for

a greater diversity of park visitors, while protecting park resources. Under alternative B snowmobiles, snowcoaches, and mass transit wheeled vehicles would

access the Old Faithful Area. Due, in part, to the clear lack of support for plowing the road to Old Faithful the NPS will identify a new preferred alternative in

the FEIS.

Page 2. Re: Access to Mammoth. The DEIS has not ignored that a more affordable access exists from Gardiner, Montana to Mammoth Terraces. This area is

described on pages 136, 140, 141,and 145 of the DEIS. The North Entrance is the second busiest winter entrance to Yellowstone. As indicated on page 145

of the DEIS traffic using the highway to access Cooke City, Montana is not counted when compiling visitor use statistics for oversnow access. The Mammoth

area is, as you indicate in your letter, a popular attraction. However, it does not typically receive a reliable level of snowfall. While the northern areas of the

park are popular, the sights most visitors want to experience are Old Faithful and the Grand Canyon of the Yellowstone (see page 148 of the DEIS).

Page 2. Re: Effects on wildlife. The effects of alternative B on wildlife have been disclosed for stress, habitat fragmentation and the trapping of wildlife in

road berms. This analysis can be found in Chapter IV of the DEIS on pages 176-327.

Page 2. Re: EPA and emissions standards. The suggestion that the NPS should defer to EPA on the matter of emission standards for snowmobiles is

considered in the range of alternatives presented in the DEIS.
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Page 2. Re: Decibel levels. The NPS disagrees that the agency has misunderstood the function of a decibel rating. A range of decibel ratings have been

presented (from 60 to 78 dB(A)) in the range of alternatives in the DEIS. The analysis of the effects of these various decibels levels on the natural soundscape

of the 3 parks can be found for each alternative in Chapter IV of the DEIS. Impacts on the natural soundscape have received further study and this information

will be included in the FEIS.

Page 3. Re: Independent review of scientific studies and monitoring: published studies and monitoring reports should be available to the public. For what

should be obvious reasons, this information should not be subjected to a political process in advance of their publication. There are policies and protocols

already in place to ensure appropriate scientific review. If future studies or monitoring indicate the need for management action, NPS will follow the

requirements already set in law (such as NEPA), regulation and policy. At that time, the scientific basis for an action can be scrutinized and criticized by any

interested parties.

Page 3. Re: Establish an advisory committee to assist with study design. For obvious reasons, this information should not be subjected to a political process

in advance of their publication. There are policies and protocols already in place to ensure appropriate scientific review. If future studies or monitoring

indicate the need for management action, NPS will follow the requirements already set in law (such as NEPA), regulation and policy. At that time, the

scientific basis for an action can be scrutinized and criticized by any interested parties.

Page 3. Re: Require the sale of bio-based fuels within the Parks. This is a feature of alternatives B, C and D.

Page 3. Re: Carrying capacity. NPS is encouraged by support for establishing a recreation carrying capacity. In practice, setting a carrying capacity is a

highly complex and potentially divisive exercise. NPS managers decided there was not sufficient time available in the settlement time frame to devote to this

type of analysis. More explanation of the carrying capacity issue will be included in the FEIS.

Page 3. Re: Nighttime closure. This suggestion will be analyzed as part of alternative G in the FEIS.

Page 3. Re: Disperse use to better utilize existing facilities. Alternatives C, D and G conceptually include the opening of such facilities to one degree or

another. A reference to other plans and environmental analysis on page 17 of the DEIS includes commercial services plans for both parks. Since these plans

were in process, the decision was made not to include analysis of facilities currently being addressed. Several alternatives (B, C and D) propose new warming

huts.

Page 3. Re: Congestion and visual concerns at Old Faithful. This suggestion may be useful in site-specific implementation of any of the alternatives retaining

snowmobile use at Old Faithful. It is not a key programmatic feature; i.e. it does not require an EIS analysis for approval – it could be done now.

Page 3. Re: Expanded nonmotorized routes away from motorized routes, served by shuttle service. Additional routes are proposed in alternatives B, C, D and

G. This suggestion is programmatically compatible with all alternatives, and could be implemented without further significant environmental review (as a

function of the Winter Use EIS and the decision resulting from it). Whether solitude can actually be achieved by this separation depends upon site

characteristics and the degree to which motorized use sounds travel in the area.

Page 3. Re: Prepaid passes requirement at West Yellowstone– prepaid passes for other gates. Pre-paid passes are available in West Yellowstone. Should the

need arise at other gates for the same reasons, the service could be expanded. The rationale for this measure – mitigating pollution impacts on visitors and

employees – has a cost associated with it. Opportunities for necessary NPS-visitor contact at the gate are lost. Suggesting that all visitors forego an important

safety element of the park experience, so that their snowmobiles will be less polluting is clearly not in compliance with 36CFR 2.18. The regulation states that

snowmobiles are prohibited except where designated and only when their use is consistent with the park’s natural, cultural, scenic and aesthetic values, safety

considerations and will not disturb wildlife or damage park resources. In this case, mitigating an effect on park values and resources by completely

eliminating an important information and safety resource for park visitors is illogical. Voluntary compliance with this management option is reasonable, but

only for those visitors who wish to utilize it.

Page 3. Re: Length of season. The length of the winter season is currently mid December to mid March and is analyzed as part of alternative A, the no action
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alternative.

Page 4. Re: CDST. This suggestion is a feature of alternative B in the DEIS.

Page 4. Re: Improve grooming on the Grassy Lake Road and permit commercial outfitters. These measures do not require a programmatic EIS. They could

be considered at any time.

Page 4. Re: Continue snowmobiles and snowplanes on Jackson Lake. This suggestion is a feature of alternatives A and C in the DEIS.

Page 4. Re: Continue existing plowed road access in YNP. This is a feature of alternatives A, D, E, F and G.
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Page 2. Re: Health – EPA report on damaging sound levels. NPS will review available literature and consider existing sound levels in comparison to findings

by EPA.

Page 2. Re: Visitor surveys, visitor preferences. Additional surveys have been completed by NPS since the DEIS was published. The results will be reported

in the FEIS. Information in the comment reflects conclusions about visitor expectations presented in the DEIS

Page 2. Re: Reduction of noise impacts on cross-country skiers. These features are considered within the present range of alternatives in the DEIS. The

decision to be made will address sound impacts.

Page 2. Re: Limit snowmobile use to 6 hours a day. The EIS seeks to determine the impacts of snowmobile use. This feature could be implemented through

the decision to be made.

Page 2. Re: Air and water pollution. Since publication of the DEIS, more studies on air and water are available for inclusion in the FEIS. Additional

quantification of related impacts is possible.

Page 2. Re: Timetable for implementation is too long in alternative B. Mitigation of impacts for the various alternatives will be incorporated into the FEIS.

Interim limits on use, pending recreation capacity analysis, will be considered.

Page 3. Re: Amend EIS to require cleanest possible snowmobiles. The EIS is not the decision. The EIS evaluates a variety of alternatives in moving from the

existing to the desired condition, and their consequences. The eventual decision will select an alternative based on the disclosed impacts as compared to NPS

mandates, executive orders, regulations and policies.

Page 3. Re: Health and safety. Health and safety factors and current conditions are discussed in the DEIS on pages 93-103. The degree to which each

alternative improves conditions is disclosed in DEIS Chapter IV.

Page 3. Re: Health and safety. These comments go to the decision to be made. Alternatives were formulated to evaluate alternative approaches to safety,

including closing various road segments to over-snow motorized use and eliminating this use from Jackson Lake. All alternative features are available to the

decision maker in considering health and safety issues.

Page 4. Re: Unique resources – thermal features. This comment goes to the decision to be made. Commenter expresses how and why the decision must be

made. This goes to the purpose and need for action and the decision to be made by NPS. The final strategy, or decision is based on selection criteria used by

the decision maker, which are disclosed in the record of decision through discussion of “preferences among alternatives based on relevant factors and agency

statutory missions” (§1505.2(b)). Possible impacts on thermal features are disclosed in the DEIS.

Page 4. Re: Impacts on ungulates. Impacts of winter use on ungulates are disclosed in the DEIS for each alternative. Alternative F was designed to address

issues relating to wildlife impacts.

Page 4. Re: Impacts on ungulates. This comment goes to the decision to be made. Commenter expresses how and why the decision should be made. This

goes to the purpose and need for action and the decision to be made by NPS. Choices are available to the decision maker for protection of large ungulates.

The final strategy, or decision is based on selection criteria used by the decision maker, which are to be disclosed in the record of decision.

Page 4. Re: Bald eagles. The impacts of winter use on bald eagles are disclosed in the DEIS, and further documented in the Biological Assessment to be

produced in conjunction with the FEIS. The recommendation to remove snowmobiling from eagle habitat goes to the decision to be made.

Page 4. Re: Predators, protection of wolves. The impacts of winter use on predators are disclosed in the DEIS, and further documented in the Biological

Assessment to be produced in conjunction with the FEIS. The recommendation to remove snowmobiling from grassy lake road to protect the Soda Butte wolf

pack goes to the decision to be made.
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BLUEWATER NETWORK

Page 4. Re: Ban snowmobile use along lakes and rivers to protect fish. The impacts of winter use on snowpacks, water and aquatic resources are disclosed in

the DEIS. More information on these impacts is available since the publication of the DEIS, and will be incorporated into the analysis. The recommendation

to essentially remove snowmobiling from most of the 3 park units goes to the decision to be made.

Page 4. Re: Snowmobile operating hours. Several alternatives in the DEIS limit operating hours for oversnow motorized use. This choice is available for the

decision to be made, based on the assessment of effects in the FEIS.

Page 5. Re: Mass transit. Alternative G provides for oversnow mass transit only.

Page 5. Re: Park mission and mandate. Park mandates also include visitor use. Management must balance use and resource needs in ways that ensure

preservation for future generations. Where impacts clearly indicate that adverse impacts are occurring, NPS must act. Without a finding of adverse impact

through environmental analysis, it is not proven, on its face, that snowmobiles and trail grooming are inconsistent with the mission to any degree greater than

roads, auto use and developed facilities.
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THE ECOLOGY CENTER

Page 1. Re: The DEIS is deficient because it does not contain a “no action” alternative that prohibits all winter use. NEPA does require a “no

action” alternative (§1502.14(d)), and the DEIS complies with this requirement. In this case, since motorized use exists, and was sanctioned in the

past under existing rules, policies and plans, “no action” is correctly interpreted as the existing management situation. CEQ directly supports this

position. Its opinion is that in instances where ongoing programs are being evaluated, “no action” is “no change” from current management direction

or level of management intensity. In these instances, CEQ states: “To construct an alternative that is based on no management at all would be a

useless academic exercise (Question 3 of CEQ 40 Most-Asked Questions).”

Page 1. Re: The Desired Condition section of the DEIS is fatally flawed because there is no NPS mandate to provide for motorized winter recreation

in the winter. NPS agrees – there is no mandate that requires the NPS to provide for motorized recreation; the NPS mandate, as stated in the Organic

Act and General Authorities Act, places personal enjoyment and freedom of access in a subordinate role to protection of park resources so they remain

unimpaired for the enjoyment of future generations. Personal access may be reflected in the statements of desired condition, but personal access by

oversnow motorized vehicles is not a right or a guarantee. Use of off-road motorized vehicles is authorized by Executive Order 11644 (as amended)

Use of Off-Road Vehicles. The EO allows off-road motorized use only where adverse impacts to park values and natural resources resulting from that

use do not occur. The impacts are not, at face value, indisputable, and it will be up to the decision maker to weigh the available information and

determine whether effects constitute an impairment. The FEIS will be amended to make this point clear.

Page 1. Re: Cumulative effects analysis must consider the effects of year round motorized use or be in violation of NEPA. NPS disagrees. Under

NEPA, future actions can be excluded from the analysis of cumulative effects if the actions are outside the time frame established for the cumulative

effects analysis. In this case, the effects of year round motorized use are clearly outside the scope of the analysis.

Page 1. Re: Cumulative effects analysis was insufficient in regards to the effects that changes in winter use in the parks will have on adjacent lands.

NPS reiterates, in answer to comments about the lack of facts or certain impact analysis on national forests, that the Forest Service (USFS) is

responsible under its cooperating agreement for providing such information to us. NPS has provided the USFS an estimate, or a scenario based on

answers from the winter use survey and current use statistics. The USFS should know where its current problems, conflicts, and use levels are (Multiagency WVUA). The USFS is in somewhat of a better position than NPS to create scenarios for future winter use in national forests near the affected

communities. A good indicator would be winter recreation demand trends developed for forest plan analyses, and forest programs that have been

developed in anticipation of that. As indicated by the USFS letter, use on national forests (especially off-trail snowmobiling) is increasing each year.

USFS should have some effects analysis in place that would be invaluable for dealing with the issue of increased use, regardless of whether the

increase is due to displacement from the parks.

Relative to cumulative effects analysis, if there are other sources of impact occurring on forest lands that would be additive to the indirect effects of

displaced (from the parks) winter recreation, then the USFS should provide that information. The USFS best knows where these sources are and

where any increased recreation use would occur – it is unreasonable to expect NPS to create such an analysis without the direct assistance of the

USFS. Any information provided by the USFS is incorporated into the FEIS.

Page 2. Re: No analysis of the effects of bison removals on grizzlies or loss of other food sources. These issues are included in the cumulative effects

analysis section of the Biological Assessment (BA) for grizzly bears which is incorporated into the FEIS. The Bison Management EIS/Plan addresses

these concerns in detail.
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THE ECOLOGY CENTER

Page 2. Re: Insufficient analysis on the effects that increased use of lands on the west side of YNP will have on eagles. The biological assessment to

be prepared and published along with the FEIS similarly includes areas of concern for wildlife, including eagles, beyond the park boundaries. NPS has

invited the USFS to provide information for this assessment, and for the FEIS.

Page 2. Re: No BA published with the DEIS constitutes a breach of good faith in the Settlement and in the NEPA process. BAs are to be completed

within 60 days of the determination of a final preferred alternative. NEPA (CEQ Regulations) state that the preferred alternative does not have to be

identified until the FEIS. The statement of preference for one or more alternatives in a draft EIS is discretionary, depending upon whether the agency

has a preference at that point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded by the public as extremely

tenuous. This is because an EIS is to serve as a means of assessing impacts of proposed agency actions “rather than justifying decisions already made”

(§1502.2(g)). The FEIS preferred alternative might be viewed more as a “precursor” decision, which will only become final in a Record of Decision

that expresses the rationale for the choice. In any case, it is clear that merely the expression of a preferred alternative in the DEIS does not require a

Biological Assessment to be completed in 60 days. A BA has been prepared and submitted to the USFWS.
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THE FUND FOR ANIMALS INC.

Page 1. See responses to detailed comments from Schubert and Associates. “The primary purpose of an environmental impact statement is to serve as an

action-forcing devise to insure that the policies and goals defined in the Act [NEPA] are infused into the ongoing programs and actions of the Federal

Government (§1502.1).” “The range of alternatives discussed in an [EIS] shall encompass those to be considered by the ultimate agency decision maker

(§1502.2 (e)).” The purpose and need for action described in the DEIS is sufficiently broad to act as an action forcing tool. It is within the discretion of the

decision maker to set the scope of analysis. Considering that motorized use in the Parks is an existing use, not a proposed use, it is logical to frame the

purpose and need in terms that would include that use and facilitate an incremental investigation of the impacts of that use. To do otherwise, and to accept the

Fund’s assertion, would result in a narrow scope of analysis and one viable alternative relative to motorized use. The settlement agreement that resulted in a

need to develop this EIS requires a comprehensive evaluation of winter recreation use – the presumption that only nonmotorized use should be considered in

light of policy, law, regulation and existing use, is not appropriate.

Attachment to cover letter. Commenter puts forth a new alternative not evaluated in detail in the DEIS. This alternative and the contention that it would be

the only viable alternative consistent with NPS legal mandates are based on premises that NPS does not accept. The completion of the EIS and the final

decision are critical to any such determination. The insistence upon natural regulation comes from a misplaced focus on individual animals rather than

populations, and it ignores the bigger picture that people, roads and facilities are located in National Parks and will remain so. Hence, as indicated in the EIS,

NPS will not analyze in detail an alternative that removes all oversnow motorized use from the 3 park units.
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Page 4. Re: Adaptive management is not a mechanism to put off or delay important decisions as the commenter suggests. Adaptive management is a process

by which management actions are implemented based on the best available information and are tested as a hypothesis using an identified monitoring program.

It is the nature of the decision that is in question. It has been the Park Service’s intent from the beginning of the process to prepare a programmatic plan

(§1508.18(b)(2) and (3)). This would be the purpose of preparing a “comprehensive EIS.” There should have been no illusions that a plan of this magnitude

would be based upon detailed, site-specific data in order to make every decision possible relating to winter use. This programmatic approach is acceptable

under the law, in the way that NEPA is the vehicle for producing NPS General Management Plans and USFS Forest Plans, and amendments thereto. Such

documents do, in fact, make decisions and allocations at a general level and defer many site-specific types of decisions to a later date. In this context, it is also

acceptable to spell out processes that would be followed, such as adaptive management, as alternative features. It will be up to the decision-maker to weigh

the available data, the possible impacts of such alternatives in the short term, and decide if park resources and values are sufficiently protected.

Page 4. Re: Guiding laws and regulations. NEPA (CEQ Regulations) does not stipulate the rationale for selecting a preferred alternative in an EIS. It

stipulates that in a final EIS, a preferred alternative must be identified. The statement of preference for one or more alternatives in a draft EIS is discretionary,

depending upon whether the agency has a preference at that point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded by

the public as extremely tenuous. This is because an EIS is to serve as a means of assessing impacts of proposed agency actions “rather than justifying

decisions already made” (§1502.2(g)). The FEIS preferred alternative may be viewed more as a “precursor” decision, which will only become final in a

Record of Decision that expresses the rationale for the choice. In any case, it is clear that merely the expression of a preferred alternative, by itself, can in no

way invalidate the entire EIS analysis. The decision maker can select any of the proffered alternatives in a Final EIS through consideration of a variety of

factors, including but not limited to environmental impacts. The selected alternative does not have to be the most environmentally preferable alternative,

which must also be revealed in the decision document.

Page 5 and 6, 7-9. Re: The Citizens’ Solution for Winter Access to Yellowstone. The proposed “Citizens’ Solution” is not significantly different from

alternative G as presented in the DEIS, especially considering the programmatic nature of the proposed action. See the matrix comparison of “The Citizens’

Solution” versus the features analyzed in the range of alternatives. This may be found in Chapter I of the FEIS under Alternatives Suggested During the

Public Comment Period. All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree.

Page 9. Re: Failure to act immediately. There has as yet been no legal finding that snowmobiling violates any of the mandates described in the purpose and

need section. Montana DEQ points out that there has been no actionable violation of Montana or Federal clean air standards. Where standards have been

approached, West Entrance and Flagg Ranch, there clearly needs to be some action taken with respect to health and safety. Pollution levels throughout the

park units do not approach this level. Class I air quality in the remainder of the park units has less to do with health standards and more to do with park values

(visibility, odor) for which no specific standards exist. The eventual decision will, through a finding, provide direction on the issue of derogation of park

values, and an appropriate implementation period will be selected.

Page 10. Re: Airborne toxins created by 2-stroke engines. That PAH and other toxic elements are included in emissions from 2-stroke engines is disclosed in

the DEIS, page 163 et al. The information in the DEIS will be reviewed and enhanced as appropriate for the final document.

Page 10. There is no requirement in CEQ regulations (§1502.14) to justify a preferred alternative, just to name one or more alternatives as preferred in the

DEIS if there is a preference. The agency must express a preferred alternative in a Final EIS. It appears many commenters place too much emphasis on the

alternative designated as preferred in the DEIS. This designation is tenuous at best. Under the CEQ regulations, the requirement in an EIS is to provide a

range of reasonable alternatives that clearly define the issues, and to fully evaluate and disclose the possible effects of those alternatives. The DEIS meets this

requirement.

Pages 10-12. Re: Current air quality degradations within the parks warrant stronger action. Information provided on pages 10-12 of the letter relates to

snowmobile emissions. Much of this information is either stated or cited in the DEIS. Due to work that has been ongoing since publication of the DEIS, air

quality analysis in the FEIS will be updated.
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Pages 12-13. Re: Snowmobile emissions. Information provided on pages 12-13 of the letter relates to snowmobile emissions. Much of this information is

either stated or cited in the DEIS. Due to work that has been ongoing since publication of the DEIS, air quality/public health analysis in the FEIS will be

updated.

Pages 14-15. Re: Legal and policy requirements. Legal and policy discussion: NPS is fully cognizant of its mandate and policy requirements, as reflected in

the purpose and need section of the DEIS. There has as yet been no legal finding that snowmobiling per se violates any of the mandates described in the

purpose and need section. Montana DEQ points out that there has been no actionable violation of Montana or Federal clean air standards. Where standards

have been approached, West Entrance and Flagg Ranch, there clearly needs to be some action taken with respect to health and safety. Pollution levels

throughout the park units do not approach this level. Class I air quality in the remainder of the park units has less to do with health standards and more to do

with park values (visibility, odor) for which no specific standards exist. The eventual decision will, through a finding, provide direction on the issue of

derogation of park values, and an appropriate implementation period will be selected.

Page 15. Re: Citizens’ Solution. The proposed “Citizens’ Solution” is not significantly different from Alternative G as presented in the DEIS, especially

considering the programmatic nature of the proposed action. See the matrix comparison of “The Citizens’ Solution” versus the features analyzed in the range

of alternatives. All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree.

Page 15. Re: NPS must mitigate or eliminate impacts to air quality from snowmobile use. Improved snowmachine technology and snowcoach, mass transit

access are evaluated in the DEIS as possible alternatives to the current situation. Once again, the NPS solution will be articulated in a record of decision.

Page 16-17. Re: Effects of noise on wildlife. This issue will be reviewed and updated in the FEIS if necessary.

Page 17. Re: Approach to mitigating snowmobile noise. The analysis of sound will be updated in the FEIS.

Pages 17-18. Re: Policy requirements and data insufficiencies. The DEIS on page 126 and in Appendix C (Volume II) express policy requirements regarding

natural quiet, as they relate to winter use issues.

Pages 18-19. Re: Failure to collect useful data on noise pollution in the parks. Additional data has been collected during the 1999-2000 winter season.

Sound modeling has been conducted. Inadequacies pointed out in this comment are being addressed, and the analysis will be reflected in the FEIS.

Page 19. Re: The mode of access utilized by winter visitors must be the most quiet vehicle possible. This comment goes to the decision to be made.

Commenter expresses how and why the decision must be made. This goes to the purpose and need for action and the decision to be made by NPS. The final

strategy, or decision is based on selection criteria used by the decision maker, which are disclosed in the record of decision through discussion of “preferences

among alternatives based on relevant factors and agency statutory missions” (§1505.2(b)).

Pages 19-23. Re: Impacts on water quality and aquatic resources. Impacts such as those detailed by commenter are summarized and cited in the DEIS, page

163 and subsequently for each alternative. An additional study not available for the DEIS has been completed and will be used in updating the analysis in the

FEIS.

Page 23. Re: The use of snowmobiles and NPS mandates. The assertion that use of snowmobiles, because of perceived air and water impacts, violates the

entire set of NPS mandates, executive orders and policies is a gross generalization. Such a finding has yet to be made relative to the three park units in

question. Many places throughout this comment letter provide a restatement, or expansion, of literature summarized and cited in the EIS. The commenter

extrapolates or generalizes from the literature to conclude that the activity in question conclusively demonstrates that the resources of the three park units are

impaired beyond some legal limit. NPS maintains that the standard of impairment in most instances is a function of the criteria used by a decision-maker in

the record of decision. The latter is a part of the decision to be made, based on relative effects between alternatives disclosed in the EIS.

Pages 23-26. Re: Impacts on water quality and aquatic resources. Impacts such as those detailed by commenter are summarized and cited in the DEIS, page

163 and subsequently for each alternative. An additional study not available for the DEIS has been completed and will be used in updating the analysis in the

FEIS. Please see earlier response to this letter in regard to page 23 “Use of snowmobiles and NPS mandates.”

Pages 27-30. Re: Impacts on wildlife. This comment is a restatement, or expansion, of literature summarized and cited in the EIS.
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Page 30. Re: Regulatory requirements to protect wildlife. The commenter extrapolates or generalizes from the literature to conclude that the activity in

question conclusively demonstrates that the resources of the three park units are impaired beyond some legal limit. NPS maintains that the standard of

impairment in most instances is a function of the criteria used by a decision maker in the record of decision. The latter is a part of the decision to be made,

based on relative effects between alternatives disclosed in the EIS and consideration of regulatory requirements.

Pages 30-32. Re: Impacts on wildlife. This comment is a restatement, or expansion, of literature summarized and cited in the EIS.

Page 33. Re: Impacts on individual animals and populations. These impacts are disclosed in the DEIS, pages 165-167, and subsequently for each alternative.

Page 33. Re: Winter road grooming impacts on bison and wildlife. These impacts are disclosed in the DEIS, pages 165-167, and subsequently for each

alternative on pages 183, 209, 231, 250, 265, 281, and 291.

Page 34. Re: Recommendation for NPS to use road closures as an assessment tool. Assertion that “ The Citizens’ Solution” is an interim plan which is

amendable pending thorough examination and mitigation of issues impacts. This suggestion appears to be no different than the adaptive management process

incorporated directly into two of the DEIS alternatives – B and E. It is an approach that remains a choice for the decision maker.

Page 34. Re: User conflict. NPS points out that the issues regarding existing versus desired condition, the basis of the purpose and need for action, includes

visitor experience (nonmotorized users and user conflicts). Analysis of visitor experience issues is presented in the DEIS, pages 149-154, 174 and

subsequently for each alternative. NPS feels that this analysis is sufficient to ascertain the effects of various alternatives on the park visitor, as support for a

programmatic plan. To a degree, effects are quantified in terms of visitor opportunities for each alternative. The commenter notably does not suggest a more

specific means for quantifying impacts of snowmobile use on other park users.

Page 34. Re: Recent user surveys. Survey summaries regarding this kind of information may be found on pages 149-154 of the DEIS. Recently completed

survey results will be reflected in this section of the FEIS.

Page 34. Re: NPS regulations and policies. The assertion that use of snowmobiles, because of perceived impacts on other users, violates NPS mandates and

policies over generalizes the true situation. Such a finding has yet to be made relative to the three park units in question. NPS maintains that the standard of

impairment in most instances is a function of the criteria used by a decision-maker in the record of decision. The latter is a part of the decision to be made,

based on relative effects between alternatives disclosed in the EIS.

Page 35. Re: The park service must implement an alternative that ensures that access to the park does not detract from other visitors’ experiences. This

comment goes to the decision to be made. Commenter expresses how and why the decision must be made. This goes to the purpose and need for action and

the decision to be made by NPS. The final strategy, or decision is based on selection criteria used by the decision maker, which are disclosed in the record of

decision through discussion of “preferences among alternatives based on relevant factors and agency statutory missions” (§1505.2(b)).

Pages 35-44. Re: Legal and policy framework. Most of the discussion on these pages restates the information in the purpose and need section and Appendix

C of the DEIS. The commenter uses this information to come to a conclusion that snowmobile use is, on its face, inconsistent with laws, executive orders and

NPS policies. Commenter assumes on page 37 a level of documented adverse impacts that amounts to violation of law, etc. NPS maintains that such

documentation is the purpose of an EIS: to analyze and disclose impacts of various alternatives, and to sharply define issues. NPS concludes that this

comment is the rationale GYC would use in making a decision, as opposed to criticism on the adequacy of the EIS or the range of alternatives considered.

Therefore, the comments on these pages go to the decision to be made, and requires no further response

Page 44. Re: Grand Teton and the CDST. No information is offered to exclude consideration of a separate CDST in Alternative B. This alternative feature is

a possible alternative to the current situation which involves safety concerns, and it should be evaluated. Commenter appears to object because it is a feature

in the preferred alternative. Should this feature be implemented, it is recognized that possible rule changes would be necessary, in addition to further NEPA

and decision making on a site-specific level. These possibilities might discourage a decision maker, but they do not strictly prohibit the analysis of the option

or its eventual selection.

Pages 44-45. Re: Cooperator process. The intent of granting cooperating agency status was in the spirit of cooperation and coordination consistent with
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NEPA, FACA and APA. The content of the document has been affected, but NPS disagrees that the analysis has been. The document incorporates material

from the cooperating agencies, which is reported as a matter of full disclosure even though the results disagree with NPS analysis. Letters from the

cooperators and the signed agreements between NPS and cooperators were included in the DEIS, Volume II. These items relate to content. As to

inappropriate influence, one need only review media reports, comment letters or other correspondence from the cooperators to obtain their assessment of how

they were involved. Regarding the commenters statement about NEPA provisions relating to cooperating agencies, NPS agrees.

Page 45. Re: Economics. The EIS presents a fair disclosure of impacts of winter use alternatives, including social and economic effects. Consideration of

impacts and other factors is in the purview of the decision maker, who will select an alternative and provide rationale for that selection in a record of decision.

Page 47. Re: Public values and attitudes. The discussion of surveys in the DEIS is clear about the winter use survey methods, sampling, and participation.

Survey results and conclusions have not been represented in any way that is inconsistent with this. Additional surveys have been completed and are available

for incorporation into the FEIS analysis.
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JACKSON HOLE CONSERVATION ALLIANCE

Page 1. Re: Rationale for preferred alternative. NEPA (CEO Regulations) does not stipulate the rationale for selecting a preferred alternative in a DEIS. It

stipulates that in a final EIS, a preferred alternative must be identified. The statement of preference for one or more alternatives in a draft EIS is discretionary,

depending upon whether the agency has a preference at that point (§1502.14(e)). The identification of a preferred alternative in a DEIS should be regarded by

the public as extremely tenuous. This is because an EIS is to serve as a means of assessing impacts of proposed agency actions “rather than justifying decisions

already made” (§1502.2(g)). The FEIS preferred alternative may be viewed more as a “precursor” decision, which will only become final in a Record of

Decision that expresses the rationale for the choice. In any case, it is clear that merely the expression of a preferred alternative, by itself, can in no way

invalidate the entire EIS analysis. The decision-maker can select any of the proffered alternatives in a Final EIS through consideration of a variety of factors,

including but not limited to environmental impacts. The selected alternative does not have to be the most environmentally preferable alternative, which must

also be revealed in the decision document.

Page 1. Re: Analysis of alternative B. An analysis of how alternative B responds to the issues identified during scoping is provided in the DEIS on Pages

197–221. All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree. In our estimation, it is unrealistic to expect all

alternatives in an EIS to meet all the desired conditions expressed in the purpose and need for action equally well. Such a set of alternatives would likely have

no significant differences between them.

Page 2. Re: Encourage snowcoaches. Alternative G would limit travel in the parks to snowcoach only. Alternative B and alternative D both would require that

if clean and quiet technologies are not available by 2008-2009 that oversnow travel would be limited to snowcoaches.

Page 2. Re: Stringent noise and emissions standards for snowmobiles. Each of the alternatives analyzed in the DEIS, with the exception of the no-action

alternative, proposes some level of emission and sound standards which are more restrictive than those imposed today.

Page 2. Re: Close the Potholes area in Grand Teton NP. The Potholes area along with the Grand Teton park road, would be closed to motorized use in

alternatives B, D, E, F, and G.

Page 2. Re: Discontinue the Continental Divide Snowmobile Trail. This proposal is a feature of alternatives G and E-F.

Page 2. Re: Require a study to determine visitor carrying capacity. This proposal is a feature of all alternatives considered.

Page 2. Re: Limit or restrict off trail and backcountry use. This is an alternative feature analyzed in the DEIS for Yellowstone National Park under alternatives

B, D, F, and G. In Grand Teton National Park, backcountry use is prohibited in bighorn sheep winter range.

Page 2. Re: Close the East Entrance to Yellowstone National Park. This feature is proposed in alternative D.

Page 2. Re: Encourage further research on the needs of wintering wildlife. This is a feature of alternatives B, D, and F.

Page 3. Re: Effects associated with winter use in the parks. These issues mirror the issues and concern raised during scoping. Consequently they are topics

analyzed in Chapter 4 of the DEIS.
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Page 2. Re: Revised Alternative E. It appears too much emphasis is placed on support or justification for a course of action or decision. Under the CEQ

regulations, the requirement of an EIS is to provide a range of reasonable alternatives that clearly define the issues, and to fully evaluate and disclose the

possible effects of those alternatives. The DEIS meets this requirement. Revised Alternative E comes from cooperating agencies and the Blue Ribbon

Coalition in a variety of forms. The essentials of Revised Alternative E (all versions considered) are not significantly different from alternative E as presented

in the DEIS, especially considering the programmatic nature of the proposed action. See the matrix comparison of Revised Alternative E versus the features

analyzed in the range of alternatives. All alternatives in the DEIS, including B, meet the purpose and need for action to a greater or lesser degree. In our

estimation, it is unrealistic to expect all alternatives in an EIS to meet all desired conditions expressed in the purpose and need for action equally well. Such a

set of alternatives would likely have no significant differences among them and fail to meet the CEQ requirement for evaluating a range of options.

Pages 3-4. Re: Particulate matter study. Criticism stemming from the release of the ARD report and its content is beyond the scope of this EIS analysis and

requires no response. The report’s contents, in respect to the alleged faulty information, was not a part of the Draft EIS. The fact that there may be

disagreement with how the document was publicized and distributed does not affect the air resources analysis in the EIS. The release of the document, done

independently from the EIS process, was hardly a media blitz. Certainly, the ensuing media coverage, in which the cooperating agencies played a large role,

was not encouraged by NPS. The commenter should be aware that the mathematical errors and related comparisons have been corrected in the report, which

has been re-released and is available for use in support of the FEIS.

Page 4. Re: Support of alternative E and not B. In general, the tenor of these expressions of support and opposition relate to the decision that the commenter

would like to see NPS make, or not make. The general response to such comments is that the commenter’s opinions will be considered in making the final

decision, but that there is nothing in those opinions that substantively would alter the range of alternative features to be evaluated in the Final EIS. For

example, if the features that are not supported were to be deleted from the range of alternatives then the analysis would be left only with features that the

commenter likes or agrees with. If only the actions that are liked by the commenter remain, then there is effectively only one alternative. From the NEPA

standpoint, the analysis cannot be channeled in this fashion. Therefore, expressions of support or objection will not be responded to, in general, by changes in

alternative features – they will be responded to when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in

the Record of Decision. People who commented in this fashion are asked to consider that there is a very clear separation between alternatives legitimately

considered in an analysis and the expression of a preferred alternative or the decision to be made.

Page 4-7. Re: B.1. Fund for Animals V. Babbitt. How the settlement timeframes were set is not material to the EIS process itself, which must be conducted in

accordance with NEPA and the CEQ regulations. Certainly the time frames represent a challenge to all involved in the process. Arguments about extensions

do not relate substantively to the adequacy of the EIS or the alternatives in a way that NPS can respond to. NPS will respond to comments on both when

presented as such.

Page 7. Re: B.2. Release of the DEIS over the internet. NPS put the DEIS on the internet to meet the requirement of the settlement agreement that the draft be

released in August 1999. The plaintiffs in the suit did not object to that method of complying with the settlement agreement. Once the hard copies of the

DEIS were available, NPS allowed a 60 day comment period to comply with CEQ requirement for requesting public comment (§1503.1(a)(4)).

Page 8. Re: B3. Small Business Regulatory Enforcement Act. NPS disagrees that it must submit the Winter Use Plan and EIS to Congressional review under

the terms of the SBREFA. If a rule change is required as a result of the final decision, NPS will comply with all applicable requirements.
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Pages 8-9. Re: B.4. Cumulative impact for planning the road from West Yellowstone to Old Faithful. NPS evaluated the impacts of alternative B and other

alternatives that incorporate the features mentioned in this comment. A systematic, interdisciplinary process was used in accordance with CEQ regulations.

NEPA does not absolutely require the use of actual data. It requires sufficient information in the context of the scope of analysis, which in this case is

programmatic and not site-specific. The EIS analysis is aimed at developing a programmatic plan (§1508.18(b)(2) and (3)) for winter use. If the concern

relates to site-specific gaps in information, it should also be noted that there is no requirement to develop exhaustive site-specific information (“hard data”) to

support a programmatic planning document. An EIS is not, per se, a scientific analysis. It is intended to disclose environmental effects over a range of

alternatives, in which the analyses must demonstrate scientific integrity by disclosing methods and making explicit references to sources used (40 CFR

1502.24). The DEIS does this. CEQ regulations also allow for incomplete or unavailable information, by describing procedures that are to be following in

these instances (§1502.22). For any identified gaps in the DEIS, NPS will follow the requisite procedures.

The CEQ regulations define special expertise as “statutory responsibility, agency mission, or related program experience” §1508.26. NPS has fully documented

its procedures in this regard. Methods of analysis, including assumptions and expertise (in the form of current literature) are revealed for all impact topics at the

beginning of DEIS Chapter IV. The EIS preparers and consultants used are listed in Appendix B of the DEIS for all interested parties to see.

Page 10. Re: C.1. Revised Alternative E. Please see response to comment, “Page 2.”

Page 10. Re: C.1.a. Actions common to Yellowstone, Grand Teton and the Parkway. Please see responses to Letter 1, Wyoming comments on Revised

Alternative E. Most suggested features are evaluated in the DEIS alternative E or in another alternative, so these choices remain for the decision maker. NPS is

encouraged by support from the cooperating agencies on establishing a recreation carrying capacity. In practice, setting a carrying capacity is a highly complex

and potentially divisive exercise. NPS managers decided there was not sufficient time available in the settlement time frame to devote to this type of analysis.

However, in response to EPA and a variety of cooperating agency comments, NPS will analyze the use of interim use limitations to mitigate effects in several

alternatives. The seven year average will be used in one or more instances.

Page 12. Re: C.2. Adaptive management and the Federal Advisory Committee Act. Adaptive management will be better described in the FEIS. Adaptive

management is a strategy to move from the existing condition to the desired condition in two alternatives. The strategy represents a very deliberate way of

proceeding, erring on the conservative side to maintain existing motorized use at the risk of possible short-term impacts on resources or other visitors.

Processes associated with adaptive management will be provided in the FEIS: definitions, administrative actions, study methods, management actions, and

NEPA requirements. Although FACA is not necessarily a concern should adaptive management be implemented, any decision that requires ongoing advice

from a group of non-agency persons must comply with FACA. This does not necessarily mean that the NPS will charter a formal advisory committee under

FACA, as certain exceptions to such formal action are available.

Page 13. Re: Bison Management DEIS/Plan and the Winter Use DEIS; two different methodologies used. Work accomplished by biologists on defining the

wildlife affected environment and the effects of winter use on it are cognizant of the carrying capacity issue. Such determinations include many factors other

than those associated with winter use. For this reason, NPS holds to its determination that setting carrying capacities is beyond the scope of this effort. The

winter use FEIS will be made as consistent as possible with the Bison Management FEIS/Plan. It should be understood that the Bison Management EIS/Plan is

not yet published, and no decision has yet been made for bison management. The final EIS for winter use will be made as consistent as possible with the final

EIS for bison management in terms of analysis. Certainly the decisions will need to be consistent.
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Page 13. Re: C.3.a. Tunnel effect on ungulates and plowing on bison. Refer to responses to Letter 35, John Mundinger. In all alternatives, including B, the

effects of plowed roads on ungulates are disclosed. For alternative B, this may be found on DEIS pages 208-209. Although it does not explicitly mention

bison, it states that plowed roads may provide “wildlife” with an energy efficient mechanism for movement. The FEIS will be revised to include the effects of

plowed roads on bison migration. Although the DEIS does not use the term “tunnel effect” it does discuss the negative impact associated with snow berms

along the plowed road corridor, and suggests mitigation (p. 209). NPS and the commenter disagree on whether or not a tunnel effect would result from

plowing. In many other areas within the three park units, and in the 3 state area, roads are plowed and no tunnel effect exists. As for the Settlement

Agreement, bison monitoring is ongoing and current information pertaining to that effort will be included in the FEIS.

Pages 14-15. Re: C.3.b. Groomed winter roads and bison movement. The bison analysis will be reviewed and updated as necessary. In an effort to better

understand the relationship of bison movements and the use of the winter groomed road system, managers have instituted studies that address this issue.

While groomed roads may have contributed to the redistribution of bison within park boundaries (Meagher 1997), it appears that bison tend to use waterways

and off-road trails for much of their travel on the west side of the park (Bjornlie and Garrott 1998). Their movement toward park boundaries may occur on

such routes. Monitoring of bison movements in the Hayden Valley and Mammoth to Gibbon Falls sections of the park has found that less than 12% of bison

movements occurred on the groomed road surface (Kurz et al. 1998, 1999). However, groomed roads may have allowed larger numbers of bison to exist in

the park than in the absence of groomed roads, by allowing access to otherwise unavailable foraging areas. In addition, westward redistribution early in the

winter may predispose some bison to exit the park (Meagher 1997). Therefore closing of groomed roads could have the effect of reducing population size and

shifting distribution back to patterns observed before grooming, thereby possibly reducing the magnitude of bison movements outside park boundaries.

Conversely, bison are highly social and appear to retain and pass along knowledge through generations (Meagher 1985), so it is possible that closing groomed

roads may not impact bison movements and distribution. Research is currently being conducted to better understand the relationship between road grooming

and bison movement and distribution patterns.

Page 15. Re: C.3.a. Analysis of wildlife carrying capacities. Work accomplished by biologists on defining the wildlife affected environment and the effects of

winter use on it are cognizant of the carrying capacity issue. Such determinations include many factors other than those associated with winter use. For this

reason, NPS holds to its determination that setting carrying capacities is beyond the scope of this effort. The winter use FEIS will be made as consistent as

possible with the Bison Management FEIS/Plan. It should be understood that the Bison Management EIS/Plan is not yet published, and no decision has yet

been made for bison management. Relative to adaptive management, see response to comment, “Page 12. Re: C.2.”

Page 15. Re: C.4. Natural quiet requirements. Natural quiet (natural soundscape) is a value that attracts many people to national parks. Commenter is

referred to page 126 in the DEIS, and to Appendix C which elucidates on NPS policies relating to this. The sound analysis will be updated for the FEIS to

provide more quantitative analysis relative to the concerns expressed.

Pages 16-18. Re: C.4. Water and solid waste quality standards. Please see response to comment, “Pages 8-9.” EPA notes that the DEIS includes extensive

analysis of the effects from current winter use that demonstrates significant environmental and human health impacts, and that it includes among the most

thorough and substantial science base they’ve seen to support a NEPA document. Regarding air quality and related impacts on water and aquatic resources,

the FEIS will incorporate additional data and recent studies in these areas. The comments on sewage spills in Yellowstone are not pertinent to the issue at

hand – impacts from winter use. Such events may be more appropriate to a discussion of cumulative impacts. The eventual decision from the winter use EIS

will provide direction on monitoring needs pursuant to winter recreation use. Such a decision represents a commitment to funding focused monitoring efforts.
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Pages 19-27. Re: C.5. Snowmobile emissions. The ARD report is not pertinent to this discussion. The material cited and discussed by the commenter is not in

the DEIS, nor was it part of the DEIS process. Comments were not solicited on the ARD report, but on the DEIS. In the DEIS, the purpose and need for action

(Chapter I) indicates there is a gap between existing conditions and desired conditions for air quality and other resources in the parks. Alternative B and other

alternatives prescribe actions, or standards for actions, intended to close that gap. The baseline for comparison is the existing condition, as reflected in

alternative A. An improvement in air quality would be expected from implementing alternative B, as disclosed in the DEIS. NPS has an affirmative

responsibility to protect park values and Class I air quality, and it has the authority to do so. The DEIS states that at any time, if EPA adopts stricter standards

applicable to park resources, they will be adopted.

Page 20. Re: C.5. Montana DEQ. The air resources impact analysis will be updated in the FEIS, partly in response to comments from Montana DEQ.

Page 28. Re: C.6. Winter economy of West Yellowstone. The economic impacts of all alternatives are evaluated and disclosed in the DEIS. NPS

acknowledges that any decision resulting from this EIS is likely to cause economic change in all local communities. However, a legal decision will not be

made or justified until after the final EIS is published, and all alternatives must be considered in the decision process.

Page 28. Re: C.5. Use levels if snowmobiling in lower loop unavailable. The possible impacts of the alternatives on recreation and visitors to the parks are

disclosed in the document. The results of the winter use surveys conducted in the parks, which are reported in the DEIS, address this question. With reference

to alternative B and plowing the road from West Yellowstone to Old Faithful, there is a clear disagreement on whether or not people will continue to come.

Certainly some current users will not; there could be many others who presently decline to snowmobile but would be happy to see Old Faithful in the winter.

Page 29. Re: C.6. Decrease in visitor spending and loss of jobs. The economic analysis will be updated for the FEIS. The states’ analyses produce different

results. Both analyses will be disclosed, as is appropriate under CEQ regulations.

Page 29. Re: C.6. One stated purpose of plowing the road (DEIS, page 28) is to “improve affordable access” – not, as the commenter states, to “provide

affordable access for minority and low-income people”. A thorough reading of the EIS would reveal that a required impact topic in an EIS is to evaluate the

effects of a proposed action on socially or economically disadvantaged populations (DEIS, page 80). These populations are characterized on page 90 in the

DEIS, and the effects on those populations are disclosed in the socioeconomic section for each alternative (DEIS, pp 176, 199, 224, 245, 260, 274, 288). The

stated impacts on socially or economically disadvantaged populations are not used as “justification” for plowing in alternative B.

Page 30. Re: Alternative B road plowing, alleged increased use, and overcrowding at Old Faithful: NPS will review the discussion and clarify it as necessary

(Ref. DEIS page 218. WVUM page 14).

Page 30. Re: C.6 Plowing the road harmful. The inference is that since people choose to come to parks to snowmobile, they would not choose to experience

the Park in any other fashion. The commenter seems to further infer that because the economies have thrived on this demand, then freedom and economic well

being in the gateway communities should have priority over any adverse impacts that this use may cause. However, the NPS mandate, as stated in the purpose

and need section, places personal enjoyment and freedom of access in a subordinate role to protection of park values so they are unimpaired for future

generations. NPS acknowledges that management changes could impact local businesses, particularly those catering to the snowmobile visitor immediately

outside the park. NPS is also aware that other opportunities for winter visitors exist. In short, the EIS effort to evaluate various alternatives for winter use will

result in a decision fully compliant with the stated policy of sustainable, responsible, informed and managed visitor use.
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Page 30. Re: C.6. Failed to adequately examine the socioeconomic impacts. Economic effects of all alternatives are fully disclosed. We fail to understand

what the commenter means by the Park Service’s “failure to implement the socio-economic information provide by the cooperating agencies.” NPS has not

disregarded the cooperating agencies’ information. According to the CEQ regulations, §1503.3(b), commenting agencies that criticize an analysis

methodology should describe an alternative methodology and why it prefers it. The commenter does not specifically indicate what is incorrect about the

agency methods used. If there is a significant difference of opinion regarding economics, as there may be in this case, then the remedy provided in CEQ

regulations (§1502.9(a)) is to report both opinions in order to meet the disclosure requirement. This approach was taken in the DEIS by reporting the results of

NPS studies and the reports from each cooperating agency. Page 83 of the DEIS makes reference to the use of source information provided by the cooperators,

all of which is presented in DEIS Appendix A. The characterization of the socioeconomic environment specifically cites information from the cooperators or

their consultants, such as Dr. Taylor. On pages 298 through 315, the DEIS discloses the impacts of each alternative on adjacent lands in the cooperating

agencies’ own terms.

Page 31. Re: 7. Sound Concerns.The analysis of sound will be updated and clarified in the FEIS.
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NATIONAL PARKS AND CONSERVATION ASSOCIATION

Page 1. Re: The use of snowmobiles in YNP and GTNP violates laws and regulations. The NPS and its basic mandate are authorized under the NPS Organic

Act (16 USC 1,2-4) and the General Authorities Act (16 USC 1a through 1a-8):

 “The Service thus established shall promote and regulate the use of the Federal areas known as National Parks...by such means and measures as to conform

to the fundamental purposes of the said Parks...which purpose is to conserve the scenery and the natural and historic objects and the wildlife therein and to

provide for the enjoyment of same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”

An EIS is necessary to evaluate alternative choices for plans while revealing the possible environmental impacts of activities that may be included in the plan.

All alternatives presented in the EIS meet the purpose and need for action. The purpose and need for action in an environmental impact statement (EIS) is a

brief statement specifying the underlying purpose and need to which the agency is responding in proposing the alternatives, including the proposed action. The

need to develop a plan through an EIS is indicated by the difference between overall desired condition and the conditions that presently exist. The desired

condition reflects the parks’ mandates, and is articulated in the EIS as series of general objectives. The final plan will be designed to move the existing

condition toward the desired condition.

The effects of all the alternative actions on natural resources, public health and safety, socioeconomics, adjacent lands and visitor access and experience are

analyzed in the EIS, Chapter IV, Environmental Consequences. The eventual decision will make a finding about impacts on resources relative to the mandates

and regulations cited in the comment.

Page 1. Re: Support for Citizens’ Solution. Comments place a great deal of emphasis on support or justification for a course of action or decision. Under the

CEQ regulations, the requirement in an EIS is to provide a range of reasonable alternatives that clearly define the issues, and to fully evaluate and disclose the

possible effects of those alternatives. The DEIS meets this requirement. Comments of support or nonsupport go to the decision to be made; they do not affect

the range of alternatives considered.

Page 1. Re: Suggested alternative features. The essentials of the “Citizen’s Solution are not greatly different from alternative G as presented in the EIS. See the

matrix comparison of the Citizens' Solution versus the features analyzed in the range of alternatives in Chapter II.

Page 2. Re: Research needs. The NPS agrees that the analysis presented in the EIS concerning the sound emissions of oversnow vehicles must address

frequency, distance traveled and the effects on park visitors. The analysis of the effects of snowmachine sound will be revised in the FEIS to include this

information.

Page 2. Re: Wilderness values. Wilderness values consist of elements that are intrinsic to wilderness, as well as elements that are experiential and relative to

people’s appreciation of wilderness. The analysis does not avoid the subject of wilderness values, rather it considers impacts on factors like natural

soundscapes, scenic quality, wildlife and air quality. Such elements are considered important wilderness components and impacts on them are considered in the

disclosure of effects in Chapter IV, Environmental Consequences. Because of this disclosure, and because proposed actions are overtly designed to avoid

impacting proposed and recommended wilderness, this topic was dismissed from further consideration.

Page 3. Re: Displacement of snowmobile users on to adjacent lands. The analysis of effects on adjacent lands, including the effects of displaced recreationists

will be revised in the FEIS.
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NATIONAL WILDLIFE FEDERATION AND INTERTRIBAL BISON COOPERATIVE

Page 2. Re: Determining visitor use capacities. Setting a carrying capacity is a highly complex and potentially divisive exercise. NPS managers

decided there was not sufficient time available in the settlement time frame to devote to this type of analysis. Regardless of which alternative is

decided upon in the Record of Decision, a carrying capacity study will be in place within two years, and the FEIS will set interim visitor use levels.

More explanation of the carrying capacity issue will be included in the FEIS, and mitigation features for the alternatives will include carrying capacity

analyses.

Page 2 and Page 3. Re: Integration of the Bison Management EIS/Plan and Winter Use EIS. NPS is working to ensure that the Winter Use Plan and

the Bison Management EIS/Plan are coordinated and consistent in regard to the effects of winter use on bison.

Page 3. Re: No increase in groomed or motorized routes. This feature is included in alternatives A, E, F, and G. Expressions of support or objection

will be responded to when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of

Decision. There is a very clear separation between alternatives legitimately considered in an analysis and the expression of a preferred alternative or

the decision to be made.

Page 3. Re: Closing the roads that allow for the migration of bison out of the park. The bison analysis will be reviewed and updated as necessary. In

an effort to better understand the relationship of bison movements and the use of the winter groomed road system, managers have instituted studies that

address this issue. While groomed roads may have contributed to the redistribution of bison within park boundaries (Meagher 1997), it appears that

bison tend to use waterways and off-road trails for much of their travel on the west side of the park (Bjornlie and Garrott 1998), and that much of their

movement toward park boundaries may occur on such routes. Monitoring of bison movements in the Hayden Valley and Mammoth to Gibbon Falls

sections of the park has revealed that less than 12% of bison movements occurred on the groomed road surface (Kurz et al. 1998, 1999). However,

groomed roads may have allowed larger numbers of bison to exist in the park than in the absence of groomed roads, by allowing access to otherwise

unavailable foraging areas, and westward redistribution early in the winter may predispose some bison to exit the park (Meagher 1997). Therefore,

closing of groomed roads could have the effect of reducing population size and shifting distribution back to patterns observed before grooming, thereby

possibly reducing the magnitude of bison movements outside park boundaries. Conversely, bison are highly social and appear to retain and pass along

knowledge through generations (Meagher 1985). Thus, it is possible that closing groomed roads may not impact bison movements and distribution.

Research is currently being conducted to better understand the relationship between road grooming and bison movement and distribution patterns.

Page 4. Re: Legal mandates. The NPS fully intends to comply with the Clean Air Act and the Prevention of Significant Deterioration provision.

Additional work is being accomplished on air quality, including the modeling of air quality impacts, which will be incorporated into the FEIS.

Page 4. Re: Setting a maximum limit on emissions. Limiting emission levels will be addressed in the FEIS under the context of setting carrying

capacities. More explanation of the carrying capacity issue will be included in the FEIS, and mitigation features for the alternatives will include

carrying capacity analyses. Furthermore, additional work is being accomplished on air quality and will be incorporated into the FEIS.

Page 5. Socioeconomic concerns should be a lower priority compared to maintaining natural resources. Under NEPA, there are no specific

regulations requiring the protection of social values, but the consideration of social and economic impacts are routinely done in any environmental

analysis. There are several major reasons for this. First, the scoping process as conducted under §1501.7 inevitably raises the social and economic

effects of a proposed action. In many instances, these are regarded as significant issues. Second, the impacts must be considered in the context of

society as a whole, the affected region, the affected interests, and the locality (§1508.27(a)). Third, the intensity of impacts on the quality of the

human environment must be gauged (§1508.27(b)), where “human environment” is to be viewed comprehensively (§1508.14). Effects (direct, indirect

and cumulative) are defined as including both economic and social impacts (§1508.8). The NPS mandate, as stated in the Organic Act and General

Authorities Act, emphasizes protection of park resources above all other park values, including socioeconomic. It will be up to the decision-maker to

weigh the available data, evaluate the possible impacts of each alternative, and decide if park resources are impaired. The impacts in question are not

on their face indisputable, and it is the function of an EIS to focus the issues by addressing those impacts as well as possible.
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NATIONAL WILDLIFE FEDERATION AND INTERTRIBAL BISON COOPERATIVE

Page 5. Re: Additional socioeconomic concerns. NPS should regulate snowmobiling for the health and safety of the public and wildlife. The effects

of snowmobiling on the public and on wildlife were assessed for all alternatives. The commenter’s opinions will be considered in making the final

decision, but there is nothing in this suggestion that would alter the range of alternative features to be evaluated in the FEIS. Expressions of support or

objection will be responded to when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the

Record of Decision. There is a very clear separation between alternatives legitimately considered in an analysis and the expression of a preferred

alternative or the decision to be made. 3) NPS should implement a winter use plan that will restore and maintain the natural quiet and stillness. The

effects of noise on the natural quiet of the parks were assessed for all alternatives. Additional information acquired since the DEIS will be

incorporated into the FEIS. See also response to Point 2 above.

Page 6. Re: 1) NPS working with ITBC. NPS received and will consider comments on the DEIS from the ITBC. Throughout the planning process,

NPS has and will continue to consult with the eight contemporary American Indian Tribes traditionally affiliated with the GYA (P. 133).

Page 6 Re: Frequency and mileage of groomed roads should be minimal. Several alternatives include provisions for decreasing the mileage of

groomed roads over the current scenario. Expressions of support or objection will be responded to when the decision criteria are developed, and

accordingly, when the rationale for the decision is presented in the Record of Decision. There is a very clear separation between alternatives

legitimately considered in an analysis and the expression of a preferred alternative or the decision to be made.

Page 6. Re: None of the alternatives are supported. Statements of opposition relate to the decision that the commenter would like to see NPS make.

Please see earlier response to this letter in regard to page 5 “Socioeconomic concerns.”

Page 7. Re: Statements of opposition relate to the decision that the commenter would like to see NPS make. Please see earlier response to this letter

in regard to page 5 “Socioeconomic concerns.”

Page 8. Statements of opposition relate to the decision that the commenter would like to see NPS make. Please see earlier response to this letter in

regard to page 5 “Socioeconomic concerns.”

Page 8. Re: Modify alternative F to include visitor use carrying capacity. Please see earlier response to this letter in regard to page 5

“Socioeconomic concerns.”

Setting a carrying capacity is a highly complex and potentially divisive exercise. NPS managers decided there was not sufficient time available in the

settlement time frame to devote to this type of analysis. Regardless of which alternative is decided upon in the Record of Decision, a carrying

capacity study will be in place within two years, and the FEIS will set interim visitor use levels. More explanation of the carrying capacity issue will

be included in the FEIS, and mitigation features for the alternatives will include carrying capacity analyses.
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PREDATOR CONSERVATION ALLIANCE

Page 1. Re: none of the alternatives adequately protects park resources. NPS disagrees. All of the alternatives, to various degrees, protect park

resources. Under the CEQ regulations, the requirement in an EIS is to provide a range of reasonable alternatives that clearly define the issues, and to

fully evaluate and disclose the possible effects of those alternatives. In our estimation, it is unrealistic to expect all alternatives in an EIS to meet all

desired conditions expressed in the purpose and need for action equally well. Such a set of alternatives would likely have no significant differences

among them.

Pages 1-2. Re: Support The Citizen’s Solution. Expressions of support or objection to specific alternatives or alternative features will be responded to

when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision.

Page 1. Re: Banning all motorized use or building a monorail are the best ways to protect wildlife. See page 37-38 in the DEIS “Alternatives

Considered But Eliminated From Detailed Study” for a discussion of these issues.

Page 1. NPS is working to ensure that the Winter Use Plan and the Bison Management EIS/Plan are coordinated and that analyses are parallel and

consistent in regard to the effects of winter use on bison.

Page 2. 1) Re: NPS failed to provide documentation about the effects of road grooming on bison and other wildlife. It is not clear to NPS if the

commenter is referring to the Winter Use DEIS or the 1997 EA. If it is the former, NPS disagrees: the effects of grooming are discussed on pages

166-169, and in Chapter 4 under each alternative. If it is the latter, it is outside the scope of this project to respond to comments referring to another

document, and no response is required. 2) Adverse effects of nonmotorized use. The effects of nonmotorized use are analyzed for each alternative. It

will be up to the decision-maker to weigh the available data, evaluate the possible impacts of each alternative, and decide if park resources are

impaired. The impacts in question are not on their face indisputable, and it is the function of an EIS to focus the issues by addressing those impacts as

well as possible.

Page 3. Re: Against avalanche control. Alternative D proposes to cease avalanche control and close the East Entrance.

Page 3. Re: Effects of winter use on grizzly bears. An analysis of the impacts on grizzlies associated with winter use is contained in the biological

assessment and the FEIS will be revised to include this information.

Page 3. Re: Effects of winter use on wolves. An analysis of the impacts on wolves associated with winter use is contained in the biological

assessment and the FEIS will be revised to include this information. The new preferred alternative restricts travel in certain ungulate winter ranges,

and consequently disturbance to foraging wolves should be decreased over the current management scenario.

Page 4. Re: Citation on the effects of snowmobiles on wolves. NPS is aware of the effects of snowmobiles on wolves. An analysis of the impacts

on wolves associated with winter use is contained in the Biological Assessment and the FEIS will be revised to include this information. The new

preferred alternative restricts travel in certain ungulate winter ranges, and consequently disturbance to foraging wolves should be decreased over the

current management scenario.

Page 4. Re: Effects of packed trails on lynx. An analysis of the impacts on lynx associated with winter use is contained in the biological assessment

and the FEIS will be revised to include this information.

Page 4. Re: Effects of humans on wolverines. The FEIS will be revised to include additional information on wolverines and winter recreation.

Page. 5. Re: Effects of East Entrance Road/ Sylvan Pass use on wolverine. The FEIS will be revised to include additional information on wolverines

and winter recreation.

Page 5. All of the alternatives contain features that serve to mitigate impacts to wildlife. The preferred alternative, for example, restricts use in

important wildlife winter range and proposes adaptive management to continually provide feedback to management on the effects of human use on

wildlife. In addition, park policy allows managers to close areas at any time to protect resources.

Page 5. Re: Snowmobiles cause noise. The analysis of sound impacts will be updated in the FEIS. The extent to which motorized sounds affect the
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experience of visitors will be addressed.

Page 5. Re: Snowmobiles cause air pollution. Inventories and monitoring data relating to the condition of air quality and air quality related values are

presented in the affected environment portion of the DEIS. The evaluation of pollution impacts by alternative is presented in the environmental

consequences section of the DEIS. This analysis will be enhanced in the FEIS using results from air quality modeling.

Page 5. Re: Ban snowmobiles. This statement refers to the decision to be made and is among the alternative features available for the decisionmaker to choose among.

Page 5. Re: Support mass transit. This statement refers to the decision to be made and is among the alternative features available for the decisionmaker to choose among.
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Page 1. Re: Presumption that motorized winter access must continue. “The primary purpose of an environmental impact statement is to serve as an actionforcing devise to insure that the policies and goals defined in the Act [NEPA] are infused into the ongoing programs and actions of the Federal Government

(§1502.1).” “The range of alternatives discussed in an [EIS] shall encompass those to be considered by the ultimate agency decision maker (§1502.2 (e)).”

The purpose and need for action described in the DEIS is sufficiently broad to act as an action-forcing tool. It is within the discretion of the decision maker to

set the scope of analysis. Considering that motorized use in the Parks is an existing use, not a proposed use, it is logical to frame the purpose and need in terms

that would include that use and facilitate an incremental investigation of the impacts of that use. To do otherwise, and to accept The Fund for Animal’s (Fund)

assertion, would result in a narrow scope of analysis and one viable alternative relative to motorized use. The settlement agreement that resulted in a need to

develop this EIS requires a comprehensive evaluation of winter recreation use – the presumption that only nonmotorized use should be considered in light of

policy, law, regulation and existing use, is not appropriate.

Page 2. Re: Dual or conflicting mandate. NPS asserts that there is a dual mandate which, in application, often presents management conflicts. Where

management that serves the enjoyment of the people steps over a line in respect to resource preservation, the action to be taken is clear. It is that line, or

threshold, or “impairment standard”(terminology coined by commenter) that is not often clear. The impacts in question are not on their face indisputable, and

it is the function of an EIS to focus the issues by addressing those impacts as well as possible. The purpose and need for action was developed with this intent.

Page 2. Re: No snowmobile, no snowcoach, no trail grooming alternative. See first response, above. It is within the discretion of the decision maker to set the

range of alternatives to be considered. How can the decision maker assess the impacts of an action without considering an alternative that includes it? If there

is doubt about the level or type of use that might be acceptable, relative to impacts and mandated tolerances, then how can a determination be made without an

appropriate range of alternatives? If NPS understands correctly from this comment that the Fund would not find the DEIS “permanently damaged” if there had

only been a no-motorized use alternative, then NPS disagrees because of its discretionary authority in setting the scope of analysis. If the Fund relies on

NEPA for its opinion that a no-motorized use alternative is required, NPS also disagrees. NEPA requires a “no action” alternative (§1502.14(d)). In this case,

since motorized use exists, and was sanctioned in the past under existing rules, policies and plans, “no action” is correctly interpreted as the existing

management situation. CEQ directly supports this position. Its opinion is that in instances where ongoing programs are being evaluated, “no action” is “no

change” from current management direct or level of management intensity. In these instances, CEQ states: “To construct an alternative that is based on no

management at all would be a useless academic exercise (Question 3 of CEQ 40 Most-Asked Questions).”

Page 2. Re: Preferred alternative proposes to prohibit motorized oversnow vehicle access. CEQ Regulations do not stipulate the rationale for selecting a

preferred alternative in an EIS. It stipulates that in a final EIS, a preferred alternative must be identified. The statement of preference for one or more

alternatives in a DEIS is discretionary, depending upon whether the agency has a preference at that point (§1502.14(e)). The identification of a preferred

alternative in a DEIS should be regarded by the public as extremely tenuous. An EIS serves as a means of assessing impacts of proposed agency actions

“rather than justifying decisions already made” (§1502.2(g)). The FEIS preferred alternative may be viewed more as a “precursor” decision, which will only

become final in a Record of Decision that expresses the rationale for the choice. It is clear that the expression of a preferred alternative, by itself, can in no

way invalidate the entire EIS analysis. The decision maker can select any of the proffered alternatives in a Final EIS through consideration of a variety of

factors, including but not limited to environmental impacts. The selected alternative does not have to be the most environmentally preferable alternative,

which must also be revealed in the decision document.
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Page 3. Re: The contention that the focus on economic impacts in the EIS is both unnecessary and misplaced, and that because of this focus the DEIS does not

meet legal standards under NEPA. NPS disagrees. The commenter is undoubtedly aware that the consideration of social and economic impacts is routinely

done in any environmental analysis. There are several major reasons for this. First, the scoping process as conducted under §1501.7 inevitably raises the

social and economic effects of a proposed action. In many instances, these are regarded as significant issues. Second, the impacts must be considered in the

context of society as a whole, the affected region, the affected interests, and the locality (§1508.27(a)). Third, the intensity of impacts on the quality of the

human environment must be gauged (§1508.27(b)), where “human environment” is to be viewed comprehensively (§1508.14). Effects (direct, indirect and

cumulative) are defined as including both economic and social impacts (§1508.8).

Page 4. Re: Snowmobiling and trail grooming cause significant adverse impacts. As stated in the comment, these impacts are disclosed in the EIS. The

commenter cannot reasonably state on the one hand that the analysis is deficient and on the other hand, sufficient. The question is what are the impacts, and at

what point do they result in an adverse impact on park values. It is the purpose of the EIS to speak to the magnitude, intensity and duration of the impacts, and

it is left basically to the decision maker to determine what constitutes impairment given the context of the situation. Contrary to the assertion of the

commenter, the level at which impacts are considered adverse is in dispute until resolved through an FEIS and Record of Decision.

Page 4. Re: Snowcoach use and trail grooming. It is the purpose of the EIS to speak to the magnitude, intensity and duration of the impacts associated with

snowcoaches. It is left to the decision maker to determine what constitutes an adverse impact given the context of the situation. Contrary to the assertion of

the commenter, impacts on the 3 park units are in dispute until resolved through an FEIS and Record of Decision. It is unreasonable to expect NPS to produce

an EIS, which conveys the necessity to evaluate alternatives, and then to state that there is only one alternative because the impacts of all others are on their

face prohibitive. This rationale is not effective in proving the DEIS is deficient, and it offers no constructive advice for producing a Final EIS.

Page 5. Re: Human use is secondary to preserving nature. The content of this comment on NPS mandates may also be found in the DEIS, page 2. Issues the

commenter lists to show that NPS is not following its mandate are the same issues given in the DEIS purpose and need for action. The intent of the purpose

and need for action, and the EIS is to improve the situation that the commenter decries.

Page 6. Re: Winter use mandate. The enabling legislation for Grand Teton National Park recognizes the right of access across Federal lands within the

exterior boundaries of the park to state, national forest and private lands. It also recognizes U.S Highway 89 and authorizes the construction of an alternate

route within the park to “facilitate public use and enjoyment of the [park].” The act is silent about the use of these or other travel-ways within the park by

autos, trucks, buses, bicycles or other forms of transport – summer or winter. By the commenter’s logic, there would be at least two highways through GTNP,

but no traffic should be allowed on them.

The commenter is correct in his statement that winter use is not explicitly or implicitly mandated by Yellowstone National Park’s enabling legislation.

However, neither does the act mandate implicitly or explicitly that winter access be disallowed. The act does state that the park is set apart as a pleasuring

ground for the benefit and enjoyment of the people. The act also allows for the construction of paths and roads and buildings to accommodate visitors, with

the overriding criteria that the resources therein be preserved and retained in their natural condition. The fact that buildings and roads may be constructed

implies that a certain level of impact is acceptable to allow for access by the public. It is the purpose of this NEPA process to examine just this issue and to

provide a meaningful analysis on which to base a sound decision. The acceptable level of impact on park values for all winter uses relates directly to the

decision to be made based on the analysis presented in the FEIS.

Page 7. Re: Public use. NPS does not disagree with this conclusion regarding its authority to prohibit uses that cause impairment of natural resources and the

enjoyment of those resources by future generations.
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Page 7. Re: Impairment standard. The action referred to in this comment is one that has long been implemented, supported by past policies, rules, and plans.

The “no action” alternative is “no change from current management.” Granting for the moment the commenter’s assertion that said action was not legal at the

beginning, NPS cannot just turn back the clock and start over. It must start at the present, assess the true impacts on these parks and proceed accordingly.

It should be noted that the attachments to these comments purporting to do not conclusively demonstrate that the resources of the three park units have

exceeded an “impairment standard.” There are a great number of inferences drawn from general studies, or studies that were undertaken elsewhere. Results

are extrapolated to the 3 park units, where conditions or circumstances are not demonstrated in the literature to be applicable. Where some studies of impacts,

notably those associated with Mary Meagher, apply directly to park resources (e.g., bison in Yellowstone), the site-specific impacts are presented as rationale

to prohibit use throughout the park. With few exceptions such as Meagher’s conclusions, there is very little in the literature to provide a solid basis for

determining at what point a potential impact becomes an adverse effect on park resources. This is contrary to the commenter’s apparent assumption that

“impairment standards” are self-evident and agreeable to all. NPS maintains that the standard of impairment can be a function of the criteria used by a

decision maker in the record of decision. The latter is a part of the decision to be made.

Page 9. Re: Footnote reference to the CDST and other snowmobile use in GTNP: NPS agrees that it is appropriate to provide more discussion of the CDST in

the final EIS.

Page 10. Re: Snowmobile use prohibited if in conflict with the park’s values. This comment restates material from the purpose and need for action.

Page 10. Re: Legal basis for grooming winter trails. A true legal basis for drawing conclusions about what is and isn’t allowed in the parks begins with

scrutiny of the enabling legislation. In this case, reference is made to regulations which are subject to change within the strictures of legislative guidance. The

enabling legislation is silent about grooming winter trails, as it is about a great many other facets of modern management. However, to conclude from the

absence of regulations (on the practice of grooming) that grooming is unauthorized.... is highly erroneous. There are a great many standard practices and

management measures that are not explicitly allowed in the regulations, and it is unreasonable to expect that this should be so. Aside from the question of

legal authority for grooming winter routes, NPS has clearly felt for many years that it is within its management authority. The DEIS discloses the

environmental impact of this activity.

Page 12. Re: Snowmobiling and trail grooming impact on animal populations. The commenter faults NPS for “conceding” impacts of winter grooming

operations on wildlife in the DEIS while failing to take action to remedy the impacts. Since we are engaged in a NEPA analysis, the remedy for any impacts

that are disclosed can only come with a decision. Since the decision will not be made until a Record of Decision is published, the criticism is premature.

Commenter is getting the cart before the horse. If the criticism is based on NPS’ identification of a preferred alternative in the DEIS, then we reiterate the

response to comment, “Page 2. Re: Preferred alternative...”

Page 13. As stated in the comment, the impacts on air and water are disclosed in the DEIS. The actions that NPS must take in regard to the impacts goes to

the decision to be made.

Page 13. Re: The NPS required to be aggressive in safeguarding air quality. Inventories and monitoring data relating to the condition of air quality and air

quality related values are presented in the affected environment portion of the DEIS. The evaluation of pollution impacts by alternative is presented in the

environmental consequences section of the DEIS. This analysis will be enhanced in the FEIS using results from air quality modeling.

Page 14. Re: Snowmobiles create substantial amounts of noise. The effects of winter use, in particular sound from motorized vehicles, are disclosed in the

DEIS. This analysis will be enhanced in the FEIS using additional monitoring data and results from sound modeling.
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Page 15. There has not yet been a determination that snowmobiling and trail grooming are antithetical to preservation mandates. The action referred to in this

comment is one that has long been implemented, supported by past policies, rules, and plans (Please see the earlier response to this letter in regard to page 2

“Preferred alternative.”) The “no action” alternative is “no change from current management.” Granting for the moment the commenter’s assertion that said

action was not legal at the beginning, NPS cannot just turn back the clock and start over. It must start at the present, assess the true impacts on these parks and

proceed accordingly. Impacts that need to be considered includes economic effects. Please see earlier response to this letter in regard to page 3 “The

contention...,” above. The decision maker must weigh all impacts, and be guided in the end by her or his criteria that would protect the parks for enjoyment

by future generations.

Pages 17-18. Re: Executive Order 11644, as amended. The NPS interpretation of Executive Order 11644 is set forth in the NPS policies the commenter cites.

Recently, NPS proposed revisions to its management policies and solicited public comment on the revisions. 65 Fed. Reg. 2984. The Service’s interpretation

of the Executive Order may change following the NPS analysis of public comment on the revised policies. If that occurs before the final EIS or Record of

Decision are ready for publication, NPS will include a notice of the change in those documents as appropriate.

Page 18. Re: Groomed routes to facilitate oversnow vehicle use. The commenter has constructed an argument whereby all choices involving any level of

motorized use are gone, on the basis of a determination which has yet to be made. Adverse impacts may be associated with both motorized and nonmotorized

uses, as disclosed in the EIS. Whether or not an adverse impact is tantamount to impairment or derogation of park values is also a function of the magnitude,

intensity, duration and context of the impact. This determination of significance, for most resources and park values, is made in the final decision considering

impacts disclosed in a final EIS, for a full range of choices. The commenter cannot have it both ways – a sufficient legal process under NEPA and a range of

one alternative that is not pre-decisional. Assuming the illegality of an action initiated years ago by the perceived impacts of today is incorrect logic. NPS

disagrees and feels that the assumption is wrong, therefore the conclusion drawn from it is wrong. NPS does feel that conditions have changed, and has taken

steps for the 3 park units, first in 1990 (Winter Use Plan/EA), then starting in 1994 with a Multi-Agency Assessment, and presently in this EIS to address those

changed conditions.

Page 18. Re: Involvement of cooperating agencies. The intent of granting cooperating agency status was in the spirit of cooperation and coordination

consistent with NEPA, FACA and APA. The content of the document has been affected, but NPS disagrees that the analysis has been. The document

incorporates material from the cooperating agencies, which is reported as a matter of full disclosure even though the results disagree with NPS analysis.

Letters from the cooperators and the signed agreements between NPS and cooperators were included in the DEIS, Volume II. These items relate to content.

As to inappropriate influence, one need only review media reports, comment letters or other correspondence from the cooperators to obtain their assessment of

how they were involved.

Page 20. Re: Involvement of cooperating agencies in forming alternatives. Please see previous comment, immediately above. Cooperating agencies did have

a participatory role in alternative development. However, they were not exclusively involved. The process used in the cooperating agency alternatives

workshop began with exercises in developing problem statements from the public scoping effort.

Pages 20-21. Re: 2. The analysis of economic impacts. Please see the response to comment, “Page 3. The contention...,” above. There is no emphasis from

NPS on economic impacts. It would appear that this emphasis might be conveyed by the cooperating agencies, but the document and the process are merely

fulfilling NEPA requirements. Also, NPS is not responsible for the economic viability of the surrounding areas, but what NPS might propose to do is certainly

an issue which must be addressed in the EIS. For reasons given in earlier in this response, NPS disagrees with the contention that effects analysis for

economics is subservient to analysis of ecological impacts. If the commenter truly means that economic impacts are subservient to ecological impacts, such as

they are disclosed and understood through the EIS analysis, NPS feels this kind of determination is left to the decision maker.
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Pages 21-22. Re: Cost assessment Appendix F in Volume II of the DEIS describes construction and operation costs by alternative at a level regarded as

sufficient for a programmatic EIS and plan (§1508.18(b)(2) and (3)). NPS will review and update this cost analysis for the FEIS, but the commenter has not

provided any specific criticisms that can be addressed at this time. NPS will consider providing some additional discussion on environmental costs in the

FEIS.

Page 23. Re: Alternative formulation. Please see response to comment, “Page 1” and “Page 2. Re: No snowmobile...” at the beginning of this letter response.

Page 23. Re: The major issues. The major issues are articulated in the DEIS on pages 13-15.

Page 23. Re: Alternative formulation. Please see response to comment, “Page 1” and “Page 2. Re: No snowmobile...” at the beginning of this letter response.

CEQ regulations do not stipulate how alternatives are to be formulated. The regulations at §1501.7(a)(2) require the agency to consider public comment from

scoping and determine the significant issues – or the issues to be analyzed in depth in the EIS. The regulations at §1502.14 require the agency to develop

alternatives that sharply define the issues and provide a clear basis for choice among options. NPS developed significant issues from a broad scoping effort,

and the DEIS alternatives respond to these issues in varying ways that allow a comparison of options and their effects or opportunity costs. The formulation of

alternatives meets the requirements of the regulations.

Page 23. Re: Consistency with federal law and NPS regulations and policies. Laws, regulations and policies do not, by themselves, drive an action. An

identified gap between existing conditions and desired conditions form the basis for the purpose and need for action. The underlying purpose (§1502.13), or

goal to be achieved as stated at the scoping stage is to provide a full range of quality winter experiences offered in appropriate settings and having no

significant adverse impacts on park values. This purpose is represented by the desired condition shown on page 3 of the DEIS. The underlying need

(§1502.13) is defined by the existing conditions expressed on page 4. Despite the complexities introduced by multiple goals and multiple issues, all

alternatives represent possible actions that meet the underlying purpose and need. As stated in the DEIS, the desired conditions in this case reflect relevant

laws, regulations and policies. A decision maker may set the scope of analysis and the decision to be made within the constraints of those dictates. However,

NEPA does not require this. An environmental analysis may evaluate a proposed change in policy, or a decision based on effective analysis may indicate the

need for a change in policy.

Page 23. Re: Identification of the decision. The decision to be made will be presented in the purpose and need section of the final EIS.

Page 24. Re: Development of desired conditions. NPS developed the desired conditions, as it is this agency’s responsibility to do. The DEIS clearly states

that the desired conditions proceed from NPS mandates including legislation, regulations, executive orders, and governing policies. That motorized winter use

has been ongoing in these parks since at least 1963, there is some indication that parks’ leadership at the time found adequate direction in NPS mandates to

allow the use. For reasons also described in earlier responses, it is reasonable to include a goal of motorized access as part of the purpose.

Page 25. Re: Plowing in alternative B. It is the commenter’s opinion that plowed road access from West Yellowstone to Old Faithful would drastically and

adversely affect wildlife. The analysis in the EIS does not bear out this contention, at least in the sense that the impacts would constitute an impairment or

derogation of park values – which goes to the decision to be made. Alternative B, in this regard, is constituted to provide access for a number of visitors, via

mass transit, equal to that facilitated by present snowmobile use. The alternative would drastically reduce the number of vehicle miles traveled on this route

during the winter, even though the number of visitors could potentially increase.

Page 25. Re: The purpose of the EIS. It is the nature of the decision that is in question. It has been NPS’ intent from the beginning of the process to prepare a

programmatic plan (§1508.18(b)(2) and (3)). This would be the purpose of preparing a “comprehensive EIS.” There should have been no illusions that a plan

of this magnitude would be based upon detailed, site-specific data in order to make every decision possible relating to winter use. This programmatic

approach is acceptable under the law, in the way that NEPA is the vehicle for producing NPS General Management Plans and USFS Forest Plans, and

amendments thereto. Such documents do, in fact, make decisions and allocations at a general level and defer many site-specific types of decisions to a later

date. In this context, it is also acceptable to spell out processes that would be followed, such as adaptive management, as alternative features. That this is
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done in two alternatives cannot be construed as a violation of NEPA. It will be up to the decision maker to weigh the available data, the possible impacts of

such alternatives in the short term, and decide if park resources and values are sufficiently protected.

Page 26. Re: Conducting scientific studies. See preceding response. Technically, this issue is debatable and it is why NPS is performing NEPA at this time.

Page 27. Re: Grooming. The impacts of grooming are evaluated and disclosed in the DEIS. It is unclear what the commenter is referring to in the statement

that substantial impacts of grooming have not in some cases been disclosed. There may be a difference of opinion on the nature of impacts associated with

this action.

Page 27. Re: Failure to evaluate a nonmotorized alternative. The adequacy and range of alternatives, regarding the inclusion of motorized use, has been

addressed in numerous foregoing responses.

Page 27. Re: Failure to evaluate a nonmotorized alternative. NEPA does not require the detailed consideration of a no snowmobiling, no grooming, or no

motorized use alternative. See especially response, “Page 2. Re: No snowmobiles...”

Page 28-29. Re: Alternatives presented by commenter. Five possible “alternatives” are presented by the commenter on these pages. Except for suggested total

closures to motorized use or grooming for an entire park, or for timing restrictions that appear to be administratively unviable, many of the alternative

suggestions are incorporated within the DEIS alternatives. As such, they are available as choices for the decision maker. Also, the suggested alternatives

could at the appropriate time be the result of adaptive management procedures, further study, or recreation capacity determination.

NPS takes this opportunity to further address the complexity of alternative formulation in this effort. Many suggestions for alternatives or alternative features

were made in the thousands of comments received. A great deal of criticism was leveled at the current range of alternatives because people did not like the

way features were “mixed.” At the same time, many people focused on features of alternatives that they liked, and features to which they were opposed. It is

clear that for such complex issues there could be an infinite number of possible alternatives. CEQ states that in such instances, the agency need only consider

a reasonable number of examples that cover the full spectrum of possible alternatives that meet the purpose and need (Question 1b, CEQ 40 Most-Asked

Questions). What constitutes a reasonable range depends on the nature of the proposal and the facts in each case, where the proposal is at the discretion of the

agency.

The final selected alternative that is to be documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS. Such

mixing can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside the range of

alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the record of decision, along with the

rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail. This material needs to be explained in a new

FEIS section on the decision to be made.

Page 29. Re: 4. The Draft EIS fails to disclose or discuss environmental impacts associated with trail grooming. The DEIS discloses and discusses the

environmental impacts of trail grooming for each alternative. Since this activity has relevance primarily for wildlife, its impacts are discussed in the wildlife

consequences section for each alternative.

Page 30. Re: Increase in snowmobiles and their impacts. This statement of effects relates more to use by snowmobiles than to effects of groomed surfaces.

Effects due to snowmobile use are also disclosed in the DEIS by alternative. The alteration of snowmelt patterns by trail grooming and use and their alleged

effect on road surfaces is not a significant issue requiring study in this EIS.

Page 30. Re: Reduction in the rate of snowmelt due to grooming. The impact of groomed surfaces and how they may facilitate the transport of toxins into the

aquatic environment is more appropriately addressed by directly speaking to the presence and sources of the toxins. The DEIS discusses this under effects on

water resources for each alternative. Additional information has become available (Ingersoll, Effects of Snowmobile Use on Snowpack Chemistry in

Yellowstone National Park, 1998) since publication of the DEIS, and will be incorporated into the final document.
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Page 31. Re: Use of groomed routes by wildlife beneficial. If the issue is the effect of groomed surfaces on the energy balance of individual animals, as is the

intent of the DEIS discussion, then groomed surfaces by themselves allow animals to save energy. This is why they use the surfaces, and it is apparently to

their benefit. The DEIS also makes the point that recreation use of groomed surfaces contributes to stress and energy expenditures by animals. The larger

issue – given the balance of energy savings vs. energy loss – is if and to what extent these circumstances constitute an adverse impact on park resources. The

total picture – groomed routes, type and amount of use, stressful periods for wildlife, availability of forage – needs to be considered in the final decision. The

goal of natural regulation applies to whole populations, not individuals, and must factor in the presence of people.

Re: All comments on pages 31-41. The commenter relies heavily upon the work of Dr. Meagher to support his opinion that groomed roads have had a major

and devastating effect on bison, and that, consequently, natural regulation does not operate on the YNP herd. While work by Dr. Meagher was considered and

used in the preparation of the DEIS, as stated on page 166 wildlife biologists disagree on the extent to which bison use roads, and as to the effects of use on

population dynamics and movements. Therefore the results of other studies were cited as well. Providing the reader with both opinions fulfills the disclosure

requirement in CEQ regulations (§1502.9(a)). A discussion as to the effects of groomed roads on ungulates in general is found on pages 183, (alternative A)

and subsequent evaluations of each alternative compare the effects of groomed roads to those incurred under alternative A. Additionally, the conclusion

section contained in the discussion of the impacts of each alternative addresses the effects of groomed surfaces on ungulates. The DEIS discloses that

groomed surfaces may positively affect the energy expenditures incurred by bison and other ungulates. Furthermore, the cumulative effects of winter

recreation and severe weather on wildlife are discussed on pages 166-67 (also see above response). The commenter provides a lengthy literature review about

the effects of recreation, in particular groomed roads, on bison and other wildlife species. The major points repeatedly expounded upon are found within the

DEIS. Please see the following response as it relates to CEQ requirements for adequate disclosure. NPS will include a few additional citations in the FEIS:

Aune (1981) on the ability of bison to habituate to snowmobiles and Moen et al. (1982) on the physiological responses associated with disturbance. Although

wolves have been documented to use snowmobile trails, this relationship has not been evident for the wolves tracked in YNP (Smith, pers. comm. 2000). The

latter fact will be included in the FEIS and Biological Assessment.

Pages 42-46. The CEQ regulations do not require exhaustive and voluminous discussion, especially when the discussion can be characterized as background

and adding needless detail (§1500.4 (f)). The amount of detail to be included in an EIS should be that level which is relevant to the decision to be made, and

preparing analytic as opposed to encyclopedic documents (§1500.4 (b)). The regulations recommend page limits on documents, which the draft EIS already

exceeds. Finally, the regulation at §1502.21 (Incorporation by reference) requires agencies to incorporate material by reference to cut down on the bulk

without impeding agency review. Brevity and incorporation by reference of large amounts of literature in the DEIS, and in the FEIS, does not constitute

inadequate disclosure. Work by Dr. Meagher and others was considered and used in the preparation of the EIS. The lengthy discussion of wildlife and

impacts on pages 42-46 of the letter, presented as a listing of flaws in the DEIS, is drawn from literature summarized and cited in the EIS.

Pages 46-53. Re: T&E species. First of all, the preparation of a biological assessment (BA) is a requirement of ESA; whether or not formal consultation is

required is up to the USFWS upon review of the BA. The commenter implies in Footnote 40 that NPS is negligent in its duty to prepare a BA. A draft BA was

prepared and submitted to the USFWS. There is no requirement under NEPA for public review of a BA. Otherwise, 1) Grizzly bears —The FEIS will be

amended to include a more thorough discussion of impacts to grizzly bears associated with winter recreation. The NPS does not dispute that carrion is

important to grizzly bears in the spring, but it does not agree that multiple pages of literature review (as provided by the commenter) are necessary to support

this fact. Furthermore, it is not clear, as the commenter asserts, that indirect impacts associated with the alleged “altered distribution and movement patterns of

large ungulates” result in lowered availability and accessibility of carrion. Although some studies have indicated that grizzlies use carrion within 1.5 km of a

road or development less than its availability, there has not been shown a causal link between roads, where animals die, and grizzly bear survival as influenced

by lack of carrion. Any disturbance to scavenging bears as a result of roads and developments are alleviated by a YNP policy that closes to the public

important spring foraging habitats for grizzlies beginning March 15 (before the majority of bears emerge from their dens) and keeps much of that area closed

until Memorial Day weekend. This discussion will be expanded upon in the FEIS and BA. Lastly, the potential indirect effects of air pollution on grizzlies are

not supported by data and are consequently highly speculative. Gray wolves —The FEIS will be amended to include a more thorough discussion of impacts to
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gray wolves associated with winter recreation. Although wolf use of packed snow routes has been documented to occur, this relationship has not been

established in YNP. The commenter’s contention that groomed routes allow wolves a competitive advantage over ungulates, which are also attracted to the

routes, misses the point: wolf habitat is ungulate habitat. Ungulates, regardless of whether groomed routes occur or not, travel to areas of low snow in the

winter, i.e., winter range and wolves follow. Lynx —The FEIS will be amended to include a more thorough discussion of impacts to lynx associated with

winter recreation, in particular the effects of groomed roads on interspecific competition. Wolverine —The FEIS will be amended to include a more thorough

discussion of impacts to wolverines associated with winter recreation. Snowmobile impacts to denning wolverine, however, are not expected to occur because

snowmobile routes are not located in wolverine denning habitats, which are generally in high elevation, remote areas.

Page 53, including material through page 56. Re: Analysis of public health. There is a greater amount of final study information available to the NPS for

inclusion in the FEIS than was available prior to the publication of the draft. Public health sections will be updated in accordance with this data. Please see

response, “Pages 42-46,” above.

Page 53, including material on pages 56-59. Re: Analysis of water and aquatic resources. There is a greater amount of final study information available to the

NPS for inclusion in the FEIS than was available prior to the publication of the draft. Water and aquatic resources sections will be updated in accordance with

this data. Please see response, “Pages 42-46,” above.

Page 53, including material through page 56. Re: Analysis of air resources. There is a greater amount of final study information available to the NPS for

inclusion in the FEIS than was available prior to the publication of the draft. Air resources sections will be updated in accordance with this data. Please see

response, “Pages 42-46,” above.

Page 59. Re: Effects on vegetation. The commenter extrapolates from data involving actively photosynthesizing vegetation. Otherwise, statements about

impacts on vegetation are too broad to be conclusive about effects on this resource during the winter in the three park units. The question appears to be more

about fuel and oil residues deposited in snowpacks, and how that may indirectly affect vegetation during the spring growth season.

Page 60. Re: Polycyclic Aromatic Hydrocarbons. That PAH and other toxic elements are included in emissions from 2-stroke engines is disclosed in the

DEIS, page 163 et al. The information in the DEIS will be reviewed and enhanced as appropriate for the final document.

Page 61. Re: Analysis of noise impacts in the DEIS is deficient. Analysis of sound in the DEIS is sufficient in its determinations, by alternative, that winter

use activities have adverse impacts on the natural soundscape. Information from Bowlby and Associates was used in the DEIS analysis, but was inadvertently

omitted from the bibliography. This will be remedied in the FEIS. Also, additional data has been developed for the sound analysis and will be incorporated

into the final document.

Page 61-62. Re: Impacts of non-natural sound on wildlife. Because quantifying the effects of non-natural sound on animals in the wild (as opposed to a

controlled laboratory setting) is extremely difficult, NPS believes that analyzing the effects of machine noise on ambient sounds levels is a legitimate

substitute (see following response). NPS also believes that the effects of noise on wildlife are inherently included in the overall effects of snowmobiles on

wildlife in terms of disturbance. Nonetheless, a review of the impacts of noise on wildlife will be included in the FEIS.

Page 62. Re: Consistency of noise restrictions with NPS regulations. If it were determined beyond speculation that machine noise as it occurs in the 3 park

units adversely affects wildlife to a point that it represents derogation of park values, then the restriction would apply. The same is true of possible impacts on

aesthetics or experiences of other visitors, although these are disclosed as adverse impacts in the DEIS, and may be more supportable. This issue goes to the

purpose and need for action, and to the decision to be made, addressed in earlier response to comments in this letter.
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Page 63. Re: 9. NPS must not rely on survey findings to revise and justify its final strategy and Record of Decision. NPS will continue to use the best

information available. As this survey information is reported or cited in the DEIS, the limitations of the survey are made evident. Additional survey

information is now available for the FEIS, and those data will similarly be accompanied by assumptions and survey limitations. The data is used to report

impacts, primarily those involving visitor experience and social and economic environments. The final strategy, or decision is based on selection criteria used

by the decision maker, which are disclosed in the record of decision through discussion of “preferences among alternatives based on relevant factors including

economic and technical considerations and agency statutory missions” (§1505.2(b)). Please see the response, “Page 2. Re: Preferred alternative...”

Page 64. Re: Influence on results of Winter Use Survey. See previous response. NPS is aware of this survey factor, and the conclusions drawn from the

survey are placed in this context.

Page 64. Re: Purpose. Commenter’s statement of how the decision must or must not be arrived at. This goes to the purpose and need for action and the

decision to be made. Please see the response, “Page 63. Re: 9,” above.

Page 65. Re: New alternative. Commenters put forth new alternative not evaluated in detail in the DEIS. This alternative and the contention that it would be

the only a viable alternative consistent with NPS legal mandates are based on premises that NPS does not accept. The completion of the EIS and the final

decision are critical to any such determination. “The primary purpose of an environmental impact statement is to serve as an action-forcing devise to insure

that the policies and goals defined in the Act [NEPA] are infused into the ongoing programs and actions of the Federal Government (§1502.1).” “The range of

alternatives discussed in an [EIS] shall encompass those to be considered by the ultimate agency decision maker (§1502.2 (e)).” The purpose and need for

action described in the DEIS is sufficiently broad to act as an action-forcing tool. It is within the discretion of the decision maker to set the scope of analysis.

Considering that motorized use in the parks is an existing use, not a proposed use, it is logical to frame the purpose and need in terms that would include that

use and facilitate an incremental investigation of the impacts of that use. To do otherwise, and to accept the Fund’s assertion, would result in a narrow scope

of analysis and one viable alternative relative to motorized use. The settlement agreement that resulted in a need to develop this EIS requires a comprehensive

evaluation of winter recreation use – the presumption that only nonmotorized use should be considered in light of policy, law, regulation and existing use, is

not appropriate. The insistence upon natural regulation comes from a misplaced focus on individual animals rather than populations, and it ignores the bigger

picture that people, roads and facilities are located in National Parks and will remain so. Hence, as indicated in the EIS, NPS will not analyze in detail an

alternative that removes all oversnow motorized use from the three park units.
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Page 1. Re: Sierra Club’s Principles Concerning Natural Quiet. Natural quiet is governed sufficiently by regulations and policies excerpted in DEIS

Appendix C. This direction forms a part of the purpose and need for action.

Pages 2. Re: Volume II, Appendix C, include the numbered “Conclusion Cites”. Volume II will not be revised.

Page 2. Include addition citations on natural quiet from the Grand Canyon and Everglades. The CEQ regulations do not require exhaustive and

voluminous discussion, especially when the discussion can be characterized as background (§1500.4 (f)). The amount of detail to be included in an

EIS should be that level which is relevant to the decision to be made, and preparing analytic as opposed to encyclopedic documents (§1500.4 (b)).

The regulations recommend page limits on documents, which the draft EIS already exceeds.

Page 3. Re: Acknowledge and assess the real effect of aircraft on the parks. Aircraft effects are considered in the cumulative impact analysis on

parks. They are not the focus for study in the winter use EIS.

Page 3. Re: Credibility of Bowlby study. New information is now available on sound and will be incorporated into the FEIS.

Page 3. Re: Recalculate background sound level (Table 16). New information is now available on sound and will be incorporated into the FEIS.

Page 3. Re: Use %TA for sound analyses. New information is now available on sound, including %TA, and will be incorporated into the FEIS.

Pages 4. Re: NPS implies that %TA was calculated in Borrie et al. (1999) or in Friemund et al. (1997). There is no implication intended. The

sound analysis will be updated in the FEIS.

Page 4. Re: 1.) “Low-end” ambience is erroneously inflated in DEIS. 2.) Can %TA now be provided? New information is now available on sound,

including %TA, and will be incorporated into the FEIS.

Page 4. Re: Survey regarding attitudes about natural quiet was biased. NPS clearly states the parameters of the surveys. NPS also indicates (DEIS

pages 153-154) that natural quiet, as defined by solitude and an expectation of hearing the sounds of nature, are among the most important reasons that

people visit national parks.
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Page 1. Re: Support Citizen’s Solution. Expressions of support or objection to specific alternatives or alternative features will be responded to when

the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision.

Page 1. Re: Against alternative B. See previous response. Partly in response to the overall non-support of plowing the road from the West Entrance to

Old Faithful, NPS expresses a new preferred alternative in the FEIS. This alternative would provide mass transit oversnow motorized access from

West Yellowstone to Old Faithful, and allow visitors to experience the park by snowcoach.

Page 2. Re: Support mass transit. See previous responses.

Page 2. Re: Alternative B will result in greater impacts from snowmobiles than stated in the DEIS. NPS disagrees. However, it will be up to the

decision-maker to weigh the available data, evaluate the possible impacts of each alternative, and decide if park resources are impaired. The impacts

in question are not on their face indisputable, and it is the function of an EIS to focus the issues by addressing those impacts as well as possible.

Page 2. Re: NPS must establish carrying capacities for winter use. Setting a carrying capacity is a highly complex and potentially divisive exercise.

NPS managers decided there was not enough time available in the settlement time frame to devote to this type of analysis. However, numbers of

users is recognized as an element of any impacts associated with winter use, so determining use numbers must be a part of the eventual solution to be

reached under any alternative. Incorporating this as a common feature is a necessity. NPS is developing visitor use scenarios for each alternative that

will be the basis for a more quantified effects analysis and for mitigation. Some mitigation will be in the form of interim use limits pending carrying

capacity analysis. More explanation of the carrying capacity issue will be included in the FEIS.

Page 2. Re: Cite acts pertaining to resource protection and belief that NPS is in violation due to impaired resources. Laws, regulations and policies do

not, by themselves, drive an action and the impacts in question are not on their face indisputable. It is the function of an EIS to focus the issues by

addressing those impacts as well as possible. An identified gap between existing conditions and desired conditions form the basis for the purpose and

need for action. The underlying purpose (§1502.13), or goal to be achieved as stated at the scoping stage is to provide a full range of quality winter

experiences offered in appropriate settings and having no significant adverse impacts on park values. This purpose is represented by the desired

condition shown on page 3 of the DEIS. The underlying need (§1502.13) is defined by the existing conditions expressed on page 4. Despite the

complexities introduced by multiple goals and multiple issues, all alternatives represent possible actions that meet the underlying purpose and need.

As stated in the DEIS, the desired conditions in this case reflect relevant laws, regulations and policies. A decision maker may set the scope of

analysis and the decision to be made within the constraints of those dictates; however, NEPA does not require this. An environmental analysis may

evaluate a proposed change in policy, or a decision based on effective analysis may indicate the need for a change in policy.

Page 2. NPS expresses a new preferred alternative in the Final EIS that contains features supported by the commenter. For example, it would provide

mass transit oversnow motorized access from West Yellowstone to Old Faithful, and would restrict access in certain wildlife winter ranges.

Expressions of support or objection to specific alternatives or alternative features will be responded to when the decision criteria are developed, and

accordingly, when the rationale for the decision is presented in the Record of Decision.

Page 2. Re: Support certain features of alternative B for GTNP. The features that the commenter supports are contained within the new preferred

alternative described in the FEIS. Please see preceding response.
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Pages 2-3. Re: Do not support a separate trail for the CDST in GTNP, do not support oversnow motorized use on the Moose-Wilson Road, do not

support additional warming huts or further development. Please see preceding response to this letter in regard to page 2 “Support certain...”). The new

preferred alternative described in the FEIS prohibits snowmobiles in the parks.

Page 3. Re: Validity of visitor survey data in DEIS. As this survey information is reported or cited in the DEIS, the limitations of the survey are made

evident. Additional survey information is now available for the FEIS, and those data will similarly be accompanied by assumptions and survey

limitations. The data is used to report impacts, primarily those involving visitor experience and social and economic environments. This is entirely

appropriate under NEPA. The final strategy, or decision is based on selection criteria used by the decision maker, which are disclosed in the record of

decision through discussion of “preferences among alternatives based on relevant factors including economic and technical considerations and agency

statutory missions” (§1505.2(b)).

Page 3. Re: The DEIS does not disclose the impacts of snowmobiles on wildlife. NPS disagrees. The DEIS discloses impacts from snowmobiles on

wildlife for every alternative.

Page 3. Re: Tunnel effect caused by plowing the road will not benefit wildlife or visitors. Although the DEIS does not use the term “tunnel effect” it

does discuss the negative impact associated with snow berms along the plowed road corridor, and suggests mitigation for wildlife (p. 209). NPS and

the commenter disagree on whether or not such a tunnel effect would result from plowing. In many other areas within the three park units, roads are

plowed and no tunnel effect exists.

Page 4. Re: Cite numerous laws by which the NPS must comply. NPS is fully aware of the laws by which it must abide and fully intends to comply

with these laws.

Page 5. Re: Statement of effects for air quality. There is a greater amount of final study information available to the NPS for inclusion in the FEIS

than was available prior to the publication of the draft. Air resources sections will be updated in accordance with this data including results from air

quality modeling

Page 5. Re: Statement of effects for snowmobile emissions exposure. The emissions analysis will be more comprehensive for all alternatives in the

FEIS and a discussion of limiting emission levels will be addressed in the FEIS under the context of setting carrying capacities.

Page 6. Re: Support snowcoaches over snowmobiles. Expressions of support or objection to specific alternatives or alternative features will be

responded to when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision.

The new preferred alternative described in the FEIS prohibits snowmobiles in the parks and emphasizes mass transit snowcoach system.

Page 7-8. Re: NPS must protect natural quiet. NPS does not dispute that it must protect the natural quiet. Additional data has been developed for the

sound analysis and will be incorporated into the final document.

Page 8. Re: Effects of noise on wildlife. Because quantifying the effects of non-natural sound on animals in the wild (as opposed to a controlled

laboratory setting) is extremely difficult, NPS believes that analyzing the effects of machine noise on ambient sound levels is a legitimate substitute

and can be used to infer effects on wildlife. NPS also believes that the effects of noise on wildlife are inherently included in the overall effects of

snowmobiles on wildlife in terms of disturbance. Nonetheless, a review of the impacts of noise on wildlife will be included in the FEIS.

Page 8. Re: Effects of noise on natural quiet. Analysis of sound in the DEIS is sufficient in its determinations, by alternative, that winter use activities

have adverse impacts on the natural soundscape. Additional data has been developed for the sound analysis and will be incorporated into the final

document. The extent to which motorized sounds affect the experience of visitors will be addressed.

Page 8. Re: Mitigation measures in alternative B fail in terms of protecting natural quiet. NPS disagrees. Please see previous response.

Page 8. Re: Change sound level requirements and time line for compliance in alternative B. These features are within the range of alternatives that
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the decision maker may choose among in the record of decision.

Page 9. Re: NPS must be violating its mandate to protect the natural quiet. NPS disagrees because the impacts in question are not on their face

indisputable, and it is the function of an EIS to focus the issues by addressing those impacts as well as possible. At question is the difficulty of

determining the “threshold of impairment.” For example, when do the impacts associated with sound impair park values, such as natural quiet)? It

will be up to the decision maker to weigh the available data, evaluate the possible impacts of each alternative, and decide if park resources are

impaired.

Page 9. Re: Only citizens’ solution will effectively deal with the noise issue. Expressions of support or objection to specific alternatives or alternative

features will be responded to when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record

of Decision.

Page 9. Re: 1) Establish daylight only hours to protect safety of humans and wildlife in all alternatives; 2) Close CDST and close East Entrance in all

alternatives; 3) Restrict backcountry travel in all alternatives; 4) Implement public education programs in all alternatives. The commenter’s opinions

will be considered in making the final decision, but that there is nothing in those opinions that substantively would alter the range of alternative

features to be evaluated in the Final EIS. For example, if the features that are not supported were to be deleted from the range of alternatives then the

analysis would be left only with features that the commenter likes or agrees with. If only the actions that are liked by the commenter remain, then

there is effectively only one alternative, or a set of alternatives that are not significantly different. Proof of this logic lie in the commenter’s opinion

that there is only one alternative that warrants consideration, and that is the Citizens’ Solution. From the NEPA standpoint, the analysis cannot be

narrowed in this fashion. Therefore, expressions of support or objection will not be responded to, in general, by changes in alternative features – they

will be responded to when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of

Decision. People who commented in this fashion are asked to consider that there is a very clear separation between alternatives legitimately

considered in an analysis and the expression of a preferred alternative or the decision to be made.

Page 10. Re: Economic effects of eliminating snowmobiling are minor compared to the revenue generated by the parks year-round. See pages 158-161

for a description of the assumptions and methodologies for evaluating socioeconomic impacts.

Page 10. Re: Citizen’s Solution will have a minor economic impact. Please see previous response.

Page 10. Re: Cooperative, proactive planning is needed to address impacts to adjacent lands should snowmobiling be eliminated from the parks. We

agree that decisions relating to winter use management may, to some degree, affect adjacent lands. Therefore, the DEIS evaluates effects on adjacent

lands, including national forests, on pages 298-315, and it evaluates cumulative effects on pages 319-327. The information NPS had for these

evaluations in the DEIS was dependent on information provided by the forest service, a cooperating agency. The biological assessment to be prepared

and published along with the FEIS similarly includes areas of concern for wildlife beyond the park boundaries. NPS has invited the FS to provide

information for this assessment. The national forests in the GYA all participated in an assessment of winter use under the purview of GYCC, and the

DEIS incorporated the multi-agency winter visitor use assessment by reference and cited it specifically under cumulative effects on forest lands (page

326). NPS encouraged the forest service to use that document as a starting point for effects analysis considering the possible displacement of use from

the parks. Potential displacement is noted as an impact on national forests in Effects on National Forest Lands (DEIS pages 298-303), and the FS has

been provided with our best estimate of displaced use, based in part on the winter survey results. The FEIS will incorporate mitigation in terms of

interim recreation use limits for some alternatives.

Page 11. Re: A list of supported alternative features, most of which are contained in the new preferred alternative. Please see response, “Page 9. Re:

1) Establish daylight...”
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Pages 1-2, Point 1. Re: Logistical problems if alternative B adopted. NPS agrees this would be a logistical consequence to the lodge operation for about 2

months of the year, for alternative B. At the present time, the Old Faithful operation is snowbound. It seems this is a logistical problem that has been

overcome through time, since everything must be accomplished by oversnow vehicle during the winter. NPS does not feel that this logistical problem is

insurmountable.

The objective of the EIS analysis is to consider alternative winter programs. Certainly for those who wish to access Old Faithful from West Yellowstone as an

oversnow experience, wheeled access would be a change. NPS feels that there are a number of people who would take advantage of this change in

opportunities and visit Old Faithful using wheeled mass transit access. In alternative B, oversnow access would still be possible via the south entrance and

Flagg Ranch.

The implementation of any alternative that might make substantial changes affecting a concession operator will require negotiation between NPS and the

concessionaire or be deferred until a new concessions contract is pending. This EIS and plan will decide broad program direction. The details of

implementation are left until after the broad program is decided. Since the preferred alternative will change in the FEIS, the questions raised no longer apply

to the direction NPS is leaning toward.

Page 2, Points 2 and 3. Re: Shifts in visitation due to plowing or season length. These points will be included in the effects analysis for alternative B.

Page 2, Point 4. Re: Plow entire north and west side of park, for logistic ease and economic viability of Yellowstone NP Lodge concessions. Plowing the road

from Mammoth to Norris and then south to Madison was not considered to be a feasible alternative for several reasons. These sections of road receive a good

deal more snow and wind during the winter season than other road sections proposed for plowing. Park maintenance staff are concerned that during the deep

winter, the narrow curvy road template coupled with high cross winds would prohibit any degree of certainty in keeping the road open. Plowing these road

sections during the late winter season as suggested in alternative C was considered to be the only feasible option for plowing from Mammoth to Madison. In

agreement with the commenter, the analysis presented for both alternatives C and B (see pages 219-222 and 240 –242) suggest that adverse effects would

occur under these alternatives because of the complex travel logistics required by both park visitors and employees.
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Page 1. Re: Support for The Citizen’s Solution. Features of this alternative were for the most part analyzed throughout the range of alternatives in the DEIS.

Please refer to the matrix which illustrates where the features of The Citizen’s Solution are evaluated in the DEIS. This alternative is not substantively different

from alternative G in the DEIS, supplemented by features available in other alternatives. A remixing of features would yield an alternative whose impacts

would be within the range expressed in the DEIS alternatives. Therefore, it does not warrant consideration as a separate alternative in the Final EIS.

Page 1. Alternative B will not be the preferred alternative in the FEIS. Conclusions drawn by commenters on “good” features versus “bad” features may be

helpful to the decision maker. However, absent any rationale that would indicate a feature is not possible, all features will remain in the range of alternatives

available for the decision. Most actions that are entertained within the range of alternatives have consequences one way or another, and these are disclosed to

the necessary degree in the EIS.

Pages 1-2. These comments are interpreted as the commenter’s rationale for the decision to be made based on his opinion about impacts. There is nothing

persuasive in the comment that affects the range of the alternatives considered.

Alternative formulation in this DEIS effort is highly complex. Many suggestions for alternatives or alternative features were made in the thousands of

comments received. A great deal of criticism was leveled at the current range of alternatives because people did not like the way features were “mixed.” At the

same time, many people focused on features of alternatives that they liked, and features to which they were opposed. It is clear that for such complex issues

there could be an infinite number of possible alternatives. CEQ states that in such instances, the agency need only consider a reasonable number of examples

that cover the full spectrum of possible alternatives that meet the purpose and need (Question 1b, CEQ 40 Most-Asked Questions). What constitutes a

reasonable range depends on the nature of the proposal and the facts in each case, where the proposal is at the discretion of the agency.

The final selected alternative that is to be documented in a Record of Decision may mix features from the range of alternatives evaluated in the final EIS. Such

mixing can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside the range of

alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the Record of Decision, along with the

rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail.

Page 3. Re: Use limits; the plan is meaningless without limits. As an action associated with all alternatives, visitor use capacities are to be determined (DEIS

page 25). In practice, setting a carrying capacity is a highly complex and potentially divisive exercise. NPS managers decided there was not sufficient time

available in the settlement time frame to devote to this type of analysis. NPS is developing visitor use scenarios for each alternative that will be the basis for a

more quantified effects analysis and for mitigation. Some mitigation will be in the form of interim use limits pending carrying capacity analysis. The 7-year

average will be one level of mitigation looked at in the FEIS, capping at current use will be another. These changes respond to cooperating agencies, EPA and

others.

Page 3. NPS’ programmatic plan will direct the types of use that are appropriate relative to constraints or standards that are part of the FEIS alternative (or

alternative feature) that is selected in the decision. This includes limits on sound or emissions, and locations that are closed or open, and phase-in periods.

Within that context, later implementation will consider how to allocate use to outfitters, guides or concessions, how park administration must change, and other

“how to” kinds of details. Some details may be spelled out in the decision to be made, others may require additional site-specific analysis.

Pages 3-4. Re: closures. These comments are interpreted as the commenter’s rationale for the decision to be made based on his opinion about impacts. There

is nothing persuasive in the comments that affects the range of the alternatives considered, or the analysis of impacts disclosed in the EIS.

Page 5. Backcountry nonmotorized use is addressed in one or more alternatives by designating closed areas or areas in which travel is on designated trails only.

These choices are available for the decision maker.

Page 5. These comments are interpreted as the commenter’s rationale for the decision to be made based on his opinion about impacts. Though these opinions

may be of interest to the decision maker, there is no other response to be made to them by changing the analysis or the alternatives.
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Page 5. The range of alternatives in the DEIS is adequate, considering the decision to be made and the issues being addressed. Other alternatives effectively

close large portions of the park, but the closed segments – e.g. Fishing Bridge to East Entrance, Mammoth to Madison and West Yellowstone to Old Faithful –

respond to identified and significant problems. In terms of issues and impacts, NPS saw no reason, to date, to have an alternative closing the east side of the

park including the Canyon to West Thumb segments. It would be a function of adaptive management in alternatives B and E, or the determination of some

significant impact at a later date, to find the need for closing the entire east side.

Page 5. A few of the alternative features presented by the commenter are actions that would be associated with any alternative that might be selected. A

majority of suggested features are present in the range of alternatives in the DEIS. NPS determines that to evaluate this alternative would not yield significant

benefits toward the desired condition to a greater degree than any DEIS alternative.
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Page 2. Winter use carrying capacity is mentioned in a very key context in the DEIS. On page 25, carrying capacities must be determined as a feature

of any alternative that might be selected. Owing to court settlement time frames, NPS did not feel that such a complex task could be completed in

association with the EIS and that the appropriate context for such a determination would be after a decision is made on the winter program.

Page 2. Alternative formulation in this effort is highly complex. Many suggestions for alternatives or alternative features were made in the thousands of

comments received. A great deal of criticism was leveled at the current range of alternatives because people did not like the way features were

“mixed.” At the same time, many people focused on features of alternatives that they liked, and features to which they were opposed. It is clear that for

such complex issues there could be an infinite number of possible alternatives. CEQ states that in such instances, the agency need only consider a

reasonable number of examples that cover the full spectrum of possible alternatives that meet the purpose and need (Question 1b, CEQ 40 Most-Asked

Questions). What constitutes a reasonable range depends on the nature of the proposal and the facts in each case, where the proposal is at the discretion

of the agency.

The final selected alternative that is to be documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS.

Such mixing can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside

the range of alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the record of decision,

along with the rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail.

Many comments on pages 4-19 of the letter refer to incorrect terminology, minor clarifications, suggestions about wording, typographic errors, etc. Some

comments crosswalk into more substantive issues responded to above. Others may be dismissed by virtue of the level of analysis that is appropriate in

this programmatic EIS, versus a more site-specific analysis. Overall, these comments are helpful and each will be considered and incorporated as

needed. NPS feels that there is no need to respond individually to these types of comments, beyond this statement.
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WALT FARMER

Pages 1-2 Re: Good initiatives to pursue and bad initiative not to pursue. Alternative formulation in this effort is highly complex. Many suggestions for

alternatives or alternative features were made in the thousands of comments received. A great deal of criticism was leveled at the current range of alternatives

because people did not like the way features were “mixed.” At the same time, many people focused on features of alternatives that they liked, and features to

which they were opposed. It is clear that for such complex issues there could be an infinite number of possible alternatives. CEQ states that in such instances,

the agency need only consider a reasonable number of examples that cover the full spectrum of possible alternatives that meet the purpose and need (Question

1b, CEQ 40 Most-Asked Questions). What constitutes a reasonable range depends on the nature of the proposal and the facts in each case, where the proposal

is at the discretion of the agency.

The final selected alternative that is to be documented in a record of decision may mix features from the range of alternatives evaluated in the final EIS. Such

mixing can occur as long as the mixed features are consistent with one another, and as long as the features and their effects would not fall outside the range of

alternatives disclosed in the EIS (§1505.1(e)). A finding as to that circumstance would be entirely appropriate in the record of decision, along with the

rationale, should the selected alternative not precisely correspond with one of the “mixes” evaluated in detail.

Conclusions drawn by commenters on “good” features versus “bad” features may be helpful to the decision maker. However, absent any rationale that would

indicate a feature is not possible, all features will remain in the range of alternatives available for the decision. Most actions that are entertained within the

range of alternatives have consequences one way or another, and these are disclosed to the necessary degree in the EIS.

Page 2. Re: Species of special concern. Please see page 125 in the DEIS. The species and its presence are of sufficient concern to address possible impacts.

Page 2. Re: Reference to studies regarding carrying capacity. Work accomplished by biologists on defining the wildlife affected environment and the effects

of winter use on it are cognizant of the carrying capacity issue. Such determinations include many factors other than those associated with winter use. For this

reason, NPS holds to its determination that setting, or determining, carrying capacities is beyond the scope of this effort (see page 16 in the DEIS). Steps are

being taken to make the winter use EIS analysis as consistent as possible with that of the Bison EIS/Plan. NPS will clarify this issue as much as possible in the

final document.

Pages 2-3. Re: Impacts of snowmobiles, and issues relating to safety, wildlife, natural resource damage, etc, are disclosed in the DEIS. The reader can note the

differences in impact between the current condition (alternative A) and other alternatives that limit or eliminate snowmobile access in various areas of the

parks. Alternative G provides for oversnow mass-transit access only. NPS feels that access to the national parks is a key element in the purpose and need for

action, which is the major reason why total closure to motorized vehicles in the winter was considered but eliminated from detailed study.

Page 4. Re: Economic hardships to gateway communities should not be determining factor. The EIS presents a fair disclosure of impacts of winter use

alternatives, including social and economic effects. There is no emphasis from NPS on economic impacts; the document and the process fulfil NEPA analysis

requirements. It should be pointed out that cooperating agencies – primarily state and local government – are chiefly concerned about economic impacts on

local communities and such concerns have been given due consideration. NPS is not responsible for the economic viability of the surrounding areas, but what

NPS might propose to do is certainly an issue that must be addressed in the EIS. Consideration of impacts and other factors is in the purview of the decision

maker, who will select an alternative and provide rationale for that selection in a record of decision. If certain uses are determined in the EIS to cause adverse

impacts on park resources and values, and if it is further determined by the decision maker that such impacts are contrary to law, executive order, regulation and

policy, then action must be taken. Mitigation that is necessary to reduce an impact to the appropriate level, or elimination to get rid of the impact entirely, could

cause economic effects in local communities. NPS maintains that the proximity of such communities to the parks will always represent opportunities as well as

risks for local businesses.
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JIM GERBER

Page 1. Re: Opposition to alternative B. Under the CEQ regulations, the requirement in an EIS is to provide a range of reasonable alternatives that clearly

define the issues, and to fully evaluate and disclose the possible effects of those alternatives. The DEIS meets this requirement, while acknowledging that the

commenter disagrees about many of the impacts disclosed. In general, the expressions of opposition relate to the decision that the commenter would like to see

NPS make, based on myriad disagreements about the effects disclosed in the DEIS. The general response to such comments is that the commenter’s opinions

will be considered in making the final decision, but that there is nothing in those opinions that substantively would alter the range of alternative features to be

evaluated in the Final EIS. For example, if the features that are not supported were to be deleted from the range of alternatives then the analysis would be left

only with features that the commenter likes or agrees with. If only the actions that are liked by the commenter remain, then there is effectively only one

alternative. Therefore, expressions of support or objection will not be responded to, in general, by changes in alternative features – they will be responded to

when the decision criteria are developed, and accordingly, when the rationale for the decision is presented in the Record of Decision. People who commented in

this fashion are asked to consider that there is a very clear separation between alternatives legitimately considered in an analysis and the expression of a preferred

alternative or the decision to be made.

Page 1. Re: Personal freedom of access. Please see the purpose and need section in the DEIS and the FEIS. Personal access may be reflected in the statements

of desired condition, but personal access by snowmobile is not a right or a guarantee. The NPS mandate, as stated in the purpose and need section, places

personal enjoyment and freedom of access in a subordinate role to protection of park values so they are unimpaired for future generations. All alternatives but

one in the EIS allow the use of snowmobiles in varying degrees and places, depending upon the alternative concept. The impact of each alternative on visitor

experience is disclosed, including impacts on snowmobile users as a group. The difficulty is that personal access via snowmobile, considering present

commercial technology and usage, causes a variety of impacts on park resources, values and other visitors.

Page 1. Re: Grand Loop experience. Several alternatives (A, D, and E) propose maintaining the sections of road known as the Grand Loop for snowmobile use.

Other alternatives propose that road plowing or closures occur on sections of the Grand Loop. The effects of road plowing and closures on visitor experience

proposed in these alternatives are disclosed in Chapter IV of the DEIS. Please see response to this letter in regard to page 1 “Oppositions to alternative B.”

Page 1. Re: Economies of local communities. Please see response to this letter in regard to page 1 “Oppositions to alternative B.”

Your comment is correct in that the NPS cannot arbitrarily eliminate snowmobile use in the parks. However, basing a decision as you suggest, on the fact that

local communities rely on snowmobiling for economic viability without an examination of other alternatives and their effects on park resources would certainly

be arbitrary. The NPS is involved in a lengthy and detailed process that is designed to ensure that arbitrary decisions are not made. The NEPA process is

intended to help public officials make decisions that are based on understanding of environmental consequences and take actions that protect, enhance and

restore the environment (§1500.1).

Page 1-2. Re: Support of Revised Alternative E. The alternative feature suggested in this comment are all components of alternative E as presented in the DEIS

pages 34-35.

Page 2. Re: Omission of socioeconomic issue. The commenter is referred to pages 13 and 14 where social and economic topics are identified as major issues

and to the corresponding discussions presented in Chapters III and IV.

Page 2. Re: Formulation of alternatives. In October of 1998 representatives from the 3 states and 5 counties that are designated as cooperating agencies met in

Idaho Falls, ID to share their ideas for alternatives to be presented in the Winter Use DEIS. (Please see Volume II Appendix A for a complete list of ideas

generated at that workshop). A review of the ideas generated at that workshop indicate that maintaining or adding opportunities for winter recreation while

protecting the park’s natural resources were most important to the cooperating agencies. Alternatives A, C, D and E reflect these concerns. The overwhelming

support for Revised Alternative E indicates that at least one alternative was proposed in the DEIS that, with a few minor modifications, would meet the needs

and interests of the cooperating agencies. This alternative will remain in the range of options the decision-maker may consider when making his or her decision.

As an aside, the final selected alternative may mix features from the range of alternatives evaluated in the final EIS. Such mixing can occur as long as the
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features are consistent with one another, and as long as the effects of such an alternative would not fall outside the range of effects disclosed in the EIS.

Page 2. Effects of alternative B. This comment restates the disclosure of effects present in the DEIS. Readers should understand that it is the purpose of an EIS

to disclose the possible effects of a proposed action and alternatives to it.

Page 2. These comments restate the disclosure of effects present in the DEIS. It should be noted that many interested parties commented during scoping and

during the DEIS review that snowmobiles produce unwanted noise, air pollution and water pollution. The impacts of human winter use activities on the natural

soundscape, air quality and water quality will be enhanced in the FEIS.
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PAUL HOFFMAN

Page 1. Re: Park mission. The mission is clear that if adverse resource impacts are occurring that would compromise the protection of park values, then some

management must occur to eliminate the source of impact. Balancing use with protection does not mean that impairment of park values and resources is

acceptable. It is the purpose of the winter use EIS to assess the impacts and provide a basis for determining the level of use that is consistent with park service

mandates, executive orders, and regulations. The cooperating counties were not granted cooperating agency status on the basis of enjoyment and economic

benefits. Cooperating agency status is based on their professed special expertise in social and economic analysis that is appropriate to conducting an EIS.

Page 1. Re: Junk science. NPS disagrees with the commenter’s conclusion that the document is based on “junk science.” Commenter offers no evidence for

this conclusion. On the other hand, EPA notes that the document has a very strong basis in science. Compelling reasons for performing an analysis of winter

use are presented in the DEIS in the purpose and need section. Clearly, the commenter disagrees with the purpose and need for action.

Page 1. Re: YNP winter visitations. Comment about declining use numbers begs the issue of the impacts associated with this type of use (it is understood that

commenter is referring to snowmobile use).

Page 1. Re: No evidence supports emissions cause adverse impact on wildlife. DEIS has not made the claim that emissions affect wildlife.

Page 2. Re: Decision to be made. It is implicit in the DEIS from the alternatives and from the analysis that the decision to be made will involve only winter use

and only lands within the three park units. Impacts analysis includes effects on adjacent lands, and cumulative effects that might go beyond the parks – in

accordance with CEQ regulations. However, to be absolutely clear about the decision to be made, a section will be added to the FEIS.

Page 2. Re: Establishing carrying capacity. Establishing a recreation carrying capacity is an action associated with all DEIS alternatives. As stated in the

DEIS, page 16, establishing a carrying capacity for wildlife is outside the scope of analysis for winter use. It would seem that the Bison EIS/Plan would be a

more appropriate place in which to deal with bison population issues. Any decisions from the Bison EIS/Plan and the Winter Use EIS must be consistent.

Page 2. Re: No evidence that particulate matter has adversely impacted biological life forms in the Parks. The DEIS makes no definitive statements to the

contrary. However, additional studies of snowpacks have been completed and are available for use in the FEIS.

Page 2. Re: Historically, YNP encouraged surrounding communities and industry to direct efforts towards snowmobiles and snowcoaches. There are

compelling reasons to perform an analysis of impacts associated with all possible and reasonable approaches to identified issues. Conditions change, issues

arise, and management needs change over time.

Page 2. Re: Affordable access. NPS disagrees. Affordable access is an issue – but it may not weigh heavily in the eventual decision. As an aside, it seems

there is always a great deal of local public consternation and discussion whenever fees for use of public lands are proposed or increased. We believe the cost of

access through the gate is an important consideration.

Page 3. Re: Impacts on wildlife due to plowing. Impacts on wildlife are disclosed for all alternatives, including alternative B. The Park Service’s assessment

of impacts is at variance with commenter’s opinion; “snow walls” would be more like berms, and they would not be insurmountable barriers over the entire

plowed road distance. Rationale for this comment argues against plowing many of the roads that are currently plowed in parks and on adjacent lands in the

GYA.

Page 3. Re: Dilution of economic impacts. The Park Service’s economic consultant will run the economic model for the 5-county area around the park

gateways at issue.

Page 3. Re: Cultural or economic significance of the Lower Loop of the Grand Loop. The DEIS (page 220) discloses this impact. Park County Wyoming – as

a cooperating agency with special expertise in socio-economic analysis – has not provided the Park Service with any data that expresses the significance of

impacts on the East Entrance. Commenter offers no information that would substantiate this claim. NPS does not argue that this alternative feature would

affect the experience and the opportunity and it has disclosed the impact in those terms.

Page 3. Re: DEIS does not address plowing costs on the road from West Yellowstone to Old Faithful. The costs are estimated in Appendix F of the DEIS.

The basis for estimates relates to average unit costs for performing the types of activities included in each alternative. This analysis is deemed sufficient to be

able to compare the relative costs between alternatives.

Pages 3-4. Re: Public safety. The impacts of all alternatives on public safety are disclosed in the document. The Park Service’s interpretation is that the
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commenter feels that safety concerns do not justify a preference for alternative B. Such comments go to the decision to be made, in which the decision maker

must weigh the relative merits and impacts of all the alternatives and make a selection accordingly. Alternative B effectively separates snowmobile and vehicle

traffic on the CDST, and it does not create this circumstance elsewhere – therefore the commenter’s point is not evident.

Page 4. Re: Air quality. Air quality has also been investigated at the South Entrance and Flagg Ranch. Additional work has been conducted since the

publication of the DEIS, and this information will be incorporated into the final document. Air quality sampling and modeling does discriminate between the

effects of wood fires and the pollutants generated by internal combustion engines. Relative to standards: no one wishes to see air pollution become so bad in

national parks that it hovers at or just below a health standard. Air quality as compared to NAAQS standards is not the only determinant of air quality.

National Parks are charged with management of air resources and air quality related values like visibility and odor. Most visitors, judging by a long string of

visitor surveys, expect clear, clean air when they visit national parks.

Page 4. Re: Failure of alternative B to recommend easy ways to mitigate emission problems associated with backed up traffic at the West Entrance. There are

ways to mitigate (i.e. lessen) impacts, some of which have been implemented. There is nothing in the DEIS that says new practices to reduce identified

problems cannot be adopted at any time. However, there is a systemic or programmatic set of issues to be addressed, and this is the purpose of the EIS and

eventual decision. In terms of the pollutants generated by diesel buses, these vehicles are much cleaner than snowmobiles, and autos as well. The FEIS will

incorporate additional analysis that quantifies impacts among different vehicle types.

EPA supports the approach taken to analysis of air quality impacts in the DEIS. EPA indicates NPS has not gone far enough to deal with the issue in the short

term and feels there is a risk in not limiting vehicle numbers or not implementing various measures for up to eight or nine years. EPA also expressed to us that

there is no assurance EPA will act to deal with regulatory matters on snowmobile emissions any time soon, and that NPS has the authority under the Clean Air

Act to deal with the issue.

Page 5. Re: County Commissioners Revised Alternative E. Revised Alternative E comes from cooperating agencies and the Blue Ribbon Coalition in a variety

of forms. The essentials of Revised Alternative E, all versions considered, are not significantly different from alternative E as presented in the DEIS, especially

considering the programmatic nature of the proposed action. See the matrix comparison of Revised Alternative E versus the features analyzed in the range of

alternatives. All alternatives in the DEIS meet the purpose and need for action to a greater or lesser degree. The support for revised E, or for DEIS alternative

features that are consistent with it, does not indicate any need for change in the range of alternatives or the associated analyses. The decision maker will weigh

support for or against various alternatives as he or she deems appropriate prior to making a final selection (in the record of decision).
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Page 1. Re: Visitor experience. Concern about park values, opportunities and experiences is reflected in the purpose and need for action expressed in

the DEIS.

Page 1. Re: Importance of bison carcasses. Bison carcasses’ importance to grizzly bears is indicated on pages 116, 121 of the DEIS.

Pages 1-2. Re: Bison EIS/Plan effort. The winter use EIS team did in fact anticipate that information about bison population dynamics would be a

significant part of the Bison EIS/Plan effort. The winter use team sought assistance from members of the bison team, and coordination between the

two teams has ensued. NPS analysis in the winter use DEIS is sufficient for a programmatic assessment (§1508.18(b)(2)). Nothing in NEPA could be

construed to require the park service to close roads in order to study their effect. It is permissible under the CEQ regulations to proceed with an EIS

without complete data (§1502.22), under certain circumstances. It is not necessary to have exhaustive site-specific data in order to produce a

programmatic plan.

Page 2. Re: Close applicable road segments to winter travel. The conservative approach is put forth in the DEIS alternatives. Adaptive

management as applied in alternatives B and E would allow NPS to do as the commenter suggests.

Pages 2-3. Re: Lynx analysis. The DEIS acknowledges the effect of groomed surfaces on lynx, should they be present. On pages 124 and 168, and

subsequently for each alternative evaluated in Chapter IV, impacts on lynx are identified as habitat fragmentation from groomed surfaces. The

biological assessment to be published with the FEIS incorporates literature cited in this comment (USDA RMRS-GTR-30), and the FEIS analysis will

be updated as necessary. NPS reiterates that exhaustive detail is not necessary in an EIS. CEQ regulations encourage the agency to liberally

incorporate analysis by reference to reduce the volume and bulk of documents.

Page 3. Re: Lynx management. NPS will follow the recommendations of the Lynx Conservation Assessment and Strategy, and will map habitat

accordingly. Lynx surveys are being initiated, and new research is being funded. These measures are indicated as mitigation activities in the

biological assessment for winter use. Information derived from these efforts will not be available prior to the decision on winter use, but it will help

guide future management.

Page 3. Re: Wolverine analysis. Impacts on wolverine will be reviewed, including those represented by avalanche control.

Page 4. Re. East Entrance should be closed during winter. Alternative D includes the closure of the East Entrance. This feature remains a choice

for the final decision.

Page 4. Re: Grizzly bear and off-road motorized use. 10 case incidents are on record. Even if illegal side-running occurs adjacent to groomed trails,

which is the usual offense, there are no documented instances of conflicts with bears. The Park Service’s assessment remains as stated in the DEIS.

Page 4. Re: Grizzly bear protection. The winter use plan will set broad programmatic direction for winter use. Park biologists do not feel that

winter use, as reflected in the DEIS alternatives, represents a significant impact on the species. It should be clear that individual bears will be

protected as circumstances arise to create conflict situations. Park superintendents have authority to act assertively by trail closures or other

restrictions to protect threatened or endangered species.

Page 4. Re: Closing roads to snowmobile use in order to protect wildlife. There must be a determination that adverse impacts on wildlife are

occurring. The extent of the documented adverse impact will drive some form of management action. It is the purpose of this EIS and the decision to

be made to arrive at a determination and the action to be taken.

Page 4. Re: Support of elements of alternatives B, D, and E that would designate “areas of designated trail use” to protect watering wildlife.

Statements of support are appreciated, however there is no way to respond to such comments except through the decision to be made. The options for

backcountry management remain as choices for the decision maker.
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Page. 1. Re: “Yellowstone bison serve as a window of insight...” NPS appreciates the value and uniqueness of the bison population; the bison discussion and

analysis will be revised as necessary in the FEIS.

Page. 1. Re: None of the alternatives offer a “solution” to what is happening biologically in the park. This comment refers to alternative formulation, which is

discussed in the DEIS on pages 21-22. Alternatives were formulated based on concepts generated during public scoping and interagency workshops that best

responded to identified major issues and concerns, the decsion to be made, and the purpose and need for the Winter Use Plan. The alternatives were not

formulated to “offer a solution” to the bison issue.

Page. 1-2. Re: The fact that: 1) groomed roads do not facilitate bison movements out of the park, 2) the issue of how many vehicles and people is not

important, the issue of the groomed roads is central, 3) the combination of a population at carrying capacity in 1981-1982 led to the bison beginning to use the

groomed roads to seek out other range options, and 4) resultant change in distribution, not number, of bison led to bison use of lower quality habitat. Many of

the commenter’s statements about bison are referenced in the DEIS on page 166. If there is a significant difference of opinion, as there appears to be in this

case, then the remedy provided in CEQ regulations (§1502.9(a)) is to report all opinions in order to meet the disclosure requirement. Thus, the findings of other

bison researchers are disclosed as well.

Page. 2. Re: Winter use of the interior park roads will drive the bison population down because they will be removed when they leave the park, and numbers

will not rebound due to poor range quality. NPS is evaluating the effects of groomed roads on bison and will revise the discussion of effects in the FEIS if

necessary.

Page. 2-3. Re: Recommends keeping the plowed northern road open, and allowing access to oversnow vehicles only from the South Entrance to Old Faithful.

This comment refers to the decision to be made. This suggestion is a feature of alternative F. Consequently, the decision maker could choose it from among

the range of alternatives presented in the FEIS.
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Page 2. The purpose and need for action is clear about the NPS mandate, as supported by Appendix C in Volume II, excerpts from legislation, executive orders,

regulation and policy. Nothing in this material would indicate that adverse impacts are appropriate or acceptable when they impair park resources.

Page 2. NPS finds nothing wrong with the objective, as stated. NPS’ analysis in the FEIS, using more quantitative information, will better disclose the impacts

of the alternatives relating to visitor use and access. Also, on DEIS page 25, carrying capacities must be determined as a feature of any alternative that might be

selected. Owing to court settlement time frames, NPS did not feel that such a complex task could be completed in association with the EIS and that the

appropriate context for such a determination would be after a decision is made on the winter program.

Page 2. The impacts of all alternatives are disclosed in the DEIS. The final decision will depend on how the decision maker weighs the impacts as compared to

NPS mandates, executive orders, regulations and policies.

Page 2. The settlement agreement required NPS to perform a comprehensive EIS on winter use. NPS did not interpret this requirement as stipulating the

specific alternatives to be considered.

Page 2. NPS maintains that all alternatives address possible approaches to bridge the gap between existing and desired conditions. The issues and impact

topics are addressed to varying degrees by the alternatives, as is normal in a NEPA analysis. The disclosed impacts do in fact show differences among the

alternatives, and in all alternatives some aspects of the existing condition (alternative A) would be improved. The FEIS will express the differences in a more

quantitative fashion. Please see the actions and assumptions common to all alternatives (DEIS page 25). NPS has the authority to address key issues by

implementing management actions under special circumstances or conditions (including closures). The purpose of the EIS and eventual plan is to develop a

programmatic plan that addresses ongoing adverse impacts through a legal finding and decision process.

Page 3. Re: DEIS does not account for uncontrolled increased use. Recreation carrying capacities must be determined as a feature of any alternative that might

be selected (DEIS page 25). Owing to court settlement time frames, NPS did not feel that such a complex task could be completed in association with the EIS

and that the appropriate context for such a determination would be after a decision is made on the winter program. The FEIS will express mitigation measures

for some alternatives, including interim use limits.

Page 3. CEQ regulations require a range of alternatives sufficient to meet the purpose and need for action (§1502.13). The purpose and need for action is

discretionary to the agency and the decision maker (§1500.4(g) and §1501.7(a)(2)) to set the scope of analysis. It is clear the commenter disagrees with the

purpose and need. If the court settlement carried as much weight as the commenter feels, it seems there would be no need to actually perform an environmental

analysis.

Page 3. NPS does not see evidence of pre-decisional behavior in this statement.

Page 3. NPS feels there is a valid range of choices in the existing alternatives. NPS has the latitude to mix features of alternatives in the final decision.

Pages 3-4. There have to date been no known or recorded instances of conflicts between winter recreation use and grizzly bears. This fact speaks volumes.

This, coupled with the notion that the bear population is expanding, is a realistic view of the extent to which winter use might impact grizzly bears. The

biological assessment to accompany the FEIS provides a detailed analysis. Winter use does not impact white-bark pine as a food source for bears.

Page 4. NPS stands by its conclusion that regular, scheduled traffic (whether motorized or nonmotorized) has less impact of this type than random human

presence. As with many other comments, this statement represents a preoccupation with the preferred alternative or its “justification.” The preferred alternative,

or its justification, does not affect the range of alternatives available as choices for the decision maker, or the assessment of impacts. The only possible

response to such comments on a DEIS is to change the preferred alternative in the FEIS. The preferred alternative in either document is not a decision.
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Page 4. The court has not proven that alternative A is unacceptable. There is no court decision, only a settlement requiring the writing of this EIS. The EIS is

the vehicle by which programmatic actions are evaluated in terms of their effects. Naturally, effects are relative to current conditions and it is perfectly valid to

state that in some respects the effects would be the same as in “no action.” Such a statement, taken out of context, is not tantamount to a finding of impairment.

Page 4. NPS finds no contradiction. When a snowmobiler stops and walks away from his or her machine, is the action that potentially affects wildlife a

motorized or nonmotorized source? Both sources of impact are evaluated in the DEIS. Potential mitigation for the kinds of impacts raised in the comment

includes a prohibition on stopping for either snowmobiles or snowcoaches. Nonmotorized uses can likewise be prohibited from entering areas where wildlife

might be affected. These mitigations are either contained in or consistent with language in most alternatives.

Page 4. The preferred alternative will change in the FEIS.

Page 4. The statement by the commenter that any snowmobile use is unacceptable appears to be based on a personal opinion about impacts and a personal view

of a certain group of users. The eventual decision is to be based on an assessment of documented impacts for all alternatives.

Page 4. Statements of support for The Citizens’ Solution do not respond directly to information in the DEIS. That alternative most closely resembles

alternative G in the DEIS. Support for a course of action goes to the decision to be made – and may be of interest to the decision maker but does not provide

rationale that affects the DEIS analysis.
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Cover letter. An identified gap between existing conditions and desired conditions form the basis for the purpose and need for action. The underlying purpose

(§1502.13), or goal to be achieved as stated at the scoping stage is to provide a full range of quality winter experiences offered in appropriate settings and

having no significant adverse impacts on park values. This purpose is represented by the desired condition shown on page 3 of the DEIS. The underlying need

(§1502.13) is defined by the existing conditions expressed on page 4, with detailed expansion in Chapter III, Affected Environment. Despite the complexities

introduced by multiple goals and multiple issues, the alternatives in Chapter II represent possible actions that meet the underlying purpose and need.

The commenter feels that the treatment of existing versus desired condition, et al, are too general to be of value. NPS feels there is a lack of understanding

about the nature of the decision that is in question. It has been NPS’ intent from the beginning of the process to prepare a programmatic Plan. This would be

the purpose of preparing a “comprehensive EIS.” There should have been no illusions that a plan of this magnitude would be based upon detailed, site-specific

data in order to make every decision possible relating to winter use. It would certainly not be possible to accomplish this and avoid the criticism of generating

voluminous paperwork. The programmatic approach is acceptable under the law, in the way that NEPA is the vehicle for producing NPS General Management

Plans and USFS Forest Plans, and amendments thereto. Such documents make decisions and allocations at a general level and defer many site-specific types of

decisions to a later date (§1508.18(b)(2) and (3)).

Point 1, page 1. See above response. The commenter should note that the Multi-Agency Assessment initiated in 1994 was in fact prompted by the increased

use and the exceedance of a threshold described in the 1990 plan. Clearly, NPS was not moving fast enough for the complainant in the lawsuit.

Point 2, page 1. The FEIS will include a section on the decision to be made.

Point 3, page 1. The legal mandate section will be reviewed and clarified as necessary.

Point 4, page 1. There is a desire on the part of NPS to cooperate. The effectiveness of the process used in this EIS relative to cooperating agencies is subject

to debate, especially given the short time frames as noted. Early on, NPS intended to invite the 3 states surrounding the parks to participate as cooperating

agencies in developing the EIS. NPS believed the states could provide information on impacts to natural resources and local and regional economies. Without

consulting with NPS, CEQ opined to a Wyoming Senator that counties also should act as cooperating agencies in this process. Thus NPS was faced with

working with nine cooperating agencies, several of which had never before participated in a NEPA process as cooperators. Due to the schedule set by the

settlement agreement, NPS had little time to work with cooperating agencies on what was expected of them in that role. This includes disagreements about the

nature of special expertise in the NEPA process, and the burden of the cooperator in providing it. As a result, the cooperators often acted as though the

relationship was one where the NPS was to provide information to them, instead of the reverse.

Point 5, page 1. See response to cover letter.

Point 6, page 1. The purpose and need for action and the major issues derived from scoping are not, and should not be a function of the lawsuit. The settlement

required NPS to prepare a comprehensive EIS, not an EIS based strictly on the lawsuit issues.

Point 7, page 2. Re: Failure of the DEIS to describe the degree to which winter industry growth has occurred in response to federal policy. Pages 83-93

describe the affected social and economic environments. If the commenter has definitive information about this issue, he fails to reveal it. NPS does not feel

this would be an especially relevant disclosure. Growth in winter use industries and increased use was not entirely at the behest of the federal government.

Communities willingly engaged in these activities, and marketed them accordingly while NPS found supportive policies. The relevant frame of reference is, as

indicated in the purpose and need for action, to determine the level of use that may occur without impairing park values.

Point 8, page 2. Work accomplished by biologists on defining the wildlife affected environment and the effects of winter use on it are cognizant of the carrying

capacity issue. Such determinations include many factors other than those associated with winter use. For this reason, NPS holds to its determination that

setting carrying capacities is beyond the scope of this effort.

Point 9, page 2. See response to cover letter. This is a programmatic EIS and planning document, which are general by nature (§1508.18(b)(2) and (3)). Each
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alternative concept, which is a paragraph appearing under the alternative title in Chapter II of the DEIS, links the alternative with objectives from the purpose

and need section. The NPS planning team will review this linkage and clarify it if possible. However, NPS feels that the deficiency is overstated. All

alternatives evaluated in detail respond to one or more needs identified in the existing condition, where the intent is to achieve one or more of the purposes

described as desired conditions.

Point 10, page 2. NPS disagrees. In the light of programmatic (§1508.18(b)(2) and (3)) goals and objectives, there is sufficient specificity in the DEIS to view

programmatic alternatives that are distinctly different. Program direction is made explicit in the legal mandate described in the purpose and need section.

Standards for aesthetics, disturbance to wildlife, public safety, minimizing visitor conflicts, and other parameters implicit in the mandate are not described.

However, it is possible to describe the general effects of winter use on those parameters for the consideration of the decision maker, who will determine at what

level impairment may occur. With this determination in a programmatic plan, standards are in effect made for future management.

Point 11, page 2. NPS, being aware of the complexities of recreation capacity studies, felt that there was insufficient time to complete such studies before the

court ordered settlement date for the EIS. However, numbers of users is recognized as an element of any impacts associated with winter use, so determining

use numbers must be a part of the eventual solution to be reached under any alternative. Incorporating this as a common feature is a necessity. NPS performs

analysis under NEPA, in part, by virtue of issues or potential impacts that accrue to a proposed action. It is not necessary to have specific indicators and

standards in order to have an issue. Indicators or measures of impact for this programmatic analysis are presented in the consequences section of the document

for identified issues.

Point 12, page 3. Purpose and need indicates there is a gap between existing conditions and desired conditions for air quality and sound in the parks.

Alternative B and other alternatives prescribe actions, or standards for actions, intended to close that gap. The baseline for comparison is the existing condition,

as reflected in alternative A.

Point 13, page 3. Processes associated with adaptive management will be provided in the FEIS.

Point 14, page 3. Program direction is made explicit in the legal mandated described in the purpose and need section. Standards for aesthetics, disturbance to

wildlife, public safety, minimizing visitor conflicts, and other parameters implicit in the mandate are not described easily in a quantitative way. We refer the

commenter to Table 2 on page 23 of the DEIS. For each management prescription, or zone, qualitative general standards are set. Then, these zones are applied

to areas of the parks in different ways to discriminate between alternatives. Using qualitative terms, it is possible to describe the general effects, both beneficial

and adverse, of winter use on those parameters for the consideration of the decision maker, who will determine at what level impairment may occur. With this

determination in a programmatic plan, standards are in effect made for future management.

Point 15, page 4. The cooperators had an opportunity to participate through an alternative development workshop, as documented in DEIS Volume II,

Appendix A. A majority of the ideas generated by the cooperators (about 75%) were incorporated into the range of alternatives in the DEIS. Some of the

remaining 25% of ideas were not legally possible, and some were practices that could be considered for implementing any of the alternatives site-specifically.

See also response to point 4.

Point 16, page 4. NPS finds the logic to be consistent where winter motorized use is being addressed. The various zone choices, or prescriptions, developed to

analyze motorized use are assigned to various road segments in the parks by alternative. The alternatives thus formulated are consistent with the purpose and

need for action. An example of cooperating agency suggestions (referring to the previous comment) that were not incorporated into alternatives were those that

created new motorized routes in places that are not available for such use during other seasons.
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Point 17, page 4. Commenter is referred to the material presented in the economics section of the DEIS (pages 83-88) which speaks to regional economies,

employment and income associated with winter use in the GYA. This material has everything to do with services that are available and provided to winter

visitors by local industry.

Point 18, page 4. Wording in this section will be reviewed and altered to avoid confusion.

Point 19-20, page 4. Refer to our responses to points 5 and 11. Health, safety and resource issues are evident in the description of the existing condition on

page 4 of the DEIS. Given the programmatic nature of the document, as explained, the general impacts of winter motorized use on resources and public health

are disclosed. The disclosures may be found throughout Chapter IV.

Points 21-24, pages 4-6. Point 21. The FEIS will be revised to include citations by Cheville et al. 1998. In an effort to better understand the relationship of

bison movements and the use of the winter groomed road system, managers have instituted studies that address this issue. While groomed roads may have

contributed to the redistribution of bison within park boundaries (Meagher 1997), it appears that bison tend to use waterways and off-road trails for much of

their travel on the west side of the park (Bjornlie and Garrott 1998), and that much of their movement toward park boundaries may occur on such routes.

Monitoring of bison movements in the Hayden Valley and Mammoth to Gibbon Falls sections of the park has found that less than 12% of bison movements

occurred on the groomed road surface (Kurz et al. 1998, 1999). However, groomed roads may have allowed larger numbers of bison to exist in the park than in

the absence of groomed roads, by allowing access to otherwise unavailable foraging areas, and westward redistribution early in the winter may predispose some

bison to exit the park (Meagher 1997). Therefore closing of groomed roads could have the effect of reducing population size and shifting distribution back to

patterns observed before grooming, thereby possibly reducing the magnitude of bison movements outside park boundaries. Conversely, bison are highly social

and appear to retain and pass along knowledge through generations (Meagher 1985), so it is possible that closing groomed roads may not impact bison

movements and distribution. Research is currently being conducted to better understand the relationship between road grooming and bison movement and

distribution patterns. Point 22. A discussion of the GRTE herd will be included in the FEIS. Point 23. Mention will be made in the FEIS that bison migrate

down the Shoshone. Point 24. A discussion of the population objectives for each elk herd is outside the scope of the FEIS.

Point 25, page 6. The lynx naming error will be rectified in the FEIS.

Point 26, page 6. A revised definition of “species of concern” will be provided in the FEIS.

Point 27, page 6. The discussion of fish will be revised in the FEIS.

Point 28, page 6. Ethnographic resources pursuant to bison: this material will be revised in the FEIS to be consistent with analysis presented in the Bison EIS.

Point 29, page 6. The benchmark is alternative A, the no action or current management alternative. That alternative describes the existing condition.

Alternatives B through G are designed to move the parks toward the desired conditions (described on pages 3-4 of the DEIS) from the existing condition.

Therefore, comparisons of beneficial and adverse impacts of each alternative are measured with respect to alternative A. Complexities are introduced by the

fact that current management is not the “ecological baseline” or natural, unaffected condition. There are impacts associated with it that represent an identified

need to change.

Point 30, pages 6-7. See response to Point 21.

Point 30, page 7. A discussion of the effects of plowed roads on ungulate and bison movements will be included in Chapter IV.

Point 31, page 7. With respect to wording in Table 38 of the DEIS: this section will be rewritten to clarify the effects presented in the FEIS as compared to the

biological assessment; two new categories of effect well also be defined.

Point 32, page 7. The analysis of sound impacts will be updated in the FEIS. The extent to which motorized sounds affect the experience of other users will be

addressed.

Point 33, page 7. Ethnographic resources pursuant to bison: this material will be revised in the FEIS for each alternative to be consistent with analysis presented

in the Bison Management EIS/Plan.
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Point 34, page 8. Based on the review of all DEIS comments, a great many people have no trouble identifying with the problems identified in the purpose and

need section of the document. NPS does not know which “majority” of people is being referred to. The DEIS presents a variety of solutions, or alternatives;

there will not be a solution until a decision is made and supported by rationale (or logic) expressed in the Record of Decision.

Point 35, page 8. Work accomplished by biologists on defining the wildlife affected environment and the effects of winter use on it are cognizant of the

carrying capacity issue. Such determinations include many factors other than those associated with winter use. For this reason, NPS holds to its determination

that setting carrying capacities is beyond the scope of this effort. The winter use FEIS will be made as consistent as possible with the Bison Management

FEIS/Plan. It should be understood that the Bison Management EIS/Plan is not yet published, and no decision has yet been made for bison management. The

final EIS for winter use will be made as consistent as possible with the final EIS/Plan for bison management in terms of analysis. Certainly the decisions will

need to be consistent.

Point 36, page 8. Ethnographic resources pursuant to bison: this material will be revised in the FEIS for each alternative.

Point 37, page 8. The stated purpose of plowing the road (DEIS, page 28) is to “improve affordable access.” It is not to “provide affordable access for minority

and low-income people”, as perceived by some commenters. As an aside, this would seem to be a worthy goal – the parks are for all the people, not just those

who can afford to purchase or rent a snowmobile at the current rate. A thorough reading of the EIS would reveal that a required impact topic in an EIS is to

evaluate the effects of a proposed action on socially or economically disadvantaged populations (DEIS, page 80). These populations are characterized on page

90 in the DEIS, and the effects on those populations are disclosed in the socioeconomic section for each alternative (DEIS, pp 176, 199, 224, 245, 260, 274,

288).

Point 38, page 9. Processes associated with adaptive management will be provided in the FEIS: definitions, administrative actions, study methods, management

actions, and NEPA requirements.

Points 39-40, page 9. The DEIS discusses the effects of plowed roads on page 208. Although it does not explicitly mention bison, it states that plowed roads

may provide “wildlife” with an energy efficient mechanism for movement. The FEIS will be revised to include the effects of plowed roads on bison migration.

Although the DEIS does not use the term “tunnel effect” it does discuss the negative impact associated with snow berms along the plowed road corridor, and

suggests mitigation (p. 209). NPS and the commenter disagree on whether or not a tunnel effect would result from plowing. In many other areas within and

near the 3 park units, roads are plowed and no tunnel effect exists.

Point 41, page 9. Adaptive management will be better described in the FEIS, as noted above. Adaptive management is a strategy to move from the existing

condition to the desired condition in two alternatives. The strategy represents a very deliberate way of proceeding, erring on the conservative side to maintain

existing motorized use at the risk of possible short-term impacts on resources or other visitors. NPS fails to see how this might be objectionable to those who

favor maintaining existing uses, such as the cooperating agencies. In fact, the cooperating agencies embrace this strategy as part of their Revised Alternative E.

To see adaptive management as a ploy is purely speculative.

Point 42, page 9. Commenter’s logic doesn’t follow. Future management hinges upon the Record of Decision and the FEIS which supports it, not upon the

DEIS. Any alternative in the FEIS could be selected. Future actions to be taken under the plans’ programmatic direction (§1508.18(b)(2) and (3)) are likely to

be subject to future NEPA, irrespective of whether the adaptive management strategy is involved. The level of NEPA that would be incurred by a proposed

action is a case-by-case determination.

Point 43, page 9. The effects of plowed roads in alternative F are stated in the DEIS as being the same as in alternative A.

Point 44, page 10. NPS does not agree that significant bison movements would occur to the south and east if roads to the north and west were not groomed

because bison make little use of the roads on the west side of the park for movements, and because bison use traditional winter range areas. For these reasons,

NPS would not expect significant changes in bison movements simply because groomed roads were no longer available on the west side of the park.

Additional information on bison movements will be included in the FEIS.
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Point 45, page 10. Though the commenter appears to disagree, NPS has presented programmatic goals and objectives in Chapter I – in the form of desired

conditions which all alternatives are oriented to. These are general by nature. The goals and objectives presented as an adjunct to the decision and the final

plan would be different in terms of specificity. For example, an alternative is defined by a particular set of zones or prescriptions allocated to road and trail

segments. Each zone is further defined by a set of goals, objectives or standards for management (as in Table 2 of the DEIS). The alternative that is selected in

a decision therefore brings with it goals, objectives and standards that are consistent with the overarching purposes or desired conditions. NPS will clarify this

planning hierarchy in the FEIS.
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JOHN SPAHR

Page 1. Statements of support for The Citizens’ Solution do not respond directly to information in the DEIS. That alternative most closely resembles

alternative G in the DEIS. Support for a course of action goes to the decision to be made – and may be of interest to the decision maker but does not provide

rationale that affects the DEIS analysis.

Page 1. All alternatives in the DEIS address the purpose and need for action to some degree. Alternative B addresses safety issues, affordable access, and

concerns about impacts on sound and clean air. Criticism of alternative B as the preferred alternative goes to the decision to be made. At this juncture, the

criticism is moot because the preferred alternative will change in the FEIS.

Page 1. Criticism of alternative B as the preferred alternative goes to the decision to be made. At this juncture, the criticism is moot because the preferred

alternative will change in the FEIS. The effects of alternative B are disclosed in the DEIS, and that alternative or its various features remain as choices for the

decision maker.

Page 2. Recreation carrying capacity determination would be performed under any alternative (DEIS page 25).

Page 2. Capacity determination is not mandated. Protection of resources and values for the enjoyment of future generations is the primary mission. Findings

must be made regarding the extent, magnitude and duration of adverse impacts relative to the mission. Carrying capacities and subsequent use limitations may

be a means to achieve a balance between recreation use and protection of resources. Carrying capacity determination is a highly complex task that will require

a great deal of time to accomplish.

Page 2. Support for a course of action goes to the decision to be made – and may be of interest to the decision maker but does not provide rationale that affects

the DEIS analysis. Alternative G in the DEIS provides a mass transit oversnow access option for the decision maker.

Page 2. Support for a course of action goes to the decision to be made – and may be of interest to the decision maker but does not provide rationale that affects

the DEIS analysis. Alternatives D and E in the DEIS provide options for backcountry nonmotorized use limits in YNP. The preferred alternative in the FEIS

will incorporate such features for both park units.

Pages 2-3. Statements of support for The Citizens’ Solution do not respond directly to information in the DEIS. That alternative most closely resembles

Alternative G in the DEIS. Support for a course of action goes to the decision to be made – and may be of interest to the decision maker but does not provide

rationale that affects the DEIS analysis. See matrix that compares features of the Citizens’ Solution with alternative features in the DEIS.

Page 3. NPS acknowledges the comment. Additional survey results are available for use in the FEIS. Determinants of winter use, or how various impact

topics/effects are weighted, will fall to the decision maker and the rationale for the eventual decision.

Page 3. Our assessment indicates that there will not be a tunnel effect. Berms will be created, but for most of the distance they would not impede the view of

scenery. These impacts are discussed on page 219 of the DEIS. Created berms will be laid back to allow wildlife to exit the road, as a provision of all

alternatives in which road segments are plowed (DEIS page 25).

Pages 3-4. The purpose and need for action is predicated on NPS mandates, executive orders, regulations and policies, including those that relate to air quality.

Pages 4-5. Re: impacts of snowmobiles on air quality. The DEIS discloses the impacts of snowmobiles on air quality, beginning with the methods and

assumptions section on page 164 and subsequently for each alternative. This information is updated in the FEIS using recently completed studies and modeling.

Page 7. The impacts on sound alluded to in this comment have been disclosed in the DEIS. Suggesting what the decision should or shouldn’t be, or questioning

the justification for designating the preferred alternative, is insufficient rationale for dismissing an alternative from the range to be considered.

Page 9. Recreation carrying capacity determination would be implemented under any alternative (DEIS page 25). Carrying capacity determination is a highly

complex task that will require a great deal of time to accomplish.
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MELISSA STRINGHAM

Page 1. Comments in this letter are critical of alternative B. Attention to this alternative is a function of its designation in the DEIS as the preferred

alternative. The preferred alternative will change in the FEIS. The impacts of alternative B are disclosed in the DEIS. It is the purpose of an EIS to

disclose impacts; identification of impacts is not suitable rationale for changing or removing the alternative from the EIS.

Page 1. The potential impacts of alternative B in regard to visitor experience and safety are disclosed in the DEIS on pages 203 and 217. The impacts

on ungulates are disclosed on pages 208-210. NPS maintains that the plowing of the West Yellowstone to Old Faithful road segments represents a safer

situation than currently exists. Unregulated use by large numbers of snowmobiles, piloted in many instances by novice riders, and snowcoaches amid

the presence of wildlife is more hazardous than controlled and scheduled mass-transit traffic using trained and experienced drivers. On road segments

that are less traveled, or less occupied by wildlife, snowmobile use continues in alternative B – this is status quo in terms of visitor experience and

safety. Impact on scenic viewing and other aspects of visitor experience are discussed on pages 219-221 in the DEIS.

Page 2. Concerns about how use in the park units might change as a result of alternative B are understandable. The impacts of redistributed use are

discussed to a degree in the DEIS. The FEIS will provide a more quantified scenario of how use might change by alternative.

Page 2. NPS is aware of the positive aspects of snowcoach travel, and agrees that for many people oversnow mass-transit access is a wonderful

experience.

Pages 2-3. The amount of use and its distribution under alternative B, from West Yellowstone to Old Faithful, would be more easily scheduled and

controlled using mass transit systems. The DEIS illustrates that there is sufficient capability using such a system to replace the number of visitors who

presently use this route and destination services via snowmobile.

Pages 3-4. Winter wildlife habitat, and how the alternatives relate to it using trail designations or closures, will be clarified in the FEIS.
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MICHAEL J. YOCHIM

Page 1. Re: Incorporation of Yochim publications as literature to be cited. NPS will review the information and incorporate it as necessary.

Pages 1-5. Commenter presents variations on alternative B, and reasons for the variations. Since an alternative selection and the rationale for it are reserved for

the decision to be made, most of this subject matter cannot be responded to. Also, since the preferred alternative will change in the FEIS, the context for the

comments no longer exists. Alternative B and its various features remain as choices for the decision maker.

Re: Plow entire north and west side of park, for logistic ease, visitor access, and cost reduction. Plowing the road from Mammoth to Norris and then south to

Madison was not considered to be a feasible alternative for several reasons. These sections of road receive a good deal more snow and wind during the winter

season than other road sections proposed for plowing. Park maintenance staff are concerned that during the deep winter, the narrow curvy road template

coupled with high cross winds would prohibit any degree of certainty in keeping the road open. Plowing these road sections during the late winter season as

suggested in alternative C was considered to be the only feasible option for plowing from Mammoth to Madison. In agreement with the commenter, the

analysis presented for both alternatives C and B (see pages 219-222 and 240 –242) suggest that adverse effects would occur under these alternatives because of

the complex travel logistics required by both park visitors and employees.

Re: Restrict plowed roads to public vehicles only. Alternative B does limit use to concessions or NPS managed access on the plowed road from West

Yellowstone to Old Faithful. A very limited number of private vehicles would be accepted on the basis of reservations taken.

Re: Closing Sylvan Pass. This feature is present in alternative D, and remains available for selection by the decision maker.

Re: Close remainder of YNP to snowmobiles. Alternative G limits motorized oversnow access in all three park units to snowcoach only. This feature is

available for selection by the decision maker.

Re: Affordable housing at Old Faithful. Commenter has a point. However, there remains a distinction between access and lodging unfortunately. The lodging

portion of the experience is in the purview of concessions, not winter use access and recreation.

Re: Snowmobile access. This comment goes to the purpose and need for action. Snowcoach only access is a choice available to the decision maker, in

alternative G.

Pages 5-6. Re: Non-support for The Citizens’ Solution. Insofar as it resembles DEIS alternative G, is a comment going to the decision to be made. NPS

acknowledges the expense of snowcoaches, as an affordability issue similar to the cost of lodging in the park interior. As with all alternatives, and their

features, there are down-sides as well as up-sides. The Park Service’s chief concern is to decide on the means whereby the public can enjoy the parks during

the winter while protecting park values and resources. The preferred alternative in the FEIS will reflect this thinking.