CONSULTATION & 

COORDINATION

WITH OTHERS

Andy Foster Brian Crocket

Jeff Blaylock Jeff Blaylock

Adam Smith
204 
205 

PUBLIC INVOLVEMENT 

The General Management Plan / Environmental 

Impact Statement for Big Bend National Park 

represents thoughts presented by the National 

Park Service, Native American groups, and the 

public. Consultation and coordination among 

the agencies and the public were vitally 

important throughout the planning process. The 

public had two primary avenues by which it 

participated during the development of the plan: 

participation in public meetings and responses 

to newsletters. 

PUBLIC MEETINGS AND NEWSLETTERS 

Public meetings and newsletters were used to 

keep the public informed and involved in the 

planning process for Big Bend National Park. A 

mailing list was compiled that consisted of 

members of governmental agencies, nongovernmental groups, businesses, legislators, local 

governments, and interested citizens. 

The notice of intent to prepare an 

environmental impact statement was published 

in the Federal Register on May 3, 2000. A 

newsletter issued in May 2000 described the 

planning effort. Public meetings were held 

during May 2000 in Study Butte/Terlingua, 

Alpine, Sanderson, and Austin and were 

attended by 63 people. A total of 80 electronic 

and mailed comments were received in response 

to that newsletter. The National Park Service 

also met with city, county, and state agencies. In 

July 2000 the park held meetings in Mexico at 

Santa Elena, San Vicente, and Boquillas del 

Carmen. These meetings were attended by 

nearly 40 people. The National Park Service 

received comments in the meetings and in the 

response to the newsletter, and these comments 

were incorporated into the issues for the plan. 

A second newsletter distributed in June 2001 

described the draft alternative concepts for 

managing the national park. A total of 120 

electronic and mailed comments were received 

in response to that newsletter. A number of 

letters favored only minimal changes to the 

current management of the park. Other people 

favored more visitor amenities, such as more 

recreational vehicle camping areas, trails, etc., 

while others favored removal of park development from areas of the park like the Chisos 

Basin. 

CONSULTATION 

Section 106 Consultation 

Agencies that have direct or indirect jurisdiction 

over historic properties are required by section 

106 of the National Historic Preservation Act of 

1966, as amended (16 USC 470, et seq.) to take 

into account the effect of any undertaking on 

properties eligible for the National Register of 

Historic Places. To meet the requirements of 36 

CFR 800, the National Park Service sent letters 

to the Texas historic preservation office and the 

Advisory Council on Historic Preservation on 

May 15, 2000, inviting their participation in the 

planning process. Both offices were sent all the 

newsletters with a request for comments. 

Under the terms of stipulation VI.E of the 1995 

programmatic agreement among the National 

Park Service, the Advisory Council on Historic 

Preservation, and the National Conference of 

State Historic Preservation Officers, the 

National Park Service, “in consultation with the 

SHPO, will make a determination about which 

are programmatic exclusions under IV.A and B, 

and all other undertakings, potential effects on 

those resources to seek review and comment 

under 36 CFR 800.4-6 during the plan review 

process.” 

In the following table the specific undertakings 

are listed, along with the National Park Service’s 

determination of how those individual undertakings relate to the 1995 Programmatic 

Agreement. 

The Texas historic preservation office concurred that the NPS preferred alternative would 

not impact known cultural resources. In areas 

where there may be undiscovered resources or 

sites with undetermined National Register of 
CONSULTATION AND COORDINATION WITH OTHERS

206 

TABLE 11: ACTIONS THAT MIGHT AFFECT CULTURAL RESOURCES AND ASSOCIATED COMPLIANCE 

REQUIREMENTS 

(Requirements of the Texas Historic Preservation Office and/or the Advisory Council on Historic Preservation) 

Action Compliance Requirement 

Adaptively use Barker Lodge for housing Further SHPO review may be necessary at the scoping, conceptual, 

and possibly at the design stage of the project. 

Development at Buttrill Spring No further SHPO review necessary unless it is determined that the 

spring and its features are eligible for the National Register of 

Historic Places or it is determined that visitation to the spring 

would impact archeological resources. 

Removal of one NPS employee residence 

and NPS “bunkhouse” 

No further SHPO review necessary. 

Construct new visitor center No further SHPO review unless eligible National Register of 

Historic Places archeological sites are impacted by construction. 

Relocation of campsites at Rio Grande 

Village and Cottonwood Campground 

No further SHPO review unless eligible National Register of 

Historic Places archeological sites are impacted by construction or 

sites would impact cultural landscapes. 

Construct new storage warehouse at 

Panther Junction 

No further SHPO review unless eligible National Register of 

Historic Places archeological sites are impacted by construction. 

Construct new employee housing at Rio 

Grande Village, Castolon, and 

Persimmon Gap 

No further SHPO review unless eligible National Register of 

Historic Places archeological sites are impacted by construction or 

sites would impact cultural landscapes. 

Construct fire bays at Rio Grande Village 

and Castolon 

No further SHPO review unless eligible National Register of 

Historic Places archeological sites are impacted by construction. 

Relocation of Maverick entrance station No further SHPO review unless eligible National Register of 

Historic Places archeological sites are impacted by construction. 

Rehabilitate visitor center No further SHPO review necessary unless the building is 

determined eligible for the National Register of Historic Places or 

is a part of a cultural landscape. If so, further consultation would 

be necessary to protect the landscape and the character-defining 

features. 

Identification and evaluation of 

potentially eligible cultural landscapes 

and resources. 

Further SHPO review and consultation necessary to determine if 

any of the cultural landscapes or properties are potentially eligible 

for listing on the National Register of Historic Places. 

Historic Places eligibility, the National Park 

Service has developed a plan that would 

preserve or avoid cultural resources. The state 

historic preservation officer has asked to be 

consulted during any inventory work to determine whether cultural resources are present and 

to determine their eligibility and any effect. 

Consultation with Native Americans 

Letters were sent to the following Native 

American groups on May 15, 2000, to invite their 

participation in the planning process: 

Fort Sill Apache Tribe of Oklahoma 

Mescalero Apache Tribe 

Apache Tribe of Oklahoma 

Blackfeet Tribe 

Caddo Indian Tribe of Oklahoma 

Cheyenne-Arapaho Tribes of Oklahoma 

Jicarilla Apache Tribe 

Kiowa Indian Tribe of Oklahoma 

Comanche Indian Tribe, Oklahoma 

Kickapoo Traditional Tribe of Texas 

The tribes were briefed on the scope of the 

planning project and the preliminary alternatives 

by newsletter and follow-up telephone calls 

soliciting comments. Oral comments by some 

tribes included recommendations to maintain 

the park as it is; other tribes had no comments at 

this time. The Mescalero Apache commented 

that traditional cultural properties be identified 

and protected and that interpretation takes in 

the Native American viewpoint. Conversations 
Public Involvement 

207 

have been ongoing throughout the planning 

process to inform the tribes about the progress 

of the plan and identify how and to what extent 

they would like to be involved. The listed tribes 

were sent a copy of the draft plan. This was 

followed by telephone calls to the tribes. There 

were no comments from the tribes at this time. 
208 

COMMENTS ON THE DRAFT DOCUMENT 

This section contains a summary of comments 

received through public meetings, letters, and emails after the Draft General Management 

Plan/Environmental Impact Statement for Big 

Bend National Park was released on June 11, 

2003. The Council on Environmental Quality 

(CEQ) regulations that implement the National 

Environmental Policy Act (NEPA) provide 

guidance on how an agency is to respond to 

public comments (40 Code of Federal 

Regulations, section 1503.4.1-5). 

(a) An agency preparing a final 

environmental impact statement shall assess 

and consider comments both individually 

and collectively, and shall respond by one or 

more of the means listed below, stating its 

response in the final statement. Possible 

responses are to 

(1) Modify alternatives including the 

proposed action. 

(2) Develop and evaluate alternatives not 

previously given serious consideration by 

the agency. 

(3) Supplement, improve, or modify its 

analyses. 

(4) Make factual corrections. 

(5) Explain why the comments do not 

warrant further agency response, citing the 

sources, authorities, or reasons which 

support the agency’s position and , if 

appropriate, indicate those circumstances 

which would trigger agency reappraisal or 

further response. 

The National Park Service considered all written 

comments according to the requirements of 40 

CFR 1503. 

A notice of availability of the draft document 

was published in the Federal Register on June 11, 

2003 (Federal Register Vol. 68, No. 112). About 

750 copies of the draft were distributed to 

government agencies, organizations, public 

interest groups, and individuals. In addition, the 

complete text of the Draft General Management 

Plan/ Environmental Impact Statement was 

posted on the NPS Web site. 

The National Park Service held four public 

meetings in Dallas, Houston, Alpine, and Study 

Butte in July 2003. Postcards giving the time and 

location for each meeting were sent out to the 

mailing list and to the Friends of Big Bend 

National Park at their request. There were a total 

of 91 people at these four meetings. In general, 

the comments at the public meetings sought 

clarification of the various alternatives, with 

some discussion on the pros and cons of each 

alternative. Many questions centered on 

retaining or removing the lodging unit in Chisos 

Basin. Comments were also made concerning 

how and when the park would receive funding 

to carry out implementation of the approved 

alternative. 

A total of 75 comment forms, letters, and 

electronic messages were received from 

individuals in response to the draft; of these, 18 

were form letters. Twenty comment letters were 

received from governing bodies, government 

agencies, organizations, and organized interest 

groups during the comment period. Written 

comments were accepted through August 29, 

2003. All letters from governing bodies, 

government agencies, and organizations as well 

as substantive letters from individuals are 

reproduced on the following pages. 

CHANGES RESULTING FROM 

COMMENTS 

In response to public comments, the National 

Park Service has decided not to remove the 

lodge unit from Chisos Basin in its preferred 

alternative. If a water shortage occurs in the 

Basin then facilities, concessions, and the NPS 

campground could be closed on a temporary 

basis. Also the National Park Service could build 

additional housing units in Panther Junction to 

accommodate NPS needs, as well as those of the 

Border Patrol and the concessioner. 
209 

RESPONSES TO COMMENTS ON THE DRAFT DOCUMENT 

Following are reproductions of letters from all 

agencies and letters from all organizations and 

individuals that had with substantive comments. 
COMMENTS ANDRESPONSES

Response to International Boundary and WaterCommission Letter1. Thank you for your review and comment on the Draft

General Management Plan / Environmental ImpactStatement. Additions have been been made to the "Purposeof and Need for the Plan," chapter in the "Laws, Policies,and Mandates" section to reflect the IBWC's mission andreaffirm the commitment of staff at Big Bend National Parkto work with the commission on issues of concern to thecommission.
International and Federal Agencies

2. The additional information you provided on flows at

Candelaria has been added to "EnvironmentalConsequences" chapter under "Methods for AnalyzingImpacts," "Upstream of the Rio Grande."
COMMENTS AND RESPONSES
International and Federal Agencies
COMMENTS AND RESPONSES
International and Federal Agencies
COMMENTS AND RESPONSES
International and Federal Agencies
COMMENTS AND RESPONSES
International and Federal Agencies
COMMENTS AND RESPONSES
State and Local Agencies
COMMENTS AND RESPONSES
State and Local Agencies
COMMENTS ANDRESPONSES

Response to Big Bend Resorts Letter1. When known, the plan uses actual counts for analysis purposes.
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2. In the section of the plan on "Laws, Policies and Mandates"

in the table with "Visitor Understanding and ParkRequirements" the requirement to do an updated visitor survey has been added.
COMMENTS ANDRESPONSES

3. The preferred alternative has been modified to reduce, if not

eliminate, this impact.
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4. The National Park Service would encourage additional

development to be done outside park boundaries. Duringthe development of the range of alternatives, considerationwas given to expanding concession facilities in PantherJunction and other locations in the park. Without detailedanalysis, it was determined that such actions in conjunctionwith other potential development could be stressful on thenatural resources of the park, especially water. Further, suchdevelopment could be subject to flash flood hazard. Also thelevel of proposed development in the park seemed adequateto meet the needs of visitors and park staff for the life of thisplan.

In addition the Park Service examined the replacement ofthe Panther Junction service station/convenience store, and itwill be part of the new concessions contract prospectus. ThePark Service does not regard this as new development but asreplacing an aging, out-of-date structure with a modern facility that will meet the demands of current and future visitors.The footprint will not be any bigger than the current development if you include the housing that used to be behind thecurrent facility. Rather than have an automobile service bay, itwill have public showers and more retail space as there areauto mechanics in the gateway communities now. They willstill fix flat tires in the new facility, but there will not be fullmechanic service.
COMMENTS ANDRESPONSES

6. The current operation is a viable one with 25 sites. It will

also be viable with 30 sites in an attractive, up-to-date RVpark. The draft alternative B calls for an increase of up to40% in size with a total of 30 sites available. NPS concessions policy requires that the overall contract provide a reasonable opportunity for the concessioner to make a profit,not for every facility or aspect of the operation to make aprofit. The park is also considering turning the Rio GrandeVillage NPS campground over to the concessioner in thenew contract, but a final decision has not been reached onthat. The overall contract will provide ample opportunity fora reasonable profit.

Also, the National Park Service determines the appropriate

level of commercial development in a park, not the currentconcessioner. When that determination has been reached,then the prospectus is released for bids.

5. The National Park Concessions Inc. Foundation approved

$600,000 to be spent to build two new duplex units that willprovide eight bedrooms at Panther Junction. The park hasthis money in hand. 

The design is from the NPS Prototype Design Catalogue —

Housing for Trailer Replacement — Permanent 2-Plex, pages12 and 13. The construction of new concessions housing ispart of the concessions contract, which is currently on athree-year extension. Their new contract will also call fortrailer replacement housing. This is not really new development, but, again, the replacement of very old facilities (trailers) with modern housing. This is NPS concessions policy.

Only two units have been approved, but the park alsoapplied for a dorm-style building and a recreation hall. Again,the contract calls for this and they will be in Panther Junction.National Park Concessions Inc. is also working with the parkon building housing outside of the park but, as the only 24/7operation in the park, the concessioner has to have most oftheir employees housed in the park.
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7. The plan does not propose to locate concessioner employee

housing outside the park. Rather than requiring the concessioner to build any housing outside the park, the NationalPark Service is encouraging the concessioner to do so.Concessioner housing levels in the park would remainroughly the same as they are now with most of the housingin the park. Having housing outside the park would add anadditional operational cost that would be taken into consideration during the financial analysis aspect of the prospectusdevelopment.
COMMENTS AND RESPONSES
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Response to National Parks Conservation AssociationLetter1. Preparation of a comprehensive interpretive plan has been

added to the "Laws, Policies and Mandates, VisitorUnderstanding and Park Use Requirements" section.

2. Please see the Draft General Management Plan, pages 

12 and 1

3. The revision has been made.4. Management of riparian vegetation and exotic species is

governed by laws, policies, and mandates of the federal government and the National Park Service. They are not beyondthe scope of NPS management. In fact, wetlands (includingriparian areas) are an impact topic in the document.Therefore, the paragraph on riparian vegetation has beendeleted.

Because management of exotic species is governed by laws,policies, and mandates, and no proposals of the generalmanagement plan alternatives would necessitate furtheraction, exotic species are not an impact topic in the GeneralManagement Plan /Environmental Impact Statement.
COMMENTS AND RESPONSES 

5. See the "Laws, Policies, and Mandates — Wetlands, and Exotic Species," and "Mitigation and Additional Studies" sections. 6. The park staff has listed the plans they find most necessary under "Laws, Policies and Mandates," and "Mitigation and

Additional Studies." The need for a comprehensive interpretive plan was added to the "Laws, Policies, and Mandates"section. Cultural landscape studies are addressed in"Mitigation and Additional Studies" section. At the end ofeach alternative, under "Estimated Costs," is the percentageincrease in employees that would be needed to implementthe alternative.
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7. In the "Laws, Policies and Mandates," "Visitor Understanding

and Park Use Requirements," section (page 33 in the draftplan), the last bullet describes the approach that will be takenregarding carrying capacity.

8. According to NPS Management Policies 2001, lands within

authorized park boundaries can be acquired or managed usingmethods that protect the park's resources. On lands within theauthorized boundary that have not been acquired, the NationalPark Service would seek, in cooperation with landowners, toprovide appropriate protection measures. For example, boththe inholdings near Persimmon Gap and the Pitcock Ranch arealready within the approved park boundary. The park staffwould attempt to acquire them should the opportunity arise. 

As part of the planning process, the National Park Service is

required to identify and evaluate boundary adjustments thatmay be necessary or desirable to carry out the purposes of thepark unit. As found in NPS Management Policies 2001, section

3.5, boundary adjustments may be recommended to:

• Protect significant resources and values, or to enhance opportunities for public enjoyment related to park purposes;

• Address operational and management issues, such as the need

for access or the need for boundaries to correspond to logicalboundary delineations such as topographic or other naturalfeatures or roads; or

• Otherwise protect park resources that are critical to fulfilling

park purposes.

During the course of the planning process it was determinedthat no lands outside Big Bend National Park met the abovementioned criteria. This finding will serve as guidance for updating the park's Land Protection Plan.See the "Ideas Suggested and Eliminated from FurtherConsideration" section (page 75 in the draft document), whichfound that the lands of Christmas Mountains were "protectedby a strict conservation easement, and that the easementremains in place regardless of ownership. The easement willprotect the park viewshed and the Christmas Mountains fromany development."
COMMENTS AND RESPONSES 

9. In all alternatives including no action, the park has undertaken and continues to undertake a series of measures

designed to better protect park resources and provide forenhanced visitor safety. The park's goal is to eliminate crossborder illegal activities and to provide sufficient law enforcement presence to deter such activities. The partnershipbetween the U.S. Border Patrol and the park would bestrengthened to provide for additional security. The parkcontinues to upgrade communication capability and otherequipment necessary to accomplish this task.

10. The intensity definitions for water quantity have been

revised. The suggested change in intensity level has beenmade.

11. The statement on page 149 (in the draft plan) refers to

existing conditions at the park and not the preferred alternative for cultural resources. By following laws, regulations,and policy, the National Park Service will continue to protect and preserve all significant cultural resources in thepark.
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Response to Sierra Club Letter1. Rio Grande and other riparian/wetland ecosystems.

Please see the "Wetlands" section in the "Laws, Policies andMandates," section of the "Purpose of and Need for thePlan" chapter (page 21 in the draft document). The NationalPark Service is required by law, policy, and executive orderto protect wetlands. Actions that the Park Service will take tocomply with these mandates are listed in that section.

The preferred alternative (alternative B) proposes finding a

separate source of water for human use at Rio GrandeVillage and relocating some campsites farther from the gambusia pond. This would, in addition to eliminating thesource of impacts on the gambusia, improve the condition ofthe pond and associated wetlands.Chisos Basin. Most of the Chisos Basin is in designatedwilderness and is protected. Alternative C in this General

Management Plan / Environmental Impact Statement proposes removing all development from the Basin except the mainroad, a parking area, and a restroom. This alternativereceived almost no support from the public. Objectionsincluded that it would eliminate the only non-campingovernight accommodations in the park and make it moredifficult for many people to visit. Chisos Basin is a favoritearea of visitors. The plan's preferred alternative, alternativeB, proposes no additional development in the Basin andproposes removing one NPS employee residence and anNPS bunkhouse (and relocating them to Panther Junction).Rio Grande Wild and Scenic River Plan. The draft management plan states (pages 15-16) that "The GMP proposesno actions that could adversely affect the values that qualifythe Rio Grande River for the national wild and scenic riversystem. None of the actions proposed in this draft GeneralManagement Plan conflict with the draft river managementplan." The Rio Grande Wild and Scenic River (WSR) is aseparate unit of the national park system. The WSR plan,including objectives for managing the river, will govern howthe river is managed. The General Management Plan /Environmental Impact Statement for Big Bend will 

Response 1 continues on next page.
COMMENTS ANDRESPONSES

cover management of the park up to the river. Both unitsare managed by the staff at Big Bend National Park. Thismeans that there is no need for a separate document to reconcile the GMP and the WSR plan.

2a. Air Quality. Please see pages 12 and 13 of the draft document that describe the park's air quality monitoring program, the park's ongoing negotiations with Mexico, and the

ongoing cooperation with the Texas Commission onEnvironmental Quality, NPS Air Resources Division, andU.S. Environmental Protection Agency. Page 13 states thatthe impact topic was dismissed because "There are no general management plan proposals that, when consideredalong with required mitigation, would further impact airquality." 

Page 23 of the draft document describes specific actionsthat National Park Service will take in cooperation with theTexas Commission on Environmental Quality and theEnvironmental Protection Agency to monitor air qualityand ensure that it will be maintained at the cleanest levelpossible.

2b. Water quality. Page 13 of the draft document explains that

the park has developed a "Water Resources ManagementPlan" that describes strategies the park staff will employ toaddress, among other issues, water quality. Actions proposed in the general management plan might impact waterquality positively by raising fuel tanks above the level of the500-year floodplain or protecting them from the 500-yearflood. This would reduce the chances that fuel would enterfloodwaters. These beneficial impacts do not necessitateaddressing water quality further.

Page 18 of the draft describes specific actions that theNational Park Service will take, on its own or in cooperation with others, to monitor and improve water quality.Intrusive sounds. Please see page 25 of the draft documentfor actions that will be undertaken to protect quiet and natural sounds.

Response 2b continues on next page.
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Riparian vegetation. This topic was not dismissed. Impactson riparian vegetation from implementing alternatives of theplan are described in the "Environmental Consequences"chapter under "Natural Resources, Wetlands." Additionalactions are described on page 21 of the draft.Exotic species. Perhaps it was difficult to find the information on page 19 in the draft document about exotic speciesbecause it is combined with threatened and endangeredspecies. Actions that the Park Service will take regardingexotic species were placed under a separate heading under"Laws, Policies, and Mandates" in the final document. Amitigating measure is on page 77 of the draft documentunder "vegetation."Vandalism, graffiti, and the illegal collection of plantsand animals. These are illegal activities that are prohibitedby law and policy. The park's interpretive program endeavors to educate visitors about the impacts of these activitiesand the fact that they are illegal. Apprehending and prosecuting people who engage in these activities is an ongoingactivity of law enforcement personnel.

Illegal grazing. This issue is beyond the scope of the general management plan because it is a law enforcement issuefor which direction is not needed. Law enforcement personnel simply need to continue to work with Mexican villages to educate them about the consequences of allowingtheir cattle to cross the border, enlist their cooperation, andenforce existing park rules and regulations when and if cattle do cross the border.

Current law enforcement efforts would continue under anyof the alternatives. Park staff would continue with botheducation and enforcement actions. These include trespasslivestock roundups where the stock rounded up is confiscated, as well as such things as furnishing used fencingmaterials to the Mexican ranchers so they use them to blockeasily used access and crossing areas on the Mexican side ofthe river. However, the closing of the border has severely

Response 2b continues on next page.
COMMENTS ANDRESPONSES

impacted the ability of park staff to communicate with theranchers and protected area staff directly. Again, under anyof the alternatives, these efforts would continue. Althoughpark staff does not have control over Mexican livestockwhen they are on the Mexican side of the river, it can anddoes take action when livestock cross into the park.Confiscating livestock, and not returning them to Mexico,has proven to be a very effective method to raise awarenessand stop this destructive activity.Reducing the irrigation at Rio Grande Village would nothave a significant impact, if any, on this issue. 

2c. This information comes from the approved 1984 wilderness

proposal. It is not a proposal of this plan. The NationalPark Service is required to evaluate for wilderness designation lands added to units of the national park system. Thedraft wilderness suitability assessment (appendix E, pg. 222in the draft document) evaluates for wilderness values, alllands added to the park since the 1984 Wilderness Study.Most public comment has been opposed to designatingadditional wilderness at the park.

There was no call for the reevaluation of the original 1984

wilderness proposal by anyone during the initial scopingprocess. Comments focused only on the NorthRosillos/Harte Ranch addition and the possibility that all orparts of it may be eligible for wilderness designation. Thepark will do a wilderness study on the lands found suitablefor wilderness by the "Wilderness Suitability Assessment."

2d. Exotic Species. See response 2b, exotic species.2e. Air and Water Issues. See responses 2a and 2b.
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3. A general management plan focuses on "what" the park

plans. Subsequent, separate plans that tier off the generalmanagement plan will provide more detailed information on"how" the National Park Service will accomplish these goals.For instance, it would hardly be productive or effective tothreaten to sue a state agency in a general management planon the basis of what they may or may not do in the future.See response 2a above regarding air quality, response 1above regarding the wild and scenic river, response 1 aboveregarding riparian vegetation, and response 2b above regarding exotic species.

Water Quantity. Please see page 18 of the draft for specificactions the Park Service will take to address water quantity.Page 47 states that the park has already instituted a programof conservation and visitor education on the need to limitwater use and the role of water in a desert environment. Thelast paragraph on page 47 states that the Park Service wouldcontinue coordination with agencies and other groupsregarding water quality and quantity in the Rio Grande. In alternative B, the preferred alternative, beginning on page55 of the draft document, several actions would reduce parkuse of water and have a positive impact on water quantity.Actions mentioned in the preferred alternative includereducing irrigation water use at Rio Grande Village by 59%,phasing out plants that are heavy water users at Rio GrandeVillage and Cottonwood Campground, relocating up to 15%of NPS personnel to gateway communities, and removingsome development from Chisos Basin.

4. Please see the draft document page 25 for actions that will

be undertaken to protect quiet and natural sounds.

The only area that would receive any new use under alternatives described in the draft document is the Harte Ranch - an

interpretive area in the Buttrill Spring area. The area is zonedbackcountry nonwilderness. There would be virtually noimpact on solitude from implementation of the preferredalternative.

Response 4 continues onnext page.
COMMENTS AND RESPONSES Most of the park is proposed wilderness under the park's 1984 "Wilderness Study/ Environmental Impact Statement." The park manages these lands, most of the park, for their wilderness values. Solitude is one of these wilderness values. None of the alternatives in the draft plan propose to alter management of the proposed wilderness. Therefore, the wilderness value of solitude will not be impacted by the plan. 5. Air Quality. Please see response 2a, air quality.

6. Water Quality. Please see response 2b, water quality.7. The wilderness suitability assessment is the initial step in a

process that is separate from the general management plan.Park staff studied the two units that have been added sincethe 1984 Final Environmental Impact Statement, ProposedWilderness Classification, applied the criteria in theWilderness Act, and found the acreage described in thewilderness suitability assessment suitable for wilderness. The"Draft Wilderness Suitability Assessment" is preliminary. Itsfindings are provided in the document for public information only. A wilderness suitability assessment does notrequire that alternatives be formulated.

Approval of the general management plan will not constitute

approval of the wilderness suitability assessment. The wilderness suitability assessment has not been approved by theNPS regional director of the Intermountain Region or thedirector of the National Park Service. If the wilderness suitability assessment was approved by these officials, a wilderness study would be undertaken. A notice of intent to prepare an environmental impact statement on a wildernessstudy would be published in the Federal Register. The notice

of intent would request that agencies and the public identifyissues to be addressed (scoping). The study would consideralternative configurations of wilderness and would beaccompanied by an environmental impact statement. Awilderness hearing would be held on the Draft WildernessStudy / Environmental Impact Statement. Only after completion of the Wilderness Study / Environmental ImpactStatement and signing of a "Record of Decision" could therebe a wilderness proposal for the North Rosillos and NinePoint units. Then Congress would have to act for wildernessto be designated.
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8. The Park Service does not send copies of the Federal

Register to members of the public. The Federal Register is

available at larger libraries and on line. The park would issuepress releases throughout any wilderness study process bothfor general information and to announce public meetings.

9. As shown on page 17 in the draft plan, this is an excerpt

from NPS Management Policies 2001. Determining specificcriteria for implementing this policy is not consistent withthe broad level of planning in a general management plan(Director's Order 2). Such criteria would be developed byresource professionals based on site-specific conditions atthe time of implementation of specific actions.

10. The general management plan is general and conceptual in

nature. The details of how and with whom the long-termcomprehensive plan for conservation and use of the RioGrande corridor would be developed will be determined aspart of a separate process.

11. The draft plan, pages 11 and 12, explains why the Mexican

long-nosed bat is not an impact topic.

12. Public notice will be given for any undertaking requiring it.13. As explained on page 10 in the draft plan, these items are

beyond the scope of the general management plan.However, the park is working with others to improve airquality.
COMMENTS ANDRESPONSES

14. The quotation for which you suggest revision is from the

NPS Management Policies 2001. The general managementplanning team does not have the authority to change thewording of these policies.

15. According to NPS Management Policies 2001, lands within

authorized park boundaries can be acquired or managedusing methods that protect the park's resources. In landswithin a park unit's authorized boundaries that have notbeen acquired, the National Park Service would seek, incooperation with landowners, to provide appropriate protection measures. For example, both the inholdings nearPersimmon Gap and the Pitcock Ranch are already withinthe approved park boundary. The park staff will attempt toacquire them should the opportunity arise. 

As part of the planning process, the National Park Service is

required to identify and evaluate boundary adjustments thatmay be necessary or desirable to carry out the purposes ofthe park unit. As found in NPS Management Policies 2001,section 3.5, boundary adjustments may be recommendedto:

• Protect significant resources and values or to enhance

opportunities for public enjoyment related to park purposes;

• Address operational and management issues, such as the

need for access or the need for boundaries to correspondto logical boundary delineation such as topographic orother natural features or roads; or

• Otherwise protect park resources that are critical to fulfilling park purposes.

If the acquisition would be made using appropriated fundsand is not merely a technical boundary revision, the criteriaset forth by Congress at 16 USC 4601-9(c) (2) must be met.All recommendations for boundary changes must meet thefollowing two criteria: 

• The added lands will be feasible to administer, considering their size, configuration, and ownership, and hazardous 

Response 15 continues on next page.
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substances, costs, the views of and impacts on local communities and surrounding jurisdictions, and other factorssuch as the presence of exotic species; and 

• Other alternatives for management and resource protection are not adequate.

During the course of the planning process it was determinedthat no lands outside Big Bend National Park met the abovementioned criteria. This finding will serve as guidance for updating the park's Land Protection Plan.See the "Ideas Suggested and Eliminated from FurtherConsideration" section (page 75 in the draft document),which found that the lands of Christmas Mountains were"protected by a strict conservation easement, and that theeasement remains in place regardless of ownership. Theeasement will protect the park viewshed and the ChristmasMountains from any development."

16. The National Park Service has analyzed an adequate range

of alternatives.

Preliminary alternatives were distributed to agencies andthe public in a newsletter in June 2001. Public comment onthe newsletter is summarized on page 193. No suggestionsfor additional alternatives were made at that time. However,suggestions were made that some actions should beremoved from the alternatives. The newsletter presentedfour alternatives for consideration (no action and three others). The actions below were in the preliminary alternatives,but were removed based on unacceptable environmentalimpacts and NPS staff reflection. Alternatives consideredbut eliminated from further consideration, pages 74-75 inthe draft plan, discussed these and other alternatives/actions that were considered but dismissed.

Alternative B in the newsletter proposed a relocated campground and amphitheater near Castolon in the mesquite flat

or southeast along the river from the existing campground.At Castolon, it proposed relocating concessions housing outof the historic district. At Rio Grande Village the gas station 

Response 16 continues on next page.
COMMENTS AND RESPONSES and store would be relocated outside the 500-year flood- plain. It considered encouraging the Texas General Land Office to find a buyer for the Christmas Mountains tract who would manage it to be compatible with park purposes. Alternative C in the newsletter would have removed all con- cession and NPS facilities from Chisos Basin except for the campground and two NPS residences for law enforcement and maintenance. The lodge and concession operations

would be relocated to an area between Basin Junction andPanther Junction. If this were not feasible, there would beno concession lodging in the park. The campground andamphitheater near Castolon would be relocated to themesquite flat or southeast along the river from the existingcampground. The concessions housing at Castolon wouldbe moved out of the historic district. At Rio Grande Village,campsites and certain park support facilities such as the visitor center and housing would be relocated outside the 100-year floodplain. At Rio Grande Village the gas station, store,and park support facilities such as maintenance would berelocated outside the 500-year floodplain, possibly at thejunction of the road to Boquillas. Also, NPS facilities at RioGrande Village would be reduced to five residences. Most ofRio Grande Village would be managed under the backcountry nonwilderness prescription. Concession facilities at RioGrande Village would be reduced to two residences. Most ofthe land in the Harte Ranch area would be managed following the wilderness prescription. It considered encouragingthe Texas General Land Office to find a buyer for theChristmas Mountains tract who would manage it to be compatible with park purposes.

Alternative D would have undertaken the same actions at

Castolon as alternatives B and C. Most of the land in theHarte Ranch area would be managed following the wilderness prescription. It would enlarge the park boundary toinclude the Christmas Mountains and seek funds for landacquisition.
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17. The National Park Service has addressed all substantive

comments received as part of the NEPA process consistentwith CEQ regulations. Any substantive comments on theDraft General Management Plan / Environmental ImpactStatement submitted by the public, agencies, and officialshave been addressed in the comment and response sectionof this Final General Management Plan / EnvironmentalImpact Statement. Any revisions to the alternatives based on

public comment and/or other considerations are describedin the final document.

18. Alternative B has been chosen as the environmentally preferred alternative based on criteria found in the National

Environmental Policy Act, Section 101 (b), as directed bythe CEQ “Forty Most Asked Questions”, 6a. These criteriaare listed on page 76 of the draft plan. The criteria include,among other things, consideration of visitor use and experience as well as potential resource impacts.

19. Please see our response to item 15. Some of the actions

implied in the suggestion to add an alternative B1 were dismissed because of public comment. See sections on ChisosBasin and Rio Grande Village on page 74 of the draft plan.

The National Park Service believes that it has considered

the full spectrum of reasonable alternatives for Big Bend,and that no useful purpose would be served by evaluatingan alternative between B and C. In fact, many commenterson the draft suggest that even alternative B is not practicalor feasible from an economic standpoint. 

20. Please see our response to item 7. The “Wilderness

Suitability Assessment” is part of a process that is separatefrom the general management plan.

21. Removal of the airstrip was not considered because park

staff finds it essential for park operations. The air strip isessential for park operations in terms of search-and-rescueoperations, trespass livestock, and general law enforcementincluding drug and undocumented alien interdiction. 

Response 21 continues on next page.
COMMENTS ANDRESPONSES

Retention of the airport within the park went through acomplete compliance review during which alternative locations were considered and dismissed due mainly to security concerns for the aircraft if it was outside the park.

22. Page 230 of the draft document, next to last paragraph,

explains why the alternative of relocating all facilities wasdismissed. That section of the document includes mitigation of the potential harmful effects of flooding.

Alternatives in the draft consider moving 15% of employee

offices and residences outside the park. It is felt that this isa reasonable first step and the most that could be done during the approximately 15-year life of the plan. Manyemployees need to remain in the park to perform theirfunctions.

There are more than 80 buildings at Panther Junction.

Obtaining funding to relocate all of them over a period of15 years is highly unlikely.

The "Appendix F: Statement of Findings for Floodplains

for Panther Junction," page 234, does state that, "If thedeveloped area is damaged by flooding or, as additionalfacilities are developed outside the park, the park staff willconsider whether replacement facilities would best be sitedat Panther Junction, other locations in the park, or outsidethe park."

23. CEQ Forty Most Asked Questions, # 3, defines no action

for updating a management plan as "'no change' from current management direction or level of management intensity...continuing with the present course of action until thataction is changed."

Actions that will occur with or without the implementation

of an approved plan are included in the no-action alternative. For example, the park already has funding for design ofthe two new buildings at Panther Junction. Whether a new plan is approved or not, the park must comply with laws, executive orders, and policies. Relocation of

Response 23 continues on next page.
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campsites at Rio Grande Village is needed to protect theendangered fish, Big Bend gambusia. Executive Order11998 and NPS guidelines require that fuel tanks be raisedabove the level of the 500-year floodplain or protected fromthe 500-year flood. Likewise, "inclusion of funds for construction, rehabilitation, and restoration of park facilities tomaintain current health and safety standards" are appropriate under "no change from current management direction."

24. Please see response 22.25. At Rio Grande Village the preferred alternative would

reduce irrigation by 50% and phase out plants that areheavy water users.

26. Regarding the inholdings, please see response number 15.

Regarding the landing strip, please see response number 21.

27. This information comes from the approved 1984 wilderness proposal. It is not a proposal of this management plan.

See responses 2b (paragraphs 4 and 7) and 2c for additionalinformation. In a national park, all lands are protected tosome degree or another. There are no plans for any newdevelopment of any of the land along the river south of theriver road under any of the alternatives. Some of this landhas been impacted over the years, particularly near the border crossings, and that is why it is not considered worthy ofwilderness designation. Just because land is not recommended or designated as wilderness does not mean it is notprotected. The National Park Service was protecting landfor nearly 50 years before the Wilderness Act, including BigBend National Park.
COMMENTS ANDRESPONSES

28. Please see the draft page 33, last bullet.29. Generator noise is considered a park operational issue, and

in all alternatives the park staff has and continues toenforce restrictions on noisy generators.

30. See response 21.31. See response 15.32. See response 21. 33. See response 15.34. According to NPS Director's Order 12, page 51, feasibility

is only one of the reasons for dismissing an alternative.Other acceptable reasons include inability to meet projectobjectives or resolve need; duplication with other, less environmentally damaging or less expensive alternatives; andtoo great an environmental impact.
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35. See response 15. The owner of the land is the Texas

General Land Office. That office would be the appropriateentity to determine if it wishes to provide copies of theconservation easement to the public.

The National Park Service did indeed analyze the acquisition of the Christmas Mountains and the reasons for not

pursuing acquisition are clearly spelled out in the document (see page 75 in the draft document).

36. See response 18.37. A statement of findings for wetlands at Panther Junction is

included in the draft document on pages 219-235. Theplanning team believes that the document, including thestatement of findings, is in compliance with the NPS guidelines for implementing Executive Order 11988. If the superintendent of Big Bend National Park, the chief of the NPSWater Resources Division, and the director of the NPSIntermountain Region agree with this finding, alternative B,including the mitigation included in the statement of findings, can be implemented. (Note: A final plan / environmental impact statement, waiting period, and "Record ofDecision" on the final plan / environmental impact statement are also required.)

38. The disputed sections of the boundary are all relatively

minor, involve small areas of land, and are in the northwestsection of the park near the North Rosillos/Harte Ranchaddition as well as near Lajitas in the southwest part of thepark. Park staff simply needs to resolve these disputes sothat the park and its neighbors have an official, markedboundary in these areas so each can pursue his own actionswithout disputes about whose land one is on. We know ofno other "issues raised."
COMMENTS ANDRESPONSES

39. The National Park Service thinks that "moderate" accurately describes the impact because 700 acres is a tiny portion of the park. It may be more visible than other areas but

would not have a "major, long-term, beneficial impact" onnative vegetation. It would have only a local impact onthose areas. However, right below that section the ParkService indicates that the impact on 638 acres at RioGrande Village would be a major, long-term impact. Thereason for the difference is that at Rio Grande Village thereare many more nonnative species in greater abundancebecause of the effects of years of irrigation.

40. Impacts on fragmentation have been added to impacts and

cumulative impacts. The National Park Service doubts thatthere would be an appreciable difference in the incidenceof roadkill in alternative B relative to alternative A.Development and levels of traffic would stay about thesame. In Alternative C, at Chisos Basin and Rio GrandeVillage, where most development would be removed, therecould be a reduction in traffic levels resulting in fewerroadkill in these localized areas. However, traffic levelscould remain the same there if reduced development simply attracted the same number of a different visitor type.

Big Bend gambusia and black capped vireo, the endangeredspecies that might be impacted by implementing proposalsin the general management plan, are not killed by automobiles. Therefore, impacts on threatened and endangeredspecies from road kill are not described. 

41. In its response to the draft document, the U.S. Fish and

Wildlife Service said,

"Eliminating the groundwater pumping of Big Bendgambusia habitat at Rio Grande Village may have beneficial impacts on this species. We understand that thepark is committed to developing groundwater wells thatwill use shallow aquifer water, eliminating the currentuse of the deep, geothermal source that feeds the habitat springs. Additionally, the removal of campsites nearthe habitat springs and restoration to natural conditionsmay further reduce potential impacts."

Response 41 continues on next page.
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Note that the U.S. Fish and Wildlife Service says the actions"may" have beneficial impacts. The Park Service believesthat the actions to eliminate groundwater pumping of habitat and remove campsites near the habitat pond are themore important actions in alternative C. The Park Servicedoes not think that removing the campground and otherfacilities will constitute a major impact as suggested bySierra Club. The U.S. Fish and Wildlife Service does notobject to the Park Service's characterization of the effect asmoderate, and using the NPS intensity definitions, moderate best represents the level of impact.

42. The comment is on a conclusion found in the "Comparison

of Impacts" table (3), which is based on the"Environmental Consequences" section of the document.The analyses of ethnographic resources in "EnvironmentalConsequences" section for alternative C provide the background and justification for this conclusion. 

43. See response 2b regarding exotic species.44. See page 47 in the draft document under the "Throughout

the Park" section.

The park's resource management plan will be one of the

implementation plans of the general management plan. Itwill describe in greater detail how wildlife populations willbe managed and research needed to obtain information tobetter manage wildlife in the park.

The intensity definition for a major impact on wildlife, page

134 in the draft document, is "Impacts on wildlife andhabitats would be obvious, long term, and would have substantial consequences on wildlife populations in theregion." The Park Service does not agree that alternative Cwould have a major impact.

45. See response 40.
COMMENTS ANDRESPONSES

46. The park staff will pursue the purchase of water rights, and

any other legal mechanism that will leave water in the river.It will also work cooperatively with other users to achieve

its goals. The National Park Service has a responsibility topreserve and protect the river.

47. Language to this effect has been added to "Wetlands"

under "Laws, Policies, and Mandates" (draft documentpage 21).

48. This is called for in the draft on page 28.49. These issues are day-to-day park management issues rather

than GMP issues and are covered by NPS managementpolicies. Bear/human interaction is not much of a problemat Big Bend because of the park staff's efforts to get aheadof the issue when the bears originally returned fromMexico. The park has had no serious encounters. 

Page 116 in the draft document explains what the ParkService has done and is doing about the "infrequent incidents between humans and large mammals."

50. Please see response 28. On page 47 of the draft, it is noted

that "The park has instituted a program of conservationand visitor education on the need to limit water use and therole of water in a desert environment."

51. The park does NOT propose to have hunting of mountain

lions within the park. To allow hunting, new legislationwould be required. The park's goal is to have mountainlions throughout the park, not eliminate them. The sentence on page 116 was deleted from the final plan.

52. The updated plan is described in the final document in the

"Introduction to the Alternatives" section.

53. The Park Service considered increasing the boundary of

the park and determined that such an action was not needed.

45.
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54. These are issues that law enforcement personnel at the

park are already dealing with.

At the end of each alternative is a section called "Estimated

Costs." The percentage increase in FTE (full-time equivalent) employees includes additional law enforcement personnel where the park has deemed them to be needed.

55. See response 3, water quantity.56. The required cumulative analysis is included in the draft.

Pages 131-32 has the cumulative impact scenario uponwhich the cumulative impacts for each subtopic are based(e.g., see pages 141-142 for cumulative impacts on soil foralternative A).

57. The Houston Sierra Club contends that impairment of

some resources is occurring, but it does not give its reasons.It does state that the National Park Service is ignoring theseissues and not addressing them in the draft. Regarding airquality, see response 2a; water quality, see response 2b;water quantity, see response 3; riparian areas, see response2b; and for wildlife resources see the pages listed in theindex under wildlife. 

In the professional judgment of the superintendent, BigBend National Park, no impacts of implementing the alternatives in the draft document would harm the integrity ofthe resources and values, including the opportunities thatotherwise would be present for the enjoyment of thoseresources or values. Therefore, there would be no impairment

The Houston Sierra Club does not state its reasons for

thinking that wildlife resources are being impaired. In apark of about 801,000 acres, with about 660,000 of thoseacres managed as wilderness, the National Park Servicedoes not think that there is any impairment of wildliferesources. Page 18 of the draft calls for a study to determine the impacton local aquifers "of Big Bend National Park, Big Bend 

Response 57 continues on next page.
COMMENTS ANDRESPONSES

Ranch State Park, Black Gap Wildlife Management Area,and gateway communities." This would help determineindirect impacts, if any, on wildlife from water quantitychanges.

The National Park Service manages 118 miles of the Rio

Grande on the park's southern boundary. The only "developed areas" along this stretch of river are Rio GrandeVillage and Cottonwood campground. These developmentsare not of a scale that causes impairment of wildliferesources. 

The National Park Service has added more of its past

actions and the past actions of others to the cumulativeimpact scenario.

58. See page 213 of the draft document for the cover letter

from the state. Note that it requests that we not print thelist itself. See pages 215-218 of the draft plan for the list thatwe compiled. In the draft plan, see page 12 for the reasonsthat some state species were dismissed from further consideration, and see page 19 for actions the National ParkService would take to meet legal and policy requirementsrelated to threatened, endangered, and other specialspecies. Some of this information was updated in the finaldocument because additional information was receivedfrom the state.

59. Standard dictionary definitions are adequate for understanding what is meant by these terms. Impacts in a general

management plan / environmental impact statement aregeneral and conceptual. These terms are meant to assist thereader in understanding the relative intensities of theimpacts.

60. The Park Service thinks that the impacts on water quantity

are accurately characterized by the intensity definitions. 
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61. See response 59.62. The statement referenced on page 141, column 1, paragraph 2, last sentence, of the draft document refers to

impacts of alternative A and not to cumulative impacts. Onpage 142, paragraph 2, cumulative impacts have been identified as major and adverse. Language on page 142, paragraph 2, has been revised to include impacts of livestocktrails in the cumulative analysis.

63. Traffic at Chisos Basin has not actually increased over the

last eight years. Chisos Basin used to be the site of a majorcommercial horse-riding concession that corralled 50-75horses. This was removed in the early 1990s, substantiallyreducing vehicular traffic in the area 

In addition, at Chisos Basin, there are six employee housingunits, two employee dorms, 72 lodging rooms, a 65-sitecampground, a restaurant, a small visitor center, and a smallstore. Vehicular traffic has increased as developmentincreased over time, but speeds are low and current rates ofroadkill are relatively small.Development in the park is relatively limited and concentrated in a few small areas. Habitat fragmentation is not amajor issue in this park of more than 800,000 acres.

64. The National Park Service describes cumulative impacts of

implementing alternative A on water quantity at RioGrande Village on page 144 in the draft document.

The impact analysis acknowledges adverse impacts associated with implementation of the plan alternatives.

However, in the professional judgment of the superintendent, Big Bend National Park, no impacts of implementingthe alternatives in the Draft General Management Plan /Environmental Impact Statement would result in impairment, i.e., harm the integrity of the resources and values,including the opportunities that otherwise would be present for the enjoyment of those resources or values. 
COMMENTS AND RESPONSES 

65. Regarding the comment that alternative A is not a true "no- action" alternative, see response 23. Quantification of cumulative impacts on water quantity is not possible for several reasons. First, data on current affects of local users on aquifers is lacking. Consequently, the National Park Service proposes to work cooperatively with local users to determine effects on local aquifers (see page 18 of the draft document). In addition, growth in

Brewster County has only amounted to a 16% increase inpopulation over the last 50 years. With a "straight line" projection, population growth over the next 20 years wouldresult in only a 6.4% increase in Brewster County. Withrespect to development, past activity is not a reliable indicator of future development levels. Efforts to increase water quantity in the river are alsodescribed in the draft document, page 18.

The National Park Service describes the cumulative impacts

of implementing alternative A on water quantity at RioGrande Village on page 144 in the draft document. TheNational Park Service stated that there would be no cumulative impacts on water quantity in Oak Spring because thespring originates in the Chisos Mountains within the park.The impact analysis acknowledges adverse impacts associated with implementation of plan alternatives. However, inthe professional judgment of the superintendent, Big BendNational Park, no impacts of implementing the alternativesin the Draft General Management Plan / EnvironmentalImpact Statement would result in impairment, i.e., harm theintegrity of the resources and values, including the opportunities that otherwise would be present for the enjoymentof those resources or values.

66. In the cumulative impacts on floodplains the National Park

Service has quantitatively described the impacts of cattleand sheep. The impacts of illegal cattle and sheep grazingare no different than the impacts of cattle and sheep grazing in general. Quantification of such cumulative impacts isneither necessary nor especially valuable given the basicpurpose and need for the general management plan. TheNPS contribution to cumulative impact under alternative Awould be minimal.
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67. The quotation in the Sierra Club letter is not in the stated

location in the draft plan. When the National Park Servicestates on page 147 of the draft plan that "The resources andvalues of Big Bend National Park would not be impaired"[emphasis added] as a result of implementing alternative A,it is referring to natural resources. This section is aboutimpacts on natural resources. Buildings that might be damaged or destroyed by flooding are not natural resourcesand therefore do not meet any of the three criteria forimpairment. In other words, natural resources would notbe impaired by having buildings destroyed.

68. See responses 1 and 2b. A clause has been added to the

cumulative impacts to make sure it is clear that NPS actionshave contributed to cumulative impacts on wetlands. Thedraft document acknowledges, under impacts of alternativeA, "Wetlands, cumulative impacts" that "The past impactsof agriculture, ranching, urbanization, and dam construction on wetlands covered wide areas and were major andadverse...Impacts on wetlands of current and anticipatedfuture actions outside the park, in conjunction with theimpacts of alternative A and restoration at NorthRosillos/Harte Ranch, would be moderate, long-term andadverse." 

In the view of the park superintendent, the damage to wetlands at Rio Grande Village (caused mostly by park visitorsand NPS irrigation) do not meet the criteria stated on pages132 and 133 in the draft plan for a determination of impairment. Degradation of resources does not necessarily meanimpairment. Impairment of resources depends upon theimpact intensity and its relationship to the three criteria forimpairment presented in NPS Management Policies 2001.

The wetlands that have already been lost are not impacts of

implementing the no-action alternative from plan approvalforward. The purpose of the impact analysis is mainly todescribe future impacts. The impacts of continuing currentmanagement of wetlands in the park would affect wetlandson one side of the river at Rio Grande Village andCottonwood Campground for less than 1 mile. Comparedto the 118 miles of river managed by the park a relatively

Response 68 continues on next page.
COMMENTS ANDRESPONSES

small portion of riparian area has been damaged by visitoruse, irrigation, and trespass livestock. Although the NationalPark Service wishes to improve the condition of all wetlands in the park, it does not agree that implementation ofalternative A would have a major impact on wetlands. 

The National Park Service agrees that wetlands require

maximum protection and mitigation.

69. Your statement has brought to the attention of the Park

Service an error in the draft document pages 147, 148 and154. The purpose of the impact analysis is mainly todescribe future impacts. The section on impacts of alternative A should describe the impacts of continuing management as at present with any foreseeable changes.Continuing current management of wetlands in the parkwould not use more water than is used at present.Therefore, using the definitions of intensity of impacts forwater quality found on page 134 in the draft document, theimpact on wetlands would be negligible rather than moderate as stated in the document or major as the HoustonSierra Club suggests.

70. It is appropriate for a general management plan to say what

needs to be done without specifying how it will be done(Director's Order 2).

The campsites to be relocated at Rio Grande Village are

close to the pond where Big Bend gambusia live. Thecampsites will be moved farther from that pond. This isstated in the draft document, for example on page 161.

The campsites to be relocated at Cottonwood

Campground are near the riverbank. The bank is caving insome places.
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71. It is appropriate for a general management plan to say what

needs to be done without specifying how it will be done,for example a trail's specific alignment (Director's Order 2).The general impacts are included under impact topics suchas soils and visitor understanding.

Page 156 of the draft document states that 0.5-1 acre wouldbe impacted by the Buttrill Springs trail.

72. See response 70. Pages 77 and 78 of the draft document list

mitigation and additional studies that will be done whenimplementing the general management plan.

73. Trail rehabilitation is ongoing and occurs all over the park

based on park assessment of need and availability of funding. According to NPS Director's Order 12, routine maintenance and repairs of trails do not require an environmentalassessment or impact statement. In fact, trail maintenancework is often undertaken to reduce impacts on soils such aserosion.

74. In the view of the superintendent of the park, the impacts

on soils described in the impact analysis do not meet thecriteria stated on page 132 and 133 of the draft documentfor a determination of impairment.

75. The act establishing the National Park Service calls for the

Park Service to manage for preservation and use ofresources. The use of Oak Spring is illustrative of the tradeoffs that the Park Service must make to comply with theact. At Chisos Basin, visitors to the park use the water fromOak Spring that would otherwise remain in associated wetlands or be used by wildlife. It is unfortunate that thespring does not produce enough water to provide for thedesired human and wildlife uses at Chisos Basin. The ParkService considered the alternative of removing almost alldevelopment from the basin but determined that alternative C (which proposes removing this development) wasnot the preferred alternative.

The Park Service is satisfied that the cumulative impact

analysis meets the requirements for this section.
COMMENTS ANDRESPONSES

76. The Park Service does quantify this water use and make it

available to the public in the draft document (page 144).The Park Service has acknowledged adverse impacts onvegetation and water quantity. 

The impact analysis acknowledges adverse impacts associated with implementation of the plan alternatives. However,

in the professional judgment of the superintendent, BigBend National Park, no impacts of implementing the alternatives in the Draft General Management Plan /Environmental Impact Statement would result in impairment, i.e., harm the integrity of the resources and values,including the opportunities that otherwise would be present for the enjoyment of those resources or values. 

77. Regarding impairment of floodplains, see response 66.

Regarding impairment in general see response 76, paragraph 3.

78. Less than 10% of park land would be in management prescriptions that would allow development in any alternative.

No additional development is proposed for alternative Bother than the actions that are discussed in the alternativewrite-up. In this conceptual general management plan, it isimportant to show areas of potential development to domeaningful analysis. The precise acreages and location ofdevelopment will be determined when the plan is implemented. However no more acreage will be developed thanis absolutely necessary to accomplish the actions specifiedin the approved alternative. Most of the developmentwould occur in areas that have already been disturbed.

79. Visitation statistics can be found in the draft document on

pages 114-116. Other than unusual periods of extendeddrought, the periods when the most water is used are frommid-October through the holidays (Thanksgiving to NewYears), and during the spring and early summer before theseasonal summer and early fall monsoon rains. The timeperiod varies year to year just like the weather. In 2003 thepark had 24.2 inches of rain in the Chisos Mountains.Therefore, this year, there was not any period where nearlyall of the water was used from Oak Spring. Parks are natural areas and nature is dynamic; it changes.
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80. See response 70.81. Alternative B calls for more funding and additional staff to

address the park's natural resource needs.

82. It is appropriate for a general management plan to say what

needs to be done without specifying how it will be done,for example mitigation of impacts on soils (Director'sOrder 2). The general impacts are included under impacttopics such as soils and visitor understanding. General mitigation for soils is listed on page 77 of the draft document.Specific mitigation needs will be determined by resourceprofessionals on a site-by-site basis during implementationof the approved plan.

83. The beneficial impact on vegetation at Chisos Basin and

Rio Grande Village was characterized as major in the draft.The Park Service thinks that the impacts on wildlife andwater quantity are accurately characterized by the intensitydefinitions. An additional impact on wildlife from withdrawal of irrigation water was added to the final document.This impact is characterized as moderate, meaning readilydetectable, long term, and localized, with consequences atthe population level. The impact on water quantity at OakSpring in alternative C was characterized as major in thedraft document. The impact on water quantity at RioGrande Village was characterized as moderate for reduction in irrigation and major for cessation of human use ofspring water. The Park Service, having no information thatshortage of water has been a factor in its decline, thinks it isdoubtful that decreased use of the water at Oak Spring forhuman use would impact the Black-capped vireo.Regarding the intensity level described for Big Bend gambusia, see response 41. There would be no impact on thefloodplain at Oak Spring. The beneficial impact on thefloodplain at Rio Grande Village is characterized in thedraft document as major. The document characterizes theimpacts on wetlands at Chisos Basin and Rio GrandeVillage as major.

The impact on vegetation at Rio Grande Village from withdrawal of irrigation water from about 638 acres of exotic 

Response 83 continues on next page.
COMMENTS ANDRESPONSES

vegetation in alternative C is characterized in the draft document as major.Irrigating less at Rio Grande Village will benefit native vegetation by reducing competition from exotic plants.

The impacts on wildlife in those areas are more accurately

characterized by the statement defining moderate — readily detectable, long term, and localized, with consequencesat the population level rather than the one defining major— obvious and long term and would having substantialconsequences on wildlife populations in the region.

84. See responses 1 and 3, water quantity.85. No additional development is proposed for alternative C

other than the actions are discussed in the alternativewrite-up. In this conceptual general management plan, it isimportant to show areas of potential development to domeaningful analysis. The precise acreages and location ofdevelopment will be determined when the approved plan isimplemented. However no more acreage would be developed than is absolutely necessary to accomplish the actionsspecified in the alternative. Most of the development willoccur in areas that contain previously disturbed soils.

86. Despite the fact that alternatives B and C contain a number

of different factors, it appears that visitor figures wouldremain about the same. The key is that each alternativewould likely attract a different type of visitor.

87. Please note that, in alternative C, both visitor contact stations at Rio Grande Village and Chisos Basin, and the two

amphitheaters at those locations, would be removed. Thatwould directly reduce visitor opportunities to understandthe park's significance by severely reducing the number ofinterpretive programs available to visitors as well as theopportunity to ask questions of trained professional interpreters. The NPS position is better understood when thisstatement is placed in the context of the full sentence,which reads as follows: "Alternative C reduces the numberand types of visitor activities and in so doing reduces 

Response 87 continues on next page.
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opportunities to understand the park's significance." Alsothis alternative would reduce the opportunity for somepeople to enjoy an overnight experience in the park.Visitation could well remain the same for each alternative,but alternative C might result in lessening the time thatsome visitors would spend in the park.

88. NPS policy and legal mandates require that any cultural

resource that is listed on the National Register of HistoricPlaces or considered eligible for listing on the NationalRegister of Historic Places be provided equal treatmentand consideration for Section 106 of the National HistoricPreservation Act and planning purposes. Thus Mission 66structures and landscapes must be given equal consideration along other eligible archeological features, structures,and cultural landscapes.

89. In alternative C, structures to house park maintenance,

interpretive, and resource protection equipment and supplies would be removed from Rio Grande Village andChisos Basin. This would require the park to house thisequipment and material at some distance from where itwould be used. The effect of this would be slightly offset bythe fact that alternative C would require less maintenanceof park infrastructure. Still it would make park operationsless efficient.

90. The goals of experiencing solitude, experiencing the natural

world, experiencing the richness of biological diversity, andseeing plants and animals in their natural setting seem totake in the same ideas as suggested. 
COMMENTS AND RESPONSES Response to Betty Alex Letter Maps: Concern about information and nomenclature found on some maps in the draft document. Response: Comments on the maps have been considered and maps have been corrected where appropriate. As explained in the document, the maps are for illus- tration purposes only and are not drawn perfectly

to scale; the maps are not meant to be more thanconceptual.
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COMMENTS AND RESPONSES
Individuals

Responses to Thomas Alex LetterMaps: Concern about information and nomenclature foundon some maps in the draft document. Response: Comments on the maps have been considered, and

maps have been corrected where appropriate. Asexplained in the document, the maps are for illustration purposes only and are not drawn perfectlyto scale; the maps are not meant to be more thanconceptual.
COMMENTS ANDRESPONSES

Interpretive Themes: Concern over lack of recognition of therole of the Spanish in the park area.Response: A correction has been made in the text. Alternatives: There was concern about the lack of stewardshipfor cultural resources in the alternatives.Response: By law, regulations, and policy, the National Park

Service is required to provide stewardship for thepark's cultural resources. These cultural resourcemanagement requirements are spelled out in the"Cultural Resource Management Requirements"for archeological resources, ethnographicresources, historic buildings/structures, and collections section of the document (see pages 28-31 inthe draft document). These stewardship requirements would be the same in all alternatives.Measures beyond the basic stewardship requirements are shown in the discussion of the alternatives.
International and Federal Agencies

Big Bend Management Prescriptions: There was concern

that as inventories are completed, new sites and structures thatare significant cultural resources might be identified outside thecultural prescription that has already been defined.Response: Newly identified sites and structures that are significant cultural resources would be treated following

NPS policies and procedures for such resources.NPS requirements for the preservation, treatment,and protection of cultural resources can be accommodated within any management prescription.

Cultural Prescription: There was concern that this management prescription does not recognize the important of archeological and ethnographic resources in Big Bend National Park.Response: The cultural resource prescription has been modified to accommodate this concern. See the description of management prescriptions. Also the suggestion for conducting a parkwide cultural sites inventory has been incorporated into the section on

"Mitigation and Additional Studies."
COMMENTS AND RESPONSES Affected Environment, Cultural Resources, Archeological Resources: There was concern that some of the text was inac- curate. Response: Text has been corrected. Affected Environment, Cultural Resources, Historic Structures: There was concern about the preservation and maintenance of historic structures.

Response: The text has been corrected to better describe the

preservation and maintenance of the park's historicstructures.
271 

AGENCIES AND ORGANIZATIONS TO WHICH THIS 

DOCUMENT WAS SENT 

Note: An * indicates that that agency or 

organization commented on the draft plan. 

International Agencies 

International Boundary and Water Commission, 

United Sates and Mexico* 

Federal Agencies 

Federal Emergency Management Agency 

U.S. Army Corps of Engineers 

U.S. Department of Agriculture 

 Natural Resources Conservation Service 

 U.S. Forest Service 

U.S. Department of the Interior 

 Advisory Council on Historic Preservation 

National Park Service 

 Amistad National Recreation Area 

 Guadalupe National Park 

 Organ Pipe Cactus National Park 

 Rivers and Trails Program 

 U.S. Fish and Wildlife Service* 

 Ecological Field Office 

U.S. Geological Survey 

U.S. Environmental Protection Agency* 

Mexican State Agencies 

Patricio Martinez 

Palacio de Gobierno 

Chihuahua, Chihuahua 25000 

Mexico 

Rogelio Montemayor 

Palacio de Gobierno 

Saltillo, Coahuila 25000 

Mexico 

Mexican Protected Areas 

Maderas del Carmen 

Julio Carrera 

Apdo. Postal 486 

Saltillo, Coahuila 2500 

Mexico 

CaZon de Santa Elena 

Pablo Dominquez 

Col. San Felipe 

Chihuahua, Chihuahua 31240 

Mexico 

U.S. Senators and Representatives 

Office of Senator John Cornyn 

Office of Senator Kay Bailey Hutchison 

U.S. Representative Henry Bonilla 

U.S. Representative Gene Green 

U.S. Representative Silvestre Reyes 

State Agencies 

Texas Commission on Environmental Quality 

Texas Parks and Wildlife 

 Big Bend Ranch State Park 

 Black Gap Wildlife Management Area 

 Davis Mountains State Park 

 Endangered Species Branch* 

 Wildlife Habitat Assessment Program* 

Texas Historical Commission (state historic 

preservation office)* 

State Officials 

Texas Governor Rick Perry 

Texas State Representative Pete Gallego 

Texas State Senator Frank Madla 

American Indian Tribes with Potential 

Cultural Affiliation to the Park 

Fort Sill Apache Tribe of Oklahoma 

Mescalero Apache Tribe 

Apache Tribe of Oklahoma 

Blackfeet Tribe 

Caddo Indian Tribe of Oklahoma 

Cheyenne-Arapaho Tribes of Oklahoma 

Jicarilla Apache Tribe 

Kiowa Indian Tribe of Oklahoma 

Comanche Indian Tribe of Oklahoma 

Kickapoo Traditional Tribe of Texas 
CONSULTATION AND COORDINATION WITH OTHERS

272 

Local, City, and County Governments 

Alpine, Texas, local government* 

Amarillo, Texas, local government 

Brewster County 

 Commission* 

 Judge, Val Beard 

 Historical Commission* 

Brownsville, Texas, local government 

Fort Stockton, Texas, local government* 

Pecos County Historical Commission* 

San Vicente School District 

Terrell County Commission 

 Judge Dudley Harrison 

Organizations and Businesses 

Abilene Reporter-News 

Alpine Commerce 

Alpine Observer 

American Whitewater Association 

Andy White Ranches 

Associated Press 

Audubon Texas 

Austin American-Statesman 

Balmorhea Commerce 

Barton Warnock Center 

Big Bend Motor Inn/Mission Lodge 

Big Bend Natural History Association 

Big Bend Resorts* 

Big Bend River Tours 

Big Spring Commerce 

Big Spring Herald 

Borderline 

Brewster County Tourism Council* 

Brownsville 

Brownwood Bulletin 

Bullis Gap Ranch and Paradise Valley Ranch 

Center for Environmental Resource 

Management 

Chevron USA 

Chisos Mountain Lodge 

Continental Divide Trail Society 

Conservationists’ Wild River Committee 

Crane Chamber of Commerce 

Dallas Morning News 

Davis Mountains Trans Pecos Heritage 

Association 

Del Rio Commerce 

Del Rio News Herald 

Desert Sports 

Eagle Pass News-Guide 

El Paso Times 

Far Flung Adventures 

Forever Resorts, LCC 

Fort Davis Chamber of Commerce 

Fort Stockton Commerce 

Fort Stockton Pioneer 

Fort Worth Newsletter 

Fort Worth Star Telegram 

Galveston Daily News 

Geofactors* 

Houston Chronicle 

Indian Creek Landowners Association 

Isleta del Sur Pueblo 

Jeff Davis County Mountain Dispatch 

Judge Roy Bean Center 

Kent State University 

KFST Radio 

KLKE and KDLK Radio 

KMID-TV Channel 2 

KVLF Radio 

KOSA-TV 

KVLF Radio 

KWES-News West 9 

KWES-TV 

KWMC Radio 

Lajitas Resort* 

Lajitas Trading Post 

Laredo Morning Times 

Lubbock Avalanche-Journal 

Marathon Commerce 

Marathon Museum Society* 

Marfa Chamber of Commerce 

Midland Commerce 

Midland Reporter-Telegram 

Mission Chamber of Commerce 

National Parks and Conservation Association* 

National Park Concessions, Inc. 

Northern Arizona University 

Northwestern University 

Odessa American 

Odessa Convention & Visitors Bureau 

Paradise Valley 

Pecos Commerce 

Pecos Enterprise 

Pitcock Ranch 

Presidio Commerce 

Randolph Company 

Rio Grande Adventures 

Rio Grande Sun 

Riskind Natural Resources 

Rhodes Welding 
Agencies and Organizations to Which This Document Was Sent 

273 

San Angelo Commerce 

San Angelo Standard-Times 

San Antonio Express-News 

Sanderson Commerce 

San Marcos Record 

Sanderson River Ranch 

Santa Fe New Mexican 

Sierra Club 

 Coastal Bend* 

Houston Club* 

 Lone Star Chapter* 

Standard/Radio Post 

Study Butte Store 

Sul Ross University 

Terlingua Moon 

Terlingua Ranch Lodge 

Terrell County News Leader 

Terrell Visitor 

Texas Audubon Society 

Texas Explorers Club 

Texas Mountains Regional Tourism Council* 

Texas River Adventures 

Texas Rivers Protection Association 

Texas Tech University 

The Alpine Avalanche 

The Battalion 

The Big Bend Sentinel 

The Conservation Fund 

The Conservationists’ Wilderness and Wild 

River Committee 

The Crane News 

The Desert Candle Newspaper 

The Gage Hotel 

The International Presidio 

The Lajitas Sun 

The Sweetwater Reporter 

The Van Horn Advocate 

University of Northern Colorado 

University of Texas-El Paso 

Uvalde Commerce 

Valley Star 

Voyageur Outward Bound 

Waco Tribune-Herald 

World Wildlife Fund