snowmobile community responds to epa ecosystem protection comments regarding yellowstonegrand teton seis
Amsnow
The snowmobile community expressed surprise at the comments recently presented by the US-EPA Ecosystem Protection Group. At first glance, the EPA document would appear to suggest that the Agency supports closing the park to snowmobile use. However, when one reviews the EPA analysis, it becomes clear that the EPA could support continued snowmobile use within the parks under a modified version of Alternative 2, if it were fully implemented. Full implementation of a modified version of Alternative 2 would require the prompt supply of new technology snowmobiles to park rental fleets and active management of snowmobile use. The snowmobile community supports such an approach. The Agency's statement that emission standards authority for any vehicle entering into the park is to be established by the EPA, per Congressional mandate, is equally supported by snowmobilers.
The EPA expressed concern in their comments that snowmobile rental outfitters may not have adequate notice to purchase appropriate technologies for use to comply with a Park Service Concessionaire Requirement. We agree that the timetable put forward by the Park may be overly aggressive and the timetable may need to be revisited. Snowmobilers always support adaptive management of the Park.
The snowmobile community supports a careful study of the SEIS and recognizes the importance of preserving mixed-use recreation in our national parks. We too realize that Alternative 2 may not be perfect and we share the EPA's concern about having the right kind of policies in place to ensure that snowmobile use is adequately regulated and managed. Park management may be required to consider an appropriate phase in schedule, proper limits and use management, which have been supported by the Yellowstone Cooperators.
The SEIS based its projections on models predicting 166,000 snowmobiles entering the park when the average for the past several years has been closer to 65,000, therefore projections related to air quality impact are overstated. It is possible that among the modifications to which the EPA referred in its comments would be a change in the number of snowmobiles allowed into the park.
The EPA office for Ecosystems Protection and Remediation does not have a full grasp of the snowmobile market make up and distribution. The analysis presented in their comments on snowcoaches is not supported by the extensive work performed for the state of Wyoming, and their discussion of the severe economic impact that a ban would have on the economies of the region is ill informed. We believe that market analysis should be conducted by an agency trained in economics, not in Ecosystems review.
The position of the Ecosystems Group supporting no personal vehicular access to National Parks should not be favored over a properly managed use that would allow citizens to enjoy the great parks that were established for their enjoyment.
The snowmobile community looks forward to interacting with all of the cooperators of the Yellowstone's SEIS. We are convinced that an active, progressive management style, considering all issues, will allow snowmobiling to continue in Yellowstone in a reasonable, limited fashion.