Below is the comment letter I sent for SAWS regarding Yellowstone this year. It has plenty of facts regarding wildlife and links as evidence for many of them. Quote her a few of these - that should burn her briches.
Thankfully Judge Brimmer got the number of snowmobiles allowed in the park back up to 720 for this winter after I submitted this comment letter.
Below is my YNP comment letter that you requested a copy of on Snowest through email.
2008 Winter Use Plans Environmental Assessment Comment
Neither of the two proposed alternatives are acceptable to the Snowmobile Alliance of Western States (SAWS) for snowmobile access to Yellowstone National Park (YNP) past the 2008-2009 winter season. However, due to time constraints this year, we reluctantly support Alternative 2 as an emergency measure for the 2008-2009 season only. For future winter seasons we support the National Park Service (NPS) preferred Alternative 4 (1,025 snowmobiles allowed per day) from the 2007 Winter Use Plans Draft Environmental Impact Statement (DEIS). We would like to commend YNP personnel for scrambling at the last minute to put forth some sort of plan to allow snowmobiles in the park this season after “the U.S. District Court for the District of Columbia vacated and remanded to the NPS the 2007 Final Environmental Impact Statement, 2007 Record of Decision, and 2007 Final Rule” on September 15, 2008. We are still left with serious concerns regarding the number of sleds allowed per day in this plan as we have been with most all of the previous plans.
No where could we find in Judge Emmet G. Sullivan’s ruling that he instructed the NPS to go back and reduce the number of sleds from 540 to some lower magical number - 318 in this particular plan for this year - to somehow satisfy his opinion or the opinion of the plaintiffs (Greater Yellowstone Coalition and National Parks Conservation Association). Judge Sullivan did want the NPS to provide valid data as to why 540 sleds were not harmful to the park. It seems with all of the facts and data available regarding snowmobile use and the lack of negative affects they cause to the park’s environment/wildlife, that this should be a fairly easy task. In fact, we believe the NPS should be able to equally prove that 1,025 snowmobiles a day have less of a negative effect on the park’s environment/wildlife than does wheeled traffic throughout the year, especially during the heavy use warmer months.
Please provide us with the date the last summer use Environmental Impact Statement (EIS) was performed, and we would also like a copy of the EIS and Environmental Assessment (EA) on a CD mailed to the contact address provided in this comment letter. We searched the various NPS websites that contain numerous EIS and EA documents, and we could not find one for summer use (
http://www.nps.gov/yell/parkmgmt/planning.htm). It is quite obvious to us that the effect on the environment and wildlife is much greater in the non-winter non-snowmobile use months (April – October) when 960,737 Automobiles, 49,115 Recreational Vehicles, and 5,871 Buses entered the park (2008). This compared to winter use months (December – March) when 18,290 Automobiles, 49 Recreational Vehicles, 109 Buses, 23,814 Snowmobiles and 2,653 Snowcoaches entered the park (2008).
http://www.nature.nps.gov/stats/park.cfm
If emissions are the concern you should be aware that the snowmobile industry has done their part in reducing emissions from snowmobiles. When will the snowcoach industry do the same? "Modern snowmobile HC emissions are down by a factor of >12/vehicle and CO emissions by a factor of >2. The measured snowcoaches emit significantly more per mile than the snowmobiles. Measured snowcoach emissions of CO, even when calculated per passenger mile, now exceed modern snowmobile emissions".
http://pubs.acs.org/subscribe/journa...re_bishop.html
Snowmobiles do not put unreasonable stress on wildlife. Numerous studies have shown that wildlife are more stressed and “fear flight” far more often by the sudden unannounced presence of approaching humans on foot (cross-country ski/snow-shoe recreationists) than they do by the well observed appearance of snowmobilers. Snowmobilers can be heard by ungulates at a greater distance than non-motorized users can be heard, which in turn gives wildlife ample opportunities to calmly move off trails into nearby denser vegetation, thus avoiding last minute “fear flight” as when startled by the sudden unannounced presence of non-motorized users which are perceived by ungulates as predators.
One such recent study found that “ski trails seem to displace mule deer to greater distances than occurs along snowmobile routes” (Recreation Effects on Wildlife [2002] - Bill Gaines, Forest Service Wildlife Biologist, Wenatchee National Forest). Another study states “snowmobiles appear less distressing than cross-country skiers, and for several ungulate species, the greatest negative responses were measured for unpredictable or erratic occurrences”. This study also states “Greater flight distances occur in response to skiers or individuals on foot than to snowmobiles, suggesting that the most detrimental disturbances to the wintering animal is that which is unanticipated.” (Effects of recreation on Rocky Mountain Wildlife [1999] – Ungulates). “Harassment and displacement of wildlife, even if inadvertent, probably occurs more often than we know. Boating, camping, hiking, fishing, and other popular activities, including simply driving along the park’s roads, cause wildlife to modify their behavior and use of habitats. Only by careful monitoring of animal populations can we infer when human activities are causing too much stress to individual animals or to the health of their local populations. Outside the park, continued population growth and land development cause competition between humans and animals for living space.” (NPS
http://www.nps.gov/yell/parkmgmt/upload/preserving.pdf)
Wildlife is also seriously impacted by wolves. This is a fact according to several sources, including 2008 NPS documents and recent NPS biologists comments which include; “1995-96 - “31 wolves from Canada relocated to Yellowstone…as of January 2008, 443 wolves live in 51 packs in the greater Yellowstone area. 171 wolves live in Yellowstone National Park…some people are now concerned because elk counts have declined approximately 50% since 1994”. (Reference: Park Issues -
http://www.nps.gov/yell/planyourvisit/resourceandissues.htm). “Park wide we estimate 2200-2700 ungulates (mostly elk, but also including moose, deer, bighorn sheep, pronghorn antelope, and bison) are killed by wolves per year. This is out of an estimated 30,000-35,000 elk that use YNP sometime during the year.” (2006 - Comment by Michael J. Yochim, Ph.D. National Park Service).
Summer vehicle traffic in the park is also much more of a fatal threat to wildlife than snowmobile traffic. “During 1998, 88 large mammals are known to have been fatally struck by vehicles in the park; the annual average from 1989 to 1997 was 113. This tally does not include animals that may have been hit and died from their injuries later away from the road. Because of their large number, elk are the most frequent road fatalities, followed by mule deer.”
http://www.nps.gov/yell/parkmgmt/upload/preserving.pdf
“Prior to the beginning of mandatory commercial guiding for all snowmobilers, we lost 1 or 2 animals due to snowmobiles per year. Since 2003, when guiding was instituted, there have been no wildlife fatalities.” (2006 - Comments by Michael J. Yochim, Ph.D. National Park Service)
The public deserves a plan that is based on science; not politics and emotion. SAWS would hope that the NPS agrees and will go back to put together a bullet proof (non-court overturning plan - based on such science showing that although ALL forms of non-motorized human and motorized vehicle interaction with wildlife will cause some level of disturbance, but that snowmobile use is one of the least of such disturbances.
Sincerely,
Dave Hurwitz
Chairman, Snowmobile Alliance of Western States
