Chapter 2 ~ Purpose and Need (cont.)

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Section 2.5 ~ Implementation

The implementation of projects proposed under the Draft Yosemite Valley Plan is a concern for many respondents. Including specific Yosemite Valley Plan implementation timelines is "the single most significant issue to our organizations," according to a letter authored by a conservation group coalition. A binding timetable would guide future planners, this respondent continues. "Unless the Park Service and the public seize this opportunity to lock-in the size and direction of future development, this plan will likely end up on a shelf next to the GMP, a visionary document defeated by the inertia and shifting priorities of new administrations," the organization concludes.

Similarly, the California Department of Justice would like to see a comprehensive implementation program included in the Final Yosemite Valley Plan/SEIS. "A detailed, comprehensive implementation program is the key to ensuring that the Yosemite Valley Plan actually accomplish its goals and directives," the Department indicates.

The Department of Justice not only asserts that the Yosemite Valley Plan should explicitly link implementation activities to the goals of the plan but also believes the National Park Service should prioritize implementation activities based on its ability to accomplish these goals. The Final Yosemite Valley Plan/SEIS should also clearly specify when additional environmental review will be required for the implementation of specific projects, the Department submits.

Addressing a similar topic, a U.S. Representative believes the National Park Service should clarify which aspects of the Plan warrant further review and public input. "You have assured me that many of the elements of the plan which have engendered public controversy will continue to be subject to public review through several more steps in the planning process," the representative writes. "Which elements of the plan fit into this category versus elements that you intend to implement as a result of the adoption of the Valley plan?"

A conservation organization makes a similar request. The group wishes to know which decisions can be implemented without further review or analysis and which will require additional review. The organization asserts that answering this question "will allow the agency to analyze the cumulative impacts of development at maximum limits." In addition, this group believes that the National Park Service should implement the restoration, visitor facilities, and transportation aspects of the Yosemite Valley Plan simultaneously. The organization writes, "It makes the most sense for the National Park Service to proceed along all three lines concurrently, rather than making one group of stakeholders wait through years of employee housing projects before major transportation improvements are implemented."

Several respondents request clarification on how the Yosemite Valley Plan restoration projects are prioritized. According to one person, "The draft YVP offers no explanation of why the restoration of the Church Bowl Picnic Area and the removal of the old sewer plant (which has not been a priority in the twenty years since the GMP first proposed it), for example, now take precedence over the restoration of Upper and Lower River Campgrounds, the Stoneman and South Ahwahnee Meadows, and the North Pines campground."

In addition to prioritizing restoration projects, some respondents believe the National Park Service should complete an aggressive inventory and monitoring program prior to a Yosemite Valley Plan decision. Such a program "needs to be in place first to provide information critical to the planning process–not within five years after a Record of Decision. Under the direction of practicing scientists, volunteers could certainly assist in gathering data," according to the Madera County Board of Supervisors.

Many of the aforementioned suggestions for improvement are contained in the Grand Canyon National Park General Management Plan, according to one conservation organization. "The Grand Canyon GMP breaks all items into one of two phases, and proposes completing actions concurrently across the categories of transportation, visitor services, employee housing, and management support (which includes relocation and restoration of administrative facilities)," this group offers. "For each action item, the phasing schedule includes a cost estimate, anticipated funding source, estimated completion date, explanation of the action sequence, and an indication of whether additional NEPA compliance will be required." This group proposes that the National Park Service use the implementation strategy of the Grand Canyon National Park General Management Plan as a model for Yosemite Valley Plan implementation.

Finally, the Mariposa County Board of Supervisors posits that the National Park Service decrease the level of manager discretion allowed under the Yosemite Valley Plan. The Supervisors’ request that the alternatives be revised to limit discretionary activities "which may occur in the future but which are not sufficiently delineated at the present time for the public to adequately comment on."

Note: One response is provided for Public Concerns #116 and #292 and placed following Concern #292.

116. Public Concern: The Yosemite Valley Plan should contain specific implementation time lines.

"When the Park Service produces its final ‘Record of Decision’ on the Valley Plan, it should include a detailed description of how and when the various elements of the plan will be implemented. Neither Yosemite nor the public can afford to have yet another plan that sits on the shelf." (Individual, Yountville, CA - #492)

"We can not fully embrace the current draft unless and until it contains a detailed timetable controlling the implementation and funding of future Park decisions. This timetable will become the document by which the public, the department of the Interior, and Congress will hold the Park Service accountable for the completion of this plan. This is the single most significant issue to our organizations–neither Yosemite nor the public can afford to have another good plan sit on the shelf. This timetable must bind future planners, rangers, and superintendents, who will be required to implement the bulk of the YVP years and decades after the issuance of the ROD. We commend the current Park administration and staff for their willingness to utilize the planning process to engage the public in a serious and open debate about the future of Yosemite. But it is unrealistic to believe that these groups of Park staff will stay the fifteen or twenty years necessary to implement this plan in full, and naive to think that future employees will necessarily share our common vision. Unless the Park Service and the public seize this opportunity to lock-in the size and direction of future development, this plan will likely end up on a shelf next to the GMP, a visionary document defeated by the inertia and shifting priorities of new administrations." (Conservation Organization, San Francisco, CA - #4594)

292. Public Concern: The Yosemite Valley Plan should include a comprehensive implementation program.

ﾒThe Yosemite Valley Plan should include a more comprehensive implementation program. A detailed, comprehensive implementation program is the key to ensuring that the Yosemite Valley Plan actually accomplish its goals and directives. Although we recognize and understand that the Plan is a programmatic document, it does not include a sufficiently detailed discussion of how and when the various actions adopted to meet the goals will be implemented. While Appendix M describes a ‘conceptual three phase approach’ to implementation of specific projects, it is sorely lacking in detail. YVP Vol. 1I at II-73. There is no discussion of the basis upon which the various projects were divided into the three phases, no timelines to explain what actions will be implemented when, and no explanation of how the NPS proposes to obtain the necessary funds for implementation." (California Department of Justice, Sacramento, CA - #5430)

Response: Due to public comment, Vol. II, Appendix M has been modified in the Final Yosemite Valley Plan/SEIS to include detailed project sequencing. In the Draft Yosemite Valley Plan/SEIS Appendix M-Phasing was used as the starting point to develop the final sequencing for nine target project groups. These groups are made up of over 250 independent actions of the Preferred Alternative which are now linked in a logical sequence that relate to physical and operational connections. These linkages determine the order in which implementation will occur. For example, with a clear sequence of action determined it is now possible to see that in order to get the new visitor/transit facility on-line in Yosemite Valley, it is necessary to provide a location to maintain and store the shuttle fleet at the current National Park Service maintenance area (Fort Yosemite). In order to complete this action, among other things, it is necessary to relocate National Park Service operations and stable functions from that area. Before these functions can be relocated, replacement functions need to be built outside the Valley. Before refining the phasing plan to the project sequence level, it was not readily apparent that building these replacement facilities was a necessary action to the completion of a full-functioning visitor/transit center. See Appendix M, Sequencing Plan, for more project sequencing information. (This response also applies to the previous Public Concern #116.)
(Also see responses to Concerns #293 and #294.)

293. Public Concern: The Yosemite Valley Plan should explicitly link implementation activities to the goals of the plan.

"The Plan fails to link the implementation activities to the goals of the Plan, thus there is no guarantee that the limited resources available for implementation will be spent in a manner to ensure that the most important projects are commenced first." (California Department of Justice, Sacramento, CA - #5430)

Response: In the Final Yosemite Valley Plan/SEIS, actions called for in the Preferred Alternative intend to accomplish the goals and criteria established in Vol. IA, Chapter 1, Purpose and Need, of the Final Yosemite Valley Plan/SEIS. Sometimes when projects are viewed independently, they may or may not seem to directly accomplish the plan’s goals, but often these independent actions are interim steps to implement major projects that do in fact encompass the goals. For example, in order to meet the criteria to "make high-quality interpretive and educational facilities and services available for all Valley visitors," it becomes important to update and modernize the existing level of interpretive services currently being provided in the Valley. Many of the independent actions begin to meet these particular criteria. However, another action, such as relocating park operational functions out of the Valley District Building seems unrelated to enhancing interpretation and education until the major project that follows this action is completed. Conversion of the Valley District Building to a museum for park visitors would directly meet the criteria and the goal of both the Yosemite Valley Plan and the park’s General Management Plan to "Promote visitor understanding and enjoyment." Also see Vol. II, Appendix M, Sequencing Plan, for more details on project sequencing.
(Also see responses to Concerns #292 and #294.)

294. Public Concern: The Yosemite Valley Plan should prioritize implementation activities based on their ability to accomplish the goals of the Plan.

"Appendix M should be significantly revised to prioritize implementation activities based on how successful they will be at accomplishing the goals of the Plan to reclaim priceless natural beauty, to allow natural process to prevail and to markedly reduce traffic congestion." (California Department of Justice, Sacramento, CA - #5430)

Response: The Final Yosemite Valley Plan/SEIS contains action items in the Preferred Alternative which are linked either physically or functionally to meet the goals and criteria established in the plan. The priority and order for the implementation of projects would be based on physical and operational sequencing, funding, and additional regulatory compliance if necessary. All proposed actions help to achieve the goals and criteria established in Vol. IA, Chapter 1, Purpose and Need, of the Final Yosemite Valley Plan/SEIS.
(Also see responses to Concerns #292 and #293.)

290. Public Concern: The Yosemite Valley Plan should clarify when additional environmental review will be required for implementation of specific projects.

"The Yosemite Valley Plan should more clearly specify when additional environmental review will be required for implementation of specific projects. The Draft Yosemite Valley Plan contemplates that a number of site-specific construction projects will be undertaken in the Valley, including the construction of new lodging units, visitor center facilities, facilities to service transit and shuttle bus operations, and rerouting of roads. Because It addresses land use allocation for the entire Valley, the Plan is necessarily general in its level of analysis of the myriad projects evaluated. Some of these site-specific projects, however, while they may be ultimately beneficial to the environment of the Valley as a whole, may result in substantial localized impacts which need to be evaluated and mitigated. Under NEPA, site-specific implementation of projects called for in the Plan may require more detailed analysis, specific to the particular resources affected. Other than providing a few examples for which further review ‘may’ be required however, the draft Plan, however, does not specify when and under what circumstances further site-specific analysis will actually occur. YVP Executive Summary (‘ES’) at I-10; see also YVP ES at 2-23, YVP Vol. IA at I-14. Accordingly, it is difficult to determine whether the Plan will ultimately result in adequate analysis to enable the public and decision-makers to understand and fully evaluate the environmental consequences of the proposed actions. The Plan could be greatly improved by clearly identifying the actions for which the NPS will conduct additional specific analysis, and distinguishing them from the actions for which the NPS believes the more general level of analysis included in the Yosemite Valley Plan is adequate." (California Department of Justice, Sacramento, CA - #5430)

Response: Some of the action alternatives in the Final Yosemite Valley Plan/SEIS are more fully developed than others with design level details for specific elements. Some projects are not as fully developed and would require additional planning and environmental analysis prior to implementation. The appropriate level of compliance and studies would be determined and accomplished on a project-by-project basis. Vol. II, Appendix M, Sequencing Plan, provides a general time line for project implementation and additional details regarding the need for future environmental compliance.

365. Public Concern: The Yosemite Valley Plan should clarify which aspects of the plan warrant further review and public input.

"A document that shows which elements of the plan may be implemented with the adoption of the Valley Plan, and which take further public review and comment would be helpful. You have assured me that many of the elements of the plan which have engendered public controversy will continue to be subject to public review through several more steps in the planning process. Which elements of the plan fit into this category versus elements that you intend to implement as a result of the adoption of the valley plan?" (U.S. Representative, Fresno, CA - #2951)

Response: At this time it is difficult to determine which projects will require further environmental compliance and associated public review. The next step in the planning process–the development of specific site design–would determine the need for and level of additional planning compliance and environmental review. Currently, it is anticipated that most regulatory compliance for actions taking place in Yosemite Valley are complete, unless:

• The proposed actions extend beyond the land areas identified and analyzed in the Final Yosemite Valley Plan/SEIS
• The proposed actions involve a substantive change in location, function and capacity from that discussed in the Final Yosemite Valley Plan/SEIS
• Previously unknown resources are discovered, such as an archeological site or a threatened or endangered plant or animal species

The National Park Service is committed to continued public involvement as the Yosemite Valley Plan is implemented. Site designs will be made available to the public in order to come up with the best design solutions possible. See Vol. II, Appendix M, Sequencing Plan, for more information.

(Also see response to Concern #290.)

469. Public Concern: The Yosemite Valley Plan should identify decisions that can be implemented without further review or analysis.

"The Park Service must identify the decisions that can be implemented without further review or analysis pursuant to the National Environmental Policy Act of 1969 (NEPA) and those which will require additional review, such as new construction at Yosemite Lodge. This approach will allow the agency to analyze the cumulative impacts of development at maximum limits. If this approach is not adopted, and the Park Service instead views the YVP as committing it to full build-out of development projections, the adequacy of the EIS becomes less certain. Specifically, every action alternative proposes at least 141 new rooms at Yosemite Lodge, which may contradict Judge Breyer’s holding that the Park Service must rigorously explore alternatives created by the 1997 flood, including building fewer Lodge units, siting lodging elsewhere in the Park, and abstaining from building replacement facilities at all." (Conservation Organization, San Francisco, CA - #4594)

Response: There are numerous actions identified in the Preferred Alternative of the Final Yosemite Valley Plan/SEIS, some of which may require further National Environmental Policy Act review and analysis. The construction of the new visitor/transit center is a good example of a complex project with multiple project links that may require additional regulatory compliance. Until a site-specific design plan is prepared for the Yosemite Village area, it is difficult to determine if additional National Environmental Policy Act compliance is necessary. Regardless of the need for additional National Environmental Policy Act compliance, as site designs are prepared, the design alternatives would be made available to the public.

Also see Vol. II, Appendix M, Sequencing, for additional information.
(Also see response to Concern #365.)

502. Public Concern: The National Park Service should implement the restoration, visitor facilities, and transportation aspects of the Yosemite Valley Plan simultaneously.

"Our organizations therefore strongly believe that the timetable must go forward with simultaneous projects relating to restoration, visitor facilities, and transportation. These three dilemmas drove the draft plan, and they are the three issues the public cares most about. It makes the most sense for the Park service to proceed along all three lines concurrently, rather than making one group of stakeholders wait through years of employee housing projects before major transportation improvements are implemented. Thus, for example, in year one after the ROD is signed, we believe that the NPS should: begin giving people who park at satellite lots a financial incentive for taking the bus to the Valley; move forward with building new campsites at Tenaya Creek, Upper Pines, South Camp, or Camp 4; begin planning for a new Visitor’s Center and consolidated bus and car parking at Yosemite Village." (Conservation Organization, San Francisco, CA - #4594)

Response: The Yosemite Valley Plan would be implemented with a variety of concurrent actions (i.e., restoration, development of visitor and transportation facilities). In some cases, due to physical and operational links, implementation requires removal and replacement of administrative functions outside of Yosemite Valley to make way for improved visitor facilities within the Valley. In many cases, restoration to natural conditions is often the last piece to be completed. For example, the restoration of Upper and Lower Rivers Campgrounds would require the removal of utilities before the site can be restored. See Vol. II, Appendix M, Sequencing Plan, for more information on project sequencing.

507. Public Concern: The National Park Service should clarify the prioritization of Yosemite Valley Plan restoration projects.

"It is not at all clear why the Park Service has downgraded the priority of the plan’s major restoration projects. In addition to two important projects, Phase 1 includes seven small projects, many of which do not involve highly valued resources, none of which are time-sensitive, and which total an estimated $1,833,000. The draft YVP offers no explanation of why the restoration of the Church Bowl Picnic Area and the removal of the old sewer plant (which has not been a priority in the twenty years since the GMP first proposed it), for example, now take precedence over the restoration of Upper and Lower River Campgrounds, the Stoneman and south Ahwahnee Meadows, and the North Pines campground. These latter projects represent the heart of the YVP’s restoration effort--they should not be made to wait until the Church Bowl Picnic Area is restored." (Conservation Organization, San Francisco, CA - #4594)

Response: Vol. II, Appendix M in the Final Yosemite Valley Plan/SEIS has been modified to better explain the sequencing that will need to occur to be able to implement the Yosemite Valley Plan. For example, to fully restore Upper and Lower River Campgrounds the roads and utilities must be removed, but in order to remove the roads and utilities it is necessary to reroute utilities and reroute or reduce traffic volumes first. It may be possible to phase restoration projects incrementally, but it should be noted that some very important restoration projects must await construction, replacement, or relocation of other facilities. See Appendix M for more information on sequencing.

386. Public Concern: The National Park Service should complete an aggressive inventory and monitoring program prior to a Yosemite Valley Plan decision.

"Establish a sound scientific base of information that documents the resources that are protected and preserved in the park, the condition of those resources; any changes in condition over time; and actions needed to ensure preservation. According to National Park Service Director Robert Stanton, ‘Preserving our natural resources far into the future now requires active and informed management based on sound science.’ An aggressive Inventory and Monitoring Program needs to be in place first to provide information critical to the planning process–not within five years after a Record of Decision. Under the direction of practicing scientists, volunteers could certainly assist in gathering data." (Madera County Board of Supervisors, Madera, CA - #4284)

Response: According to NPS-77, Natural Resource Management Guidelines (1991), "Monitoring is the systematic collection and analysis of resource data at regular intervals, in perpetuity, to predict or detect natural and human-induced changes, and to provide the basis for appropriate management response. Inventory is the process of acquiring, managing, and analyzing information on park resources, including but not limited to the presence, distribution, and condition of plants, animals, soils, water, air, natural features, biotic communities, and natural processes." Since inventory and monitoring are ongoing processes, they cannot be completed before the Yosemite Valley Plan. However, Yosemite National Park has established and continues to carry out a wide variety of inventory and monitoring programs in the park. Specific recent studies have included:

• Delineation of the floodplain in Yosemite Valley following the January 1997 flood
• Spotted owl surveys conducted by the U.S. Fish and Wildlife Service
• Fisheries census by the California Department of Fish and Game and the U.S. Fish and Wildlife Service
• Rockfall studies by the U.S. Geological Survey
• Flood and hydrologic studies by the National Park Service Water Resources Division
• Effects of woody debris and river restoration on aquatic systems by the U.S. Fish and Wildlife Service
• Ongoing evaluation of impacts from bridges and vegetation loss along the Merced River by the National Park Service and the U.S. Geological Survey Biological Resource Division
• Vegetation recovery following restoration of riparian, meadow, California black oak woodland, and upland forests in Yosemite Valley
• Monitoring throughout the park of the effects of prescribed fires
• Air and water quality monitoring
• Survey and mapping of soils throughout the park
• Survey and mapping of vegetation throughout the park
• Ongoing monitoring of rare, threatened, and endangered species

These past and ongoing inventory and monitoring programs were used in the development of the alternatives addressed in the Final Yosemite Valley Plan/SEIS. In addition, studies and inventory and monitoring results in similar ecosystems and habitats in adjacent areas managed by the National Park Service, U.S. Forest Service, and other agencies have been incorporated into the recommendations included in this document.

See relevant sections of Vol. IA, Chapter 3, Affected Environment; Vol. IB, Chapter 4, Environmental Consequences; and the Bibliography (Vol. IB) for references to specific studies.

501. Public Concern: The National Park Service should use the implementation strategy of the Grand Canyon National Park General Management Plan as a model for Yosemite Valley Plan implementation.

"Our organizations are merely requesting that the Park Service give Yosemite the same treatment that Grand Canyon National Park received in 1995. The NPS’s General Management Plan for Grand Canyon contains an extensive phasing plan organized almost identically to what we have proposed for the YVP. The Grand Canyon GMP breaks all items into one of two phases, and proposes completing actions concurrently across the categories of transportation, visitor services, employee housing, and management support (which includes relocation and restoration of administrative facilities). For each action item, the phasing schedule includes a cost estimate, anticipated funding source, estimated completion date, explanation of the action sequence, and an indication of whether additional NEPA compliance will be required." (Conservation Organization, San Francisco, CA - #4594)

Response: Vol. II, Appendix M has been modified to expand and explain project sequencing and costs for actions called for in the Preferred Alternative in the Final Yosemite Valley Plan/SEIS. The Grand Canyon model was not specifically used; however, project links have now identified the potential need for additional compliance with provisions of the National Environmental Policy Act.
(Also see response to Concerns #365 and #469.)

560. Public Concern: The National Park Service should decrease the level of manager discretion allowed under the Yosemite Valley Plan.

"It is our opinion that all of the alternatives, including the preferred alternative, as was the case with the ‘Merced Wild and Scenic River plan,’ contain too many unknown discretionary actions which may be taken by the Park Service. Because of the numerous discretionary actions contained within each alternative, it is very difficult for the public to comment meaningfully on the alternatives. As an example, it is unclear when and under what circumstances historic structures may or may not be removed. We respectfully request that the alternatives be tightened up in terms of discretionary activities which may occur in the future but which are not sufficiently delineated at the present time for the public to adequately comment on." (Mariposa County Board of Supervisors, Mariposa, CA - #6060)

Response: Because of the breadth of actions called for in the Final Yosemite Valley Plan/SEIS there is a necessary range in the level of detail provided. Under the National Environmental Policy Act (NEPA), it is appropriate to focus on those issues that are ripe for decision and to defer additional detail to tiered compliance (40 C.F.R. Section 1508.28). In addition, the National Park Service conservatively estimated impacts stemming from actions to disclose the most severe impacts that could occur. For example, development areas or zones were delineated where substantial facilities construction or replacement would occur. Because site-specific design would be conducted in the future, the assumption was made, for purposes of impact analysis, that all areas inside the development zones would be adversely impacted by the development even though this may not ultimately be the case once facilities are sited on the ground.

For those elements of the Preferred Alternative that do no have a specific level of detail, general provisions are identified and future public involvement and environmental review is expected. The public would again have the opportunity to comment on those actions requiring further compliance under National Environmental Policy Act in the form of an environmental impact statement or environmental assessment. General provisions guiding these actions would include the goals of the Final Yosemite Valley Plan/SEIS, general mitigation measures identified in the Yosemite Valley Plan, and other applicable park plans and policies such as the Merced River Plan. Please refer to revisions in Chapter 1, Purpose and Need, and Appendix M, Sequencing in the final document that provide discussion and further commitments regarding future National Environmental Policy Act compliance associated with future site-specific planning and design activities.
(Also see response to Concerns #365 and #469.)

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Section 2.6 ~ Funding

The funds required for the restoration, construction, and demolition of facilities within Yosemite Valley elicit numerous comments from a broad range of respondents. Many people suggest that the National Park Service establish funding prior to commencing planning efforts. "While construction costs are fairly well supported, future operational costs are not assured. This approach is topsy-turvy to how most organizations fund new construction," offers one business representative. Instead, the Park Service "should establish assured levels of funding first," this person writes, rather than assume future administrative and congressional support will be available.

Addressing a similar topic, another respondent requests that the National Park Service include an analysis of funding sources in the Final Yosemite Valley Plan/SEIS. Such an analysis is necessary, this person offers, "so that the public is not misled about the consequences if future funding is withheld." Other citizens believe the National Park Service should more aggressively seek private fund donations. "Fund raising is not addressed in the report at all and I think you need to develop and publish widely your Yosemite fund raising rules," suggests this person.

While not exhorting the Park Service to actively seek private funds, one conservation organization does suggest they establish a strict policy regulating the uses of private funds. "In the absence of strong policies specifying that private donations confer no rights to the donor (such as the right to advertise or control developments)," the group writes, "the NPS could be placed under financial pressure by donors, which may run counter to the agency’s primary mission of leaving Park resources unimpaired."

Another funding concern for many constituents is the perceived exorbitant costs of implementing the Preferred Alternative. One conservation organization asks the National Park Service to explain the rationale behind restoration costs for Phase 1 of Yosemite Valley Plan implementation. Noting that less than two percent of the total implementation budget is slated for restoration projects, this group suggests that such a small investment "could be interpreted to suggest that the Park Service places a higher priority on development and construction activities than ecological restoration projects." Using the same numbers, a resident of California comes to the same conclusion. "Instead of a vision of restoration, we have a vision of construction," this individual laments.

Emergency funds congressionally allocated after the January 1997 flood also draw attention from the public. Many perceive the National Park Service’s rush to complete this plan as being driven by a fear of losing the unspent portion of these funds. "It was stated that if this plan was not approved by the end of this year that the Park Service would lose $110 million in flood money and $60 million in gate fee money," a speaker at a public hearing states. "That is a real concern, to sell out Yosemite because you don’t want to lose the money." This person believes the National Park Service should not consider the loss of flood damage funds as a criterion for determining the decision and implementation timelines of the Yosemite Valley Plan.

Note: One response is provided for Public Concerns #359 and #362 and placed following Concern #362.

359. Public Concern: The National Park Service should establish assured levels of funding prior to planning for Yosemite Valley.

"Missing from the Plan are the sources of funds available to pay for construction and ongoing operation. . . Stated assumptions by current park planners is that the fee demonstration program, combined with funds previously allocated to pay for repair of flood damage, and administrative and congressional support for change, will generate adequate funds to pay for implementation of the Yosemite Valley Plan. The current plan, like its predecessors, is a wish list. The NPS plan, when finalized, will be cemented into public consciousness as a reality, but in truth while construction costs are fairly well supported, future operational costs are not assured. This approach is topsy-turvy to how most organizations fund new construction. Instead of planning first, then seeking funding to fit the Plan, the NPS should establish assured levels of funding first (from fee demo, add-ons and congressional allocation), then plan finance-able actions." (Business, Yosemite National Park, CA - #3962)

362. Public Concern: The Yosemite Valley Plan should include a detailed analysis of funding sources.

"More detailed analysis of funding sources and realistic assessments of their feasibility should be included so that the public is not misled about the consequences if future funding is withheld." (Business, Yosemite National Park, CA - #3962)

Response: The Yosemite Valley Plan identifies possible funding sources for project implementation. The targeting of funding sources is based on anticipated program opportunities and project eligibility. Several Yosemite Valley Plan projects, such as the Yosemite Lodge project and the restoration and redesign of several Valley campgrounds, already have funding available, as a result of the 1997 flood response. The National Park Service received $176 million as part of the Emergency Supplemental Appropriations Act (Public Law 105-18) to repair flood-damaged roads, facilities, and infrastructure. Money specifically appropriated for the above-mentioned projects has been set aside until a Record of Decision for the Yosemite Valley Plan can be reached.

The new National Park Service Fee Demonstration program has the potential to provide approximately $12 million a year toward Yosemite Valley Plan project implementation. Other funding sources include the National Park Service Line Item construction program, which requires projects to compete servicewide for funding consideration. The concession Capital Improvement Fund, grants from private philanthropy and the Federal Lands Highway Program are other potential funding sources that would be considered to implement Yosemite Valley Plan projects. See Vol. II, Appendix M of the Final Yosemite Valley Plan/SEIS for more information on available funding sources.
(This response also applies to the previous Concern, #359.)

Note: One response is provided for Public Concerns #436 and #500 and placed following Concern #500.

436. Public Concern: The Yosemite Valley Plan should include the National Park Service’s fund raising rules.

"Fund raising is not addressed in the report at all and I think you need to develop and publish widely your Yosemite fund raising rules–what is and isn’t acceptable, who is and isn’t raising money on your behalf, what you are going to use the funds for and how it differs from government funding, and you need to get aggressive about increasing your private funding and your use of volunteers. I was very surprised by the small amount of money you are raising privately–the newsletter I saw said about $4 million. With 3.5 [million] well-off visitors each year, you are sitting on a gold mine. You don’t need to do the gold rush, but deliberate, thoughtful fund raising is a resource not to be ignored." (Individual, Washington, DC - #4853)

500. Public Concern: The National Park Service should establish a policy regulating the use of private funds for Yosemite National Park developments and services.

"Our organizations strongly encourage the Park Service to establish a strict policy regulating the uses of private funds for Park developments or services. In the absence of strong policies specifying that private donations confer no rights to the donor (such as the right to advertise or control developments), the NPS could be placed under financial pressure by donors, which may run counter to the agency’s primary mission of leaving Park resources unimpaired." (Conservation Organization, San Francisco, CA - #4594)

Response: This concern is acknowledged; however, it is outside the scope of the Yosemite Valley Plan. The National Park Service has specific policies that regulate fundraising, the use of donated funds, and donor recognition. In addition to broad direction found in the National Park Service Management Policies, specific detailed guidance is provided in Director’s Order #21, Donations and Fundraising (approved September 18, 1998).
(This response also applies to the previous Concern, #436.)

503. Public Concern: The National Park Service should explain the rationale behind restoration costs for Phase 1 of Yosemite Valley Plan implementation.

"The draft plan fails to explain to the public why Phase 1, which is estimated to cost more than $213 million, includes less than $4 million for ecological restoration (less than two percent of the total). Although restoration projects of course cost less than construction activities, the disparity in these figures, in the earliest and most important phase of the plan, could be interpreted to suggest that the Park Service places a higher priority on development and construction activities than ecological restoration projects." (Conservation Organization, San Francisco, CA - #4594)

"Here is the economic analysis we did of your numbers for Alternative 2 (Appendix M). 43% of the total cost went for employee housing. Wow! As we mention later, moving employees out of the valley probably has more pros than cons, but it is a close call. If moving the employees out will cost 43% of the total tab–forget it. Next, we looked at restoration, 4.9% of the total. That sent a bad message all by itself. Instead of a vision of restoration, we have a vision of construction." (Individual, Oakhurst, CA - #3379)

Response: Restoration projects cost less than construction projects; therefore, it may not be appropriate to compare costs to indicate priorities. To be able to restore 180 acres of Yosemite Valley, it is necessary to spend money constructing replacement facilities outside of the Valley, especially employee housing. To improve visitor services and accommodate transportation systems, there are significant construction costs for work that must be done before restoration projects can be started. Construction of replacement functions will often lead to more restoration (e.g., removing roads from meadows requires reduced traffic volumes and relocation of roads, thereby making transportation projects predecessors to road removal). See Vol. II, Appendix M, Sequencing Plan, of the Final Yosemite Valley Plan/SEIS for more information.

465. Public Concern: The National Park Service should not consider the loss of flood damage funds as a criterion for determining the decision and implementation timelines of the Yosemite Valley Plan.

"We heard at the Board of Supervisors meeting Tuesday, it was stated that if this plan was not approved by the end of this year that the Park Service would lose 110 million dollars in flood money and 60 million dollars in gate fee money. That is a real concern, to sell out Yosemite because you don’t want to lose the money." (Public Hearing, Fresno, CA - #20503)

Response: The source or availability of funding is not driving the decision making in the Yosemite Valley planning effort or the timeline for its completion. Many projects funded by the Emergency Supplemental Appropriations Act (Public Law 105-18) are included in the Final Yosemite Valley Plan/SEIS and will not proceed until a Record of Decision is signed. However, the Emergency Supplemental Appropriations Act funding is not tied to any fiscal year and does not expire unless directed by Congress.

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Section 2.7 ~ Public Participation and Coordination

This section contains an analysis of public comment regarding the public participation process for the Draft Yosemite Valley Plan/SEIS. Concerns about public involvement, the weighing of constituencies, public meetings, and response to public comment follow. The section concludes with those concerns involving National Park Service coordination with individuals, groups, and other government agencies.

2.7.1 ~ Public Involvement

Numerous individuals, agencies, and organizations urge the National Park Service to extend the public comment period for the Draft Yosemite Valley Plan/SEIS. One individual, noting that the majority of items listed under the "Make Your Comments Count" section are extremely time consuming, exhorts the National Park Service for assistance. "Based on the level of participation that you are asking the public to shoulder in this process, the public comment period should be extended to one full year," this person proposes, "and the Park Service should conduct public workshops to accomplish these objectives."

Several respondents not only ask for an extension of the comment period but also request the deadline be set after the Merced River Plan’s Record of Decision. "Given the complexity of the Valley plan alternatives and especially since the Merced River Plan . . . has not been formally approved, the July 7, 2000, deadline for comments on the Yosemite Valley Plan is unreasonable," one person charges, "I urge you to extend the deadline for comments on the Yosemite Valley Plan for an additional 90 days following final approval of the Merced River Plan." Another respondent, citing the same reasoning, requests a deadline 120 days after the Merced River Plan’s Record of Decision.

Invoking similar concerns, several respondents request that the National Park Service extend the date of its final decision on the Yosemite Valley Plan. Given the administrative and political exigencies associated with an election year, many constituents feel that the planning process is being rushed. "What has been most disconcerting to me has been the manner in which the Clinton Administration has attempted to force feed this proposal to the people of this country," writes one U.S. Representative. Of those that suggest the Record of Decision date be extended, many reason that the Merced River Plan should be completed first. "It is impossible for the public to make fully informed comments during the Valley plan response period (April 7 - July 7, 2000) when the Valley plan is directly affected by a plan not yet completed. This timing renders the entire public comment process invalid," insists one constituent.

Technical aspects of the public comment process need clarification, according to several respondents. A discrepancy in the close of comment date on two separate National Park Service web pages leads one constituent to ask for clarification. Another Internet related suggestion is to offer pure text versions of the Draft Yosemite Valley Plan/SEIS on the National Park Service’s web pages. "While it only took me a few minutes to download the PDF versions of these files," this person shares, "it would have been far more useful if you also provided a pure text version (with graphs replaced with tables) for people who do not have ADSL or other relatively high-speed Internet connections." Having a pure text version would make searching the text for keywords easier as well, this individual offers.

Finally, one citizen proposes that the National Park Service provide a concise executive summary of the Draft Yosemite Valley Plan/SEIS. "Your executive summary is much too long to review for a busy person," this person remarks.

Note: One response is provided for Public Concerns #187 and #115 and placed following Concern #115.

187. Public Concern: The National Park Service should extend the public comment period for the Yosemite Valley Plan.

"Under the ‘Make Your Comments Count’ section . . . the balance of items listed would require a serious commitment of time and expertise to perform the necessary research to substantiate public comments. Based on the level of participation that you are asking the public to shoulder in this process, the public comment period should be extended to one full year, and the Park Service should conduct public workshops to accomplish these objectives." (Individual, Malibu, CA - #1164)

"As we stated in our letter dated March 23, 2000 to your office relative to the ‘Merced Wild and Scenic River Plan,’ we believe that the fast tracking of the Valley Plan that the Federal Government has established for public review and adoption is far too compressed to allow either the Board of Supervisors or the general public sufficient time to review the documentation and make meaningful comments. We therefore request that the Park Service extend the deadline for public comments to be received by a minimum of 90 days." (Mariposa County Board of Supervisors, Mariposa, CA - #6060)

"Extend the comment period on the Valley Plan for 120 days after a Record of Decision on the Merced River Plan." (Non-Governmental Organization, Wawona, CA -# 7882)

"Given the complexity of the Valley Plan alternatives and especially since the Merced River Plan, based on the Merced Wild and Scenic River Comprehensive Management Plan and Final Environmental Impact Statement, has not been formally approved, the July 7, 2000 deadline for comments on the Yosemite Valley plan is unreasonable. I urge you to extend the deadline for comments on the Yosemite Valley Plan for an additional 90 days following final approval of the Merced River Plan." (Individual, Merced, CA - #9329)

115. Public Concern: The National Park Service should extend the final decision date of the Yosemite Valley Plan.

"I hope that in our haste to make sweeping changes we do not eliminate or change too drastically. Why not extend the final decision date and allow everyone interested a chance to participate in the final plans? I know Secretary Babbitt wants the plan to be finalized before his term is up, but let us not forget, those are decisions that must not be made quickly. We all want Yosemite to be here forever. Let us not make changes that cannot be undone." (Individual, Roseville, CA - #341)

"I would like it [Record of Decision] to be postponed until we have the new administration, because we may have a new direction and some new people." (Public Hearing, Los Angeles, CA - #20333)

EXTEND decision date UNTIL THE MERCED RIVER PLAN IS COMPLETED

"We believe the Park planning process is deeply flawed as the Plan states it is based on assumptions and data that is yet to be collected. The draft Merced River Management Plan (available for comment January 14 - March 24, 2000) is the foundation of the Yosemite Valley Plan, thereby authorizing its implementation; yet the Yosemite Valley Plan was developed and printed before the public comment period for the Merced River Plan had closed. Pursuant to National Environmental Policy Act (NEPA) and Council on Environmental Quality (CEQ) regulations, the River Plan is now undergoing modifications or revisions necessary to be considered legally adequate and will not be available for a Record of Decision until later this summer. It is impossible for the public to make fully informed comments during the Valley Plan response period (April 7 - July 7, 2000) when the Valley Plan is directly affected by a plan not yet completed. This timing renders the entire public comment process invalid." (Business, Oakhurst, CA - #4276)

"What has been most disconcerting to me has been the manner in which the Clinton Administration has attempted to force feed this proposal to the people of this country. For Interior Secretary Bruce Babbitt to deny any extension to the diminutive time frame he has allowed the American people to comment on a plan that has been in the works for 20 years is a complete disgrace and an affront to the very democratic system he supposedly espouses. I find it appalling that I received in my office a copy of the Record of Decision on the Merced River Plan–a plan that is critical to the implementation of any management plan of Yosemite Valley–a mere four days before the expiration of the comment period on the YVP. Needless to say, neither my constituents nor I have had ample opportunity to fully read, comprehend and comment on a plan that will drastically change the way Yosemite National Park is managed in the future. I hope that, in the future, decisions that are so critical to Yosemite National Park and to its outlying communities will be made with the benefit of a more deliberate and adequate public comment process." (U.S. Representative, Roseville, CA - #4292)

"The public should not be asked to be commenting on a Valley Plan until a valid Merced River Plan is completed and finalized. Today there is no valid Merced River Plan, so there should be no Valley Plan on the table, period." (Public Hearing, San Jose, CA - #20533)

Response: The National Park Service does not view the planning process regarding the future of Yosemite Valley to have been conducted in haste. Planning for the Valley has not been confined to the current effort to develop a Yosemite Valley Plan, but has been an ongoing process dating back several years. The process has included preparation of the Draft Yosemite Valley Housing Plan/SEIS in 1992 (revised in 1996), as well as the Draft Valley Implementation Plan/SEIS released to the public in 1997. Public comment was solicited, received, and evaluated for each of these efforts.

The public has had ample opportunity to participate in the planning process both for the Draft and Final Yosemite Valley Plan/SEIS. The National Park Service implemented a comprehensive public involvement program during development of this document. For example, fourteen public meetings were conducted in the state of California, and additional meetings were held in the Seattle, Denver, Chicago, and Washington, D.C. areas during the public comment period for the draft document. Numerous meetings were held with interest and advocacy groups throughout the planning process. Planning Update newsletters were distributed to keep the public informed of planning progress and issues. In addition, public comments were accepted on the Draft Yosemite Valley Plan/SEIS from March 28, 2000 through July 14, 2000 far exceeding the agency’s minimum required comment period of 60 days.

Postponing the Record of Decision until the advent of a new administration would not provide tangible benefit to the planning process for Yosemite Valley. Although a change in administration may involve different people, the issues facing Yosemite Valley will remain the same, with challenging decisions to be made regardless of those involved.
(This response also applies to Public Concern #187.)
(Also see response to Public Concern #16)

51. Public Concern: The National Park Service should clarify the close of comment date for the Yosemite Valley Plan.

"Quick note on the introductory pages that I could get into: www.nps.gov/yose/planning.htm. This page states that the comment period ends on July 5th. OK; www.nps.gov/yose/planning/yvp.htm . . . states that comments must be received by July 7th. Do you mean to tell me that if I get my comment postmarked by July 5 and it doesn’t get to California by the 7th I’m S.O.L.? This is confusing. . . Let’s have less confusion, not more. A little consistency goes a long way." (Individual, No Address - #30064)

Response: This comment is acknowledged. The National Park Service web site has been corrected to show July 7, 2000, as the end of the public comment period for the Draft Yosemite Valley Plan/SEIS. In mid-August it was discovered that the official Federal Register notice published by the Environmental Protection Agency announcing the availability of the Draft Yosemite Valley Plan/FEIS for review stated that comments were due by July 14, 2000. Therefore, comments received through July 14, 2000, were included in the analysis of public comments (see the section on the Draft Yosemite Valley Plan/SEIS in Vol. IB, Chapter 5, Consultation and Coordination).

653. Public Concern: The National Park Service should offer pure text versions of the Yosemite Valley Plan on the Internet.

"While it only took me a few minutes to download the PDF versions of these files, it would have been far more useful if you also provided a pure text version (with graphs replaced with tables) for people who do not have ADSL or other relatively high-speed internet connections. With full documents in a single text file, it becomes fairly easy to use text-editor capabilities to search the files for keywords (something you can’t do with multiple web pages), and it is easier to justify storing the files on disk when the files are just simple text (and therefore much smaller), reducing the load on your servers." (Individual, Palo Alto, CA - #3714)

Response: Initially, the Draft Yosemite Valley Plan/SEIS was available on the Internet as large PDF (picture display format) files that require the use of Adobe Acrobat for viewing. As a result of public comments, the National Park Service posted a text file (HTML) version of the full Draft Yosemite Valley Plan/SEIS on the web site so that the public could read the document and view the graphics online.

185. Public Concern: The National Park Service should provide a concise executive summary of the Yosemite Valley Plan.

"Your executive summary is much too long to review for a busy person. I suggest you rewrite it into a four or five page (at the most) document. I would then review and comment on specifics." (Individual, Bakersfield, CA - #854)

Response: The National Park Service has provided a more concise Executive Summary in the Final Yosemite Valley Plan/SEIS. Please refer to the beginning of Volume Ia of this document.

2.7.2 ~ Weighing of Constituencies

The Draft Yosemite Valley Plan/SEIS states on page III-2 that "all comments are treated equally and are not weighted by number, organizational affiliation, or other status of respondents." One respondent feels that this statement contradicts another on page III-15: "The database was also used to track pertinent demographic information such as responses from special interest groups or federal, state, county and local governments." If no comment is weighted more than another, this person wonders, then why does the National Park Service track demographics? "I would like an explanation of this contradiction," this citizen remarks.

Another respondent, suspicious as well that all comments do not necessarily receive equal treatment, cites a remark allegedly made by the Secretary of the Interior: "Quote, ‘The problem with Yosemite is it’s got too many friends. I wish about 95 % of them would go home and shut up,’ end of quote, spoken by Bruce Babbitt, Secretary of the Interior, at the Commonwealth Club, March 27th, year 2000." This speaker then asks, "I wonder who are the 5% that he listens to?" Alternative 2 would restrict access to large groups of people, according to this respondent, and Secretary Babbitt’s word are proof that the National Park Service is not giving equal consideration to public comments on this Plan.

Ignoring the National Park Service’s admonition that "all comments are treated equally" some respondents believe extra weight should be given to certain groups’ comments. One such respondent believes that the Yosemite Valley Plan should include the views of equestrians who use Yosemite Valley. Similarly, a U.S. Representative insinuates that the National Park Service should give more weight to the comments of gateway community residents. "I do not disagree that these planning efforts must have as much public input as possible," the representative relates. "However, the citizens most directly impacted by park planning efforts are those in the gateway communities that support park activities. For this reason, I anticipate that the park service will listen particularly closely to the comments received from the gateway communities."

694. Public Concern: The National Park Service should clarify how public comments on the Yosemite Valley Plan are weighted.

"My final comment concerns what appears to be another contradiction. On page III-2, it says that all comments are treated equally and are not weighted by number, organization affiliation or other status of respondents. Then comes the contradiction on page III-15, where it says the ‘mailing list’ database was also used to track pertinent demographic information such as responses from special interest groups, or federal, state, county, and local governments. Then there is another contradiction on page III-16, where it says demographic coding combined with the public comment subject categories allows managers to focus on specific areas of public comment linked to type of respondent, geographic area and response method. I would like an explanation of this contradiction." (Individual, Columbia, CA - #7149)

Response: The National Environmental Policy Act (NEPA) requires that the National Park Service consider all comments offered by the public on the Draft Yosemite Valley Plan/SEIS "both individually and collectively." Public concern statements, which form a basic summary of public comment and are the primary focus of park management when considering public comment collectively, are formulated by reading each individual letter, coding each identifiably different concern in each letter to a topical database, and then using that database to identify the range of public concerns in the whole body of public comments. This process treats all comments equally, regardless of number, organizational affiliation, or other status of respondents.

The demographic information gathered from responses is another way of looking at the letters collectively, allowing managers to obtain a picture of certain general aspects of the responding public such as the geographic distribution of commenters, their affiliation with a government agency or private organization, and how different members of the public chose to offer their comments (e.g., by letter, fax, email, public testimony, etc.).

A more complete understanding of the process of content analysis of public comment letters and how the resulting information is used in planning and decision making can be obtained by reading the Public Involvement and Agency Consultation Section of Volume Ia, Chapter 1; Chapter 5, Consultation and Coordination, in Volume Ib; and in Volume III, Public Comment and Response, Introduction, Chapter 1, and Chapter 6.

221. Public Concern: The Yosemite Valley Plan should reflect the needs of all user groups in Yosemite Valley.

"Quote, ‘The problem with Yosemite is its got too many friends. I wish about 95% of them would go home and shut up,’ end of quote, spoken by Bruce Babbitt, Secretary of the Interior, at the Commonwealth Club, March 27th, year 2000. I wonder who are the 5 percent that he listens to? Could it be the thousands of Americans who will be displaced by Alternative 2? And who are these displaced visitors? Seniors, the disabled, low-income families with children, campers, rafters, hikers, climbers, swimmers, fisherman, and more. No, I rather doubt Mr. Babbitt is listening to this group of people." (Public Hearing, Costa Mesa, CA - #20302)

Response: The Yosemite Valley Plan has been developed with the needs of all park visitors in mind. One way in which those needs were identified was through public involvement during both the scoping process and the formal public comment period. The National Park Service and the public are engaged through those processes in determining what levels of visitor accommodations are appropriate for the National Park Service to provide. Public feedback is highly valuable in refining the ways the National Park Service accomplishes its mission.
(Also see response to concern # 55.)

371. Public Concern: The Yosemite Valley Plan should include the views of equestrians who use Yosemite Valley.

"You failed to answer the question regarding if any equestrian people are on the panel that made, or is making the decision regarding equestrian traffic in Yosemite National park. I do not understand why names and addresses cannot and should not be given to the general public. My intent is to provide thoughts from the equestrian point of view. How can one be expected to make an intelligent decision if all the facts are not known? The panel must gather facts [on which] to base their decisions. I’m sure you (nothing personal intended) must feel I am or could be a thorn in your side. Trust me, that is not the case." (Individual, No Address - #3825)

Response: Decisions regarding action elements of the Final Yosemite Valley Plan/SEIS are made by park management staff based upon analysis, evaluation, and public involvement. Stock use is addressed in the plan and comments from stock users and other special interest groups were fully considered during the public comment response analysis stage of planning.

385. Public Concern: The Yosemite Valley Plan should reflect the specific needs of gateway communities.

"You have detailed your activities presenting the planning document to the public in forums from Washington, DC to Seattle, on the theory that Yosemite National Park is indeed a national asset. I do not disagree that these planning efforts must have as much public input as possible. However, the citizens most directly impacted by park planning efforts are those in the gateway communities that support park activities. For this reason, I anticipate that the park service will listen particularly closely to the comments received from the gateway communities." (U.S. Representative, Fresno, CA - #2951)

Response: As part of the Final Yosemite Valley Plan/SEIS planning process, and in response to public comments, the National Park Service has identified and analyzed in detail the expected impacts on the social and economic environment surrounding Yosemite National Park. These have been further considered in response to comments received during the public comment period. The socioeconomic impact analyses and their conclusions are presented in the Visitor Populations and Regional Economies Sections in Vol. IB, Chapter 4, Environmental Consequences. Vol. II, Appendix J of the Final Yosemite Valley Plan/SEIS also discusses the difficulties associated with projecting future visitor demand and visitation. As a result, the magnitude, duration, and type of impacts that can be reliably and reasonably determined is limited by the ability to accurately project visitation characteristics. Regardless, by identifying and evaluating the impacts to the surrounding counties and gateway communities, the National Park Service recognizes local needs and concerns and, where possible, defines processes to assist the counties’ future planning and development.

2.7.3 ~ Public Meetings

Public hearings to solicit public input on the Draft Yosemite Valley Plan/SEIS were held throughout California as well as in large cities across the nation. Several respondents offer suggestions for the improvement of this facet of public participation. Additional meetings are requested by many citizens. "Currently, your schedule includes Seattle . . . Denver . . . Chicago . . . and Washington, D.C. We would suggest adding to this list–Boston, New York City and/or Philadelphia, Miami, St. Louis, Dallas or Houston, and Phoenix," proposes one respondent. One Paso Robles, California, resident decries the lack of proximal meetings: "I live in Paso Robles, California, and there is no meeting even close to this area! . . . The closest meeting would be Fresno, if I wanted to go there I’d be in the park!"

When scheduling additional meetings, the National Park Service should also consider location and public transportation accessibility, comments one respondent. A speaker at the public hearing in San Diego suggests improving outreach to students interested in national parks. "I’m surprised there are not more students here," this student attests. Including the meeting date and time in university newspapers and campus posters is one suggestion this individual presents.

199. Public Concern: The National Park Service should schedule additional Yosemite Valley Plan public meetings.

"In order that as much input as possible could be received on the Yosemite Valley Plan, we would encourage your traveling team to visit additional cities. Currently, your schedule includes Seattle . . . Denver . . . Chicago . . . and Washington DC. We would suggest adding to this list–Boston, New York City and/or Philadelphia, Miami, St. Louis, Dallas or Houston, and Phoenix." (Individual, Amherst, MA - #213)

"My objection is to the Valley Plan meetings that are scheduled. I live in Paso Robles, California, and there is no meeting even close to this area! San Luis Obispo Co.? Hello, we’re neighbors? The closest meeting would be Fresno, if I wanted to go there I’d be in the park!" (Individual, Paso Robles, CA - #50)

Response: This concern is acknowledged; although scheduling public meetings is an important aspect of the planning process, it is outside the scope of the Yosemite Valley Plan. The National Park Service was not able to visit every site it wished to visit because of time constraints, budget, and staffing limitations. The four out-of-state venues visited were selected based on criteria that included (1) whether the site was a transportation hub, (2) the sites’ geographic distribution across the country, and, most importantly, (3) the sites were in cities from which the most scoping comments were received.

179. Public Concern: The National Park Service should consider location and public transportation accessibility when scheduling Yosemite Valley Plan public meetings.

"I would like to comment right now on the poor choice of location for the Oakland area public meeting. The location you have chosen is very difficult to get to by public transportation and is not at all central. It is important that these meetings be very accessible to the public, including the public that chooses to or must ride public transportation instead of driving. . . There are many other venues in the East Bay which are highly transit accessible. Please keep convenient location and transit accessibility among your highest priorities when planning such meetings in the future." (Individual, Berkeley, CA - #443)

Response: This concern is acknowledged; although it is relevant to the planning process, it is outside the scope of the Yosemite Valley Plan. Many considerations, including public transit access, went into the process of selecting where to hold public meetings during the public comment period.

654. Public Concern: The National Park Service should provide more public outreach to students.

"But I also think that it would be excellent if you had more people of my age at these meetings, and considering that there are four universities in the area in the San Diego, I’m surprised there are not more students here. So perhaps that’s just because as a student I’m not reading the local paper that often. I do read my school newspaper, and I do read the posters around the campus and maybe at future sites, you might want to perhaps give more public outreach to students and to YMCAs, et cetera, areas where the younger people are populating." (Public Hearing, San Diego, CA - #20444)

Response: This concern is acknowledged; however, although it is relevant to the planning process, it is outside the scope of the Yosemite Valley Plan itself. The National Park Service uses a variety of ways to inform the public about public meetings. These include press releases, advertisements in major newspapers and newspapers aimed at minority populations, notices to people on the park’s extensive mailing list, and the park’s web site. The park also works with various organizations to provide information to special interest groups. For example, the park provided information to the Yosemite Institute, which in turn worked to disseminate information to schools and students. The National Park Service will continue to explore new ways to inform the public about issues and planning in Yosemite.

2.7.4 ~ Response to Public Comment

Many individuals have questions of clarification regarding the National Park Service’s responsibility to respond to public comment. Citing a previous request for information, one respondent proclaims, "requested data must be made available to the public in a more timely manner (two weeks or less)." Another individual believes that scoping comments were not addressed "adequately in either the response section or the rest of the plan document." The Yosemite Valley Plan should address all of the public concerns submitted during the scoping process, according to this citizen.

188. Public Concern: The National Park Service should provide timely responses to public information requests regarding the Yosemite Valley Plan.

"Given the sweeping proposals of the Valley Plan, the brief 90-day public comment period and the July 5, 2000 deadline for public comments, requested data must be made available to the public in a more timely manner (two weeks or less). . . If the Park Service and BRW are unable to resolve requests for information within two weeks of the date that any public request is submitted, then the Valley Plan has been prematurely released for public review and comment, and it should be retracted and revised to include critical data requested by the public. If this data cannot be readily provided, then the Park Service and BRW will have violated National Environmental Policy act requirements on a number of levels. This is a formal request for specific, targeted data related to the Valley Plan. The absence of such data is clear evidence to us that basic elements of the plan are deceptive, and therefore, many of its principal conclusions cannot be substantiated. Hence, a prompt and complete response is expected and will be appreciated." (Individual, Malibu, CA - #1164)

Response: This concern is acknowledged, and the National Park Service and the Yosemite Valley planning team have made every effort to provide timely responses to public information requests.

337. Public Concern: The Yosemite Valley Plan should address all of the public concerns submitted during the scoping process.

"My scoping comments and those of others were not replied to adequately in either the response section or the rest of the plan document. I will list a few of the non-responses below. There was no reply to my comment about the stunning inconsistency of advertising Yosemite Park in an automobile magazine when the sheer number of visitors and especially the number of automobiles is agreed to be a problem in the park. There was lack of clarity and lack of adequate reply to comments about the transportation plan. No reason was given for not using trams, or open air trailers. Neither the plan nor any response states the size, numbers or fuel source of buses to be used. (Reading between the lines one surmises that more large diesel buses are in the planners’ mind–but not in the printed plan despite its extraordinary size)." (Individual, Menlo Park, CA - #3564)

"I do hope that the thousands of public comments that you receive will be diligently used to rewrite the YVP, resulting in a much improved Plan." (Individual, El Portal, CA - #9013)

Response: Scoping is a public process used early in the National Environmental Policy Act (NEPA) process to determine the range of issues to be addressed in the environmental impact statement. Comments received during scoping for the Draft Yosemite Valley Plan/SEIS were used to identify important issues and de-emphasize or eliminate issues of lesser relevance or importance. This information sets the stage for the subsequent planning process, including development of alternatives and analysis of impacts.

Normally, a draft plan would not include response to public comments. Providing responses to individual public scoping comments would be premature, as planning and analysis have yet to take place. In addition, agency responses to public input received during project scoping are not required as part of the NEPA process. Instead, a summary of issues identified during the scoping process and subsequent public input is presented in Vol. IA, Chapter 1, Purpose and Need, of the Final Yosemite Valley Plan/SEIS.

In the case of the Draft Yosemite Valley Plan/SEIS, generalized public comment statements and responses were included because public comments were received on various preceding, incomplete planning efforts that had been reanalyzed and incorporated into the draft plan.

2.7.5 ~ Coordination and Consultation

Numerous laws and regulations require federal agencies to coordinate planning efforts with the public, interested parties, affected communities, and other governmental agencies. Specific suggestions for Yosemite Valley Plan consultation and coordination follow.

One respondent believes the National Park Service should consult with accessibility design experts regarding the Yosemite Valley Plan. "In formatting revisions to the plan, the U.S. Department of the Interior should include a technical review and concurrence by a panel of people from the National Center on Accessibility (NCA), the National Organization of Disability (NOD), or similar independent body with expertise in design for accessibility," promotes this individual.

Various Forest Service employees request that the National Park Service coordinate planning with personnel from the National Forests adjoining Yosemite National Park. "Since Yosemite is surrounded entirely by four National Forests (Stanislaus, Toiyabe, Inyo, and Sierra), cooperation between the two agencies can provide a more positive and seamless experience for our common visitors," explains one federal employee. Assistance is offered by another Forest Service employee, who states, "Representatives of the adjacent National Forests are interested in participating in the five-year visitor experience, resource protection and facility capacity study identified on page 2-12 of the Executive Summary prior to the implementation of this portion of the Yosemite Valley Plan."

According to one U.S. Representative, another governmental entity that should be consulted–especially with respect to El Portal Planning–is the Mariposa County Board of Supervisors. "As you move forward on El Portal planning, please keep in mind the direct interest of the county in assisting to ensure that El Portal be further integrated into Mariposa County, rather than increasingly isolated from the community at large," remarks this elected official.

A resident of San Jose who owns property in Yosemite West wishes to coordinate a land sale with the National Park Service. This respondent believes the park service could use the site for additional parking as well as park service and concessioner housing. "I believe that there are many private corporations that would readily fund such a relocation project for the benefit of Yosemite National Park and the American Public, with their corporation being recognized of its generosity," posits this person. "I would like to urge you to at least take a look at the potential of our property and how it might fit into your plan."

118. Public Concern: The National Park Service should consult with accessibility design experts regarding the Yosemite Valley Plan.

"In formatting revisions to the Plan, the US Department of the Interior should include a technical review and concurrence by a panel of people from National Center on Accessibility (NCA), the National Organization of Disability (NOD), or similar independent body with expertise in design for accessibility." (Individual, Mariposa, CA - #348)

Response: The Final Yosemite Valley Plan/SEIS would call for architectural and programmatic accessibility in the design of new facilities and in retrofitting old facilities, including shuttle buses, visitor centers, comfort stations, and lodging facilities. Specific site designs are beyond the scope of the Final Yosemite Valley Plan/SEIS. The Preferred Alternative proposes a full accessibility study and plan during the implementation phases of the Yosemite Valley Plan. The National Park Service, through its Accessibility Management Program, works cooperatively with the National Center on Accessibility, and produces guidelines and training on accessibility issues. Ongoing accessibility planning includes the involvement of this organization, accessibility consultants, and appropriate spokespersons for communities of individuals with disabilities.

482. Public Concern: The National Park Service should coordinate planning with personnel from the National Forests adjoining Yosemite National Park.

"Since Yosemite is surrounded entirely by four National Forests (Stanislaus, Toiyabe, Inyo, and Sierra), cooperation between the two agencies can provide a more positive and seamless experience for our common visitors. Some of the proposed actions will have an indirect impact on adjacent National Forests." (USDA Forest Service, Sonora, CA - #9221)

"The Stanislaus and Sierra National Forests, and to a lesser degree the Inyo National Forest, are uniquely impacted by changes in visitor experience and employee housing facilities in Yosemite National Park. Any major expansion or reduction in developed recreation sites, location of employee housing or modification of visitor access, causes a ripple effect beyond the park boundary and onto the adjacent National Forest System lands. If the preferred Alternative (Alternative 2) is selected for the Final Yosemite Valley Plan, there are two major consequences o? National Forest Service lands that have not been adequately mitigated. Alternative 2 identifies a reduction in almost 300 overnight visitor accommodations within the valley, with no development of additional facilities within the Park. This reduction in Park accommodations will result in a tremendous increase in visitor use of developed and dispersed recreational sites on adjacent national forests along the major corridors leading to the Park, generating increased impacts when compared to the current condition. These impacts will include increased resource damage and need for greater management oversight of affected recreational areas on National Forest System lands. This will increase our management costs and may require the Forest Service to close portions of the Forests to dispersed camping opportunities. Representatives of the adjacent National Forests are interested in participating in the five year visitor experience, resource protection and facility capacity study identified on page 2-12 of the Executive Summary prior to the implementation of this portion of the Yosemite Valley Plan." (USDA Forest Service, Clovis, CA - #8900)

Response: This concern is acknowledged; however, it is outside the scope of the Yosemite Valley Plan. In the past, Yosemite National Park has coordinated activities with many separate units of the federal land management agencies in the Yosemite region, including units of both the U.S. Forest Service and Bureau of Land Management.

For the purposes of the Yosemite Valley Plan, the National Park Service has coordinated with Inyo, Toiaybe, Sierra, and Stanislaus National Forests. This plan does analyze the cumulative effects of other actions in the region in conjunction with the impacts of each of the Yosemite Valley Plan alternatives. Refer to Vol. IB, Chapter 4, Environmental Consequences, of the Final Yosemite Valley Plan/SEIS for analysis of cumulative impacts. Management authority and jurisdiction for other federal lands rests with the appropriate land management agency.

The National Park Service has been involved with and remains committed to planning, conservation and coordination with the surrounding national forests to resolve major issues of concern. Specifically, the National Park Service is an active participant in the Sierra Nevada federal land managers Group, and the Merced River Recreation Management Work Group.

387. Public Concern: The National Park Service should coordinate with the County of Mariposa regarding El Portal planning.

"Your planning efforts include a community that is an integral part of rural Mariposa County–El Portal. As you move forward on El Portal planning, please keep in mind the direct interest of the County in assisting to ensure that El Portal be further integrated into Mariposa County, rather than increasingly isolated from the community at large." (U.S. Representative, Fresno, CA - #2951)

Response: It is the intent of the National Park Service to continue to work cooperatively with Mariposa County concerning mutual land use and planning issues. Throughout this planning effort, the National Park Service has continually consulted with Mariposa County. This consultation has been accomplished by formal and informal communications with (1) the Mariposa County Board of Supervisors, (2) various Town Planning Advisory Committees (El Portal, Wawona and Yosemite West), (3) Planning and Public Works Departments, and (4) other community service organizations.

Furthermore, in the Final Yosemite Valley Plan/SEIS, the National Park Service has acknowledged the formal role of Mariposa County concerning land use planning in El Portal, Wawona, and Yosemite West planning areas. References to these official representatives of the county can be found in Vol. IA, Chapter 3, Affected Environment, thus acknowledging these representatives, and their role as official representatives of the county and community. Additionally, in the Final Yosemite Valley Plan/SEIS, the National Park Service has analyzed the potential impacts to facilities and infrastructure of the social and economic environments of Mariposa County (the range of alternatives considered relocating housing to locations within Mariposa County only). See Vol. IB, Chapter 4, Environmental Consequences for the impacts analysis. As future site planning is done for these areas, the National Park Service will continue to consult with these representatives, analyze potential impacts on these communities, and engage in public review.

549. Public Concern: The National Park Service should develop visitor and employee facilities at Yosemite West.

"I believe that you have overlooked the value of the area known as Yosemite West in the Draft of the Valley Implementation Plan, and I would like once again to offer the values of this strategically located, privately owned, and presently undeveloped 752 acres of land for your consideration before your final acceptance of the Yosemite Valley Plan. . . We have the potential to: 1. Reduce day use parking and traffic congestion in the Valley by providing another, perhaps more convenient, economical, and desirable parking site for day use visitors, who could then be bussed to the various points of interest from this centrally located site, 2. Provide a site for relocation of NPS and concessionaire employee housing, and, 3. Perhaps doing this more economically by involving the private sector in a partnership with the Park Service which could become a model for future public/private projects within the National Park System. I believe that there are many private corporations that would readily fund such a relocation project for the benefit of Yosemite National Park and the American Public, with their corporation being recognized of its generosity. I would like to urge you to at least take a look at the potential of our property and how it might fit into your Plan." (Individual, San Jose, CA - #5604)

Response: A specific proposal for the National Park Service to participate in a public-private partnership at Yosemite West for visitor and employee facilities has not been received. What has been tentatively proposed has been for the National Park Service to purchase land from private parties, and then find the financial means to construct visitor and employee facilities. The current landowner at one time pursued an amendment to the Mariposa County Zoning Ordinance to allow for the potential development of visitor and park operational facilities. The proposal has since been withdrawn. Yosemite West is outside the boundaries of Yosemite National Park and the National Park Service does not have the legal authority to purchase land outside the boundary of the park. Land already exists in federal ownership, primarily in El Portal, that can accommodate park needs without having to incur the additional cost of acquisition. Any development of private property in Yosemite West is subject to approval by Mariposa County. The National Park Service is committed to pursuing and participating in public-private partnerships to meet visitor, employee, and administrative needs. In order for such a partnership to succeed, there would need to be a net benefit to the federal government