Summary of Public Comments and Responses
Yosemite Valley Plan/SEIS
Yosemite National Park

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Comment Analysis Provided by:
USDA Forest Service Content Analysis Enterprise Team

Comment Responses Provided by:
US Department of the Interior, National Park Service
Yosemite National Park

November 2000

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Introduction

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The Role of Public Comment

Solicitation of public comment on draft plans for major National Park Service actions is required under the National Environmental Policy Act (NEPA). Further, the National Park Service must "assess and consider [the resulting public] comments both individually and collectively." Most importantly, such comments are viewed by the National Park Service as critical in helping park managers to shape responsible plans for our national parks that best meet the Service’s mission, the goals of NEPA, and the interests of the American public. During the formal comment period the public can review and comment on a draft plan’s alternative proposals for achieving stated park goals. (The comment period described here is part of a broader effort of public involvement and agency consultation fully described in Volume Ib, Chapter 5, Consultation and Coordination.) The comments received are analyzed and the results considered by park management while developing the Final Yosemite Valley Plan/SEIS. For a more complete discussion of how the National Park Service addresses public comments, see "Considering Different Types of Comments under the National Environmental Policy Act" in Chapter 1 of this Volume.

What is the Response to Public Comments?

This volume of the Final Yosemite Valley Plan/Supplemental Environmental Impact Statement (Final Yosemite Valley Plan/SEIS) describes the process used to "assess and consider" the public comments received (from March 28, 2000, through July 14, 2000) on the Draft Yosemite Valley Plan/ Supplemental Environmental Impact Statement (Draft Yosemite Valley Plan/SEIS). This volume also presents the public concerns identified, and provides responses to each concern by Yosemite staff. Each public concern statement is accompanied by quotes, taken directly from public comment letters, that support the concern and provide context for the staff response. Also included are chapters presenting other results of the analysis of public comment that help the reader understand the public’s response and a description of the analytical process.

Background

In the fall of 1998, Yosemite National Park in conjunction with the Secretary of the Interior, decided to consolidate four Yosemite Valley planning efforts into one comprehensive plan. Those four efforts had generated five draft plans: the 1992 Draft Yosemite Valley Housing Plan/Supplemental Environmental Impact Statement, the 1996 Addendum to the 1992 Draft Yosemite Valley Housing Plan SEIS, the 1997 Draft Yosemite Lodge Design Concept Plan/Environmental Assessment, the 1997 Draft Yosemite Valley Implementation Plan/Supplemental Environmental Impact Statement, and the Administrative Review Draft Lower Yosemite Fall Corridor Project/Environmental Assessment.

All of these earlier draft plans were to be brought together into a new plan, the Draft Yosemite Valley Plan/SEIS. This new effort clearly required a reconsideration and consolidation of previous public input. Altogether, four public review and comment periods were held on these earlier draft plans over a seven-year period. In chronological order, and with open periods for public comment listed in parentheses, they were: the 1992 Draft Yosemite Housing Plan/SEIS (8/92—9/92); the 1996 Addendum to the Draft Yosemite Valley Housing Plan/SEIS (12/6/96—4/1/97); the Yosemite Lodge Design Concept Plan/Environmental Assessment (4/10/97—5/16/97); and the Draft Yosemite Valley Implementation Plan/SEIS (11/27/97—2/23/98). As an administrative draft, the Lower Yosemite Fall Project had not reached the point of being released for public review. Taken individually, each of the three planning efforts released to the public for review and comment received significant attention. Altogether, and including scoping for the Draft Yosemite Valley Plan/SEIS, over 4,000 people had offered comments on the future management of Yosemite Valley during that period of planning.

Before the comprehensive Yosemite Valley Plan was started, public input on the four earlier documents released for public review had already helped advance planning for Yosemite Valley considerably. As each draft plan was completed, comments were analyzed relative to that plan and used to help rethink and refine the criteria for making planning decisions in Yosemite Valley. However, in earlier analyses of public input, National Park Service staff generally identified public comments relative to the project at hand, plan by plan. For example, comments about regional or parkwide transportation issues made as part of a response to the Yosemite Lodge Plan may not have been analyzed. This narrow focus of analysis also was used in the initial analysis of scoping comments on the Yosemite Valley Plan. Therefore, to capture and carry forward all comments relevant to the preparation of the Draft Yosemite Valley Plan /SEIS, the National Park Service undertook the rereading and analysis of all 6,468 letters, faxes, petitions, comment forms, and emails that were received between 1992 and 1999 in formal response to those three earlier plans and during scoping for the Draft Yosemite Valley Plan/SEIS.

This new analysis built on earlier analyses of public comment in response to each of the Yosemite Valley plans mentioned above. However, it differed significantly from those analyses in its comprehensive nature. Previously, National Park Service staff considered comments that pertained broadly to the planning process, raised a pertinent issue not raised before, or identified new information relevant to the planning process. The new analysis considered all comments whether general or specific, raised previously or new. The narrative summary of that analysis (U.S. Forest Service, Content Analysis Enterprise Team (CAET) 1999; Summary of Public Comment, Yosemite Valley Planning, 1992-1999) was a key tool used by Yosemite staff to ensure that the Draft Yosemite Valley Plan/SEIS addressed the full range of public comment. Incorporating the bulk of that report, Volume III of the Draft Yosemite Valley Plan/SEIS documents the analysis and response to public comment for that earlier planning (NPS 2000b).

After the analysis of this earlier public comment and during preparation of the Draft Yosemite Valley Plan/SEIS, the Draft Merced Wild and Scenic River Comprehensive Management Plan/Environmental Impact Statement (Draft Merced River Plan/EIS; NPS 2000a) was released for public review and comment. The Forest Service Content Analysis Enterprise Team (CAET) also analyzed the public comment on the Draft Merced River Plan/EIS, which was documented in a summary report (USFS 2000a) and in Appendix I of the Merced Wild and Scenic River Comprehensive Management Plan/Final Environmental Impact Statement (Merced River Plan/FEIS; NPS 2000c). The CAET staff provided Yosemite staff with an additional report, Summary of Public Concerns Related to Yosemite Valley Planning From Public Comments on the Draft Merced Wild and Scenic River Plan/Environmental Impact Statement (USFS 2000b). The public concern statements identified in this report were included in the deliberation process for the Final Yosemite Valley Plan/SEIS and are also presented in Chapter 5 of this Volume, along with responses by National Park Service staff. Concerns originating from public comments on the Draft Merced River Plan/EIS are numbered 1001 to 1178 to distinguish them from those derived from comments on the Draft Yosemite Valley Plan/SEIS.

The Analysis of Public Comment on the Draft Yosemite Valley Plan/SEIS

All letters, e-mails, faxes, comment forms, and transcripts of public hearing testimony received as comment on the Draft Yosemite Valley Plan/SEIS were read and analyzed by the U.S. Department of Agriculture, U.S. Forest Service Content Analysis Enterprise Team (a branch of the U.S. Forest Service Washington Office Ecosystem Management Staff) using a process they developed, called "content analysis," for comprehensively analyzing the content of public comment on a proposed plan or project. Over the last five years the Content Analysis Enterprise Team has used this process for analyzing public comment from several important planning efforts, including the Glacier National Park General Management Plan revision, and the Interior Columbia Basin Ecosystem Management Plan. For Yosemite National Park, the Comment Analysis Enterprise Team has analyzed the scoping comments for the Merced River Plan/FEIS, reanalyzed public comments received on four draft plans for Yosemite Valley that led to the development of the Draft Yosemite Valley Plan/SEIS, and analyzed public comment on the Draft Merced River Plan/Environmental Impact Statement (USFS 1999a, USFS 1999b, and USFS 2000a, respectively).

This analytical process comprises three main components: a coding structure and process, a comment database, and this narrative summary. Initially, a coding structure is developed to help sort comments into logical groups by topics. The topical coding structure was derived from an analysis of the range of topics covered in relevant present and past planning documents, legal guidance, and letters received from the public. Use of these codes allows for quick access to comments in the database on specific topics. The coding structure was inclusive rather than restrictive in order to sufficiently capture all comments.

The second phase of the analysis involved reading each piece of correspondence and assigning codes to statements made by members of the public in their letters, faxes, and emails. Each letter was divided into discrete comments that were each assigned a code. Codes were assigned by one staff person, validated by another, and each discrete comment was entered as a verbatim quote, with its assigned code, into the comment database.

The third phase included identifying statements of public concern and preparing the narrative summary. Public concerns were derived directly from letters and through a review of the comment database. Each public concern presents, in a simple statement, a common theme found in the body of public comment. The public concern statement is worded to capture the action the public feels the National Park Service should undertake and provides decision-makers with a clear sense of actions the public is requesting. Concern statements are not intended to replace actual comment letters or sample quotes. Rather, they can help guide the reader to comments on the specific topic in which they are interested.

During the process of identifying concerns, all comments were treated equally–they were not weighted by organizational affiliation or other status of respondents, and it did not matter if an idea was expressed by thousands of people or a single person. Emphasis is on the content of a comment rather than who wrote it or the number of people who agree with it. All public concerns identified by the Comment Analysis Enterprise Team are included in this volume, whether supported by the comments of one person or many people. The process is not one of counting votes and no effort was made to tabulate the number of people for or against a certain aspect of the Draft Yosemite Valley Plan/SEIS. There are many reasons for this, the primary one being a desire to prepare the Final Yosemite Valley Plan/SEIS in a way that meets the mission of the National Park Service and best serves all the people–not just some.

Table III.I.1 presents three parameters that give a general picture of the scope of public response to the Draft Yosemite Valley Plan/SEIS. Because many people commented more than once, the number of signatures, though probably close, does not reflect the actual number of people submitting comments.

Table III.I.1–Number of Responses, Signatures, and Comments Received During Public Comment Period for Yosemite Valley Plan
Summary of Public Comment, Yosemite Valley Plan

Content analysis of this body of comment identified 693 public concerns that are presented in Chapters 2, 3, and 4 of this volume. Additionally, 178 public concern statements derived from the Draft Merced River Plan/EIS public comment process and related to the Draft Yosemite Valley Plan/SEIS were identified. These concerns from the Merced River planning process are presented in Chapter 5 of this volume, with National Park Service staff responses. As already mentioned, these latter concerns were also included in the deliberations leading to the Final Yosemite Valley Plan/SEIS.

Although these numbers give a general sense of public comment, they should be interpreted with caution–the analysis process used attempts to capture the full range of public comments, but those who responded do not constitute a valid random or representative sample of the general public. Thus, although this information can provide insight into the perspectives and values of the respondents, it does not necessarily reveal the desires of society as a whole.

A more detailed description of the Content Analysis Process is provided in Chapter 8 of this volume. For more information, the reader should refer to the original comment letters for the Draft Yosemite Valley Plan/SEIS, the CAET Summary of Public Comment (USFS 2000c), and database reports, all available in the Yosemite Research Library (write to: National Park Service, P.O. Box 577, Yosemite National Park, California 95389).

How to Use this Document

Generally, this Public Comments and Responses volume is divided into this Introduction; Chapter 1, which describes how public concerns were used in preparing the Final Yosemite Valley Plan/SEIS; Chapters 2-5, which present public concerns (each identified by a unique number, assigned when it is first entered into the database) and supporting quotes with National Park Service responses; and Chapters 6-8, which summarize other aspects of the analysis. Chapters 2-4 (with National Park Service responses added) and 6-8 are adapted from the CAET report, Summary of Public Comment: Yosemite Valley Plan/Draft Environmental Impact Statement (USFS 2000c). Chapter 5 (with National Park Service responses added) is based on the CAET report, Summary of Public Concerns Related to Yosemite Valley Planning, From Comment on the Merced Wild and Scenic River Plan (USFS 2000b).

Chapter Descriptions

CHAPTER 1 provides an overview of the different categories of pubic comments, as defined by the National Environmental Policy Act, and how each type of comment affects the staff response, describes how public concerns were screened by Yosemite staff in preparation for consideration by park management, outlines the thirty-three topical issues which were defined by public concerns, and briefly describes park management’s deliberation on those issues that led to modification of the Draft Yosemite Valley Plan/SEIS and the shaping of the Preferred Alternative in the Final Yosemite Valley Plan/SEIS.

CHAPTER 2 includes public concerns, supporting quotes, and staff responses on general themes regarding the purpose of Yosemite National Park, the mission of the National Park Service, the purpose and need for action, relationships between different planning efforts inside and outside the park, public involvement, compliance with land management laws, and funding for implementing plans.

CHAPTER 3 presents public concerns, supporting quotes, and staff responses relating specifically to different draft plan alternatives.

CHAPTER 4 covers concerns and responses on specific topics organized by potentially affected resource or environmental consequence and includes sections on natural resources, cultural resources, transportation, access issues, recreation, visitor services, housing and park administration, and the socioeconomic effects of park planning.

Chapters 2, 3, and 4 each begin with a general introduction followed by sections and subsections on more specific topics. At both the section and subsection levels, public sentiments on the relevant topic are summarized in a brief narrative, followed by one or more statements of public concern. Note that, because all public concerns are presented, concern statements may offer contradictory direction to the National Park Service. Each public concern statement, or sometimes a group of related statements, is followed by an explanation of how the National Park Service dealt with that comment in the Final Yosemite Valley Plan/SEIS or why the comment was not dealt with in the plan. Sometimes the reader will be directed to a section of the Final Yosemite Valley Plan/SEIS where the actual response or modification can be found. Sometimes there is a reference to the response to another concern that provides related information. The Index to Public Concern Statements at the front of the Volume can help find the reference.

CHAPTER 5 lists public concerns and supporting quotes relating to Yosemite Valley planning derived from analysis of public comment on the Draft Merced River Plan/EIS, with National Park Service staff responses. This chapter does not including the narrative introduction to each section as found in Chapters 2, 3, and 4, but the sections are arranged according to the same topical outline for ease of reference.

CHAPTER 6 briefly discusses Response Demographics of the public comment.

CHAPTER 7 presents an overview of Organized Response Campaigns that resulted in form letters or petitions.

CHAPTER 8 briefly describes the Content Analysis Process and includes a list of the CAET and Yosemite staff involved in the analysis of public comments.