Yellowstone National Park
Comments Winter Use DEIS
Box 168 Yellowstone National Park
Wyoming 82190

Dear Planning Team:

I’d like to start with a couple of facts. Recreational snowmobiling hasn’t been allowed in the Park for many decades.   There has been no cross country off roading for years. For the last several years regular snowmobiles haven’t been allowed. The snowmobiles that are allowed are specially manufactured vehicles. These vehicles are some of the cleanest and quietist of all the motorized vehicles allowed in the park. See “Portable Emission Measurements of Yellowstone Park Snow coaches and Snowmobiles” by Gary A. Bishop, Ryan Stadtmuller, Donald H. Stedman, and John D. Ray, Journal of the Air and Waste Management Association, 59:936-942.” They are so different that they deserve their own name “over the snow vehicle” (OSV). These facts aren’t new to you, but several groups are overlooking them because it interferes with their fund raising.

Snow coaches as they exist today have greater emissions per passenger and are noisier than the BAT OSVs. See “Exterior Sound Level Measurements of Snow coaches at Yellowstone National Park,” by John A. Volpe, National Transportation Systems Center of the U.S. Department of Transportation(August 2009). In fact the Park spent $5,000,000 of its own funds to come up with a workable snow coach that met the same environmental standards as a single person OSV, but were unable to develop one. These facts aren’t new to you, but several groups are overlooking them because it interferes with their fund raising.

Day light is limited in the winter, especially during cloudy days. “Human powered” recreationalists rarely travel over 10 miles from their starting point (20 miles round trip). Old Faithful is 31 miles from the West Yellowstone entrance. That means that all visitors will be using some form of motorized transportation to take them to their destinations that are over 10 miles from the Park boundaries. The report, “Winter Experiences of Old Faithful Visitors in Yellowstone National Park” by Wayne Freimund, Mike Patterson, Keith Bosak, and Shelly Walker Saxen, University of Montana, found that 87% of those surveyed were ‘very satisfied’ with their overall experience and the remaining 13% were ‘satisfied’. It is hard to argue with those results. There were over 14,000 visitors entering the Park thru West Yellowstone during this time period (winter of 2007-2008).

The Park has made great strides in balancing its’ resources and allowing the maximum number of visitors the experiences that they desire. Under ‘Alternative 7’ only approximately 11,500 visitors choosing to use single person OSVs will be allowed thru the West gate. That is compared to over 14,500 in the winter 2006-2007 and just over 14,000 in 2007/2008. I haven’t seen any documentation to support the need for a 20% reduction in visitors as compared to those previous years. The reduction will actually work out to be a greater percentage as the artificial limits that will be in place will never be reached, because:

  1. People usually travel in groups. These group numbers won’t always divide evenly into the arbitrary cap for that particular day.
  2. People historically don’t have to work on major holidays and weekends. The demand during these times will be greater than the caps and potential visitors will have to go elsewhere on their time off. Some of the weekdays won’t have the maximum number of visitors that are allowed.
  3. There is no guarantee that anyone who is bothered by motorized transportation will be able to get a reservation on those 9 days that the caps are set at an artificially low number. I believe that this will remain a first come first served reservation system. All the visitors will still have to use the transportation that the Park has available. According to the study, “Natural Soundscape Monitoring in Yellowstone National Park, December 2008-March 2009” by Shan Burson, Yellowstone National Park” you can only hear the motor vehicles for 2 minutes, 15 seconds when they pass by.    I can’t imagine how hearing these sounds for such a brief period could ruin anyone’s day. The reasoning for these artificially low numbers is flawed and will deprive many from visiting the Park.

I propose that you raise the number of visitors thru the West entrance to 14,500. Let each operator have his share of that number and use it as demand dictates. For sure, the time period around Christmas/New Years’ will have more visitors than at other times. A greater number will be able to experience Yellowstone in the winter because, after all, they can only visit the Park on their own personal schedules. The average users per day will be 160, some days more and some less. You will have a situation similar to 2007-2008.

I don’t see a need to limit the entry to 10:30 a.m. If all 160 visitors showed up at 10:30 at the rate of 3 persons per minute, it would take over an hour for all of them to enter the Park. I would think that you would want to spread out the visitors.

Closing the side roads in Yellowstone to motorized vehicles will deprive the majority of the visitors the experiences that a place like Fire Hole Falls provides.

Efforts to address “quiet times” and areas should focus on appropriate places in Yellowstone. The entire east side of the Grand Loop is very quiet and could (and has) easily provided the targeted experience. The agency should not fall victim to the anti-access strategy of attempting to create yet another reason to eliminate motorized transportation access.

I have been told that I can’t point out some glaring (at least to me) inconsistencies in Park policy. According to the internet and Park records, over 50,000 visitors enter the Park in the winter season thru the East gate in their own vehicles. There are no restrictions on these vehicles what so ever.

I looked up an aerial photograph of Old Faithful on Google Map. It must have been taken in the summer. The large sidewalk surrounding the geyser is filled with people. It looked to me like there were more busses parked in that photo than the maximum number of visitors allowed thru the West gate on any winter day. Odd!

I thank you for the opportunity to provide my comments on this matter.

Sincerely,
Robbie Holman
President
Montana Snowmobile Association