comments in PDF - Lone Star Chapter, Sierra Club

Lone Star Chapter
June 13, 2008
Mr. John Lujan
Superintendent
Guadalupe National Park
Draft General Management Plan
400 Pine Springs Canyon Road
Salt Flat, Texas 79847-9400
Dear Superintendent Lujan,
On behalf of the Lone Star Chapter of the Sierra Club (Sierra Club) I am submitting
these comments regarding the proposed Draft General Management
Plan/Environmental Impact Statement (DGMP/EIS) for Guadalupe Mountains National
Park (GMNP or the Guads). The Sierra Club requests a hard copy and CD of the final
EIS and Record of Decision when it is complete and has been signed.
The Sierra Club has a long relationship with GMNP. It was the effort to create GMNP
that resulted in the creation of the Lone Star Chapter of the Sierra Club. Since that
time, over 40 years ago, the Sierra Club and its members have visited GMNP many
times and enjoyed its beauty and incomparable radiance while speaking in favor of and
acting on behalf of its protection. It is with this history in mind, the love and awe we
have for GMNP, and the desire we have to ensure its protection that we provide these
comments.
Before we begin our specific comments about the draft GMP/EIS we want to lay out
some of our most important concerns.
1) Scenic Vistas – Scenic vistas of the Guads, both from the high and low country,
looking outside its boundaries and from outside its boundaries looking in, provide the
majestic backdrop to enjoy and visit in a state of humility. It is this magnificent
Wilderness quality of GMNP that captures our imagination and must be protected. The
focus of GMNP must be as a Wilderness park.
2) Trails – In most of GMNP trails are the way we access this mountain and desert
jewel. Trails must remain as primitive and as protected as possible. Unfortunately
some trails, like the Guadalupe Peak Trail, need better maintenance. The Kincaid Trail
is one that could be kept for hearty hikers who want to go that way. The Old Stage
Route and Old Indian Trail could be rock cairned for primitive cross country, low
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country, use. In the future a trail connecting Carlsbad Caverns National Park, GMNP,
Lincoln National Forest, New Mexico state lands, and Bureau of Land Management
(BLM) lands should be carefully considered.
3) Horses – Horses should be limited to fewer trails to reduce geological, biological,
and ecological degradation and protect the vegetation, soil, and other natural resources
while providing a better experience for other uses. The Tejas Trail proper, PX Trail, Cox
Tank Trail, and old jeep road on the west side are possible trails that make sense for
horseback riding. Currently, 60% of the Guads trails are used by horses. We have
been told that horse use is very small in GMNP but there are no figures in the draft
GMP/EIS to verify this. A reduction in percentage of trails used by horses (perhaps by
20-50%) would ensure that environmental damage is reduced. Horse concessions
should not be allowed as they result in pressure on NPS to allow more damaging horse
use. Keep the existing public corrals but do not expand their size.
Something should also be done about the other impacts of horses. For instance, in our
recent visit to GMNP, on at least three occasions, when we visited Frijole Ranch and sat
under the tree canopy at the picnic tables next to the ranch house, the unmistakable
odor of horse manure could be smelled. For a historic location that is heavily visited this
is not a good way to introduce visitors to GMNP. In addition, the horse corrals are very
close to spring flow and a natural gully. If not carefully managed nutrients from horse
manure and urine could be washed by rain into the spring flow and natural gully thus
causing non-point source water pollution. These problems should be discussed
regarding the impacts of horses on GMNP.
4) Concessions – Any desire for stores and showers should not be the NPS’s
business. These are businesses better suited to locate outside the GMNP.
5) Salt Flats and Dunes – Limit the use via group size and numbers of vehicles to
protect this unusual and fragile habitat. No through roads and only small primitive
parking areas should be allowed. No campsites in or near the dunes. Let private
enterprise occur outside GMNP. Limit use to day use, have ranger guided tours, and
ensure people stay on whatever trails are used to reduce environmental degradation
and damage.
6) McKittrick Canyon and Watershed – The NPS must work with the U.S. Forest
Service (FS) to protect the complete watershed of McKittrick Canyon if it is to remain
protected and nearly pristine. In reality the essence of GMNP should flow by
management into Lincoln National Forest and the rest of the Guadalupe Mountains that
exist on FS or BLM lands. Doing this provides for more resilient habitats for plants and
animals and helps them adapt as the full effects of climate change are expressed.
Keep all development off the entire north rim of North McKittrick Canyon.
7) Wildlife – Allow elk and turkey to remain in GMNP. Remove all aoudad sheep.
Develop a carefully crafted non-native invasive plant species plan to reduce exotic
plants. This plan must recognize that Wilderness requires that the minimum tool be
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used with a non-motorized and mechanized hand on the land for non-native invasive
plant species control.
8) Wilderness – Much of GMNP is designated Wilderness or qualifies for designation
as Wilderness. The maximum landscape that qualifies for Wilderness must be
proposed by NPS to the U.S. Congress for designation as Wilderness. Ensure that
human effects (no installations and structures) are kept to a minimum. Wilderness
management must keep in mind the minimum tool requirement. The key for GMNP is
Wilderness appreciation for the fragile ecosystems of this small, beautiful, and unique
Wilderness national park. Maintain the park experiences that are already available in
the Wilderness park and do not try to make GMNP all things for all visitors. Do not
change the Wilderness focus simply due to evolving patterns of public use. Change for
the sake of change does not make sense. GMNP is not Yosemite or Grand Canyon
National Parks. The management of the Guads as a Wilderness park is right and
should be kept that way.
Why the National Park Service Plans and Summary
1) Page v, Why the National Park Service Plans, NPS states “The planning process
ensures that decision-makers have adequate information about benefits, costs, and
impacts on natural and cultural resources, visitor use and experience, and
socioeconomic conditions.” The NPS should remember that the “public” also must have
this information. That is what the National Environmental Policy Act (NEPA) and
Council on Environmental Quality (CEQ) NEPA implementing regulations requires and
why NPS must follow NEPA meticulously. NEPA is the only opportunity for the public to
find out about, review, comment on, and understand what is proposed for GMNP, which
it owns.
2) Page vii, Summary, Park History and Planning, NPS uses the phrase “interested
stakeholders”. NPS must remember that the public is the “owner” of NPS and GMNP
and therefore it is the public, not only so-called stakeholders, that must be looked to for
review, comment, and understanding of this proposal.
The NPS has expressed a concern about becoming irrelevant to the public. NPS
should explain what it means by this and state how this concern has shaped this draft
GMP/EIS.
3) Page x, Preferred Alternative and page xii Alternative C, the NPS states “The
preferred alternative would have mostly minor, long-term, adverse impacts on most
natural resource impact topics, primarily because about 200 acres of currently
undeveloped land would be permanently converted to developed park facilities” and
“Alternative C would have mostly minor, long-term adverse impacts on most natural
resource impact topics, primarily because about 500 acres of currently undeveloped
land would be permanently converted to developed park facilities.” The Sierra Club
does not consider the loss of 200 or 500 acres of natural habitat with functioning natural
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ecological processes a “minor” environmental impact especially since much of this area
may be appropriate for Wilderness designation.
3) Page x, Preferred Alternative, NPS states “Increased visitation that would result
from park improvements would have beneficial impacts on regional economies and
community infrastructure.” NPS does not mention at any point about the problem of
falling attendance in national parks, the increase in gas prices, and the problem of
climate change and its interaction with how people get to and get around GMNP. NPS
should thoroughly explore in this draft GMP/EIS these issues including coordinating with
private and public entities to bring people via bus and van to GMNP to reduce
greenhouse gas emissions, reduce space for vehicles in GMNP and land developed,
and reduce energy impacts.
4) Page xi, Alternative B, if Alternative B really has a major adverse impact on visitor
use and experience from eliminating camping except in the backcountry and a
moderate to major adverse impact on management and administration due to
insufficient space then why does this not constitute an impairment In the past, for
other NPS decisions (for example oil/gas activities in Big Thicket National Preserve), it
was suggested that up to moderate impacts were not impairment. So if you have a
major impact would this not constitute impairment or an unacceptable impact If it does
not then there is no impact that is greater than major and you can never, according to
NPS methodology spelled out on pages 218-244, ever reach impairment or
unacceptable impacts. This makes no sense.
Chapter1: Introduction
5) Page 9, Plan Review and Public Comment, the NPS states “the NPS planning
team will evaluate substantive comments”. The Sierra Club requests that NPS review
all comments. How does NPS define a substantive comment The public and
decision-makers should be able to review, comment on, and understand this definition.
After all the public is the owner of NPS and without the public’s support NPS would not
exist.
6) Page 10, Table 1, Conditions to Be Achieved at Guadalupe Mountains National
Park Based on Service-wide Mandates and Policies, Natural Resources: Air
Quality, NPS states “Air quality in the park meets national ambient air quality standards
for criteria pollutants. Park air quality is maintained or enhanced with no significant
deterioration. Nearly unimpaired views of the landscape both within and outside the
park are present. Scenic views are substantially unimpaired.” NPS says not one word
about the State of Texas (Texas Commission on Environmental Quality – TCEQ)
proposing in its regional haze state implementation plan (SIP) that it cannot meet the
EPA mandated deadline of 2064 for GMNP.
The TCEQ states that it may meet the regional haze standard by 2081 but that for the
next 5 years has proposed that it will do nothing to reduce regional haze. The Sierra
Club vigorously disagrees with NPS that it should eliminate air quality from this draft
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GMP/EIS as an issue topic. The NPS should commit to the public that it will push
TCEQ, at the very least, to meet the 2064 mandated deadline for reductions in regional
haze and that regional haze emissions will be reduced over the next 5 years.
NPS is required to protect all resources of our National Park System, including air
quality. NPS must do a better job and must include air quality as an issue topic in this
draft GMP/EIS. Otherwise NPS abdicates its authority and responsibility to ensure the
public breathes clean air and can see beautiful natural scenic vistas in GMNP
unimpaired. Particulates, which make up the bulk of the air pollutants that obscure the
scenic vistas of GMNP, also harm human health. Right now the scenic vistas are
indeed impaired and this should be noted and the public and decision-makers given the
opportunity to review, comment on, and understand the air quality issue topic in this
draft GMP/EIS.
In addition, NPS totally ignores climate change, which is due mostly to the release of
carbon dioxide (CO2) air pollution. Climate change is an air pollution problem on an
even larger scale than regional haze. Climate change will alter existing ecosystems and
make it more difficult for plants and animals to adapt successfully to these changed
ecosystems. NPS must address questions like:
1. How will GMNP be affected by climate change
2. What can be done to create more resilient and resistant habitats and ecosystems
3. What can GMNP do to reduce CO2 or other greenhouse gas emissions within the
park
4. What can be done to assist plants and animals so they can adapt to climate change
Climate change is an air pollution issue which threatens the fate of all existing
ecosystems in GMNP. Why does NPS remain silent about this issue Why is this issue
not addressed in the draft GMP/EIS
NPS should prepare and include in this draft GMP/EIS, a climate change ecological
resilience and resistance plan. This plan would assess the biological and ecological
elements in GMNP and the effects that climate change has had and will have on them.
The plan would also assist plants, animals, and ecosystems in adapting to climate
change and would require monitoring of changes and mitigation measure effectiveness.
The plan would be based on:
1. Protecting existing functioning ecosystems in GMNP.
2. Reducing stressors on the ecosystems in GMNP.
3. Restoring natural functioning ecological processes in GMNP.
4. Using natural recovery in GMNP, in most instances.
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5. Acquiring buffers and corridors to expand and ensure connectivity of ecosystems in
GMNP.
6. Intervening to manipulate (manage) ecosystems in GMNP only as a last resort.
7) Page 15, Implementation of the Plan, NPS states, “These steps often involve
stakeholder consultation”. What about public consultation It is the public that owns
GMNP and it should be consulted.
8) Page 19, Preserve Park Resources, NPS states “Scenic vistas from within and
outside the park boundaries are protected from significant intrusions.” What is a
significant intrusion Where are they located outside or inside GMNP What does
NPS propose to do about them How does NPS propose to alleviate them How will
NPS protect GMNP from “significant intrusions” What are the solutions These
questions should be answered and this topic discussed in the draft GMP/EIS.
9) Page 19, Ensure Organizational Effectiveness, NPS states “Adequate resources,
including infrastructure, staffing, and budget are available to adequately operate,
maintain, and protect the park” and then says on Page 15, “It should be understood that
the approval of the plan does not guarantee that the funding and staff needed for plan
implementation will be available”. What if NPS does not have the money or staff to
implement the draft GMP What has the highest priority for implementation The
Sierra Club supports implementing full natural resource protection elements first before
any elements are implemented that deal with development, recreation, or that degrade
GMNP’s natural environment.
It is obvious that budgeting for complete implementation of the draft GMP/EIS is
necessary for GMNP to be protected. We are aware, for instance, that the fire budget is
not large enough to allow for appropriate actions to allow the complete implementation
of prescribed fire management plans in GMNP. The fact that there are discussions
about conducting more fire activities, including the use of hand held saws in areas with
high fuel loadings in Wilderness, but that money is lacking to do this and that personnel
are pulled to fight other fires on federal public lands, should be thoroughly discussed in
the draft GMP/EIS.
In addition, the NPS must fully explain how such manipulations in Wilderness will
protect Wilderness character. Is the preventive control of high fuel loadings in
Wilderness allowed under the Wilderness Act Is the loss or partial loss of a major
forest ecosystem in GMNP due to fire considered negative to Wilderness character of
GMNP Since there is no discussion about any proposals (which are shunted to fire
management plans) this key, significant, issue (fire in Wilderness) is not discussed in
the draft GMP/EIS. The public and decision-makers need this information so they can
review, comment on, and understand what NPS proposes to do.
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10) Page 19, Ensure Organizational Effectiveness, NPS states “Park stakeholders,
partners … contribute to the decision-making process”. It is the public that should be
invited to contribute to the decision-making process that guides effective management
of GMNP’s resources.
11) Pages 25-26, Private Entities, NPS should clearly state what it intends to do to
reduce any potential impacts that Blue Origin, Wallacetown, and two subdivisions on the
boundary of GMNP will have on the park. How does NPS plan to address these and
similar incompatible development issues in the future in the draft GMP/EIS What is it
specifically in the draft GMP/EIS that will allow NPS to take care of these incompatible
uses so that GMNP is protected
12) Page 32, Facilities and Operations, NPS states “What level of minimum
improvement is necessary in wilderness to protect character and provide for resource
protection and visitor satisfaction” Visitor satisfaction should not result in installations
or structures being placed in Wilderness which would damage Wilderness character.
The Wilderness Act does not allow this. Human improvements are antithetical to
Wilderness which is supposed to result in human traces not being noticeable. The
Sierra Club is very concerned about this statement and requests that NPS change it to
reflect and be in compliance with what the Wilderness Act mandates.
13) Page 32, Pine Spring Canyon, NPS states “There is no sanitary dump station for
recreational vehicles and potable water facilities are inadequate for filling the water
tanks of recreational vehicles.” Should NPS cater to a type of use in GMNP that
generates such a large amount of waste; uses such a large amount of water; and
causes such a large amount of climate change emissions This makes no sense if this
draft GMP/EIS is to be called sustainable.
14) Page 35, Eastern Escarpment, the Sierra Club is in favor of either removing
unharmed or killing all exotic aoudad sheep from GMNP. These non-native species eat
native plants that wildlife need; displace native wildlife; or pass diseases to native
wildlife.
15) Pages 37-38, Basin and Range and Western Escarpment/Guadalupe Peak,
NPS states Basin and Range resources “are isolated and accessible only with
substantial effort” and “Western escarpment geological resources are not accessible for
many visitors.” Why is this a problem Perhaps with the description that NPS has
given in other places in the draft GMP/EIS of the importance of these natural resources
and the need for their protection that we should leave these geological resources so
that few view them and therefore can harm them. After all, there are many other
geological resources in the GMNP that are more easily available to visitors. All
geological resources do not all have to become easily available to the public. Protection
of geological resources must come first before any viewing by the public. These
phrases need to be thoroughly discussed.
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16) Page 38, Salt Basin Dunes, NPS states “Visitors … but are encouraged to avoid
walking on the fragile black crust of the cryptobiotic evaporitic soils.” Encouragement is
not enough! Very little is said in the draft GMP/EIS about how NPS will protect
cryptogrammic soils of the Salt Basin Dunes within the alternatives proposed. The
Sierra Club is very concerned about protecting the Salt Basin Dunes and all of its
biological, ecological, and geological resources.
17) Page 43, Air Quality, Topics Dismissed From Further Consideration, as the
Sierra Club stated in 6) above, we are against not including air quality as an impact
topic in the draft GMP/EIS. Air quality should be completely analyzed, assessed, and
evaluated in all alternatives of the draft GMP/EIS.
18) Pages 43-44, Conflicts with Land Use Plans, Policies, and Controls, the Sierra
Club disagrees that this impact topic should not be completely analyzed, assessed, and
evaluated in all alternatives of the draft GMP/EIS. This is particularly true since NPS
has outlined on pages 25-26 some of the threats to GMNP that we currently know. This
is a huge issue that must be addressed in the draft GMP/EIS. Air pollution is another
“private entity” problem that should be included under this issue topic.
19) Pages 45-48, Floodplains and Wetlands, the Sierra Club disagrees that this
impact topic should not be completely analyzed, assessed, and evaluated in all
alternatives of the draft GMP/EIS.
On page 46, the Sierra Club recommends that the phrase “or acquiring” be added to the
protective elements for wetlands.
20) Page 48, Lightscape Management and page 49, Soundscape Management, the
Sierra Club disagrees that these impact topics should not be completely analyzed,
assessed, and evaluated in all alternatives of the draft GMP/EIS. NPS has already
pointed out that development pressures are increasing and therefore in the next 15-20
years there will be more lightscape and soundscape problems. This must be addressed
in the draft GMP/EIS so that public and decision-makers can review, comment on, and
understand what NPS proposes to do about these impact topics.
21) Pages 50-51, Special Status Species (Threatened and Endangered Species,
Species of Concern, and Designated Critical Habitats) and Species Restoration,
Exotic Species Control, and Extirpated Species Reintroduction, the Sierra Club
disagrees that these impact topics should not be completely analyzed, assessed, and
evaluated in all alternatives of the draft GMP/EIS. For instance, feral hogs have been
found at the very boundary of GMNP, right next to MiKittrick Canyon. NPS needs to be
specific on how it will prevent these destructive riparian species before they enter one of
the most sensitive habitats in the entire GMNP.
It is NPS’s responsibility to protect special status species, reduce problems with exotics
species, restore ecological functions, and reintroduce extirpated species. The way NPS
wants to protect these issue topics should be integrated in all alternatives of the draft
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GMP/EIS so that public and decision-makers can review, comment on, and understand
what NPS proposes to do about these impact topics.
22) Pages 51-52, Water Quality and Quantity (Surface and Groundwater), the Sierra
Club disagrees that this impact topic should not be completely analyzed, assessed, and
evaluated in all alternatives of the draft GMP/EIS. Water is the lifeblood of the desert
and high mountain areas. The way that NPS wants to protect water quality and quantity
should be in all alternatives of the draft GMP/EIS. What does “would substantially
change” mean The public and decision-makers need this information so they can
review, comment on, and understand the Preferred Alternative.
23) Page 52, Wilderness Resources and Values, the Sierra Club disagrees that this
impact topic should not be completely analyzed, assessed, and evaluated in all
alternatives of the draft GMP/EIS. This is particularly true since GMNP is a Wilderness
national park.
The Sierra Club does not support additional use of dynamite to make trails and does not
believe that NPS should focus on “improve safe access to wilderness areas”. NPS
should focus on protecting Wilderness character. Wilderness character should not be
degraded to make Wilderness safe for visitors. This is what the Wilderness Act
requires.
Wilderness is where people enter at their own risk and bow to the risks that Wilderness
poses, on Wilderness’ terms. It is a place where humans leave their arrogance at the
Wilderness boundary and enter with humility and not with the typical control and
manipulation (trammeling) that we do in our human modified and built environment.
NPS should not be in the business of de-wilding and de-fanging Wilderness.
More trails are not needed in designated Wilderness in GMNP. NPS calls building new
trails in GMNP “long-term beneficial impacts” but the Wilderness Act says that
installations and structures are not allowed. Building new trails would result in reduced
Wilderness character which is a long-term negative impact and these actions are not
beneficial to Wilderness protection and the protection of Wilderness character. The way
that NPS will protect Wilderness character should be in all alternatives of the draft
GMP/EIS so that public and decision-makers can review, comment on, and understand
what NPS proposes to do about these impact topics.
Chapter 2: Alternatives, Including the Preferred Alternative
24) Page 56, Visitor Use Capacity, the NPS states “Rather, user capacity is measured
by comparing desired resource and visitor experience conditions to actual conditions
and, when an imbalance is noted, employing management practices to return to the
desired conditions.” This may be true in instances but for some resources there is no
returning to the “desired conditions”. For instance, soil erosion and cryptogrammic crust
damage is in essence forever because the process of creating soil and cryptogrammic
crusts, especially in desert and or mountain habitats, is extremely slow. The loss of 200
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or 500 acres due to construction of built environments means these areas “would be
permanently converted to developed park facilities” and would not longer qualify as
Wilderness. These are irreversible and irretrievable commitments of resources.
25) Page 56, Visitor Use Capacity, the NPS states “Within GMNP: visitor use capacity
planning currently is needed at McKittrick Canyon … The use of this technique may also
be appropriate at the Salt Basin Dunes within the 15 to 20 year timeframe of this
document.” The Sierra Club supports and urges NPS to be proactive and not wait until
unacceptable visitor use occurs and damage is done before setting capacity limits. This
is particularly important for the Salt Basin Dunes since easily damaged natural
resources like cryptogrammic crusts can be permanently damaged or the damage can
be such and the time taken for recovery is so long that there are irreversible and
irretrievable degradation and destruction. NPS should be proactive for the protection of
all GMNP resources.
26) Page 57, Management of Wilderness, the Sierra Club requests that we be placed
on the list to be notified about any wilderness study for future designation of Wilderness
and any proposal to change the Wilderness management plan.
The Sierra Club is very concerned about NPS’s treatment of Wilderness management
and designation and the Wilderness Eligibility Assessment in Appendix D. There is no
discussion or mention that previously the NPS conducted a Wilderness Suitability
Assessment that was approved by the Director of the NPS and sent to the Department
of the Interior (Assistant Secretary of the Interior for Fish Wildlife, and Parks) and was
delayed and then rejected over a period of years, along with other similar studies for
other units of the National Park System. Enclosed are materials detailing this illegal
action and our letter of protest of February 7, 2004. The public does not know that a
previous Wilderness Suitability Assessment was conducted by reading the draft
GMP/EIS. Why
The previous Wilderness Suitability Assessment found that there were 38,134 acres of
land suitable for Wilderness designation. However, the NPS now states there are only
35,484 acres suitable for Wilderness designation. This is a difference of 2,650 acres.
The draft GMP/EIS never discusses why there is a difference between the two
analyses. What areas that were found to be suitable for Wilderness in the earlier study
have been found not to be suitable by the study that is in Appendix D Why have the
2,650 acres been disqualified for Wilderness What criteria were used The public and
decision-makers must be able to review, comment on, and understand what NPS
proposes to do about Wilderness. See Attachment 1.
NPS must also clearly show in all alternatives of the draft GMP/EIS why backcountry
zone designation “would protect these lands (Wilderness eligibility lands) from
incompatible development and inappropriate use”. There is no description of the uses
allowed in backcountry zones and how these zones differ from designated Wilderness
areas.
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27) Page 57, Management Zones for the General Management Plan and page 62,
Developing Management Concepts, “Alternative A, the no action/continue current
management alternative, does not include the use of management zones, and also may
not meet all park management goals … Alternative A does not necessarily meet all of
the goals and objectives that are critical if the National Park Service is to consider the
general management plan successful”.
How does not meeting “park management goals” equate with “impairment” in GMNP It
is not clear to the public when not meeting goals affects “impairment”. In addition, if not
meeting all park management goals is not an impairment (notice it says goals and
objectives that are “critical”) how important is meeting those goals The NPS never
says and never is as specific as it should be so the public and decision-makers can
review, comment on, and understand the proposal.
28) Page 58, Designated Wilderness, NPS states “The park’s wilderness
management plan would be updated to include specific indicators and standards to
achieve wilderness management objectives”. What are the Wilderness management
objectives Why have these indicators and standards not been developed before now
When will the update process occur The Sierra Club requests that its name be placed
on the list to be notified about this process so we can participate.
29) Page 58, Designated Wilderness, the NPS states “the resource, such as removing
invasive plants or rehabilitating damaged areas”. Throughout the draft GMP/EIS there
is no thorough discussion about how invasive plants or animals will be removed or killed
in Wilderness. In addition, NPS does not discuss how it will manage Wilderness so that
its actions protect Wilderness character. Doing so is key if Wilderness is to be
protected. Without such specific discussion and language in the draft GMP/EIS the
public and decision-makers cannot review, comment on, and understand how
Wilderness character will be protected via Wilderness management.
For instance, on page 59, Table 3: GMNP Management Zones for the Action
Alternatives, NPS states “Significant cultural resources could be present and, as
appropriate, are stabilized and preserved”. NPS uses words like stabilized, preserved,
and rehabilitated in relation to cultural resources but does not define these terms for the
public and decision-makers so they can be reviewed, commented on, and understood in
relation to the protection of Wilderness character via Wilderness management.
The Sierra Club is concerned that NPS may attempt to justify actions in Wilderness for
cultural resources that degrade Wilderness character. There is very clear and specific
case law (copies included) which does not allow the requirements of the National
Historic Preservation Act to trump the requirements of the Wilderness Act (protection of
Wilderness character). The attached decisions include Wilderness Watch and PEER
versus NPS, DOI, etc., June 28, 2005, dealing with Cumberland Island National
Seashore Wilderness; Olympic Park Associates, Wilderness Watch, and PEER versus
NPS and DOI, July 29, 2005, dealing with Olympic National Park Wilderness; and High
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Sierra Hikers Associations et al, versus United States Forest Service, June 8, 2006,
dealing with the Emigrant Wilderness Area. See Attachment 2.
The Sierra Club requests that NPS discuss in detail its proposal to allow actions in
Wilderness on behalf of cultural resource protection and how this affects Wilderness
character and will adhere to the Wilderness Act and protection of Wilderness character.
30) Page 60, Frontcountry, NPS states “improving trail delineation or hardening trails”.
The Sierra Club prefers that trails not be hardened. If hardening is needed perhaps that
is a sign that the trail should not go through the area that needs to be hardened or that
the carrying capacity of the trail has been exceeded and must be reduced to ensure that
natural resources are protected.
31) Page 61, Motorized Scenic Corridor, NPS mentions “the development of social
trails”. NPS does not state where social trails currently exist, what NPS has done about
these “social trails”, what resource damage has occurred, whether the trails have been
obliterated, what visitor use caused the “social trails”, etc.
In our recent visit to GMNP, the Sierra Club saw social trails at Manzanita Spring, on
the Smith Spring Trail, and at the Butterfield Stage historic site. These social trails
should either be restored to native ecosystem or incorporated as part of the official trail
system and protected with appropriate mitigation measures. NPS needs to fully
address this issue and its importance and how this draft GMP/EIS will deter the creation
of “social trails” or mitigate their use and damage.
32) Page 62, Developing Management Concepts, NPS states “The NPS’s preferred
alternative would incorporate “the best” elements of Alternative B and Alternative C …
seeks a balance between providing enhanced visitor opportunities and increasing
exposure to wilderness.” The Sierra Club suggests that NPS is biased on behalf of the
Preferred Alternative.
NPS uses words that are meant to sway public opinion like “best” and “balance” as if the
other alternatives also do not provide “best” and “balance”. For instance, since almost
all of the United States is not Wilderness and many natural lands have been destroyed
or heavily degraded does not Alternative B provide balance by protecting more
Wilderness or Wilderness-like lands than any other alternative and help provide some
additional balance to the loss of 90% or greater of most wild-land ecosystems Is this
not the “best” alternative for protecting Wilderness, natural resources, and human
visitation to natural landscapes It depends on how you look at the alternative and what
words are used. The Sierra Club urges the NPS to be unbiased in its use of words
when describing alternatives. NEPA and CEQ regulations require this.
33) Page 64, Annual Costs and Staffing, the Sierra Club is opposed to the reduction
in personnel at GMNP. We believe additional resource protection, law enforcement,
and interpretation employees are needed to ensure that the natural resources of GMNP
are fully protected. The Sierra Club does not support a core employee population of 34
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people since this is a loss and downgrading in needed personnel numbers from 40 in
2006.
The Sierra Club is aware that the Bush Administration has attempted to privatize and
shrink the federal employee population which protects public resources (“The
Commons”) and we have opposed these efforts. We do not support privatization of jobs
in the NPS since a person who works for the public, a public servant, is more likely to
value natural resources because they are not told to make money like someone who
works for a concessionaire or private company whose purpose is to make money. The
Sierra Club likes public servants in the NPS because we believe they can do the best
job and have the interest of the “People” in their hearts.
34) Pages 67-78, Alternative A: No Action/Continue Current Management, the
Sierra Club does not support Alternative A. This is because more protection of natural
resources, including naturally functioning ecosystems, is provided in Alternative B.
On page 71, the Sierra Club notes a wording bias by NPS against Alternative A. NPS
states “Currently, all cultural interpretive exhibits are housed at a location separate from
the visitor center that is only open part of the time”. This is where this description
should stop since it is only supposed to be a description of the alternative. However,
NPS biases the description of Alternative A so that the public will favor the Preferred
Alternative when it says “This limits the ability of visitors to see the cultural exhibits and
learn about the history of the area. Building a new headquarters would provide
additional space in the visitor center for the cultural exhibits”. This text should be found
only in Chapter 4: Environmental Consequences since this is a perceived
environmental problem; is considered to be analysis; and should be disclosed at the
time the alternatives are compared not when they are simply described.
The Sierra Club makes the same criticism about biasing against and for alternatives
with the language on page 71 which says “A new facility would allow for all museum
items to be kept in the park and stored in one place with appropriate environmental
controls.” This is analysis and rightfully belongs in Chapter 4 where alternatives are
compared and not when they are simply described. The same can be said for several
more statements on page 71. NPS must not bias this draft GMP/EIS because this
violates NEPA and the NEPA implementing regulations of the CEQ.
On Page 72, McKittrick Canyon, the Sierra Club supports removal of the electric
power line in McKittrick Canyon. The Sierra Club also recommends that the current
McKittrick Canyon nature trail interpretive signs be reviewed. The lettering used is
green and is hard to read in direct sunlight. Darker lettering may make reading of the
interpretive signs easier.
On Page 74, Management of Exotic Species, NPS does not state how Wilderness
character will be protected when exotic species are killed. The public and decisionmakers
need this information so they can review, comment on, and understand
Alternative A.
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On Page 75, Management of Research Natural Areas, the NPS should show where
these areas are, tell how many acres they cover, and state what the purpose is of each
one. The public and decision-makers need this information so they can review,
comment on, and understand Alternative A.
On Pages 75-76, Historic Structures and Landscapes, NPS uses words like
preserved and stabilized but does not provide a definition and explanation about what
these words mean. This is particularly important in Wilderness (Hunter Line Cabin)
where Wilderness character must be protected when conducting any historic work. The
public and decision-makers need this information so they can review, comment on, and
understand Alternative A.
On Page 77, Hiking Trails, Trailheads, and Horse Use, NPS states that “Horseback
riding would continue to be allowed on some of the park’s interior trails”. The word
“some” is misleading. According to the Sierra Club’s calculation, using the Trails
Unlimited Map mileage of GMNP, about 47.7 miles of the 82 total miles of hiking trails
allow horses on them, which is over 50% of the trails (58.2%). Page 191 of the draft
GMP/EIS states “About 60 percent of the trails are open to horses”. This is more than
“some” trails allowed for horse use.
On Page 77, Park Operations, the NPS states “There would not be any commercial
services planning”. The Sierra Club supports no commercial services planning because
GMNP can be both hiked and ridden by horses without commercial services. This is
done currently and has been done very successfully for many years. There is no need
for commercial services planning. The primitive, Wilderness, quality of GMNP, which is
a small national park, should be kept, protected, husbanded because it is rare to find
these days. People need to enter Wilderness or Wilderness-like areas (backcountry)
with humility and on Wilderness’s terms and not ours, which often means reliance on
mechanized means and modern gadgets instead of our primitive skills and instincts.
Wilderness is for solitude, quiet, contemplation, enjoyment of natural sounds, and peace
for the soul. There are so few places like this anymore. The Sierra Club does not want
to see GMNP loved to death. As NPS states on page 90, “Visitors to Guadalupe
Mountains would be given opportunities to have a true wilderness experience at a selfsufficiency
level … Through direct experience, visitors would be able to gain a first-hand
understanding of wilderness values”.
On Page 78, Boundary Adjustment, the Sierra Club supports including the two parcels
of NPS owned land in the boundaries of GMNP. We also support acquiring more land
to provide protection the view-shed, to protect geological, biological, and ecological
resources, and to buffer GMNP from incompatible uses and provide migration corridors
for plants and animals due to climate change. NPS should discuss opportunities for
land acquisition including the 10,000 acres of land that is adjacent to McKittrick Canyon
that has recently gone on the market for $1,000/acre.
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42) Pages 79-93, Preferred Alternative, the Sierra Club does not support the
Preferred Alternative because it is less protective of Wilderness; encourages more
recreational activities than necessary; and causes more environmental damage.
On page 79, Concept, NPS states “Cultural resources, including historic structures,
would be stabilized and or preserved or rehabilitated and protected from impacts”. NPS
uses words like preserved, stabilized, protected, and rehabilitated but does not provide
a definition and explanation about what these words mean. This is particularly
important in Wilderness (Hunter Line Cabin for example) where Wilderness character
must be protected when conducting any historic work. The public and decision-makers
need this information so they can review, comment on, and understand the Preferred
Alternative.
On page 79, Concept, NPS states “surrounding the new Salt Basin Dunes staging area
… an expanded staging area at Williams Ranch”. What is a staging area Oftentimes
in the draft GMP/EIS NPS mentions parking areas or similar areas but then does not
state how many and what type of vehicles can use these areas and does not state how
large these areas are. The public and decision-makers need this information so they
can review, comment on, and understand the Preferred Alternative.
On page 80, Visitor Center Area, the NPS states “For example, video technology
could be used to present trips in park’s wilderness areas for those unable to access it
directly.” The Sierra Club understands that NPS is not thinking of installing cameras in
Wilderness for visitor enjoyment. This would be illegal because cameras and
associated equipment are installations or structures and are not necessary for the
management of Wilderness and will negatively affect Wilderness character. NPS
should explain what “video technology” is and ensure it does not include putting
installations and structures in Wilderness. The public and decision-makers need this
information so they can review, comment on, and understand the Preferred Alternative.
On page 83, New Campground, NPS talks about a new campground, but does not
state how many acres it would be. The Sierra Club recommends that each picnic table
in GMNP have a shade roof on it. Since GMNP has very high temperatures for many
months a year; the sunlight is so intense; and since little shade is available for visitors
the options at GMNP are limited to not staying at GMNP for long periods of time or of
crowding areas where shade is available (Visitor Center, Frijole Ranch, McKittrick
Canyon Visitor Center). A simple shade roof would make it easier for people to protect
themselves from the sun and heat.
The public and decision-makers need this information so they can review, comment on,
and understand the Preferred Alternative. The Sierra Club favors campgrounds being
run by NPS and not a “concessionaire”. Public servants make better protectors of the
public “Commons”. The Sierra Club also does not support any proposal for a horseback
riding concessionaire. People can bring their own horses and ride in GMNP. This is a
small park that cannot withstand a lot of use. A concessionaire wants to make money
15

and will push NPS for more use than should occur which will lead to more resource
degradation.
On page 83, Administration Facilities, NPS talks about new administration facilities
but does not state how many acres they would cover. The public and decision-makers
need this information so they can review, comment on, and understand the Preferred
Alternative.
On page 84, Frijole Ranch, Facilities and Activities, the Sierra Club does not support
continued dredging of Manzanita Spring so the pond would continue to exist. We prefer
that the pond slowly silt in and become a natural wetland like it once was before it was
altered by humans.
On page 85, McKittrick Canyon, Facilities and Activities, the Sierra Club supports
removal of the electric power line. What does NPS mean when it says “This could
include the use of information technology and audiovisual systems to maximize the
visitor educational experience”. The Sierra Club understands that NPS is not thinking of
installing cameras in Wilderness for visitor enjoyment. This would be illegal because
cameras and associated equipment are installations or structures and are not
necessary for the management of Wilderness and will negatively affect Wilderness
character. NPS should explain what “video technology” is and ensure it does not
include putting installations and structures in Wilderness. The public and decisionmakers
need this information so they can review, comment on, and understand the
Preferred Alternative.
On page 85, Dog Canyon, Facilities and Activities, NPS states it wants to put in
another group campsite. How large will that campsite be and how many people will be
allowed to camp in it The public and decision-makers need this information so they
can review, comment on, and understand the Preferred Alternative.
On page 86, Salt Basin Dunes, Management Zoning, Facilities and Activities, NPS
talks about zoning the area north of the existing road as frontcountry and states
“Staging and access for the Salt Basin Dunes area would be improved over time to
provide enhanced use as a visitor destination for day use”. How many acres would the
frontcountry zone and the visitor day use area be What is the nature of the
improvements mentioned The public and decision-makers need this information so
they can review, comment on, and understand the Preferred Alternative.
On page 86, Williams Ranch, Management Zoning, Facilities and Activities, How
many acres would the frontcountry zone and the visitor day use area be The public
and decision-makers need this information so they can review, comment on, and
understand the Preferred Alternative.
On page 87, Ship-on-the-Desert, how many acres would the administrative
campground be How many acres would the frontcountry zone and the visitor day use
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area be The public and decision-makers need this information so they can review,
comment on, and understand the Preferred Alternative.
On page 87, PX Well, how many acres would the new trailhead and small parking lot
be How long are the two trails Does it make sense to allow horse use in a fragile
area with cryptogrammic crusts and where exotic plants can be spread easily by horse
manure The public and decision-makers need this information so they can review,
comment on, and understand the Preferred Alternative.
On page 87, Guadalupe Pass Trailhead area, how many acres will the enlarged
parking area be How many and what type of vehicles could be parked here The
public and decision-makers need this information so they can review, comment on, and
understand the Preferred Alternative.
On page 88, Wilderness, are primitive sanitary facilities really needed in Wilderness
NPS needs to give more information about this issue. The public and decision-makers
need this information so they can review, comment on, and understand the Preferred
Alternative.
On page 88, Management of Human Disturbed Ecosystems, what does “aggressive
control of exotic plants” mean The public and decision-makers need this information
so they can review, comment on, and understand the Preferred Alternative.
On page 88, Management of Exotic Species, the Sierra Club supports the total
removal or killing of aoudad sheep because they compete with native species for food
and shelter. What exotic plants specifically does NPS want to eradicate What are
“more strict control measures” What is “aggressive management action” mean What
native plants will be planted and where will they be planted How will Wilderness
character be protected with regard to these proposed actions The public and decisionmakers
need this information so they can review, comment on, and understand the
Preferred Alternative.
On page 89, Management of Research Natural Areas, what other areas may be
designated as Research Natural Areas; where are they; and how many acres are they
The public and decision-makers need this information so they can review, comment on,
and understand the Preferred Alternative.
On page 89, Cultural Resources, NPS talks about preservation, stabilization, and
rehabilitation of significant resources. Are any of these resources in Wilderness
Where and what are the other discovery sites What restoration will be allowed in
Wilderness What is the NPS definition of restoration How is it described How will
Wilderness character be protected The public and decision-makers need this
information so they can review, comment on, and understand the Preferred Alternative.
On page 91, Interpretive and Educational Outreach Programs and Media, NPS
states “New audiovisual technology would present park themes information, and values
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… and audiovisual systems to maximize the visitor educational experience …
Computer-based audiovisual media would provide enhanced opportunities for those
who do not actually explore the park … Video technology would simulate trips in park’s
wilderness areas for those unable to access it directly … Interactive media … and other
technology would be enhanced to more effectively interpret park resources and values”.
The Sierra Club understands that NPS is not thinking of installing cameras in
Wilderness for visitor enjoyment. This would be illegal because cameras and
associated equipment are installations or structures and are not necessary for the
management of Wilderness and will negatively affect Wilderness character. NPS
should explain what “video technology” is and ensure it does not include putting
installations and structures in Wilderness. The public and decision-makers need this
information so they can review, comment on, and understand the Preferred Alternative.
On page 91, Interpretive and Educational Outreach Programs and Media, the
Sierra Club supports expansion of outreach to local communities and educational
groups, including El Paso and Juarez.
On page 92, Circulation and Parking, the Sierra Club does not believe that the ranch
road trace from the Salt Basin Dunes parking area several miles north and east to PX
Well needs to be improved. How large will the gravel surfaced parking lot be at the PX
Well trailhead The public and decision-makers need this information so they can
review, comment on, and understand the Preferred Alternative.
On page 92, Hiking Trails Trailheads, and Horse Use, NPS states “the NPS may add
to the park’s trail inventory by mapping hiking trails along abandoned trails and road
traces on the park’s west side”. How many trails is NPS referring to How long are
these trails What would be their environmental impacts Where are they located
specifically The public and decision-makers need this information so they can review,
comment on, and understand the Preferred Alternative.
On pages 92-93, Park Operations, are sanitation facilities really needed in
Wilderness If so where and why The Sierra Club does not support a commercial
service plan and does not support commercial horse operations at Frijole Ranch and
Dog Canyon and commercial campground operation at Pine Springs or Frijole Ranch.
The Sierra Club visited Dog Canyon and appreciated its remote and isolated location
and the minimal facilities available. We also found the NPS ranger on duty very helpful
and friendly.
Already horses are causing unacceptable damage to geological resources (fossils),
user conflicts, eroded trails, and exotic plant species introductions. More horse use will
only exacerbate these problems. The public and decision-makers need this information
so they can review, comment on, and understand the Preferred Alternative.
On page 93, Boundary Adjustment, the Sierra Club supports the boundary adjustment
as well as additional acquisitions for GMNP.
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On page 93, Costs, the Sierra Club does not support reducing the number of
employees at GMNP from 40 in 2006 to 34. NPS has fallen in line with the Bush
Administration’s siren call of a smaller federal work force when GMNP needs more
people to protect the public’s natural resources. The Sierra Club does not believe that
temporary and seasonal staff can pick up the slack in place of permanent full-time
employees. We understand, for instance, that there are, many cultural and
archeological resource sites throughout GMNP that have not be surveyed in many
years. This and other needed natural resource protection and interpretation work must
be funded and must have the personnel to carry out these actions. By not doing so
NPS runs GMNP in a penny-wise and pound-foolish way.
What is the “landscape rehabilitation work” that is referred to here The public and
decision-makers need this information so they can review, comment on, and understand
the Preferred Alternative.
43) Pages 94-103, Alternative B, the Sierra Club supports Alternative B with the
following changes:
1) Wilderness eligibility and designation for 38,134 acres instead of the proposed
35,487 acres.
2) Reduction in, but not elimination of, horse use (day use only) on trails in GMNP by
some percentage (perhaps 20-50%) to reduce environmental impacts on geological,
biological, and ecological resources and conflicts with hikers. If horseback riding is a
relatively small amount of use certainly there is not the need for 60% of the trails to be
designated for horse use. No removal of public corrals and no horse concession.
3) Proposed boundary adjustment and acquisition of additional lands (by fee title
acquisition or conservation easement) in Patterson Hills, Salt Basin and Flats,
Guadalupe Pass area, McKittrick Canyon area, Delaware Mountains, Guadalupe
Escarpment, and other sensitive areas to protect the GMNP view-shed; acquire
important geological and ecological areas; and to buffer GMNP from present and future
development pressures and to allow plants and animals to adjust to changes caused by
climate change.
4) Employment of at least 40 people and reject the downgrading of employee numbers
to a core of 34.
5) Aggressive push by NPS to get state and federal officials to address the deterioration
of scenic views due to regional haze air pollution sooner than the mandated 2064
deadline. Air Quality as an “impact topic” should not be dismissed from further
consideration in all alternatives of the draft GMP/EIS and should be fully analyzed,
assessed, and evaluated for all alternatives.
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6) Retention and possible expansion of the Pine Springs tent camping area and the
movement of the RV camping area so it is separated from the Pine Springs tent
camping area.
7) Support the treatment of Conflicts with Land Use Plans, Policies, and Controls;
Floodplains; Wetlands; Lightscape Management; Soundscape Management; Special
Status Species (Threatened and Endangered Species, Species of Concern, and
Designated Critical Habitats); Species Restoration, Exotic Species Control, and
Extirpated Species Reintroduction; Water Quality and Quantity; and Wilderness
Resources and Values as “impact topics” with full environmental analysis, evaluation,
and assessment for all alternatives in all alternatives of the draft GMP/EIS.
8) New consolidated park headquarters and office complex and cultural museum and
storage south of U.S. Highway 62/180 close to the maintenance area.
9) Full implementation of the Wilderness Act and protection of wilderness character
versus protection of human installations and structures and other human actions in
wilderness management.
10) Provision of a shuttle system for trails to reduce driving and parking impacts.
On page 94, Concept, NPS states “Visitor use levels would be actively managed”.
NPS must explain what it means by “actively managed”. The public and decisionmakers
need this information so they can review, comment on, and understand
Alternative B.
On page 94, Concept, NPS uses words like stabilized, preserved, or rehabilitated for
cultural resources. NPS must explain what these words and this system of cultural
resources protection means. NPS must discuss what cultural resources activities will
be allowed in Wilderness and how Wilderness character will be protected. The public
and decision-makers need this information so they can review, comment on, and
understand Alternative B.
On page 94, Concept and page 102 Hiking Trails, Trailheads, and Horse Use, NPS
states the park’s trail inventory could be expanded by mapping old ranch trails and road
traces”. Where are these What is their length What would be the environmental
impacts of doing this The public and decision-makers need this information so they
can review, comment on, and understand Alternative B.
On page 99, Management of Exotic Species, the Sierra Club supports removal or
killing of all aoudad sheep due to their negative impacts on native wildlife and plants.
NPS must explain what “eradicating all species of exotic plants throughout the park” and
“more strict control measures” and “native plant re-vegetation” mean. How will
Wilderness character be protected with regard to management of exotic species The
public and decision-makers need this information so they can review, comment on, and
understand Alternative B.
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On pages 99-100, Management of Research Natural Areas, where will these possible
Research Natural Area’s be; how many acres will each one cover; and what is the
purpose of setting aside each one The public and decision-makers need this
information so they can review, comment on, and understand Alternative B.
On page 100, Cultural Resources, NPS uses words like stabilized, preserved, or
rehabilitated for cultural resources. NPS must explain what these words and this
system of cultural resources protection means. NPS must discuss what cultural
resources activities will be allowed in Wilderness and how Wilderness character will be
protected. The public and decision-makers need this information so they can review,
comment on, and understand Alternative B.
On page 101, Visitor Education, Interpretation, and Orientation, NPS uses the
phrase “enhanced resource restoration”. What does this mean and how will it be
implemented The public and decision-makers need this information so they can
review, comment on, and understand Alternative B.
On page 101, Interpretive and Educational Outreach Programs and Media, NPS
uses the phrases “information technology and audiovisual systems”; “audiovisual
media”; “video technology”; and Interactive media, the park’s Internet site, and other
technology”. What do these phrases mean
The Sierra Club understands that NPS is not thinking of installing cameras in
Wilderness for visitor enjoyment. This would be illegal because cameras and
associated equipment are installations or structures and are not necessary for the
management of Wilderness and will negatively affect Wilderness character. NPS
should explain what “video technology” is and ensure it does not include putting
installations and structures in Wilderness. The public and decision-makers need this
information so they can review, comment on, and understand Alternative B.
On page 102, Park Operations, are sanitation facilities needed in Wilderness What
criteria will be used to decide this How will Wilderness character be protected The
public and decision-makers need this information so they can review, comment on, and
understand Alternative B.
On page 102, Boundary Adjustment, the Sierra Club supports the boundary
adjustment and the acquisition of more lands to protect GMNP.
On page 103, Costs, the Sierra Club does not support the reduction of full-time
employees from 40 to 34. The Sierra Club supports NPS hiring more full-time
employees for law enforcement, resource protection, and interpretation.
44) Pages 104-117, Alternative C, the Sierra Club opposes Alternative C because it
emphasizes too much development (at least the loss of 500 acres of potential
Wilderness).
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For instance, the Sierra Club does not support an expanded corral area south of Frijole
Ranch; dredging of Manzanita Spring; extended hours in McKittrick Canyon after dark;
improved access to a seep on the McKittrick Nature Trail; construction of bridges across
McKittrick Canyon; overnight use of the Pratt Cabin; restrooms and potable water
system at Pratt Cabin; concessionaire operations for camping and horse facilities;
improving the Meadow Nature Trail; new picnic area at Dog Canyon; new trail between
Manzanita Ridge between the Tejas and Bush Mountain Trails; upgrading of
recreational vehicle camping facilities; expanded corral for commercial packers or a
horse concession in Dog Canyon; the large development proposed for the Salt Basin
Dunes; a road from Williams Ranch to the west boundary of the park; the
commercialization via corporate partnerships of the expansion of the Ship-on-the-Desert
facilities; additional trails in Wilderness; etc.
On page 104, Concept, where will the new trails that NPS mentions be What is their
length What would be the environmental impacts of doing this The public and
decision-makers need this information so they can review, comment on, and understand
Alternative C.
On page 111, Management of Human Disturbed Ecosystems and Exotic Species,
the Sierra Club supports removing or killing all aoudad sheep. What does “aggressive
exotic plan control”; “eradicating target species of exotic plants throughout the park
(which species are targeted)”; and “aggressive monitoring and mitigation measures”
mean The public and decision-makers need this information so they can review,
comment on, and understand Alternative C.
On page 111, Management of Wetland and Aquatic Environments, what does “The
trail at Smith Spring would be improved” mean The Sierra Club found the trail to Smith
Spring in good condition and not in need of improvement. The public and decisionmakers
need this information so they can review, comment on, and understand
Alternative C.
On page 111, Management of Research Natural Areas, what are the RNA’s that are
being referred to How many are they Where are they located How many acres is
each one What are the environmental impacts of visitors using these areas The
public and decision-makers need this information so they can review, comment on, and
understand Alternative C.
On page 112, Historic Structures and Landscapes, NPS talks about preservation,
stabilization, and rehabilitation of significant resources. How will NPS ensure that
historic structure activities adhere to the overarching Wilderness Act requirements and
prohibitions How will Wilderness character be protected The public and decisionmakers
need this information so they can review, comment on, and understand
Alternative C.
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On page 113, Visitor Experience, NPS proposes degrading Wilderness so “More
visitors would be able to develop an understanding and experience of solitude because
of the improved ease of access to some currently more remote areas of the park”.
Wilderness needs to be visited on its terms not ours. We are not supposed to provide
“ease of access”. NPS in essence proposes the degrade Wilderness to educate people
to respect Wilderness. NPS teaches the wrong lesson. How will Wilderness character
and abiding by the Wilderness Act be accomplished in this way The public and
decision-makers need this information so they can review, comment on, and understand
Alternative C.
On pages 113-114, Visitor Access, the Sierra Club does not support “increased horse
use” and “Overnight horse use” because this will result in more user conflicts; more
destruction of geological features; more biological and ecological damage (like
introduction of exotic plants); and more soil erosion and sedimentation.
On pages 114-115, Hiking Trails, Trailheads, and Horse Use, the Sierra Club is
concerned that NPS does not state what the environmental impacts will be of each of
the proposed trails; what are the impacts on Wilderness character; and what are the
impacts of implementation on the Wilderness Act. Some of the trails NPS talks about
are not identified, their length not stated, and their location not provided. The public and
decision-makers need this information so they can review, comment on, and understand
Alternative C.
The Sierra Club agrees that shuttle system makes sense in GMNP. The Sierra Club
does not support a horse concession in GMNP including Frijole Ranch and Dog
Canyon.
On pages 116-117, Costs, the Sierra Club supports the employment of additional fulltime
employees in GMNP for law enforcement, resource protection, and interpretation.
45) Page 118, Implementation, NPS states “The park would prioritize implementation
to focus on visitor experience and safety, resource protection …”. Resource protection
should be prioritized and implemented first over any other goal. What does this
statement mean The public and decision-makers need this information so they can
review, comment on, and understand its proposal.
46) Page 118, Implementation, the Sierra Club is very concerned about NPS’s
constant reference to concessions and other privatization type operations. For instance
NPS states “To fully implement the general management plan, the National Park
Service, would consider other mechanisms, including partnerships and providing some
visitor serves through a concession operation … Concession operations would be
considered for actions determined to be necessary and appropriate commercial visitor
services and would be implemented in accordance with a commercial services plan”. It
is obvious, from the efforts of the Bush Administration, that this means privatizing the
public “Commons” via corporate control of public resources. The Sierra Club is very
23

concerned about this and recommends no concession operations because they are not
needed at GMNP.
47) Page 119, Mitigative Measures, NPS does not tell what the “compliance
monitoring program” is for mitigation measures. The public and decision-makers need
this information so they can review, comment on, and understand its proposal.
48) Page 120, Soils, NPS states “Monitor for visitor impacts”. What monitoring is this
What will be implemented The public and decision-makers need this information so
they can review, comment on, and understand Alternative C.
49) Page 120, Plant Communities and Vegetation, NPS states “Monitor areas used
by visitors”. What monitoring is this What will be implemented The public and
decision-makers need this information so they can review, comment on, and understand
Alternative C.
50) Page 120, Water Resources, NPS states “Work to minimize erosion from trails”.
How will this be done The public and decision-makers need this information so they
can review, comment on, and understand Alternative C.
51) Page 120, Wetlands, NPS states “Improve trails through wetland areas to minimize
impacts on vegetation”. How will this be done The public and decision-makers need
this information so they can review, comment on, and understand Alternative C.
52) Page 123, Noise Abatement, NPS states “minimize objectionable noise, and
exploring opportunity to reduce the sounds of human caused noise”. How will this be
done What is “objectionable noise” The public and decision-makers need this
information so they can review, comment on, and understand Alternative C.
53) Page 123, Sustainable Design and Aesthetics, why does NPS require
sustainable projects “whenever practicable” when it requires protection of cultural
resources “to the greatest extent possible” Why should sustainability be less important
than the protection of cultural resources The public and decision-makers need this
information so they can review, comment on, and understand Alternative C.
54) Page 124, Future Studies and Implementation Plans, the Sierra Club does not
support preparation of a commercial services plan. It is not needed for a small,
Wilderness oriented park like GMNP.
55) Page 124, Alternative B, NPS should define restoration and state what the
restoration plan would be. The public and decision-makers need this information so
they can review, comment on, and understand Alternative B.
56) Pages 126-127, Environmentally Preferred Alternative and Table 5, Alternative
B has been low-balled by NPS since it met criteria 3 and 5 yet NPS says it does not.
What does “the widest range of beneficial uses of the environment” mean What does
24

“achieving a balance between population and resource use” mean The public and
decision-makers need this information so they can review, comment on, and understand
the proposal.
57) Page 128, Alternatives or Actions Considered But Dismissed From Detailed
Evaluation, NPS states “Protect air quality – Although the park is classified as a Class
1 air quality management area, the park staff has limited ability to address air pollution
that drifts to the park from regional sources, particularly pollution sources in Mexico”.
NPS does have a lot of authority to review permits, to urge EPA and TCEQ to do their
jobs, to work with Mexico to reduce air pollution. NPS should not play helpless since it
is the public’s park and air resources that suffer. The public deserves better. Air quality
should be an issue topic in the draft GMP/EIS and not cast aside because NPS says it
is helpless to do anything.
58) Page 129, Alternatives or Actions Considered But Dismissed From Detailed
Evaluation, the Sierra Club agrees that motor vehicle access to the high country;
mountain bike use on trails; selling or leasing portions of park lands; the tram to
Guadalupe Mountain; and road from Williams Ranch to the west; are inappropriate in
GMNP.
59) Pages 131-138, Table 6, Features of the Alternatives, NPS must define
“aggressive management” for exotic species”; “Eradicate target invasive species” (what
species); “more strict prevention measures”; “More aggressively protect water quality
and quantity”; “Stabilize and preserve”; “site restoration”; and other similar phrases.
The public and decision-makers need this information so they can review, comment on,
and understand the proposal.
60) Pages 139-143, Table 7, Summary of Impacts, Alternative B, NPS states “The
elimination of the hammering action of horseshoes on fossil deposits in trails would
have a long-term, beneficial impact”. Why is NPS proposing in the Preferred Alternative
to continue to allow this “hammering action of horseshoes” at the present levels The
public and decision-makers need this information so they can review, comment on, and
understand the proposal.
On page 144, Alternative B, removal of cultural structures so they can be protected is
a positive and not adverse effect. On page 145, allowing Manzanita Spring to fill
naturally is not an adverse impact on the cultural landscape because it is what the
settlers found when they first arrived. On page 147, closing the road to the Salt Basin
Dunes parking area has a positive impact environmentally and would require people to
enter Wilderness on its own terms and not theirs. On page 148, Alternative B, NPS
has shown no documentation that there would be “increased demand for commercial
camping and other overnight lodging”. Park maintenance should be lower and
beneficially affected by Alternative B because there will be fewer facilities and horse and
frontcountry camping use would be eliminated. So how does NPS come up with a
“Moderate, long-term, adverse impacts” on maintenance This makes no sense. The
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public and decision-makers need this information so they can review, comment on, and
understand the proposal.
Chapter 3: Affected Environment
61) Page 157, Soils, NPS states “Many human activities are incompatible with the
presence and well being of cryptobiotic soils … Burial can mean death because crustal
organisms need light to photosynthesis … Under ideal circumstances, a thin veneer of
cryptobiotic soils may return in five to seven years, but in some disturbed areas … a
recovery period of 50 years or more”. For this reason why has NPS not been specific
about how it will protect these soils in the draft GMP/EIS Why is horse use allowed
where these soils exist The public and decision-makers need this information so they
can review, comment on, and understand the proposal.
62) Page 163, Chihuahuan Semi-desert Grassland, NPS states “With the cessation
of livestock grazing, these grasslands are recovering and expanding”. Where are these
areas How does NPS propose protecting them from the impacts of horses and other
uses The public and decision-makers need this information so they can review,
comment on, and understand the proposal.
63) Page 189, Visitor Understanding and Experience, NPS states “In descending
order, the five most desired experiences in this park are seeing wilderness and scenery,
hiking, viewing nature, seeing wildlife, and experiencing solitude or quiet.” For this
reason NPS should focus its efforts on drafting an appropriate GMP/EIS that protects
these desired experiences. It appears that Alternative B better protects these
experiences than any other alternative and at the same time protects the natural
environment the best.
64) Page 203, Park Operations, Facilities, and Equipment and page 206, Park
Budget, NPS says that in 2006 there were 40 full-time staff positions. The Sierra Club
does not support cutting this to 34 positions. This is pennywise and pound foolish
action. We need more law enforcement, resource protection, and interpretation
employees, not less.
65) Page 205, Park Budget, NPS states “Fees have averaged $88,300 over the past
four years, and revenues beyond the cost of collection are used for special projects”.
How much for each year since 2002 have revenues exceeded the cost of collection
What total amount of money each year are we talking about What projects have been
funded The public and decision-makers need this information so they can review,
comment on, and understand the proposal.
Chapter 4: Environmental Consequences
66) Page 213, Introduction, NPS uses the word “feasible”. What does this word mean
in the context it has been used The public and decision-makers need this information
so they can review, comment on, and understand the proposal.
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67) Page 213, Introduction, pages 216-217, Decision-Making to Avoid Impairment
or Unacceptable Impacts on Resources of Guadalupe Mountains National Park;
and pages 218-226, Methods for Analyzing Impacts, NPS states “Because of the
general, conceptual nature of the actions described in the alternatives, their impacts can
only be analyzed in general, qualitative terms. Thus, this environmental impact
statement should be considered a programmatic analysis.”
The Sierra Club has seen other programmatic EISs that provide more quantitative detail
than this one. For instance, the Minerals Management Service is able to quantify, at
least partially, what the impacts will be for lease sales for oil/gas activities in the
Western, Central, and Eastern Gulf of Mexico.
A dictionary usage of words or phrases will not suffice to provide the public with a clear
picture of what the intensity, significance, and context of environmental impacts are.
This draft GMP/EIS, by using qualitative and un- or ill-defined words and phrases
(negligible, minor, moderate, and major and the undefined phrases in their definitions),
ensures that the public and decision-makers cannot compare alternatives because they
cannot see now NPS judged them. In other words, an all or mostly qualitative
assessment, analysis, and evaluation of environmental impacts is not sufficient to deal
with the clearly articulated CEQ NEPA implementing regulations, Section 1502.14, that
the EIS “should present the environmental impacts of the proposal and the alternatives
in comparative form, thus sharply defining the issues and providing a clear basis
for choice among options by the decision-maker and the public”.
Quantitative assessment, analysis, and evaluation are necessary to ensure that
alternatives and environmental impacts are clearly defined, compared, and shown in the
EIS. As stated in the CEQ NEPA implementing regulations, Section 1500.1(b),
Purpose, “NEPA procedures must insure that environmental information is available to
public officials and citizens … The information must be of high quality. Accurate
scientific analysis … are essential to implementing NEPA”.
As stated in Section 1501.2(b), “Identify environmental effects and values in adequate
detail so they can be compared to economic and technical analyses.”
As stated in Section 1502.8, “which will be based upon the analysis and supporting
data from the natural and social sciences and the environmental design arts.”
As stated in Section 1502.18(b), about the Appendix, “Normally consist of material
which substantiates any analysis fundamental to the impact statement”.
As stated in Section 1502.24, “Agencies shall insure the professional integrity, of the
discussions and analyses … They shall identify any methodologies used and shall
make explicit reference by footnote to the scientific and other sources relied upon for
conclusions in the statement.”
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Most of the analysis that NPS has conducted for this EIS is “best professional
judgment”. “Best professional judgment” is where a group of people, using their
experience, decide what is important. This level of assessment, analyses, and
evaluation for environmental impacts and alternatives is an insufficient foundation upon
which to base the draft GMP/EIS and its conclusions.
The qualitative description of phrases used for environmental impacts or the
protectiveness of an alternative does not provide the public with the degree of
comparison required by the CEQ’s mandatory NEPA implementing regulations. These
regulations state, in Section 1502.14, Alternatives including the proposed action,
that, “This section is the heart of the EIS … it should present the environmental impacts
of the proposal and the alternatives in comparative form, thus sharply defining the
issues and providing a clear basis for choice among options by the decision-maker and
the public … Devote substantial treatment to each alternative in detail … so that
reviewers may evaluate their comparative merits.”
The CEQ also states, in Section 1502.16 and (d), Environmental Consequences,
that, “This section forms the scientific and analytic basis for the comparisons … The
environmental effects of alternatives including the proposed action the comparisons
under Section 1502.14 will be based on this discussion.”
It is key for NPS to clearly compare and make apparent the distinctiveness of each
alternative and its impacts or protectiveness. This is not accomplished when words like
“small” or “substantially” are used instead of quantitative information or more
detailed and clear descriptions of qualitative information. The Sierra Club requests
that NPS clarify and detail clearly the comparative differences between each
alternative and define clearly what the words or phrases used mean including the
words or phrases used in their definition.
In addition, the phrase “best professional judgment” is not defined in the EIS. NPS
must define what “best professional judgment” means so that the public can review,
comment on, and understand what NPS is referring to. Decision-makers also need to
know this information. The qualitative description of phrases used to describe
environmental impacts or the protectiveness of an alternative does not provide the
public with the degree of comparison required by the CEQ as outlined above.
The use of “best professional judgment” (page 218) is not a substitute when
quantitative information is available to show what impacts are or could be. This is the
concern that the Sierra Club has when NPS develops and uses the “impact threshold
definitions”. This methodology is based on “best professional judgment” but the
public is not told what this phrase means. The interaction of the “impact threshold
definitions” with the requirement in Section 1502.22 of the CEQ’s NEPA implementing
regulations must be discussed in detail in this EIS and where information is missing and
the NPS cannot obtain due to money or time then Section 1502.22 must be
implemented as required by CEQ.
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Section 1502.22, requires that when evaluating reasonably foreseeable significant
adverse effects on the human environment that incomplete or unavailable information
be plainly stated as lacking in the EIS. This section requires that if the costs of
obtaining this information are “not exorbitant” then the agency must include the
information in the EIS.
Finally, this section requires that if the information cannot be obtained due to exorbitant
costs that the agency must:
1. State the information is incomplete or unavailable;
2. State the relevance of this information to evaluating the significant adverse impacts;
3. Summarize the credible scientific evidence;
4. Then provide the agency’s evaluation of impacts based upon theoretical approaches
or research methods generally accepted in the scientific community
In the EIS the use of “best professional judgment” is the theoretical approach or
research method that is generally accepted in the scientific community that NPS uses to
assess the environmental impacts in this EIS for GMNP. On pages 218-219, NPS
states “In the absence of quantitative data, best professional judgment was used to
identify impacts … Analysis of natural resources was base don research, knowledge of
park resources, and the best professional judgment … For this document, the planning
team qualitatively evaluated the impact intensity for natural resources”. Therefore NPS
must give a thorough discussion of the use of this evaluation method in place of using
quantitative data for the impact issue that is being discussed and use Section 1502.22
of CEQ NEPA implementing regulations where quantitative data is not available.
NPS cannot substitute “best professional judgment” for gathering existing
quantitative data that it does have or gathering quantitative data that does not cost an
exorbitant amount to collect for this EIS. The Sierra Club opposes the use of “best
professional judgment” in lieu of using existing or not exorbitantly costly acquired
quantitative data. The Sierra Club requests that NPS clarify and detail clearly the
comparative differences between each alternative and define clearly what the
words or phrases used mean.
This EIS should be an attempt by the NPS to implement the recent court ruling in favor
of the Sierra Club and against the NPS about assessment of impacts and the
methodology used, from impairment and NEPA perspectives, which was deemed
inadequate, arbitrary, and capricious. By United States District Judge John D. Bates,
then it has failed. The judge’s decision stated, in part, in Sierra Club v. Mainella the
following:
“Because NPS’s impairment analysis served as its NEPA analysis, the flaws in the
impairment analysis also apply to the environmental assessment. Those shortcomings
29

are, first, NPS’s lack of explanation as to how it reached its conclusions, typically simply
describing the impacts followed by a conclusion that the impact was not an impairment
or, in the case of NEPA, that it was not “significant”; and second, the use of the
descriptors “negligible”, “minor”, “moderate”, and “major” that are largely undefined or
are defined in a manner that includes few objective bounds … nowhere explained the
basis for its conclusion that potentially “moderate” impacts could not be significant under
NEPA … There is no basis in the administrative record for accepting NPS’s conclusion
that even a “minor” impact is not significant under NEPA, because there are no
determinate criteria offered for distinguishing a “minor” impact from a “moderate” or
“major” impact other than NPS’s conclusory say-so … the scoping regulations still
require the agency to explain why they {dismissed issues} will not have a significant
effect on the human environment … Thus, the EA must provide a realistic evaluation of
the total impacts and cannot isolate a proposed project, viewing it in a vacuum … In
short, NPS’s three findings of no significant impact are, the court concludes, arbitrary
and capricious for many of the same reasons as are the impairment determinations. In
each decision, NPS has failed to take a “hard look” at impacts on the Preserve from
adjacent surface activities, as evidenced by the lack of explanations supporting its
conclusions and, in particular, its methodology of describing impacts using conclusory
labels and then setting forth a bare conclusion without explanation as to the significance
of an impact. NPS also failed to provide an adequate cumulative impacts analysis that
included the other oil and gas operations in the Gore Baygall Unit … However, NPS’s
ultimate conclusions that the drilling activities would not result in impairment of park
resources and values under the Organic Act, or a significant impact on the human
environment under NEPA, are not supported by reasoned explanations, and hence are
arbitrary and capricious and an abuse of discretion.”
It does not appear that the NPS has quantified in the EIS’s assessment many of the
impacts and the methodology has not removed the “conclusory statements” that Judge
Bates ruled against. Judge Bates states in his decision that the descriptors “negligible”,
“minor”, “moderate”, and “major” are largely undefined or are defined in a manner that
includes few objective bounds. These descriptors remain largely undefined and with
few objective bounds. In addition, the NPS still does not explain the basis for its
conclusion that potentially “moderate” impacts could not be significant under NEPA.
The Sierra Club is unable to find the complete analysis, assessment, and evaluation of
“unacceptable impacts”, except for a brief description on pages 216-217 of the EIS.
NPS states “The impact threshold at which impairment occurs is not always readily
apparent. Therefore, the National Park Service manages to avoid impacts that fall short
of impairment, but are still not acceptable” and then lists some qualitative and nonspecific
criteria for unacceptable impacts. For example, “impede the attainment of the
park’s desired future conditions”; “unreasonably interfere with”; “create an unsafe or
unhealthful environment”; and diminish opportunities for current or future generations”.
What do these words and phrases mean The public and decision-makers need this
information clearly stated and transparently presented so that it can be reviewed,
commented on, and understood in relation to the environmental impacts of the proposal.
30

Therefore, the following words or phrases (including the criteria themselves – negligible,
minor, moderate, and major), are not defined, inadequately defined, or are unquantified,
and must be defined and quantified so that the public and decision-makers
can review, comment on, and understand the proposal:
1) Soils, Pages 219
a. Negligible – “lower levels of detection” and “would be slight”
b. Minor – “would be small”; “relatively simple”; “likely to be successful”
c. Moderate – “readily apparent:; “would likely be long-term”; “relatively wide area”;
“would likely be successful”
d. Major – “readily apparent”; “would substantially change”; “over a large area”; “would
be needed and extensive”; “success could not be assured”
1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
2) Plant communities and Vegetation, Page 219
a. Negligible – “some individual native plants”; “could be affected”; “native species
populations”; “small scale”
b. Minor – “would affect some individual native plants”; “relatively minor portion”; “could
be required”; “would be effective”
c. Moderate – “some individual native plants”; “affect a sizeable segment”; “relatively
large area”; “could be extensive”; “would likely be successful”
d. Major – “considerable effect on native plant populations”; relatively large area”;
“would be required and extensive”; “success of the mitigation measures would not be
assured”
1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
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3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
3) Wildlife, Page 220
a. Negligible – “would be well within natural fluctuations”
b. Minor – “would not be expected to be outside the natural range of variability”; “not be
expected to have any effects”; “would be simple and successful”
c. Moderate – “particularly vulnerable life-stages”; “occasional basis”; “outside the
natural range of variability”; “would be extensive and likely successful”
d. Major – “outside the natural range of variability”; key ecosystem processes”; “might
be disrupted”; might affect the viability of at least some native species populations”;
extensive mitigation measures”; “success would not be assured”
1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
4) Geologic Resources, Pages 220-221
a. Negligible – “could result in a change”; lowest level of detection”
b. Minor – “could result in a detectable change”; “Would be slight and local”; Mitigation
might be used”; “would be relatively simple”; “likely successful”
c. Moderate – “clearly detectable change”; “would affect a substantial area”; “would
likely be successful”
d. Major – “substantial alternation”; “would be highly noticeable”; “would affect a large
area”; “would be necessary and extensive”; “success could not be guaranteed”
32

1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
5) Paleontological Resources, Pages 221-222
a. Negligible – “disturbance would be negligible”; “would be nearly indiscernible”;
“would be minimal”
b. Minor – “a few fossils”; “might be lost”; “would be a low probability”; Volume of
bedrock disturbance would be low”; “nearly indiscernible”; “would be minimal”
c. Moderate – “A number of fossils”; might be lost”; “moderate probability”; “would be
large”; “would be small”; “some fossils”
d. Major – Many fossils”; “could be lost”; “high probability”; High fossil richness”; volume
of bedrock disturbance would be large”; “probably would be lost”
1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
6) Ethnographic Resources, Page 223
a. Negligible – “barely perceptible”
b. Minor – “would be slight but noticeable”; “would neither appreciably alter”
c. Moderate – “would be apparent”; “would facilitate traditional access”
d. Major – “would alter resource conditions”; “greatly affect traditional access”; “survival
of a group’s practices and/or beliefs would be jeopardized”
33

1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
7) Museum Collections Pages 223-224
a. Negligible – “barely measurable”; “with no perceptible consequences”
b. Minor – “would affect the integrity of a few items”
c. Moderate – “would affect the integrity of many items”
d. Major – “would affect the integrity of most items”
1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
8) Visitor Experience and Understanding, Page 224
a. Negligible – “would not be detectable”; “not be any noticeable change”
b. Minor – “small but detectable”; ”not appreciably alter”
c. Moderate – Some changes”; “would be readily apparent”; “would be substantially
altered”; Most visitors”; “Visitor satisfaction would change”
d. Major – “Changes in multiple critical characteristics”; “would be readily apparent”;
“Most visitors”; “likely express a strong opinion”; “would be considerably altered”; “would
result in substantial changes”
34

1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
9) The Socioeconomic Environment, Pages 224-225
a. Negligible – “would be detectable only through indirect means”; “would result in no
discernible effect”
b. Minor – “would be detectable but localized in geographic extent or size of
population”; “would not be expected to alter”
c. Moderate – “would be readily detectable”; “across a broad geographic area”; “could
have an appreciable effect”
d. Major – “would be readily apparent”; “affect a substantial segment of the population”;
“likely have a noticeable influence”; “temporary in nature”
1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
10) Park Operations, Facilities, and Equipment, Pages 225-226
a. Negligible – “below detectable levels”; “would not have an appreciable effect”;
b. Minor – “would not have an appreciable effect”
c. Moderate – “would be readily apparent”; “would result in a substantial change”;
“manner noticeable to staff and the public”
35

d. Major – “would be readily apparent”; “would result in a substantial change”; “in a
manner noticeable to staff and the public”; “would be markedly different”; “have a
permanent effect”
e. Other phrases: “likely to have negligible effects”; “reach reasonable conclusions”
1. What do these phrases mean in the context cited in the text and quantitatively
2. Is the uncertainly great or small
3. What is the probability, risk, potential, and likelihood of these events happening
If the information that these questions ask cannot be obtained then Section 1502.22 of
CEQ NEPA implementing regulations must be implemented. The public and decisionmakers
need to know this information so they can review, comment on, and understand
the proposal.
Because of the NPS’s failure to define quantitatively (using non-quantitative terms like
negligible, minor, moderate, and major) the environmental impacts (including cumulative
environmental impacts) of all alternatives for the draft GMNP GMP/EIS on pages 227-
284, for the issue topics of Natural Resources (Soils, Plant Communities and
Vegetation, Wildlife, Geological Resources, Paleontological Resources); Cultural
Resources (Archeological Resources, Historic Structures, Cultural Landscapes,
Ethnographic Resources, Museum Collections); Visitor Experience and Understanding
(Access, Activities and Destinations, and Scenic Views; Interpretation, Education, and
Orientation); The Socioeconomic Environment (Regional Economic and Demographic
Conditions and Housing and Community Infrastructure); and Park Operations, Facilities,
and Equipment (Management and Administration, Employee Housing, and
Maintenance); The Relationship Between Local Short-Term Uses of the Environment
and the Maintenance and Enhancement of Long-Term Productivity; Any Irreversible or
Irretrievable Commitments of Resources Which Would be Involved Should the
Alternative be Implemented; and Any Adverse Impacts Which Cannot be Avoided
Should the Action be Implemented, this draft GMP/EIS has not followed the CEQ NEPA
implementing regulations including Section 1502.22. The public and decision-makers
need this information so they can review, comment on, and understand the proposal.
68) Page 213, Cumulative Impacts and Projects That Make Up the Cumulative
Impact Scenario, what does “reasonably foreseeable future” mean The public and
decision-makers need this information so they can review, comment on, and understand
the proposal.
69) Page 214, Subdivision Development, NPS should determine if it can buy the
proposed subdivisions on the west side of GMNP in the Salt Basin and on the south
boundary, east of Patterson Hills. It is very important to avoid hemming in and prevent
any incompatible use next to GMNP.
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70) Page 214, Mining and Drilling, NPS should ensure that it does all it can to keep
drilling from Otero Mesa and Crow Flats so the vistas and ecological integrity of GMNP
is kept intact.
71) Page 214, Water Exports, how is NPS going to address protecting aquifers in the
GMNP area The public and decision-makers need this information so they can review,
comment on, and understand the proposal.
72) Pages 214-215, Aircraft Overflights, what will NPS do to reduce aircraft over-flight
noise The public and decision-makers need this information so they can review,
comment on, and understand the proposal.
73) Page 215, Lincoln National Forest, New Mexico, what logging, road building,
mineral extraction, and prescribed burning does Lincoln National Forest do in the
greater GMNP ecosystem The public and decision-makers need this information so
they can review, comment on, and understand the proposal.
74) Pages 227-228, Alternative A: No Action, Soils, what do “small areas”; “relatively
small area” mean The public and decision-makers need this information so they can
review, comment on, and understand the proposal.
75) Page 227, Alternative A: No Action, Soils, NPS states “Trails were constructed to
minimize impacts on soils by concentrating hikers on a maintained surface”. What does
“maintained surface” mean Why does NPS ignore horses since they cause more soil
and vegetation damage Horses also need to remain on the trail surface to reduce
environmental damage.
76) Page 229, Plant Communities and Vegetation and page 231, Wildlife and page
233, Geological Resources, NPS states “Lands outside the park boundary that are
considered critical to protecting important park related resources, including habitat for
important species of plants, might be acquired from willing sellers or though donation, or
could be protected through agreements or easements.” NPS should state which lands
are most important to protect. The recent proposal to sell 10,000 acres near McKittrick
Canyon should be mentioned as a priority area for acquisition.
NPS should make a statement in this draft GMP/EIS to commit to long-term land
preservation, protection, conservation, and restoration of these lands outside the park
boundary. The public needs a list of these lands and a map where they are located.
The public and decision-makers need this information so they can review, comment on,
and understand this proposal.
77) Page 229, Plant Communities and Vegetation, NPS states “The irrigation of
shade trees and lawns … would continue to cause the growth of unnaturally lush
vegetation and would allow exotic species to flourish”. What does the NPS plan to do to
control or reduce this exotic plant species growth. The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
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78) Page 230, Plant Communities and Vegetation, what does “very small increment”
mean The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
79) Page 230, Wildlife, NPS states “Development would continue to occupy less than
1,000 acres or a little more than 1 percent of the 86,416 acres in the park”. Why is the
destruction of 1,000 acres of natural area or Wilderness quality area considered
acceptable and why is this considered to be a relatively small environmental impact
After all, for cumulative impacts this is a large loss of wildlife habitat in GMNP. The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
80) Page 230, Wildlife, what does “many wildlife species” mean The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
81) Page 231, Wildlife, what does “relatively low incidence of collisions” mean The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
82) Page 231, Wildlife, Cumulative Effects, what does “would contribute only very
slightly” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
83) Page 232, Wildlife, Conclusion, what does “would be very small” mean The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
84) Page 232, Geological Resources, what does “intensity would be minor because of
the small areas involved” mean The public and decision-makers need this information
so they can review, comment on, and understand this proposal.
85) Page 232, Geological Resources, NPS states “Currently, the number of permits
issued each year is low”. How many permits of what type are issued each year What
are the environmental impacts of issuing permits for this activity The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
86) Page 233, Geological Resources, Cumulative Impacts, what does “would
contribute only very slightly” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
87) Page 233, Geological Resources, Conclusion, what does “these effects would be
very small” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
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88) Page 235, Paleontological Resources, Cumulative Impacts, what does “would
contribute only very slightly” mean What are the impacts for surface resources from 0-
50 feet below the surface The public and decision-makers need this information so
they can review, comment on, and understand this proposal.
89) Page 235, Paleontological Resources, Conclusion, what does “effects would be
very small” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
90) Page 235, Archeological Resources, what does “few if any adverse effects would
be anticipated” mean The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
91) Page 235, Archeological Resources, what does “would be avoided to the greatest
extent possible” mean The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
92) Page 236, Archeological Resources, Cumulative Impacts, what does “would be
avoided to the greatest extent possible”; “would contribute only minimally to the adverse
effects”; “would be a very small component” mean The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
93) Page 236, Archeological Resources, Conclusion, what does “Few if any adverse
effects” and “effects would be very small” mean The public and decision-makers need
this information so they can review, comment on, and understand this proposal.
94) Pages 236-237, Historic Structures, what do “Monitoring the carrying capacity of
historic structures”; “few if any adverse effects would be anticipated”; “would result in
few if any adverse effects”; “would be very small”; “Few if any adverse effects”;
“contribution to these effects would be very small” mean The public and decisionmakers
need this information so they can review, comment on, and understand this
proposal.
95) Page 237, Cultural Landscapes, NPS states “in accordance with standards and
guidelines”. NPS must explain what these “standards and guidelines” are. The public
and decision-makers need this information so they can review, comment on, and
understand this proposal.
96) Page 238, Cultural Landscapes, Conclusion, what does “would contribute a very
small increment” mean The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
97) Page 240, Access, NPS states “Horseback riding is allowed on some trails. It is
more than “some trails” that horseback riding is allowed on. From the Trails Illustrated
map it appears that horseback riding is allowed on the Tejas Trail, Mountain Trail, Bush
39

Mountain Trail, Marcus Trail, Foothills Trail, Guadalupe Peak Trail, Salt Basin Overlook
Trail, El Capitan Trail, and McKittrick Canyon Trail. According to the Sierra Club’s
calculation, using the Trails Unlimited Map mileage of GMNP, about 47.7 miles of the 82
total miles of hiking trails allow horses on them, which is over 50% of the trails (58.2%).
This is more than “some” trails allowed for horse use. Page 191 states that 60% of the
trails are used for horseback riding. The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
98) Page 240 Activities and Destinations, what does “A small increase in use” mean
The public and decision-makers need this information so they can review, comment on,
and understand this proposal.
99) Page 241, Scenic Views, how long is the electric line that will be removed from
McKittrick Creek The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
100) Page 241, Scenic Views, Cumulative Impacts, what does “the continued
protection of scenic views is substantial” mean This seems like a strange statement
since NPS has previously in this draft GMP/EIS stated that air quality, which obscures
scenic views, is not an issue topic and NPS cannot do much about. The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
101) Page 241, Scenic Views, Conclusion, what does “would have generally adverse
impacts” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
102) Page 243, Housing and Community Infrastructure, what does “minimally
increased demand” mean The public and decision-makers need this information so
they can review, comment on, and understand this proposal.
103) Page 243, Housing and Community Infrastructure, Cumulative Effects, what
does “effects would be very small” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
104) Page 243, Housing and Community Infrastructure, Conclusion, what does
“contribution to these effects would be very small” mean The public and decisionmakers
need this information so they can review, comment on, and understand this
proposal.
105) Page 243, Housing and Community Infrastructure, Cumulative Effects, NPS
states “Increases in residential development, … could result in increased visitation
levels at the park and require additional management efforts along those park
boundaries … could require a reallocation of staff, decreasing their availability in other
areas of the park” and then says on page 243, Management and Administration
“Through core operations, the park management is streamlining the organization …
40

would hire more seasonal and term position rather than using full-time staff for these
activities” and on page 244, Maintenance, states “the potential of increasing visitation,
the park staff could be presented with increasing challenges in carrying out the park’s
maintenance requirements”.
These quotes are contradictory. While park visitation may increase and cause the need
for more people, NPS is cutting its staff from 40 to 34. There is no way that seasonal
employees can do the same quality work and the same amount of work as full-time
employees. This is penny wise and pound foolish thinking. NPS pays seasonal
employees very poor salaries. Seasonal employees are only around for a few months
and cannot learn the needs and resources of GMNP in the same manner as full-time
employees.
But what happens if the opposite occurs Due to high gasoline prices fewer people
come to GMNP. The figures shown on page 190, Table 8, Recreational Visitation in
2000-2008, document a decline from a high of 222,307 in 2001 to 174,157 in 2006.
This is before gasoline prices rose astronomically to almost $4/gallon right now. The
forecast is for further rises in gasoline prices and for these increases in price to remain
high. Why does NPS not talk about this and how it will affect GMNP The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
106) Page 244, Maintenance, Cumulative Impacts, what informal trails are NPS
talking about How many of these trails are likely to be made and where What are
their environmental impacts The public and decision-makers need this information so
they can review, comment on, and understand this proposal.
107) Page 244, Maintenance, Cumulative Impacts, what does “effects would be
slight” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
108) Page 244, Maintenance, Conclusion, what does “contribution would be slight”
mean The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
109) Pages 244-245, The Relationship Between Local Short-Term Uses of the
Environment and the Maintenance and Enhancement of Long-Term Productivity,
what does “sustainable action” mean Why is Alternative A, a “sustainable action”
NPS does not explain. What criteria is NPS using to judge an alternative’s
sustainability What are the local short-term uses that this draft GMP/EIS proposes
What is the maintenance and enhancement of long-term productivity that NPS
compares to short-term uses and that this draft GMP/EIS provides The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
41

110) Page 245, Any Irreversible or Irretrievable Commitments of Resources Which
Would be Involved Should the Alternative Be Implemented, NPS ignores that what
NEPA says has to be in this section of the EIS. NPS states “Alternative A would not
involve the irreversible or irretrievable commitment of resources”. This is an untrue
statement. Alternative A, with the actions currently underway at the Frijole Ranch and
the existing 1,000 acres of Wilderness-like area that has been developed has
irreversible and irretrievable commitments of resources.
Where is the acknowledgment that energy will be used, air pollution generated, soil
eroded, sediment will go into streams, loss of solitude, loss of quiet, loss of hearing
natural sounds, trampling of vegetation will occur, materials will be used, existing acres
of what once were Wilderness quality natural area will remain developed areas, actions
currently underway at the Frijole Ranch complex will cause a loss of Wilderness quality
lands Where is the discussion about the loss of 1,000 acres of natural ecologically
functioning ecosystems in the past The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
111) Page 245, Any Adverse Impacts Which Cannot Be Avoided Should the Action
Be Implemented, NPS remains totally quiet about what these “adverse impacts” are in
this part of the draft GMP/EIS. A few adverse impacts the Sierra Club can think of
include destruction or degradation of fossils by horses, soil erosion and sedimentation
by horses and hikers, vegetation trampling by horses and hikers, existing acres of what
once were Wilderness quality natural area will remain developed areas, continuing
reductions or obscuring of scenic vistas by air pollution, etc. Why has NPS ignored
these impacts and not stated them here in the EIS The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
112) Page 246, Preferred Alternative, Natural Resources, Soils, NPS states “Actions
of the preferred alternative would disturb about 200 acres of soil through the park”. This
statement is incomplete. The 200 acres of disturbed soil, or plant communities and
vegetation, etc., must be added to the 1,000 acres already disturbed to give a true
picture of the total impacts that have and will be done due to this proposed alternative.
The loss of an additional 200 acres is a 20% increase in the loss of soils. The public
and decision-makers need this information so they can review, comment on, and
understand this proposal.
113) Page 246, Preferred Alternative, Natural Resources, Soils, Conclusion, what
does “would contribute a very small increment” mean The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
114) Page 247, Plant Communities and Vegetation, Cumulative Effects and page
248, Conclusion, what does “would contribute a very small increment” mean The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
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115) Page 248, Wildlife, NPS states “Actions of the preferred alternative would
permanently remove about 200 acres of wildlife habitat throughout the park. Because
of the relatively small area involved (about 0.2% of the park), the intensity of the longterm,
adverse impact on wildlife would be minor”. NPS appears to forget that it is
protecting a National Park in the National Park System and that the 200 acres lost could
be Wilderness or a similar designation and as a result is a considerable impact.
In addition, NPS forgets that 1,000 acres has already been lost so there is a cumulative
burden that has occurred and that is proposed. The loss of an additional 200 acres is a
20% increase in the loss of wildlife habitat. The Sierra Club does not consider the loss
of 200 acres of natural habitat with functioning natural ecological processes (wildlife
habitat) a “minor” environmental impact especially since some of this area could be
appropriate for Wilderness designation. The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
116) Page 248, Wildlife, NPS states “During construction, some smaller animals might
be killed or forced to relocate to areas … Overall, populations of affected species would
decrease slightly”. What does “decrease slightly” mean What populations What are
the populations now What animal species It is more probable, that if the habitat is at
carrying capacity, that animals that leave the site will compete with other animals off
their home range and either die, win the competition, or overuse the site because a
greater population is using it. The public and decision-makers need this information so
they can review, comment on, and understand this proposal.
117) Page 248, Wildlife, Conclusion, what does “would contribute a very small
increment” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
118) Page 249, Geologic Resources, Cumulative Effects, what does “localized and
range in intensity up to moderate” and “would contribute only very slightly” mean The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
119) Page 249, Geologic Resources, Conclusion, what does “would contribute a very
small increment” mean The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
120) Page 249, Paleontological Resources, what does “high potential for
paleontological resources” and “It might be possible” mean The public and decisionmakers
need this information so they can review, comment on, and understand this
proposal.
121) Page 250, Paleontological Resources, Conclusion, what does “would contribute
a very small increment” mean The public and decision-makers need this information
so they can review, comment on, and understand this proposal.
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122) Page 250, Archeological Resources, what does “to the greatest extent possible”
mean The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
123) Page 251, Archeological Resources, what does “would contribute a very small
increment” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
124) Page 251, Historic Structures, what does “rehabilitation”, “stabilization”,
“preservation” mean What are the “standards and guidelines” that will be used The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
125) Page 251, Historic Structures, Cumulative Effects and Conclusion, what does
“would contribute a very small increment” mean The public and decision-makers need
this information so they can review, comment on, and understand this proposal.
126) Page 252, Cultural Landscapes, Cumulative Effects and Conclusion, what
does “would contribute a very small increment” mean The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
127) Pages 253-254, Access, NPS states “and the possible addition of other primitive
trails to the park’s inventory”. What trails are these Where are they located How
long are they What are the environmental impacts The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
128) Page 256, Regional Economic and Demographic Conditions, NPS states “the
park’s role in the socioeconomic environment would increase”. What does this mean
How much Where The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
129) Page 256, Regional Economic and Demographic Conditions, what does “could
make a small, indirect contribution to population growth” mean The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
130) Page 256, Housing and Community Infrastructure, what does “would result in
small changes” and “would result in small increases” mean The public and decisionmakers
need this information so they can review, comment on, and understand this
proposal.
131) Page 256, Housing and Community Infrastructure, Cumulative Effects and
Conclusion, what does “would be beneficial but very small” mean The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
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132) Page 257, Management and Administration, NPS states “Enlarging the water
storage system and providing a fire building at Dog Canyon would enhance the NPS’s
ability to protect resources in the northern part of the park, a long-term, beneficial
impact.” How will this protect resources What resources The public and decisionmakers
need this information so they can review, comment on, and understand this
proposal.
133) Page 257, Employee Housing, NPS states “would improve the ability of the park
to recruit seasonal employees and attract volunteers, a long-term, beneficial impact”.
What does that mean How much would this improve the ability to recruit employees
The Sierra Club supports the employment of more full-time employees (40 instead of
34) so they can do the good work all year around. The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
134) Page 257, Maintenance, Cumulative Impacts and Conclusion, what does
“would be slight” mean The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
135) Pages 257-258, The Relationship Between Local Short-Term Uses of the
Environment and the Maintenance and Enhancement of Long-Term Productivity,
what does “sustainable action” mean Why is the Preferred Alternative, a “sustainable
action” NPS does not explain. What criteria is NPS using to judge an alternative’s
sustainability What are the local short-term uses that this draft GMP/EIS proposes
What is the maintenance and enhancement of long-term productivity that NPS
compares to short-term uses and that this draft GMP/EIS provides The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
136) Page 258, Any Irreversible or Irretrievable Commitments of Resources Which
Would be Involved Should the Alternative Be Implemented, NPS ignores what
NEPA says has to be in this section of the EIS. NPS states “The preferred alternative
would not involve the irreversible or irretrievable commitment of resources”. This is an
untrue statement. On pages x and xii, Visitor Use, of this draft GMP/EIS, NPS states
that the loss of 200 or 500 acres due to construction of built environments “would be
permanently converted to developed park facilities”. These are irreversible and
irretrievable commitments of resources.
Where is the acknowledgment that energy will be used, air pollution generated, soil
eroded, sediment will go into streams, loss of solitude, loss of quiet, loss of hearing
natural sounds, trampling of vegetation will occur, materials will be used, existing acres
of what once were Wilderness quality natural area will remain developed areas, actions
currently underway at the Frijole Ranch complex will cause a loss of Wilderness quality
lands. Where is the discussion about the loss of 200 acres of natural ecologically
functioning ecosystems with this alternative and 1,000 acres in the past The public
and decision-makers need this information so they can review, comment on, and
understand this proposal.
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137) Page 258, Unavoidable Adverse Impacts, NPS remains totally quiet about what
these “adverse impacts’; are in this part of the draft GMP/EIS. A few adverse impacts
that the Sierra Club can think of include destruction or degradation of fossils by horses,
soil erosion and sedimentation by horses, vegetation trampling by horses, existing acres
of what once were Wilderness quality natural area will remain developed areas,
continuing reductions or obscuring of scenic vistas by air pollution, etc. Why has NPS
ignored these impacts and not stated them here in the EIS as required by NEPA and
CEQ NEPA implementing regulations The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
138) Page 259, Soils, NPS states “The area to be restored would total about 200 acres,
or about 0.2 percent of the park”. The Sierra Club believes this is a significant, positive,
environmental benefit. It is not often that a national park reduces its footprint. All too
often the urge is to put more facilities and degrade more natural land than to restore and
or protect natural land in parks.
139) Page 259, Soils, Conclusion, what does “would contribute a very small
increment” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
140) Page 260, Plant Communities and Vegetation, why does the NPS not separate
out the erosion caused by horses and hikers and compare them. If in fact more erosion
is caused by horseback riding, as the Sierra Club suspects, when talking about soils,
plant and vegetation communities, and other natural resources, affected by horses more
than hiking, then this difference in environmental degradation should be spelled out.
How much less would the erosion and other environmental impacts be without horses
Which trails in particular would benefit being hiking only Which tails can better
withstand the additional impacts of horses The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
141) Page 261, Plant Communities and Vegetation, Conclusion, what does “would
contribute a very small increment” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
142) Page 261, Wildlife, NPS must document its assertion that “The locations of the
restored areas adjacent to developed, intensely used areas would lessen their
desirability for species that do not typically habituate to human use”. While NPS
mentions only two habituated species, deer and coyote, it mentions no other species
that would be helped or harmed by restoring 200 acres to natural habitat. The creation
of 200 acres of habitat is so overwhelmingly positive the Sierra Club does not
understand NPS’s emphasis on the potentially small negative impacts of this particular
action in opposition to the huge positive impacts which are essentially ignored. In the
Sierra Club’s view this may demonstrate bias by NPS against this alternative. The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
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143) Page 261, Wildlife, Cumulative Effects and Conclusion, what does “would
contribute a very small increment” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
144) Page 262, Geologic Resources, what does “would have little effect on
groundwater” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
145) Page 262, Geologic Resources, Cumulative Effects, there should be less
cumulative effects on geologic resources because horse use will be less in Alternative B
than the Preferred Alternative. How much less degradation will occur to geological
resources with Alternative B The public and decision-makers need this information so
they can review, comment on, and understand this proposal.
146) Page 262, Geologic Resources, Cumulative Effects, what does “would
contribute only very slight” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
147) Page 263, Paleontological Resources, Cumulative Effects, what does “would
contribute only very slightly” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
148) Page 263, Paleontological Resources, Conclusion, what does “would contribute
a very small increment” mean The public and decision-makers need this information
so they can review, comment on, and understand this proposal.
149) Page 263, Archeological Resources, what does “demolition” mean The public
and decision-makers need this information so they can review, comment on, and
understand this proposal.
150) Page 264, Archeological Resources, Cumulative Effects and Conclusion,
what does “very small increment” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
151) Page 264, Historic Structures, what are the standards and guidelines” What do
they mean What protections do they give Should the standards and guidelines be in
the appendix if they are that important so the public can easily review and comment on
their protective nature The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
152) Page 264, Historic Structures Cumulative Effects and Conclusion, what does
“very small increment” mean The public and decision-makers need this information so
they can review, comment on, and understand this proposal.
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153) Page 265, Cultural Landscapes, NPS states that if the human-made pond at
Manzanita Spring is allowed to become a natural wetland it “would have an adverse
impact on the Frijole Ranch cultural landscape”. Which is more important in GMNP,
protection and restoration of the natural landscape or the human one NPS needs to
compare and contrast these two landscapes and tell the public how it determines what
is best. The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
154) Page 265, Cultural Landscapes, what are the standards and guidelines” What
do they mean What protections do they give Should these standards and guidelines
be in the appendix if they are that important so the public can easily review and
comment on their protective nature The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
155) Page 265, Cultural Landscapes, Conclusion, what does “very small increment”
mean The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
156) Page 266, Ethnographic Resources, Conclusion, NPS states “The alternative
would result in a minor to moderate, long-term, adverse contribution to the cumulative
impacts”. It is not clear what and how much each cumulative action with environmental
impacts that is listed on pages 21-52, will effect ethnographic resources or any other
natural resource mentioned in the draft GMP/EIS. Specifically, what quantified
cumulative impacts does each cumulative action have or have had or will have If this
information is not known then CEQ’s NEPA implementing regulations, Section 1502.22,
need to be used to clearly state why. The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
157) Page 267, Access, why would a more Wilderness oriented alternative be prepared
that accepts the impacts that will come on providing “automobile access” to Williams
Ranch and the Salt Basin Dunes. It seems contradictory since the vision and feel of this
alternative is less development in GMNP and more focus on natural ecosystem
functioning and understanding and enjoyment. The public and decision-makers need
this information so they can review, comment on, and understand this proposal.
158) Page 267, Activities and Destinations, NPS states “Many riders would perceive
the loss of horse use as a major, long-term, adverse impact … Many riders elect GMNP
as their destination because riding is allowed … Many non-riders would vie w the loss of
horse use as a negligible or even beneficial, long-term impact”. NPS does not do real
analysis. How many riders use GMNP each year How many hikers use GMNP Why
is riding not allowed in other parks Do those reasons apply in GMNP This is a user
conflict problem but NPS does nothing and suggests nothing about how to resolve it.
What does NPS think about eliminating horse use NPS gives us what it perceives as
horse rider and hiker perceptions. What is NPS’s perception and idea about horse use
impacts (are they major) We are not told. The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
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159) Page 268, Scenic Views, Conclusion, how many primitive trails will be added to
the park’s inventory How many are there What are the environmental impacts if
these trails are open The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
160) Page 268, Interpretation, Education, and Orientation and Conclusion, NPS
states “improvements would be less extensive than in the preferred alternative, the
intensity of the benefit would not be a great … would be less than in the preferred
alternative” How much less and great would it be The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
161) Page 268, The Socioeconomic Environment, NPS states “the elimination of
developed camping and horseback riding would reduce the use of the park for these
purposes”. What is the proportion each of these two uses currently is of all recreation or
visitation in GMNP Are these uses declining or increasing Where is the actual
analysis of data The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
162) Page 269, The Socioeconomic Environment, what does “would be small”
mean The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
163) Page 269, The Socioeconomic Environment, Cumulative Effects and
Conclusion, what does “would be beneficial but very small” mean The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
164) Page 269, Maintenance, the NPS insists that the elimination of camping and
horseback riding “would result in few if any reductions in maintenance”. This makes no
sense. The camping facilities will be eliminated and 200 acres of destroyed habitat will
be restored. How can the maintenance not be less with less facility use Where is your
analysis to support such a conclusion The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
165) Page 269, Maintenance, Cumulative Impacts and Conclusions, what does
“would be slight” mean The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
166) Page 270, The Relationship Between Local Short-Term Uses of the
Environment and the Maintenance and Enhancement of Long-Term Productivity,
what does “sustainable action” mean Why is Alternative B, a “sustainable action”
NPS does not explain. What criteria is NPS using to judge an alternative’s
sustainability What are the local short-term uses that this draft GMP/EIS proposes
What is the maintenance and enhancement of long-term productivity that NPS
compares to short-term uses and that this draft GMP/EIS provides The public and
49

decision-makers need this information so they can review, comment on, and understand
this proposal.
167) Page 270, Any Irreversible or Irretrievable Commitments of Resources, NPS
ignores what NEPA says has to be in this section of the EIS. NPS states “The preferred
alternative would not involve the irreversible or irretrievable commitment of resources”.
This is an untrue statement. On pages x and xii, Visitor Use, of this draft GMP/EIS,
NPS states that the loss of 200 or 500 acres due to construction of built environments
“would be permanently converted to developed park facilities”. These are irreversible
and irretrievable commitments of resources.
Where is the acknowledgment that energy will be used, air pollution generated, soil
eroded, sediment will go into streams, loss of solitude, loss of quiet, loss of hearing
natural sounds, trampling of vegetation will occur, materials will be used, existing acres
of what once were Wilderness quality natural area will remain developed areas, actions
currently underway at the Frijole Ranch complex will cause a loss of Wilderness quality
lands. Where is the discussion about the loss of 1,000 acres of natural ecologically
functioning ecosystems from the past The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
168) Page 270, Unavoidable Adverse Impacts, NPS remains totally quiet about what
these “adverse impacts’; are in this part of the draft GMP/EIS. A few adverse impacts
the Sierra Club can think of include existing acres of what once were Wilderness quality
natural area will remain developed areas, continuing reductions or obscuring of scenic
vistas by air pollution, loss of solitude, loss of quiet, loss of hearing natural sounds, etc.
Why has NPS ignored these impacts and not stated them here in the EIS as required by
NEPA and CEQ NEPA implementing regulations The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
169) Pages 259-270, Alternative B, the Sierra Club supports, as mentioned earlier in
these comments, Alternative B with the following changes:
1. Wilderness eligibility and designation for 38,134 acres instead of the proposed
35,487 acres.
2. Reduction in, but not elimination of, horse use (day use only) on trails in GMNP by
some percentage (perhaps 20-50%) to reduce environmental impacts on geological,
biological, and ecological resources and conflicts with hikers. No removal of public
corrals and no horse concession.
3. Proposed boundary adjustment and acquisition of additional lands (by fee title
acquisition or conservation easement) in Patterson Hills, Salt Basin and Flats,
Guadalupe Pass area, McKittrick Canyon area, Delaware Mountains, Guadalupe
Escarpment, and other sensitive areas to protect the GMNP view-shed; acquire
important geological and ecological areas; and to buffer GMNP from present and future
development pressures.
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4. Employment of at least 40 people and reject the downgrading of employee numbers
to a core of 34.
5. Aggressive push by NPS to get state and federal officials to address the deterioration
of scenic views due to regional haze air pollution sooner than the mandated 2064
deadline. Air Quality as an “impact topic” should not be dismissed from further
consideration in the draft GMP/EIS and should be fully analyzed, assessed, and
evaluated for all alternatives.
6. Retention and possible expansion of the Pine Springs tent camping area and the
movement of the RV camping area so it is separated from the Pine Springs tent
camping area.
7. Support the treatment of Conflicts with Land Use Plans, Policies, and Controls;
Floodplains; Wetlands; Lightscape Management; Soundscape Management; Special
Status Species (Threatened and Endangered Species, Species of Concern, and
Designated Critical Habitats); Species Restoration, Exotic Species Control, and
Extirpated Species Reintroduction; Water Quality and Quantity; and Wilderness
Resources and Values as “impact topics” with full environmental analysis, evaluation,
and assessment for all alternatives in the draft GMP/EIS.
8. New consolidated park headquarters and office complex and cultural museum south
of U.S. Highway 62/180 close to the maintenance area.
9. Full implementation of the Wilderness Act and protection of wilderness character
versus protection of human installations and structures and other human actions in
wilderness management.
10. Provision of a shuttle system for trails to reduce driving and parking impacts.
170) Pages 271-284, Alternative C, the Sierra Club does not support Alternative C
because it puts development and recreational use over protection of the natural
resources of GMNP.
171) Page 272, Soils, Conclusion, what does “very small increment” mean The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
172) Page 273, Plant Communities and Vegetation and Page 274, Wildlife, NPS
states “Actions of Alternative C would permanently remove about 500 acres of wildlife
habitat throughout the park. Because of the relatively small area involved (about 0.6%
of the park), the intensity of the long-term, adverse impact on wildlife would be minor”.
NPS appears to forget that it is protecting a National Park in the National Park System
and that 500 acres lost that could be Wilderness or a similar designation is a
considerable impact. In addition, NPS forgets that 1,000 acres has already been lost so
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there is a cumulative burden that has occurred and that is proposed. The loss of an
additional 500 acres is a 50% increase in the loss of wildlife habitat. The Sierra Club
does not consider the loss of 500 acres of natural habitat with functioning natural
ecological processes (wildlife habitat) a “minor” environmental impact especially since
some of this area could be appropriate for Wilderness designation. The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
173) Page 273, Plant Communities and Vegetation, Cumulative Effects and
Conclusion, what does “very small increment” mean The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
174) Page 274, Wildlife, Cumulative Effects and Conclusion, what does “very small
increment” mean The public and decision-makers need this information so they can
review, comment on, and understand this proposal.
175) Page 276, Geologic Resources, Conclusion, what does “very small increment”
mean The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
176) Page 276, Peleontological Resources, the Sierra Club agrees with NPS that
“Because of the density of fossil resources in the area of Smith Spring, impacts from
trail improvement would have to be mitigated to reduce the intensity of the adverse,
long-term impact … Horses impact fossils in park trails because horse shoes grind
away the limestone that composes the fossils and rocks … constructing new tails
widening trails, and redeveloping abandoned roads, increasing the potential for
vandalism or unauthorized fossil collecting and increasing the use of horses”. The
Sierra Club does agree with “Visitor use education programs would provide a beneficial
impact” but the NPS does not say if this beneficial impact will reduce the damage to
acceptable levels. More law enforcement is needed and less horse use, trail widening,
and increased unnecessary access. The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
177) Page 277, Archeological Resources, what does “the greatest extent possible
mean The public and decision-makers need this information so they can review,
comment on, and understand this proposal.
178) Page 277, Archeological Resources, Cumulative Effects and Conclusion,
what does “very small increment” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
179) Page 278, Historic Structures, what are the standards and guidelines” What do
they mean What protections do they give Should the standards and guidelines be in
the appendix if they are that important so the public can easily review and comment on
their protective nature The public and decision-makers need this information so they
can review, comment on, and understand this proposal.
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180) Page 278, Historic Structures, Cumulative Effects and Conclusion, what does
“very small increment” mean The public and decision-makers need this information
so they can review, comment on, and understand this proposal.
181) Page 278, Cultural Landscapes, what are the standards and guidelines” What
do they mean What protections do they give Should the standards and guidelines
be in the appendix if they are that important so the public can easily review and
comment on their protective nature The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
182) Page 279, Cultural Landscapes, Cumulative Effects and Conclusion, what
does “very small increment” mean The public and decision-makers need this
information so they can review, comment on, and understand this proposal.
183) Page 280, Access, the Sierra Club opposes adding 37 miles of additional trails in
the “park’s interior” as well as adding other primitive trails to the park’s inventory. There
is no overall analysis of the environmental impacts of doing this. Where is the
quantification needed under NEPA If NPS cannot quantify the impacts then it must
use Section 1502.22 of CEQ NEPA implementing regulations to discuss this. The
public and decision-makers need this information so they can review, comment on, and
understand this proposal.
184) Page 281, Activities and Destinations, what is the projected use for the
proposed “hike-in” campground How was this determined The public and decisionmakers
need this information so they can review, comment on, and understand this
proposal.
185) Page 281, Activities and Destinations, the Sierra Club does not support making
the Pratt Cabin a cultural landscape and operating it as “a visitor gateway” to “provide
an interesting, them-related, enjoyable setting”. We also do not support “Expansions of
the public corrals at Frijole Ranch and Dog Canyon and consideration of operating
these facilities for use by commercial packers or a horse concession … could
substantially increase the number of visitors who would experience the backcountry by
horse”. Such actions will cause more damage to soil, plant communities and
vegetation, wildlife, and other natural resources.
186) Page 282, Scenic Views, Cumulative Effects, the Sierra Club does not agree
that all the development that will occur with Alternative C “would have a negligible
effects on cumulative impacts” since they will together reduce natural scenic views and
undisturbed landscapes. We do agree with NPS on page 281, Activities and
Destinations, that activities proposed in Alternative C “would have minor, long-term,
adverse impacts on those visitors who desire more solitude”, although we believe the
impacts will be much greater than minor.
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187) Page 282, Interpretation, NPS states “Average length of stay in the facilities
would likely increase” but does not say what it would increase to and what it is now.
The public and decision-makers need this information so they can review, comment on,
and understand this proposal.
188) Page 283, The Socioeconomic Environment, NPS states “The effects of
changes in staffing levels would be negligible”. NPS proposes a staffing level of 44 for
Alternative C to take care of the additional facilities and increased visitor use. However,
in Alternative C and the other alternatives NPS never states how it derives the staffing
levels and what its current backlog is for maintenance and other activities. The public
and decision-makers need this information so they can review, comment on, and
understand this proposal.
189) Page 283, Park Operations, Facilities, and Equipment, NPS states that the
impacts of Alternative C “on park operations, facilities, and equipment would be the
same as those described for the preferred alternative”. This makes no sense because
there would be 500 acres of additional facilities in Alternative C instead of 200 acres in
the preferred alternative. NPS must give an accurate analysis of the costs. The public
and decision-makers need this information so they can review, comment on, and
understand this proposal.
190) Pages 283-284, The Relationship Between Local Short-Term Uses of the
Environment and the Maintenance and Enhancement of Long-Term Productivity,
what does “sustainable action” mean Why is Alternative C, a “sustainable action”
NPS does not explain. What criteria is NPS using to judge an alternative’s
sustainability What are the local short-term uses that this draft GMP/EIS proposes
What is the maintenance and enhancement of long-term productivity that NPS
compares to short-term uses and that this draft GMP/EIS provides The public and
decision-makers need this information so they can review, comment on, and understand
this proposal.
191) Page 284, Any Irreversible or Irretrievable Commitments of Resources, NPS
ignores what NEPA says has to be in this section of the EIS. NPS states “The preferred
alternative would not involve the irreversible or irretrievable commitment of resources”.
This is an untrue statement. On pages x and xii, Visitor Use, of this draft GMP/EIS,
NPS states that the loss of 200 or 500 acres due to construction of built environments
“would be permanently converted to developed park facilities”. These are irreversible
and irretrievable commitments of resources.
Where is the acknowledgment that energy will be used, air pollution generated, soil
eroded, sediment will go into streams, loss of solitude, loss of quiet, loss of hearing
natural sounds, trampling of vegetation will occur, materials will be used, existing acres
of what once were Wilderness quality natural area will remain developed areas, actions
currently underway at the Frijole Ranch complex will cause a loss of Wilderness quality
lands. Where is the discussion about the loss of 1,000 acres of natural ecologically
functioning ecosystems from the past and the loss of 500 new acres The public and
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decision-makers need this information so they can review, comment on, and understand
this proposal.
193) Page 284, Unavoidable Adverse Impacts, NPS remains totally quiet about what
these “adverse impacts’; are in this part of the draft GMP/EIS. A few adverse impacts
the Sierra Club can think of include 500 acres of new facilities along with rehabilitating
and improving 37 miles of trails, existing acres of what once were Wilderness quality
natural area will remain developed areas, continuing reductions or obscuring of scenic
vistas by air pollution, loss of solitude, loss of quiet, loss of hearing natural sounds, etc.
Why has NPS ignored these impacts and not stated them here in the EIS as required by
NEPA and CEQ NEPA implementing regulations The public and decision-makers
need this information so they can review, comment on, and understand this proposal.
The Sierra Club appreciates this opportunity to comment. Thank you.
Sincerely,
Brandt Mannchen
Wild Lands Co-Chair
Lone Star Chapter of the Sierra Club
5431 Carew
Houston, Texas 77096
713-664-5962
brandtshnfbt@juno.com
Attachment 1
Attachment 2
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