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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. 10
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 11
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