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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 12
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. 13
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