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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 2
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 3
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