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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. 26
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.” 27
Page 1 and 2: Lone Star Chapter June 13, 2008 Mr.
Page 3 and 4: used with a non-motorized and mecha
Page 5 and 6: GMP/EIS as an issue topic. The NPS
Page 7 and 8: 10) Page 19, Ensure Organizational
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Page 13 and 14: people since this is a loss and dow
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Page 17 and 18: area be The public and decision-mak
Page 19 and 20: On page 93, Costs, the Sierra Club
Page 21 and 22: On pages 99-100, Management of Rese
Page 23 and 24: On page 113, Visitor Experience, NP
Page 25: “achieving a balance between popu
Page 29 and 30: Section 1502.22, requires that when
Page 31 and 32: Therefore, the following words or p
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Page 37 and 38: 70) Page 214, Mining and Drilling,
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Page 41 and 42: would hire more seasonal and term p
Page 43 and 44: 115) Page 248, Wildlife, NPS states
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Page 51 and 52: 4. Employment of at least 40 people
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