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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 4
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. 5
Page 1 and 2: Lone Star Chapter June 13, 2008 Mr.
Page 3: used with a non-motorized and mecha
Page 7 and 8: 10) Page 19, Ensure Organizational
Page 9 and 10: GMP/EIS so that public and decision
Page 11 and 12: 27) Page 57, Management Zones for t
Page 13 and 14: people since this is a loss and dow
Page 15 and 16: 42) Pages 79-93, Preferred Alternat
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 and 26: “achieving a balance between popu
Page 27 and 28: 67) Page 213, Introduction, pages 2
Page 29 and 30: Section 1502.22, requires that when
Page 31 and 32: Therefore, the following words or p
Page 33 and 34: 1. What do these phrases mean in th
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Page 37 and 38: 70) Page 214, Mining and Drilling,
Page 39 and 40: 88) Page 235, Paleontological Resou
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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decision-makers need this informati
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