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187) Page 282, Interpretation, NPS states “Average length of stay in the facilities would likely increase” but does not say what it would increase to and what it is now. The public and decision-makers need this information so they can review, comment on, and understand this proposal. 188) Page 283, The Socioeconomic Environment, NPS states “The effects of changes in staffing levels would be negligible”. NPS proposes a staffing level of 44 for Alternative C to take care of the additional facilities and increased visitor use. However, in Alternative C and the other alternatives NPS never states how it derives the staffing levels and what its current backlog is for maintenance and other activities. The public and decision-makers need this information so they can review, comment on, and understand this proposal. 189) Page 283, Park Operations, Facilities, and Equipment, NPS states that the impacts of Alternative C “on park operations, facilities, and equipment would be the same as those described for the preferred alternative”. This makes no sense because there would be 500 acres of additional facilities in Alternative C instead of 200 acres in the preferred alternative. NPS must give an accurate analysis of the costs. The public and decision-makers need this information so they can review, comment on, and understand this proposal. 190) Pages 283-284, The Relationship Between Local Short-Term Uses of the Environment and the Maintenance and Enhancement of Long-Term Productivity, what does “sustainable action” mean Why is Alternative C, a “sustainable action” NPS does not explain. What criteria is NPS using to judge an alternative’s sustainability What are the local short-term uses that this draft GMP/EIS proposes What is the maintenance and enhancement of long-term productivity that NPS compares to short-term uses and that this draft GMP/EIS provides The public and decision-makers need this information so they can review, comment on, and understand this proposal. 191) Page 284, Any Irreversible or Irretrievable Commitments of Resources, NPS ignores what NEPA says has to be in this section of the EIS. NPS states “The preferred alternative would not involve the irreversible or irretrievable commitment of resources”. This is an untrue statement. On pages x and xii, Visitor Use, of this draft GMP/EIS, NPS states that the loss of 200 or 500 acres due to construction of built environments “would be permanently converted to developed park facilities”. These are irreversible and irretrievable commitments of resources. Where is the acknowledgment that energy will be used, air pollution generated, soil eroded, sediment will go into streams, loss of solitude, loss of quiet, loss of hearing natural sounds, trampling of vegetation will occur, materials will be used, existing acres of what once were Wilderness quality natural area will remain developed areas, actions currently underway at the Frijole Ranch complex will cause a loss of Wilderness quality lands. Where is the discussion about the loss of 1,000 acres of natural ecologically functioning ecosystems from the past and the loss of 500 new acres The public and 54
decision-makers need this information so they can review, comment on, and understand this proposal. 193) Page 284, Unavoidable Adverse Impacts, NPS remains totally quiet about what these “adverse impacts’; are in this part of the draft GMP/EIS. A few adverse impacts the Sierra Club can think of include 500 acres of new facilities along with rehabilitating and improving 37 miles of trails, existing acres of what once were Wilderness quality natural area will remain developed areas, continuing reductions or obscuring of scenic vistas by air pollution, loss of solitude, loss of quiet, loss of hearing natural sounds, etc. Why has NPS ignored these impacts and not stated them here in the EIS as required by NEPA and CEQ NEPA implementing regulations The public and decision-makers need this information so they can review, comment on, and understand this proposal. The Sierra Club appreciates this opportunity to comment. Thank you. Sincerely, Brandt Mannchen Wild Lands Co-Chair Lone Star Chapter of the Sierra Club 5431 Carew Houston, Texas 77096 713-664-5962 brandtshnfbt@juno.com Attachment 1 Attachment 2 55
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Page 51 and 52: 4. Employment of at least 40 people
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