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16) Page 38, Salt Basin Dunes, NPS states “Visitors … but are encouraged to avoid walking on the fragile black crust of the cryptobiotic evaporitic soils.” Encouragement is not enough! Very little is said in the draft GMP/EIS about how NPS will protect cryptogrammic soils of the Salt Basin Dunes within the alternatives proposed. The Sierra Club is very concerned about protecting the Salt Basin Dunes and all of its biological, ecological, and geological resources. 17) Page 43, Air Quality, Topics Dismissed From Further Consideration, as the Sierra Club stated in 6) above, we are against not including air quality as an impact topic in the draft GMP/EIS. Air quality should be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. 18) Pages 43-44, Conflicts with Land Use Plans, Policies, and Controls, the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. This is particularly true since NPS has outlined on pages 25-26 some of the threats to GMNP that we currently know. This is a huge issue that must be addressed in the draft GMP/EIS. Air pollution is another “private entity” problem that should be included under this issue topic. 19) Pages 45-48, Floodplains and Wetlands, the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. On page 46, the Sierra Club recommends that the phrase “or acquiring” be added to the protective elements for wetlands. 20) Page 48, Lightscape Management and page 49, Soundscape Management, the Sierra Club disagrees that these impact topics should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. NPS has already pointed out that development pressures are increasing and therefore in the next 15-20 years there will be more lightscape and soundscape problems. This must be addressed in the draft GMP/EIS so that public and decision-makers can review, comment on, and understand what NPS proposes to do about these impact topics. 21) Pages 50-51, Special Status Species (Threatened and Endangered Species, Species of Concern, and Designated Critical Habitats) and Species Restoration, Exotic Species Control, and Extirpated Species Reintroduction, the Sierra Club disagrees that these impact topics should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. For instance, feral hogs have been found at the very boundary of GMNP, right next to MiKittrick Canyon. NPS needs to be specific on how it will prevent these destructive riparian species before they enter one of the most sensitive habitats in the entire GMNP. It is NPS’s responsibility to protect special status species, reduce problems with exotics species, restore ecological functions, and reintroduce extirpated species. The way NPS wants to protect these issue topics should be integrated in all alternatives of the draft 8
GMP/EIS so that public and decision-makers can review, comment on, and understand what NPS proposes to do about these impact topics. 22) Pages 51-52, Water Quality and Quantity (Surface and Groundwater), the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. Water is the lifeblood of the desert and high mountain areas. The way that NPS wants to protect water quality and quantity should be in all alternatives of the draft GMP/EIS. What does “would substantially change” mean The public and decision-makers need this information so they can review, comment on, and understand the Preferred Alternative. 23) Page 52, Wilderness Resources and Values, the Sierra Club disagrees that this impact topic should not be completely analyzed, assessed, and evaluated in all alternatives of the draft GMP/EIS. This is particularly true since GMNP is a Wilderness national park. The Sierra Club does not support additional use of dynamite to make trails and does not believe that NPS should focus on “improve safe access to wilderness areas”. NPS should focus on protecting Wilderness character. Wilderness character should not be degraded to make Wilderness safe for visitors. This is what the Wilderness Act requires. Wilderness is where people enter at their own risk and bow to the risks that Wilderness poses, on Wilderness’ terms. It is a place where humans leave their arrogance at the Wilderness boundary and enter with humility and not with the typical control and manipulation (trammeling) that we do in our human modified and built environment. NPS should not be in the business of de-wilding and de-fanging Wilderness. More trails are not needed in designated Wilderness in GMNP. NPS calls building new trails in GMNP “long-term beneficial impacts” but the Wilderness Act says that installations and structures are not allowed. Building new trails would result in reduced Wilderness character which is a long-term negative impact and these actions are not beneficial to Wilderness protection and the protection of Wilderness character. The way that NPS will protect Wilderness character should be in all alternatives of the draft GMP/EIS so that public and decision-makers can review, comment on, and understand what NPS proposes to do about these impact topics. Chapter 2: Alternatives, Including the Preferred Alternative 24) Page 56, Visitor Use Capacity, the NPS states “Rather, user capacity is measured by comparing desired resource and visitor experience conditions to actual conditions and, when an imbalance is noted, employing management practices to return to the desired conditions.” This may be true in instances but for some resources there is no returning to the “desired conditions”. For instance, soil erosion and cryptogrammic crust damage is in essence forever because the process of creating soil and cryptogrammic crusts, especially in desert and or mountain habitats, is extremely slow. The loss of 200 9
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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: 10) Page 19, Ensure Organizational
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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 49 and 50: 159) Page 268, Scenic Views, Conclu
Page 51 and 52: 4. Employment of at least 40 people
Page 53 and 54: 180) Page 278, Historic Structures,
Page 55: decision-makers need this informati

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