Letter to Yellowstone Superintendent Dated January 14, 2010

Executive Council:
• Robert Arnberger
• Anne Castellina
• Don Castleberry
• Maureen Finnerty
• Jake Hoogland
• Doug Morris
• J. T. Reynolds
• Pat Tiller
• Rick Smith
• Bill Wade
Voices of Experience – Advocating Protection of America’s National Park System

SENT VIA EMAIL

January 14, 2010

Superintendent
Yellowstone National Park
P.O. Box 168
Yellowstone National Park, WY
82190-0168

Dear Superintendent Lewis:

Less than two months ago, the National Park Service announced a critical effort to develop a long-term winter use plan worthy of Yellowstone National Park. The agency’s new planning process has afforded an opportunity to break from the practices of recent years, during which – according to the Federal District Court in the District of Columbia and the EPA – the law, best available sound science and expert opinion provided to NPS have been submerged. . Unfortunately, it already appears that this is not an opportunity Yellowstone’s current managers are willing to take.

In recent weeks, inaccurate and misleading information has again come out of Yellowstone about snowmobile and snowcoach access. We recently communicated with the Park’s Public Affairs Officer, Al Nash, about factual errors appearing in a January 5, 2010 news release—errors that understated public demand for snowcoach access, while overstating public demand for snowmobile access. While the park issued a “corrected” news release on January 8, it again included inaccurate and misleading information biased against snowcoach visitation to the Park. Moreover, it obscured the two central facts we brought to Mr. Nash’s attention:

▫ The number of visitors choosing to access the Park by snowcoach increased in December 2009 compared to the year before. Twice now, Park officials have informed regional and national media that the opposite has occurred.

▫ Public access to Yellowstone by snowmobile was not restricted in December by the interim rule’s reduced daily limits. This contradicted pre-season predictions by Park officials that the interim limits would thwart “access” on as many as one in four days.

Rather than addressing either of these errors, the Park’s January 8, 2010 release focused on vehicle and visitor data from Old Faithful. Ostensibly providing a “correction,” these statistics have nothing to do with access to the Park by snowmobiles and snowcoaches—the subject of the Park’s erroneous, January 5 news release.

In order to ensure the integrity of the National Park Service’s long-term planning process, by copy of this letter, we are now formally appealing to NPS Director Jarvis to review Yellowstone’s ongoing failure to provide accurate, objective, and clear information to the American people about the conservation and management of their first national park. This issue, which has already elicited more public comment than any other in the history of the National Park Service, is now entering its sixth NEPA process in a decade. As underscored by the President’s recent proclamation recognizing the fortieth anniversary of NEPA and “recommitting to environmental quality through open, accountable and responsible decision making that involves the American public,” a review of Yellowstone’s recent public releases and statements is urgently in the interest of the public and the NPS for three reasons:

First, it is the regretful, considered conclusion of the Coalition of National Park Service Retirees that Yellowstone’s management has pursued a two-year campaign to discredit and devalue snowcoaches—at times misreporting, either willfully or because of sloppy analysis, scientific data to assert, contrary to years of analysis, that the impacts of snowcoaches are “equal” to those of snowmobiles. Failing to disclose visitation data that show the public’s increasing choice of snowcoaches as the preferred means of accessing Yellowstone continues the Park’s apparent campaign to perpetuate snowmobile use, notwithstanding all evidence to the contrary.

Second, the National Park Service stands at the beginning of yet another environmental analysis. The public deserves to have accurate information as it weighs the future of winter use in the Park.

Third, the National Park Service should generally avoid making predictions unless there is very high probability evidence on which to base these predictions. In this case, a dire prediction turned out to be baseless and ought to be corrected. Only when they have accurate information are citizens, stakeholders, and decision-makers able to understand the issues at hand and, as a result, meaningfully engage in the management of our national parks. For example, earlier this year, Senator Enzi attacked NPS’s interim rule as an infringement of winter visitors’ opportunities to access Yellowstone, stating: “More people should be allowed in the park, not less.” Yellowstone officials seemed to suggest that Mr. Enzi’s criticism was warranted when they forecast, in October statements to the media, that under the interim rule this winter about 25 percent of the days would exceed the new 318 limit (e.g. Planet Jackson Hole, 10/21/08 and Billings Gazette, 10/25/08). This prediction of frustrated access omitted discussion of snowcoach access. The Park’s statements contradicted and appeared to undermine the rationale for the interim rule that Secretary Salazar gave to the American people:

“The proposed rule would allow continued access to the park in winter while ensuring the protection of this national treasure and its wildlife while we develop a new long-term plan for winter use in the park.”

In October, Yellowstone officials went beyond predicting that access would be constrained under the interim rule. In one newspaper, the Park’s spokesperson said of the rule’s limit of 318 snowmobiles a day: “It will impact our visitors and it will impact the economy of our gateway communities.” (Planet Jackson Hole, 10/21/08)

In fact, the interim rule’s limits were not reached at all in December. Peak snowmobile use never reached 300; average demand for snowmobiling was between 180 per day and 190 per day—less than 60 percent of the daily limit.

Moreover, Yellowstone recorded a 10.8 percent increase in visitors under the interim rule in December compared to the year before; this included a 9.4 percent increase in snowcoach visitation. But in its January 5 and January 8 news releases, Park officials did not report the increase in snowcoach visitation. Instead, they focused, erroneously, on a contraction of access and use. As part of this storyline, the Park misleadingly told the media, public, the gateway communities, and politicians that the number of snowcoaches that “entered the Park” actually declined in December compared to a year ago. It did not. The number of snowcoaches entering the Park in December 2009 increased compared to a year ago by 7.4 percent (539 versus 502). The number of snowcoach visitors also increased—by 9.4 percent (4786 versus 4375). These facts are clearly recorded in the summary of December 2008 and December 2009 visitation posted last week by the NPS Public Use Statistics Office (attached) – the data for which we assume came from Yellowstone National Park.

The errors in Yellowstone’s January 5 news release were first brought to the attention of its spokesperson that day. We then emailed Mr. Nash on January 7 reiterating the errors and asking for a public retraction/correction. Mr. Nash responded by email later the same day, stating:

“Unfortunately, I did err when putting together the latest news release regarding December 2009 oversnow numbers.

“The figures I used for December 2009 do not reflect snowmobile and snowcoach use originating at Old Faithful.

“The figures for December 2008 and December 2007 _do_ include the Old Faithful numbers, as first reported in a news release of January 8, 2009:
http://www.nps.gov/yell/parknews/09003.htm. Please see the attached document I used as the source for the Dec. 2007 and Dec. 2008 figures.” [This document, entitled “Xmas summary 2008-09” is also attached to this letter.]

In essence, in reporting “trends” in snowmobile and snowcoach visitation, Yellowstone officials have developed a metric apart from NPS’s traditional measure—the statistics used throughout the System, which specifically report access to the parks through their entrances. Notably, these standard entrance statistics were the basis for Yellowstone’s January 5 news release reporting record visitation to Yellowstone in 2009. But in this information, the Park omitted that the statistics reflected growth in both the number of snowcoaches and snowcoach visitors compared to the previous December, both part of the 10.8 percent increase in visitors compared to a year earlier. Instead, the Park reported the opposite: that the number of snowcoaches that “entered the park” was down from the year before.

The subsequent “correction,” which Yellowstone officials claim is more complete due to its inclusion of vehicles and visitors that originate at Old Faithful, in actuality has nothing to do with visitors accessing Yellowstone. In addition, it misleadingly compares “daily averages” in seasons with different opening dates. Anyone familiar with winter use in Yellowstone understands the 2008 and 2009 daily averages are lower than 2007’s in part because the Park has adopted a fixed, earlier opening date of December 15, which comes before there is significant demand to access the Park by any means.

Now there have been two rounds of press coverage in a week misinforming the public that snowcoach visitation to Yellowstone was down in December compared to the year before. This has led publications such as the Wyoming Business Report to report that the Park’s December visitation numbers brought “bad news,” that “unfortunately,” snowcoach as well as snowmobile visitation shrank in December compared to the previous year. This misinformation feeds into the specious frame that Senator Enzi put forward – mentioned earlier in this letter – that reform and improvement of winter use by NPS is hampering visitor enjoyment of Yellowstone rather than enhancing and protecting it. In sum, the Park’s distribution of inaccurate and misleading information has turned a 10.8 percent increase in recreational visitors in December, including a 9.4 percent increase in snowcoach visitors, into a benchmark for further cynicism.

The Coalition of National Park Service Retirees strongly supports NPS’s efforts to move winter access in Yellowstone to a sound, science based, legally defensible resolution. We are concerned that the Park’s dissemination of misleading information is making that task more difficult. We urge you to take action to curb these errors and the false impressions they are creating before they contaminate and hinder your new analysis and public involvement process. We continue to believe strongly that the Park is hampering its path forward by not explaining—particularly in the course of the winter season—the significant benefits for resources and the experiences of those entering the Park that are inherent in the ongoing shift to snowcoach access and the corresponding decreases in vehicle traffic.

Please provide us, by January 22, 2010 a response to this letter describing the actions you intend to take to correct the misinformation that has already been provided to the public and other interested parties and what actions you intend to take to avoid similar inaccurate reports and predictions in the future.

Sincerely,

J. W. “Bill” Wade
Chair, Executive Council

Copies to:

NPS Director Jon Jarvis
NPS Science Advisor Gary Machlis
IMR Regional Director Mike Snyder