FoYV Update: The Truth About the Yosemite Valley Plan: A Development Plan, not a Restoration Plan (2/2004).
Christopher A. Kantarjiev
<yo...@batnet.com>:
FoYV Update: 2/11/04
The following is a one page summary of most of the projects in the
National Park Service's Yosemite Valley Plan. For a better formatted
version go to our web site: www.yosemitevalley.org
TO DO:
** Write your Congressional Representatives (US House and US Senate)
and the Presidential candidates telling them why this plan is not a
restoration plan, but mainly a development plan which will further
commercialize the park and shut out the average family. Use a couple
of examples from this list. Ask them to stop funding its development
projects.
** Write short letters-to-the-editor in response to any related
article which is published.
The Truth About the Yosemite Valley Plan
A Development Plan, not a Restoration Plan
Cost: $441,000,000 -- 94% of which would fund construction projects
(information in this sheet from the Yosemite Valley Plan and other
documents)
In Yosemite Valley:
* The asphalted surface area of Yosemite Valley would increase
significantly (facilitated by an asphalt batch plant to be
constructed in Yosemite for this purpose)
* Approximately half of the Valley's roadways would be significantly
widened or realigned, cutting down historic oaks and impacting River
zones (including Southside Dr)
* A ten-acre traffic check station is planned for the pristine West
Valley (El Cap turnaround)
* A new segment of road would be built at Yosemite Lodge much closer
to the River than the existing segment, bulldozed through riparian
and forest areas (Northside Dr.)
* A 22-bay urban style bus station would be built in Yosemite
Village, and Y. Village would increase in size
* More than 500 round trip diesel buses projected daily during peak
season,1 shuttle arriving every 1.4 minutes
* Air pollution, including deadly small particulates, and noise
levels would increase
* A 14 acre parking lot to be paved in a National Park Service
identified "Highly Valued Resource Area" adjacent to the Merced River
-- Camp 6 (Instead continue the existing 50 yr. old Curry
day-parking)
* Annual Park transportation operating costs would increase more
than 5 times from $1,770,000 to $10,131,000 (Who will pay?)
* So-called lodging "reductions" focus on removal of modest rustic
cabins and tent-cabins in favor of constructing and/or renovating
hundreds of new, more upscale Valley hotel rooms (inappropriately
characterized as "rustic" by the National park Service) ; Yosemite
Lodge and Curry complexes would expand beyond their current borders.
* Almost 40% of the 800 pre-flood campsites were already closed in
1997 before the Valley Plan (accounting for most of the claimed
restoration in the Valley Plan -- lodging generates concession $,
camping does not)
* Restaurant seating in Yosemite Valley would significantly expand
* More development requires more employees which requires more
housing (numbers of employees, support facilities, and operating
costs significantly increase)
* Construction would destroy or degrade scores of native American
prehistoric sites
* New bridges and new and widened pathways would be constructed
through the 56-acre braided stream area of Lower Yosemite Fall
preventing natural sideways stream meandering, impacting wetlands,
degrading and destroying wildlife habitat, traditional Miwuk
gathering areas and archeology (see Lower Yosemite Fall sheet)
Outside Yosemite Valley:
* Extensive parking areas are planned replete with commercial
services producing development and sprawl
* A 600' road segment would be plowed through an intact Yosemite
National Park forest to facilitate private development (at Hazel
Green)
* Administrative stables would be moved to a sensitive low elevation
meadow/wetland habitat, requiring the trucking of horses and the
widening of roadways (McCauley Meadow -- this should be designated
Wilderness)
* A black oak sloped Park woodland is in the works to be traded and
graded for a private lodging development. (Wawona, SDA Camp)
Pristine Park wetlands would be traded to a developer at El Portal
(Fischer exchange)
* Construction would occur in sensitive habitat and endangered
species foraging areas (e.g. Great Gray Owl)
* Large new tracts of employee housing and administrative
development would be built on undisturbed land at El Portal, Wawona,
and/or Foresta
Contact: Joyce Eden <yo...@batnet.com> * Friends of Yosemite Valley
(c) 2004 * www.yosemitevalley.org
- permission is granted to reproduce or copy this in full
only -
b wolfe
plan?
Can you plot the progression this plan will follow during review and
list contacts at those stages to which opposition can be directed?
thank you
Bernard Wolfe
Birmingham, AL
Greg
b wolfe wrote:
> What is the most effective way currently to voice opposition to this
> plan?
>
> Can you plot the progression this plan will follow during review and
> list contacts at those stages to which opposition can be directed?
Great question. I'm sure there are many of us that are deeply
disturbed by "The Plan", but are unsure of the best way
to help, especially at a distance.
Chris, thanks for the updates!
-Greg
Chris Kantarjiev
I think that the best way to voice opposition is to follow the "TODO"
section in the update: write letters (historical evidence suggests that
a handwritten letter is best, faxed next, email least effective) to your
congresscritters.
If you don't know how to reach your Congressional Representatives, you
can find their names, contact info and key voting history at
http://www.congress.org/congressorg/home/ ...
Mad Dog
>I'm sure there are many of us that are deeply
>disturbed by "The Plan", but are unsure of the best way
>to help, especially at a distance.
This plan seems to be in the same spirit of the last plan - which we got tossed
out. These developers are pesky buggers. Makes me feel like I'm climbing in
the spring, repeatedly swatting mosquitos while trying to give a quality belay
to my partner.
melissa
>The following is a one page summary of most of the projects in the
>National Park Service's Yosemite Valley Plan. For a better formatted
>version go to our web site: www.yosemitevalley.org
Thanks for posting this Chris!
If anyone wants to read a digest of the plan where it is likely to impact the
climbers the most, the Access Fund has written this document. It's around 20
pages if memory, serves, but the actual plan is bigger than a big set of World
Book Encyclopedias. The Index volume alone falls somewhere between War and
Peace and Atlas Shrugged in length.
I hope Karl Baba is reading and offers up some comments as I know he's thought
about this a lot.
Here's the link to the Access Fund Doc:
http://www.uweb.ucsb.edu/~kmhay/valley_plan.htm
Here's the text...sorry if it doesn't paste well:
July 6, 2000
BY FAX: 209-372-0456:
BY E-MAIL: YOSE_p...@nps.gov
David Mihalic, Superintendent
Yosemite National Park
P.O. Box 577
Yosemite, CA 95389
Re: The Yosemite Valley Plan
Dear Mr. Mihalic:
This conveys the comments of The Access Fund on the Draft Yosemite Valley Plan
("the Plan"). Our comments concern camping, lodging, and transportation.
To summarize our comments concerning camping, we are pleased to see that the
Preferred Alternative will preserve and expand Camp 4, but we believe its
parking should be designed to be integral with the campground so that it
contributes to preserving the campground's unique culture and identity.
We are very concerned that the Preferred Alternative fails to restore the
campsites lost or demolished in the flood and proposes further removals and
demolitions. We believe the Preferred Alternative should accord a higher
priority to camping, maintain the campsite numbers proposed in the 1980 General
Management Plan, and reduce the number of developed lodgings, which are becoming
increasingly available outside the park.
Consequently, we support the proposals for campsites, but not for developed
lodging, in Alternative 5.
Our reasons are 1) that camping is a form of recreation, which lodging is not;
2) that camping brings the visitor closer to park resources than developed
lodging; 3) that developed lodgings are being built outside the park in great
numbers, while campsites are continuing to be lost both inside and outside the
park; 4) that camping brings people closer to nature and our history than
developed lodgings; 5) that camping is more democratic than lodging, and; 6)
that camping brings people into closer community with each other.
We have added an appendix containing our detailed suggestions for ways to
provide additional campsites in the Valley while preserving the high value
resources of the Merced River watershed. We concede the necessity to remove the
Rivers Campgrounds but believe their loss should be mitigated by the
construction of replacement campgrounds elsewhere in the Valley. We believe
Lower Pines should be retained at the size proposed in Alternative 5 and
expanded into the area that will become available with the demolition of Boys
Town and the Curry Orchard parking lot. We believe North Pines should be
retained as a walk-in campground, with additional sites along the north side of
the Medial Moraine, and the amphitheater proposed for this area moved to Curry
Village. We propose the removal of the Ahwahnee cabins and the development of a
Royal Arches Campground extending from the present administrative/utility site
east to the proposed Tenaya Creek campgrounds. We believe that the Yellow Pine
volunteer campground should be relocated to another site in the Valley, not
moved to Foresta. And we believe that proposals for new campgrounds in the
Upper Pines area should be expanded and that the wilderness parking and horse
corral and horse trailer parking proposed for this area should be moved to an
area that is not suitable for campground development.
Regarding lodging, we believe the Plan fails to present a vision for the park
that adequately fulfills the goals of the General Management Plan to reduce the
scale of development and restore the Valley's natural values. The Plan fails to
take into account the historical context in which the Valley's lodging was
built, the continued development of new lodging outside the park, and the
future context in which the lodging the Plan proposes in the Valley will exist.
We believe the Plan should begin the process of phasing developed lodging out of
the Valley, not create more development. We believe the Plan should create a
vision of the Valley that more closely resembles the type of development in
Tuolumne Meadows, with winter accommodations similar to what is now available at
Curry Village.
Regarding transportation, we support the Plan's effort to reduce dependence on
the automobile and increased use of transit and shuttle buses and to convert
North Side Drive to a multi-use trail. We are concerned, however, that climbers
will not be adequately served by the shuttle bus in the Mid-Valley and West
Valley, and that trailhead parking should be retained in these areas. We
believe that roadside parking and informal turnouts should be kept in the Valley
west of the proposed guard station at El Capitan crossing to maintain some
flexibility in the Valley's transportation scheme. We believe that big wall
climbers' need for overnight trailhead parking has not been given adequate
consideration. We are also concerned that insufficient thought has been given
to the parking needs of campers on their last day in the Valley. We believe
that frequent visitors who do not need intensive visitor facilities and services
upon arrival should have a place to park at Curry Village. We think the shuttle
service in the Valley east of Curry Village and Clark's bridge should be
terminated. And we think the transportation scheme will result in increased
public demand for informal means of transport and "close-in" recreational
amenities that the Plan has not addressed.
THE ACCESS FUND
The Access Fund is a national non-profit organization of climbers dedicated to
preserving the climbing environment and maintaining climbers' access to climbing
resources. The Access Fund publishes low-impact educational materials for
climbers, funds climbing impact mitigation projects, acquires land with climbing
resources, participates in the development of land management plans affecting
climbing, and contributes to the formulation of policies concerning climbing by
federal and state land management agencies.
Access Fund activities in Yosemite include participating in preparing the Draft
Climbing Management Plan; participating in meetings concerning the Lodge Plan,
commenting on that plan, and joining as a plaintiff in the climbers' lawsuit to
save Camp 4; developing a climbers' trail at Sunnyside Bench in Yosemite Valley;
preparing a climbers' low impact informational brochure; preparing extensive
comments on the Draft Valley Implementation Plan and Merced River Plan;
preparing a survey of campsites in the park, showing changes proposed in the GMP
and the shortfall in campsites today, and reporting in our regional newsletter
informational items forwarded to us by the park's climbing ranger. We are
pleased to have the opportunity to comment on the Valley Plan as well.
At the outset, let me say that we support the principles of environmental
preservation that underlie the Plan, the general goals of the Plan, and many of
the specific proposals in the Preferred Alternative. We support the effort to
reduce the use of the automobile and to increase the use of transit in the
Valley; to reduce the number of park and concessionaire employees living in the
Valley; to preserve the watershed and riparian values of the Merced River; and
to reduce the amount and scale of development.
In particular, we would like to congratulate the Park Service for proposing in
the Preferred Alternative to preserve Camp 4 and the Swan Slab area from
development for employee housing, to expand Camp 4 from 37 to 65 sites, and to
preserve its availability as a first-come, first-served campground. Plan at
2-39.[1] We are delighted by this proposal and deeply gratified to see that the
growing understanding between the Park Service and the climbing community is
reflected in concrete form in this proposal in the Preferred Alternative.[2]
We also note with concern that the Preferred Alternative would move Search and
Rescue out of the Valley. Plan at 2-49. We presume this refers to the Search
and Rescue office, and that the Plan is not proposing to terminate the park's
traditional reliance on climbers at Camp 4 to serve on search and rescue crews.
Please clarify this in the Plan--and inform us if our assumption is incorrect.
There are other aspects of the Preferred Alternative that we believe should be
modified, and we offer our suggestions and reasoning below. Our comments are
focused on the Plan's proposals for camping, overnight lodging, and
transportation.
CAMPING
In the Valley, climbers typically prefer to camp, even those who can afford to
stay in lodgings, because they like to be outdoors. Consequently, the
availability of campsites and the quality of the camping experience in the
Valley are of paramount concern to climbers.
We are very concerned that the Preferred Alternative proposes the continued
reduction in campsites in the Valley. The Valley presently has 475 campsites,
Plan at 2-18, 281 less than the 756 campsites called for in the 1980 General
Management Plan ("the GMP"). The Preferred Alternative would reduce that number
by another 10 sites, Plan at 2-39, bringing the shortfall to 291, a reduction
from GMP levels of 38%.
We are aware that the Preferred Alternative also proposes to reduce the numbers
of other types of overnight accommodations below GMP levels. Thus, under the
Preferred Alternative, all other types of overnight accommodations in the Valley
would be reduced to 981 units, 279 less than the 1,260 units proposed in the
GMP, GMP at 35, and 234 less than the 1,215 units proposed in the 1992
Concession Services Plan ("the CSP"), CSP at 8; Plan at 2-39 - 2-40. This
constitutes a reduction of 22% from the number of lodging units proposed in the
GMP. So, while the shortfall in campsites is 38% below GMP levels, the lodging
unit reduction is only 22%--about half the percentage of the proposed campsite
reductions. Why does the Preferred Alternative propose a reduction in overnight
accommodations that discriminates so heavily against camping and in favor of
developed lodging?
We believe that the proposed reduction in campsites in the Preferred Alternative
is excessive, and that the proposed reduction in developed lodgings is
inadequate. Our reasons are based on the importance of camping to the visitor
experience and park values and purposes. Since this importance is not
recognized in the Plan, we will take this opportunity to explain it at some
length.
First, camping is more than simply another form of overnight accommodation. It
is also a recreational activity. Camping entails erecting one's own shelter,
cooking one's own food, making one's own bed, and providing one's own heat,
light, and entertainment. As such, camping is appropriately distinguished from
staying in developed lodging, which is not a type of recreational activity but a
form of leisure--the consumption of an array of labor-intensive personal
services within a capital-intensive physical plant. Thus, providing campsites
does more than simply accommodate a need for overnight accommodations, it
facilitates a recreational experience.
Second, camping offers the visitor the closest relationship to park resources of
any form of overnight accommodation in the Valley. The Park Service's
Management Policies specifically state that one mission of the Park Service is
to "encourage recreational activities that . . . promote visitor enjoyment of
park resources through a direct association or relation with those resources."
Management Policies at 8:2 (1988) (emphasis added). Camping, and particularly
walk-in camping, does precisely this--by removing the visitor further from
dependence on the modern conveniences of buildings, vehicles, and concessionaire
services than any other form of overnight accommodation in the Valley.
Consequently, the Park Service should consider camping to be the "highest" form
of overnight accommodation in the park.[3]
Camping requires park visitors to step out of their normal zone of comfort and
convenience and meet the park on something approximating its own terms. The
camper has to deal with the seasons, the weather, the rising and setting of the
sun and other manifestations of the elements, wildlife in its many forms, and
other human beings and all their delightful and infuriating ways of behaving,
while relying on his own wits and resources to meet these challenges. In doing
so, the camper comes to know both himself and the park a little better. The
knowledge that comes from this is an important part of the park experience. The
lodger, by contrast, who scarcely has to step outside the bounds of the world he
lives in every day, has a far less indelible experience of the park, and is more
likely to come away with only a two dimensional appreciation of its beauty.
What is lost in the process is a deeper appreciation of the park and its
resources.
Third, the number of camping facilities in the Yosemite region has been
declining,[4] while the number of developed lodging units in the region has been
increasing, with over 1200 new lodging units proposed outside the park right
now.[5] The private sector has the capability of completely fulfilling the
demand for developed overnight lodging in the Yosemite region by building
additional lodging units outside the park. The same is not true for campsites.
In the Merced River Plan ("the MRP"), the Park Service acknowledged that camping
facilities cannot be expanded in the region outside the park, and that visitors
displaced from camping in the park may not find camping accommodations in the
region and could simply end up not coming to the park altogether. MRP at IV-28.
This growing imbalance in the availability of campsites and developed lodging
outside the park, and its effects on the needs of park visitors over time, needs
to be addressed in the Plan.
Fourth, camping serves park values and purposes better than any other form of
overnight accommodation. The values that pervade American society are the
commercial values of comfort and convenience and the expression of social status
through the consumption of goods and services. In contrast, parks are places
where people come to escape the relentless and pervasive influence of these
values, and the constant innovations in technology that are their bedfellows.
In parks, people seek the values of nature, with which many yearn for a
meaningful connection, and the experience of our past, when life was slower,
simpler, and more physically demanding. Camping allows people to pursue these
values, and to experience the simpler material conditions of our forebears,
better than any other form of overnight accommodation in the Valley.
Fifth, camping is democratic. Where people have to perform outdoors without
benefit of utilities and technology their basic daily life functions such as
cooking, washing, cleaning, erecting shelter and providing warmth and light,
social distinctions count for little. Camping has the potential to bring people
together in shared appreciation of their natural surroundings in a manner that
reduces social barriers. This is an essential element of the appeal that runs
through the great diversity of experiences that define camping--not simply in
Yosemite or even in the national parks, but wherever that uniquely American
social phenomenon called camping manifests itself, including in the summer camp
for kids, the cabin on the lake, the fishing camp in the rockies, the base camp
in the mountains, or the KOA campground in Anywhere USA.
Unfortunately, by trying to appear value-neutral while relying on the park
concessionaire's customer surveys to determine consumer demand for overnight
accommodations, the Plan simply perpetuates within the park the social and class
distinctions of the greater society outside it. This is neither a necessary nor
a desirable result. In the great parks, the Park Service has an opportunity to
be a powerful force for social equality, in somewhat the same way that the
military is a powerful force for racial equality, because they both control so
many aspects of the social environment in their respective realms. In Yosemite
Valley, the social and class distinctions of the greater society are firmly
embedded in a hierarchy of accommodations that dates back to the turn of the
century, and one that became fixed in place with the construction of the
Ahwahnee in the 1920's. This was a period not unlike our own, when the
tremendous growth in wealth of the society led to even greater social and class
distinctions. We think the Plan should begin to move the park away from this
hierarchical structure, not perpetuate it. And we find it particularly shameful
that the Plan leaves the most expensive forms of overnight accommodation
untouched while proposing tremendous reductions in camp sites and rustic units,
the very forms of accommodation that further the park's democratic values.[6]
Sixth, in addition to being democratic, camping is inherently communal, and we
believe that fostering a sense of community--or communalism--is an important
park purpose. Campsites have no walls, and people camping in close proximity to
each other, or even sharing sites together as they do at Camp 4, have an
enhanced opportunity to associate with other people, develop new relationships,
and broaden their social horizons. Visitors who stay in developed lodging, by
contrast, are more likely to limit their social contacts to the people within
the four walls of their lodging unit, and to maintain their psychological cocoon
as they move from their vehicle to their lodging unit to their restaurant table
and back to their vehicle. Drawing people out of their cocoons to join others
in a shared appreciation of nature and history is an important purpose of the
parks, and one which is greatly facilitated by the camping experience. For this
reason, we believe that preserving adequate group camping facilities in the
Valley is especially important.
We are disappointed that the Plan contains practically no discussion of these
and other human values that should underlie park management. Much is made in
the Plan of the resource values of the park and their importance in guiding the
decision-making that underlies the Preferred Alternative. But aside from a
brief mention of the goals of the 1980 General Management Plan, see Plan at I-9
- I-10, and some functional criteria for visitor improving the visitor
experience, see Plan at I-II, the Plan contains no discussion of human values at
all. Why is this?
This leaves the park with no basis for making planning decisions, and
particularly decisions regarding overnight accommodations, except the
concessionaire's reservation statistics and visitor surveys. These may seem
"objective", but in fact they simply reflect the concessionaire's own
priorities. Thus, lodging statistics may show a visitor preference for more
developed lodgings, as the Plan notes. Plan at 4.2-100 - 101. But the
concessionaire maintains its developed lodgings, and the facilities and areas
around them, at a much higher standard than its rustic lodgings, and this has to
have a tremendous influence on demand.
Compare the barren, denuded and dusty roadways of the Curry Village tent cabins
with the paved and landscaped walkways of Yosemite Lodge or the manicured lawns
and gardens of the Ahwahnee. The concessionaire is clearly working to create
increased demand for the more developed facilities, on which it doubtless makes
a greater profit per visitor night, while reducing, or at least remaining
indifferent, to the demand for more rustic and affordable facilities. What
would the demand for the Curry Village tent cabins or rustic winter cabins be if
the grounds and facilities around them were maintained at a level similar to
those around the Ahwahnee? We think it would be much higher than it is now, and
particularly if the more developed types of lodgings were greatly reduced in
number. We also think that the greatest weakness of the Plan is its failure to
create a vision for overnight accommodations in the Valley that looks beyond the
one now provided by the concessionaire.
Given the importance of camping to the visitor experience, the Plan needs to
include a clear statement that camping is a critical form of overnight
accommodation
and recreation in the Valley, that it furthers park values and purposes better
than any other form of overnight accommodation (except backpacking), and that
the provision of an adequate number of campsites deserves to be accorded a
sufficient priority among other planning goals, particularly the restoration of
watershed habitat and floodplains, so that the park can maintain the number of
campsites called for in the GMP, as well as a quality experience for campers.
Why doesn't the Plan present a value system that supports camping, since it is
such a fundamental part of the park experience?
From there, the Plan should consider retaining or replacing many of the
campsites now proposed for elimination. At present, the Preferred Alternative
proposes to remove all campsites in the flood plain with little regard for, and
absolutely no discussion of, variations in flood depths or flood water
velocities. Where 100-year or 25-year winter floods inundate vacant campsites
without causing any substantial damage to structures or harm to resources, there
is no reason that these sites should be removed. The 1997 flood inundated many
sites and left them completely unharmed.
Nevertheless, the Preferred Alternative proposes to remove all sites in the
flood plain regardless of the degree of damage they suffered in the floods or
the minimal resource benefits to be attained by their removal. Thus, under this
alternative, the Plan proposes to eliminate all 86 sites in North Pines, 38
sites in Lower Pines, all 30 sites at Backpackers, and 4 sites at Yellow Pine
campgrounds, a loss of 158 sites, and to ratify the park's undocumented
demolition or abandonment after the 1997 flood of 276 sites at Upper and Lower
Rivers, 95 sites at Lower Pines, 15 sites at North Pines, and 11 sites at Group
Camp, a further loss of 397 sites, for a total loss of 555 sites. The Plan
proposes to build only 148 new sites, leaving a net loss of 407 campsites from
the Valley's pre-flood campground numbers and a proposed final number of 475
campsites sites in the Valley. Plan at 2-18, 2-39. This is even less than the
652 sites proposed in the Preferred Alternative in the 1997 Valley
Implementation Plan ("VIP"), VIP at 46. We believe these reductions in
campsites are excessive, and that where campsite removals are justified, the
Preferred Alternative makes insufficient provision for their replacement.
Alternative 5 in the Plan proposes to retain 713 campsites in the Valley,
largely by expanding Upper Pines, preserving North Pines, and rebuilding a
portion of the Rivers campground. Plan at 2-127 - 128, Plate 5-2. This
alternative would also, like the Preferred Alternative, develop new campgrounds
along the base of Glacier Point Apron. Id. We support the campground numbers
in this alternative, which most closely approximates the 756 sites called for in
the 1980 General Management Plan. We have attached an appendix that discusses
our proposals for campsite development in more detail.
We are also concerned by the park's demolishing or abandoning many campsites
after the 1997 flood. Following the flood, the park demolished or abandoned the
Upper and Lower River Campgrounds, as well as sites in North Pines, Lower Pines,
and Group Camp. The park did so, however, without preparing the environmental
documentation required by the National Environmental Policy Act ("NEPA") and
without providing any notice to or allowing any comment by the public. The
public was given no information regarding the extent of the damage, no
opportunity to form an opinion as to whether the demolition or abandonment of
these campsites was warranted, no opportunity to consider alternative courses of
action, and no opportunity to consider actions to mitigate the loss of these
campgrounds. This arbitrary action by the park resulted in the loss of 397
campsites in the Valley, about half of the pre-flood total. This was a
violation of NEPA and an abrogation of the Park Service's duty to manage the
park in a manner consistent with the interests of the public.
In our comments on the Merced River Plan, we asked the Park Service to consider
the post-flood condition of these campgrounds as the baseline condition for both
the Merced River Plan and the Valley Plan, so that the decision-making for the
future of these campgrounds could be brought into compliance with NEPA, and so
that the public could be included in the decision-making process, as NEPA
requires. In this way, the environmental impact of the demolition of these
campgrounds would have been fully assessed and reviewed by the public and
necessary mitigation measures for the loss of these sites included in these
plans. Why was our request not granted? We are very concerned that this
omission not only ignores the concerns of the public regarding the fate of these
campgrounds, but leaves both plans vulnerable to litigation for failing to
comply with NEPA.
Instead of taking the post-flood condition of the Rivers campgrounds as its
baseline condition, as we requested, the Park Service chose the post-demolition
condition of the campgrounds as its baseline for the Valley Plan. Plan at
2-18.[7] This allowed the park to claim the Preferred Alternative would reduce
the number of campsites in the Valley by only 10, from 475 to 465, Plan at 2-38,
and that this "2 % reduction" in campsites would have only a "minor" adverse
impacts on campers. Plan at 4.2-84. The reality is that the Preferred
Alternative, which the Park Service anticipated in demolishing the campgrounds,
will result in the loss of over 400 campsites, not 10, as the Plan states.[8]
This, as the Plan acknowledges in its discussion of cumulative impacts, is a
major adverse impact. Plan at 4.2-87. For the park to say that only 10 sites
will be removed under the Preferred Alternative is fundamentally dishonest,
particularly when the Park Service admits that the Rivers Campgrounds were
demolished in part in anticipation of the Plan's recommending that they be
removed.[9]
The Preferred Alternative encouragingly suggests that the quality of the camping
experience in the Valley will be improved under the Plan. Plan at 2-39. Thus,
there would be a wider range of camping experiences, with RV sites with
electrical hookups to reduce generator use, drive-in sites, and walk-in and
walk-to sites. Id. Campgrounds would be redesigned to have better separation
between sites, although densities would not change. Id. Showers would also be
provided where feasible. Id. We welcome these improvements and strongly
suggest one more--the modernization and rehabilitation of the existing toilet
buildings, which are a disgrace. Does the Plan include this as a cost item in
its budget?
In sum, we believe that the 713 campsites proposed in Alternative 5 better
reflects the importance of camping in furthering park values and purposes and
enhancing the visitor experience. We urge you to implement the campground
proposals in Alternative 5, or our alternative suggestions, in order to achieve
a number of campsites that more accurately reflects camping's importance to the
visitor experience in Yosemite Valley. We would also be pleased to meet with
park managers to review our suggestions for new campground development in more
detail.
We also believe that the Plan should propose to designate a specific number of
recreational vehicle (RV) campsites and separate these sites from tent sites.
RV living is not camping and should not be accorded the same status as camping
in the Plan. RVs provide a self-contained living unit with facilities for
sleeping, cooking, washing, bathing, climate control, and media entertainment
that is even more insulated from park resources than developed lodging units.
RV use also conflicts with camping, not only directly through the use of noisy
generators, but indirectly by introducing into the campground people who do not
share the camping values discussed above. If the park believes that space for
overnight accommodations is at a premium in the Valley, RVs should be the first
to go. Precious space for campers' picnic tables and tent sites should not be
taken up by these movable buildings. Why doesn't the Plan make a clearer
distinction between RV parking and real camping?
LODGING
We believe the Plan's analysis of the need for lodging in the Valley should
begin by acknowledging an essential fact: there is no absolute need for
developed lodgings to remain in the Valley into the indefinite future. The Plan
could easily propose to phase out all developed lodgings in the Valley over a 20
or 30-year period. The private sector, possibly with assistance from the Park
Service and Forest Service in planning and land acquisition, could easily
satisfy the demand for lodgings that are now located in the Valley. The Plan's
lodging proposals, by contrast, are rooted in the past and fail to consider the
tremendous changes that have and will continue to take place outside the park.
We tend to overlook conditions outside the park and to assume that because the
Valley's lodging exists now, it should exist forever. This point of view
overlooks the fact that lodging was originally developed in the Valley because
day visitation in Yosemite's early years was not really an option, due to the
poor quality of the roads and the slowness of the means of transport, as well as
the unavailability of lodging near the park, at least before the development of
the Wawona Hotel.
The Plan is an excellent place to remind people that developed lodging could be
entirely removed from the Valley, and it should take the opportunity to do so.
Why doesn't it? Thus, one option the Plan should consider is the phasing out,
over a period of time, of developed lodgings in the Valley, or at least the type
of lodgings that the private sector is able and willing to provide outside the
park. Under this option, existing buildings of architectural and historical
significance that are presently devoted to lodging or employee housing, notably
the Ahwahnee Hotel and the Ranger Club could be preserved and reused in a manner
that serves other, higher park values and purposes--perhaps, for example, as an
environmental institute for the study of the ecology of the Sierra Nevada--while
less notable buildings would be simply removed and their sites restored.
Given that developed lodging is no longer an essential feature of the Valley,
and given the importance of the camping experience in furthering the park values
and purposes we have identified, we believe the Park Service needs to develop a
long-term vision for the Valley that is far different from that laid out in the
Preferred Alternative in the Plan. A model for our vision of the future of the
Valley already exists in the park, in the tiny alpine metropolis of Tuolumne
Meadows. Here, nature reigns with only minor interference from man, and social
distinctions are reduced to a narrow band of little significance. The visitor
has the choice of backpacking, high camp trekking, car camping, or platform tent
camping. Many visitors of obvious pedigree select the platform tent lodgings
and appear quite content with their choice. A jovial babble of languages from
every corner of the globe is heard at the little tent restaurant--and all this
exists year after year without any public clamor for the construction of motel
lodgings or luxury hotels. This tells us that a similar vision could be
realized in the Valley. While some accommodation to winter conditions would be
required in the Valley, surely this does not warrant the importation of
America's full suite of commercial comforts. We believe that for winter use the
rustic cabins of Curry Village are more in keeping with the park values we have
outlined.
Let the private sector outside the park accommodate those who desire the
convenience and comfort of modern lodgings. Where there is demand, commerce
will quickly respond. Begin now the process of weaning the public from these
comforts in the park. In the Plan, the Park Service has shown the courage to
pry Americans out of their cars. How much more courage can it take to drag them
out of their hotel rooms?
Let the park be the place that provides the type of overnight accommodations
that the private sector cannot--meaning camping, including the type of camping
in platform tents provided in Curry Village and Tuolumne Meadows. Provide the
type of rustic lodgings minimally necessary to accommodate winter guests.
Anything beyond that level of accommodation is antithetical to the park values
we have identified and belongs outside the park.
We realize the park cannot achieve this vision at a single stroke. Commercial
values are too strongly embedded in the thinking of park management, in the
history of the park's lodging facilities, and in the expectations of park
visitors. But in the Plan, the park can begin a process that will likely take
the rest of this century--the realization of the vision we have set out here, to
move all developed lodging except rustic winter cabins and tent platforms out of
the Valley. We urge you to develop a Preferred Alternative in the Plan that
directly addresses this goal and that explicitly considers the ability of the
private sector outside the park to provide replacement lodging for those
developed lodging units lost in the 1997 flood in both the immediate and the
distant future. Then and only then should the Preferred Alternative consider
whether new lodging units should be built in the Valley to replace those lost in
the flood or proposed for removal from the floodplain.
TRANSPORTATION
We applaud the Plan's attempt to reduce the use of automobiles and to increase
visitor reliance on transit to and in the Valley. It is obvious that the Valley
receives more automobile use during the peak season than it can handle, and that
the visitor experience suffers as a result. We also support the closure of
North Side Drive to autos, the extension of shuttle bus service to the
Mid-Valley and West Valley, and the development of parking outside the Valley
(but not at Taft Toe).
We are concerned, however, that the transportation proposals in the Preferred
Alternative are too rigid and too broad, and that the Plan is lacking in the
details necessary for the public and climbers to understand how it will affect
them. While we are willing to support the Plan's transportation proposals, even
though these changes will cause climbers some inconvenience, we are concerned
that off-season and off-hour shuttle service will not satisfactorily serve
climbers, and that both out-of-Valley and in-Valley shuttle buses will not stop
at the many out of the way places that only climbers go to. We also believe
that off-season automobile use in the Valley is not a problem, and that the Plan
should not mandate a "solution" to a problem that does not exist.
We are also concerned that the Plan is unrealistic about the levels of shuttle
bus service that will be provided. The Plan states, for example, that
off-season service from the out of Valley parking lots will run every 7-12
minutes all day long. Plan at 2-47. This is complete fiction. Bay Area
transit agencies cannot even manage to provide this level of bus service between
San Francisco and outlying metropolitan centers. How is the park going to do
better?
We also do not believe that shuttle bus service to the Valley west of the
proposed guard station at Taft Toe will adequately serve climbers' needs,
particularly in the off-season or during off-hours. Consequently, we believe it
is a mistake to remove the roadside parking and turnouts and otherwise hinder
automobile use in the West Valley. We therefore propose that the West Valley be
served by the shuttle buses, but that it also be available for auto touring and
that all existing parking areas and turnouts remain in service. Our reasons are
founded in what we believe will be the pattern of visitation under the new
transportation scheme.
Most visitors to the West Valley will be interested in visiting either El
Capitan Meadow or Bridal Veil Falls--there isn't much else of interest to the
average visitor. Right now, many people visit Bridal Veil on their way into the
Valley. They can park there and walk up to the base of the falls or stop by the
roadside and enjoy the meadows below Lower Cathedral. Under the new
transportation scheme, presumably, the falls and meadow parking would be removed
and the falls would be accessible only by taking a shuttle bus from the Valley.
No day visitor will make this trip, since it will require first driving past the
falls in a bus or car on the way to the East Valley Visitor Center, boarding a
shuttle bus back out to the falls, taking a shuttle back to the Visitor Center,
and then taking a bus or car back out of the Valley--thus transiting the same
length of the Valley four times in one day, with a wasted time in transit of at
least two hours, compared to the few seconds now needed to pull into the parking
lot.
Overnight lodgers will fare little better. How many will really want to spend
one to two hours going to and returning from a destination that has no
supporting picnic areas, no inviting beaches, and no trails that lead
anywhere--in short, where there is nothing really to do but take a quick look at
the falls and get back on the bus and leave?
We think not many. We also think it will not take the shuttle bus managers long
to figure out that nobody is interested in going to Bridal Veil Falls early or
late in the day, or when its north-facing cliffs are dark, cold, and in shadow,
or when the falls are not particularly dramatic, and that the greater number of
visitors headed to the sunny and inviting El Capitan Meadow can easily be served
by having the shuttle bus drive over the El Cap crossover, turn around at the
intersection at the other end of the crossover, and head back to the East
Valley, thereby saving a wasted trip out to Pohono Bridge and back up Southside
Drive. The result, we believe, is that in a short time the entire idea of a
West Valley shuttle will be found to be a failure, with service past El Cap
Meadow reduced to a few perfunctory mid-day circuits in the peak season.
Climbers will be the group to suffer the most as a result, since they will lose
effective access to climbs at Ribbon Falls, Leaning Tower, and the Cathedrals.
But others will suffer needlessly as well. People who come to the park but are
unable to take the shuttle buses into the East Valley because of time
constraints or because their itinerary does not permit it should have an
opportunity to stop and spend some time at Bridal Veil Falls or El Capitan
Meadow, even if they can not enter the East Valley. People turned back at the
guard station are going to expect to be able to do something in the Valley and
are likely to be very upset if they can't even pull over and spend some time
relaxing along the river or in a meadow. The access afforded by the existing
roadside and informal parking areas would serve as an important relief valve
from the rigidity of the transportation plan for the Mid-Valley and East Valley.
The Valley would then have a two-tier system, where auto use in the Mid-Valley
and East Valley was formally regulated by the guard station, while auto use in
the West Valley was informally regulated by the availability of roadside
parking. This gives the transportation element of the Plan some badly needed
flexibility and provides a transition zone between the travel strictures in the
Mid-Valley and East Valley, which many visitors will not be prepared for, and
the rest of America.
While the picture will be somewhat more positive in the Mid-Valley between El
Capitan cutoff and Sentinel Bridge, we doubt that shuttle service will be
adequate to meet the needs of climbers making early morning ascents or late
night descents at the long climbs at the Cathedral Rocks or Sentinel Rock. If
parking areas and turnouts serving this mid-Valley section of Southside Drive
are eliminated, climbers will have no effective access to these climbs. And
eliminating these turnouts will do little to further the Plan's transportation
goals, since few non-climbers will be interested in stopping at these locations.
Hence, informal turnouts and parking areas that serve these Mid-Valley climbing
resources should remain in service. If you insist on removing these informal
parking areas, what assurance are your prepared to offer climbers that off-hour
and off-season access to these locations will be available by shuttle?
We also think that overnight parking for big wall climbers should continue to be
available at trailheads, including trailheads for the West Valley walls at
Leaning Tower and El Capitan. Climbers should not have to drive or take a bus
all the way into the Valley, park at the Village, and then take the shuttle back
out to, say, Leaning Tower, for a total added time wasted in transit and waiting
of one to two hours in a single day. This goes well beyond what the Plan calls
"inconvenience." Nor should providing this parking be considered as giving
climbers "special treatment"--it is simply affording climbers the same level of
convenience for overnight parking that lodgers, campers, and wilderness users
have. Climber parking at Happy Isles, as proposed in the Preferred Alternative,
Plan at 2-38, would be adequate only to serve climbers headed for overnight
trips on Half Dome. And big wall climbers headed to Washington Column or Mount
Watkins would need to be able to park at the Ahwahnee. If you believe this
parking should not be provided, on what basis do you distinguish between
climbers using these access points and other overnight park users using access
points close to the parking you have provided for them?.
We believe the transportation system is too narrowly designed for the first-time
visitor, or visitors who have come to the Valley only a few times. These
visitors will doubtless appreciate a better "sense of arrival", Plan at 2-35,
and better information and orientation. And doubtless their transportation
needs to the Valley's primary attractions will be readily served by the shuttle
system.
Visitors more familiar with the park will pay a heavy price, however. It seems
unlikely that the transit buses from outside the park, which will apparently
carry both visitors and employees, will stop on the way to the Valley at places
like Bridal Veil Falls, Cascade Falls, or Tunnel View so people can get out and
appreciate these features. Nor is it likely that climbers riding these buses
will be able to get out at any of the climbing areas along the road in the West
Valley or Mid-Valley, such as Leaning Tower, the Cathedrals/El Capitan, or
Sentinel Rock. Rather, it seems likely that they will be compelled to ride the
out of Valley shuttle bus all the way in to the Visitor Center and then take a
shuttle bus back out to their trailhead, for an added transit time of one to two
hours one way. What provision do you plan to make for the out-of-Valley buses
to stop and let people off, either at well-known features or at the out-of-the
way places visited only by climbers? Why don't you provide "express" and
"local" buses to the Valley, so climbers and others wanting to visit sites on
the way in to the Valley can get off (and back on) the bus without first having
to go all the way to the East Valley?
We also think that frequent visitors to the Valley will want nothing more than
to avoid arriving at the urbanized transit hub at Yosemite Village, with its
hordes of jostling and disoriented first-time visitors. For these people, a
quieter arrival at their trailhead, or at a less crowded parking area in Curry
Village, would provide a more pleasant experience. For this reason, we favor
retaining some parking in Curry Village for those who do not need the services
of the Visitor Center.
The Plan should propose a special parking arrangement for campers and lodgers
who are spending their final day in the Valley and touring by shuttle bus. We
are concerned that not enough thought has been given to the parking needs of
campers and lodgers that will be generated by the plan's restrictions on vehicle
use. At present, campers who are leaving a site must get their vehicle out of
the campsite by 10:00 a.m. Campers planning to spend their last day in the
Valley, and touring or heading to a trail head by shuttle bus, will have to
either leave their cars parked at their campsite and risk getting a citation, or
get up at the crack of dawn and rush to break camp so they can get a parking
place at the day use lot before it fills up, which in the peak season will
probably occur fairly early in the morning. This is not the way to provide a
quality visitor experience for campers. Lodgers will not have to worry about
getting a ticket because their vehicles are not identified with a particular
lodging unit--although arriving replacement lodgers may wonder why there are no
parking places for them. What provision are you making for the parking needs of
campers and lodgers who plan to spend their last day touring the Valley by
shuttle bus?
We believe that the transportation proposals in the Plan, and the uncertain
transportation management process that is alluded to throughout the Plan, will
generate many unforeseen and unexpected problems. We urge the park to proceed
slowly and maintain flexibility in implementing these proposals, not only in
order to avoid widespread dislocations in the transportation system in the
Valley, but also to avoid bringing down a harsh public reaction that may derail
other more positive aspects of the Plan.
We also believe that the Plan will generate demand for alternative means of
transportation that have not been considered in the Plan, or that have been
brushed aside as details to be worked out at the implementation stage. We think
there will be a greatly increased demand for means to move and store gear of all
sorts, and not just on paved surfaces. We think there will be a greatly
increased demand for bicycles and bicycle maintenance facilities, a demand that
will not be met by the concessionaire's rental service. We think there will be
increased use of areas near roads that are now avoided by people because of the
noise of cars and because people are now more oriented to getting in their cars
and going some place other than where they are staying, and that this new demand
for "close-in leisure" will require more walkways, benches, and picnic tables in
areas near existing development that are now little used.
We think that visitors will find that the shuttle buses don't meet their needs
for leisurely and informal touring, and that there will be an increased demand
for casual, open-air transportation similar to the Green Dragon valley tour, the
tourist rickshaws at San Francisco's fisherman's wharf, the golf carts used at
airports for the elderly, the infirm, and the disabled, and the bicycles with
side cars used in retirement communities.
We believe that the existing shuttle bus service to the eastern reaches of the
Valley, east of Clark's bridge and Curry Village, should be terminated. Under
the Preferred Alternative, it is unclear whether the shuttle will run only to
Happy Isles, or whether "Happy Isles" is simply used in the Plan as shorthand
for the entire loop around the Medial Moraine, including Clark's bridge. See
Plan at 2-46, Plate 2-1. What exactly does the Preferred Alternative propose
regarding shuttle bus use in the Eastern end of the Valley? Happy Isles is 1/2
mile from Curry Village, while Mirror Lake is a bit more than one mile from
Clark's bridge. These distances are short enough that visitors can be expected
to reach these destinations by foot or bicycle. Removing the buses from this
part of the Valley will allow visitors, without walking very far, to have the
rare experience of being in the Valley without hearing any vehicles or having to
be concerned about their menacing presence.
Many commenters on the Valley Implementation Plan suggested that the park adopt
aspects of transportation systems used at other places. Does the park consider
any other place to offer a model for the transportation system it is proposing
in the Plan? If so, it would be useful for the public to know this, and to know
how well it is working.
OTHER ISSUES
The Preferred Alternative would remove the Church Bowl picnic area. Plan at
2-31. We recommend preserving the modest picnic facilities at this area.
Church Bowl is an important morning picnic site, especially for climbers. While
the campgrounds are still cold, damp, and filled with gloom, Church Bowl is
warm, dry, and sunny. In the off-season, climbers destined for the popular
climbs at Church Bowl will often have breakfast there first and enjoy the warmth
of the sun and the expansive views across Ahwahnee Meadow towards Glacier Point.
The handful of picnic tables at this area cause little impact and serve an
important need. This picnic area should be retained--is there any over-riding
reason not to do so?.
Sincerely yours,
Paul Minault
Regional Coordinator
for Northern California
Encl
cc (all w/encl):
Sally Moser, Executive Director
Sam Davidson, Senior Policy Analyst
Armando Menocal, Past President
Dick Duane, Esq., American Alpine Club
Linda McMillan, American Alpine Club
Joyce Eden, Sierra Club
Jay Watson, The Wilderness Society
Brian Huse, The National Parks and Conservation Association
Bob Hansen, The Yosemite Fund
David Brower, Earth Island Institute
Janet Cobb, the Yosemite Restoration Trust
APPENDIX TO COMMENTS OF THE ACCESS FUND
ON THE DRAFT VALLEY PLAN
PROPOSALS FOR CAMPGROUND DEVELOPMENT
In this appendix, we present our proposals for additional campsite development
in Yosemite Valley. We look at each of the campground sites more closely, using
floodplain maps that the park's consultants prepared after the 1997 flood. See
Cella Barr Associates, Hydrologic and Hydraulic Investigation for Proposed
Campgrounds in Yosemite National Park, CA (May, 1998) and the attached maps
labelled Flood Study of the 2, 10, 25, and 100-Year Storms for the Merced River
and Tenaya Creek Proposed Campgrounds, Yosemite National Park, May, 1998 (10
sheets) ("the flood maps").[10]
Upper and Lower River Campground: Before the 1997 flood, these campgrounds had
276 sites. Both campgrounds were damaged in the flood, and the park
subsequently demolished them.
The flood maps show that most of the Upper and Lower River Campground area is in
the 10-year floodplain. A small portion of Lower River campground near the
road, comprising 22 sites, is in the 25-year floodplain. Flood velocities are
in the lowest, or "slow" category (0-3 feet per second), and flood water depths
over most of the site for the 100-year flood are in the "moderate", 2-5-foot
depth, while flood water depths for the 25-year flood range from 2-5 feet for
most of the Lower River campground site and 0-2-foot for most of the Upper River
campground site. A photograph at page 1-7 of the Plan shows the entrance to
Lower River Campground during the 1997 flood, with what appears to be three to
four feet of water at the entrance kiosk. Given the flood depths in this area,
we would concur that there appears to be little alternative but to remove these
campgrounds and restore the site. However, the loss of the 276 sites at these
campgrounds and others at North Pines, Lower Pines, and Group Camp is a
significant impact on the visitor experience for campers, and one for which the
Preferred Alternative should rightly propose mitigation in the form of new
campsites at other locations.
Upper Pines Campground: Upper Pines currently has 240 sites, and the Plan
proposes to add another 15 drive-in sites adjacent to existing roads. Plan at
2-18, 2-39, Plates 1-5, 2-5. We support this effort, but believe it could be
taken further, as we suggest in our comments under Proposed New Campgrounds,
below.
Lower Pines Campground: Before the 1997 flood, Lower Pines had 173 campsites.
Of these, 95 were destroyed or damaged by the flood and subsequently abandoned
or demolished by the Park Service, leaving 78 sites. Plan at 2-18. The Plan
proposes to eliminate another 38 sites, leaving only 40 sites. Plan at 2-39.
The flood maps show that the first two loops and most of the third loop of this
campground are above the 100-year floodplain. The fourth and fifth loop
straddle a long narrow "island" in the floodplain, while most of the remainder
of the campground is within the 10-year floodplain.
We think that a considerably larger number of sites could be retained in this
campground. The flood maps show that flood velocities and depths for both the
100-year and the 25-year floodplains in Lower Pines are in the lowest
categories: slow moving, in which flood flow "does not cause significant erosion
or scour of the soil," while flood water depths range from 0-2 feet. Flood
maps, sheet C-1. It appears that all the sites in the first five loops could be
retained without risk of damage to structures or harm to resources from
flooding, particularly since they are all outside the 10-year floodplain. If
only the sites in the River Overlay Protection Zone were then removed from the 5
loops, we figure this would leave about 70 sites in this campground. This is
roughly consistent with the proposal to retain this campground in Alternative 5.
Plan at 2-129.
Park Service policies allow the retention of facilities in floodplains when
there is no feasible alternative. Plan at 3-15, 4.0-2; In the Preferred
Alternative, the park proposes to build 18-inch high berms around existing
developed lodging units at Yosemite Lodge that are in the floodplain and, when
the time comes to replace these units, to build the replacement units on raised
foundations or fills elevated above the level of the floodplain. Plan at 2-40.
The Plan even says that these actions will have a "beneficial impact." Plan at
4.2-7. Given that these extraordinary measures are sanctioned in the Plan to
preserve developed lodging units, it would seem that the preservation of these
campsites, which requires no such intrusive construction in the floodplain,
could be easily incorporated into the Preferred Alternative. Why are similar
measures to preserve campgrounds not also considered to have a beneficial
impact?
We believe that the Plan also offers opportunities to substantially expand the
size of this campground. Under the Preferred Alternative, the portion of
Southside Drive that now delimits the southwestern boundary of the campground
would be removed. Plan at Plates 1-5 and 2-5. The Boys Town cabins and
platform tents on the other side of the road from the campground, which now
house concessionaire employees, would also be removed. Plan at 2-52, Plates 1-5
and 2-5. If the existing section of South Side Drive extending from Boys Town
to the existing wilderness parking area (the old dump site) were also removed,
and access to the present wilderness parking area were provided along the nearly
parallel alignment of the existing Curry Village road that leads from the Curry
Orchard parking lot to the wilderness parking area (shown on Plate 1-5 of the
plan as a multi-use trail), then the whole area now comprising the Curry
Orchard, Boys Town, and the removed portion of South Side Drive would be
available for campground development, and most of this area is already
disturbed. Moreover, the realigned road would then form a natural dividing line
between the camping area to the north and the Curry Village area to the south.
This appears to us to be easily feasible and likely to produce another 50-100
campsites.
North Pines Campground: Before the 1997 flood, North Pines consisted of 101
campsites. Portions of the campground were damaged in the flood and the park
subsequently abandoned or demolished 15 sites, leaving 86 sites. Plan at 2-18.
The Preferred Alternative would eliminate this campground altogether, Plan at
2-39, as well as the adjacent concessionaire stables, Plan at 2-38 and relocate
the Lower Pines amphitheater to the location of the current stables parking lot.
Plan at 2-39.
This campground lies at the confluence of the Merced River and Tenaya Creek, and
the flood maps show that it is largely within the 25-year floodplain of these
streams, with portions around the edges in the River Protection Overlay Zone or
the 10-year floodplain. Water depths for both the 100-year and 25-year floods
along the Merced River tend to be in the shallowest category, 0-2 feet, while
along Tenaya Creek they are in the middle category, 2-5 feet. The line between
these two depths divides the site roughly in half. Flood velocities over the
entire site are "slow," the lowest category.
We believe there is substantial potential for the redevelopment of this area for
walk-in camping. The entrance kiosk, bathrooms, and other permanent campground
buildings could be concentrated in the sizeable area above the 100-year
floodplain at the north end of Clark's bridge. Seasonal walk-in sites could be
provided in the quite large 25-year floodplain area which is currently developed
and shows no signs of disturbance from the 1997 flood, while the River
Protection Overlay Zone and the 10-year floodplain would be restored to natural
conditions.
Additional sites could also be developed along the more level areas at the base
of the north side of the medial moraine, on the alignment of the current trail,
and the road at the base of the moraine converted to use as a combined
hiking/biking and campground internal access road, reduced in width, and closed
to shuttle bus use. The proposed amphitheater could be relocated to currently
disturbed areas at Curry Village where development is scheduled for removal. In
this way, perhaps 50 to 100 additional campsites could be accommodated in the
previously disturbed area between the two rivers north of Clark's bridge. Under
Alternative 5, there would be 70 sites in this campground, so it seems the park
believes that it is feasible to continue this use. Plan at 2-128. We urge you
to consider and implement this proposal.
Group Camp and Backpackers Camp: These campgrounds lie between Tenaya Creek and
the north wall of the Valley. The Group Camp originally consisted of 14 group
sites, of which 3 were converted to use for backpackers with wilderness permits
some years ago. After the 1997 flood, the park closed the remaining 11 sites.
The flood maps show the entire site to be within the 100-year and 25-year
floodplains, with flood velocities in the lowest, "slow" category. Flood water
depths for the 100-year flood are mostly in the "moderate" 2-5-foot range, with
0-2 foot depths on the north side and west end, and 0-2 foot depths for the
25-year flood over the entire site.
The Plan proposes to remove and restore the existing Backpackers Campground and
to create 20 "walk-to" sites squeezed into two small terraces above the 100-year
flood plain at the east and west ends of the former Group Campground site.
These would be for people who arrive in the park without a private vehicle.
Plan at 2-39, Plate 2-2. We are pleased to see this proposal, since we have
advocated the development of campsites specifically to serve the needs of
visitors without vehicles in previous correspondence with the park.
We believe that more can be done with this site, however. With permanent
facilities such as bathrooms and kiosks sited on the raised terraces or sited on
the edge of the floodplain on raised foundations, seasonal campsites could be
located on both the terraces and on adjacent portions of the floodplain,
particularly where 100-year flood depths are in the shallow ranges. In this
way, it would seem that with little effort 50 or so sites could be accommodated
in areas of previous use and disturbance without risk of damage to structures or
harm to resources. We urge you to consider and implement this proposal.
This camping area could also be expanded westward. East of the Ahwahnee Hotel
and Ahwahnee cabins there currently exists a park service "administrative site",
an area of old building slabs and disturbed land that the park uses as a utility
and storage area. This site is outside the flood plain and talus line and is a
level plain from the Ahwahnee eastward to the present Backpackers Camp. The
administrative site is about one-eighth of a mile from the Ahwahnee and is
visually screened from the Ahwahnee by tall pines and shrubbery.
The site is immediately adjacent to the Ahwahnee cabins, which could be handled
in a number of ways to reduce potential use and visual conflicts with the
proposed campground. Our preference would be to have these cabins demolished,
thereby demonstrating that the most costly and space-consumptive lodgings in the
Valley are not the only ones immune to removal, an impression that the Plan
currently conveys. Alternatively, these cabins could be physically moved to the
Yosemite Lodge area, where their lower density would offer some relief from the
ambitious development planned there. The site could then be restored to its
original condition as meadow woodland or it could be integrated into our
proposed new campground. If the cabins were left in place, an alternative we
would not prefer, they could be visually isolated from the proposed campground
by privacy fencing and vegetative screening.
Our proposed campground area could then be functionally integrated with the
proposed Tenaya Creek campground into a larger Royal Arches campground, possibly
with a mix of drive-in, walk-in, and walk-to campsites, all of which would be
served by the Ahwahnee road. Given that much of this area is already disturbed,
is one of the few areas in the East Valley outside the floodplain and talus zone
available for use, poses no insuperable problems with regard to the its visual
and functional relationship with the Ahwahnee, and could be served by the
existing Ahwahnee road, it seems to us that the additional 100 or so sites that
could be developed in this area are eminently feasible.
Yellow Pine Campground: The park maintains 4 walk-in sites for use by
volunteers at Yellow Pine campground, near the Sentinel Beach picnic area. Plan
at 2-18, Plate 1-2. This campground was created in 1970 after the riots in the
park and closed to public use in 1978 because it was isolated and hard to
manage. Under the Preferred Alternative, these sites would be removed and the
site restored, Plan at 2-39, Plate 2-2, and a new volunteer campground would be
located at Foresta, at a site previously used for this purpose. Plan at 2-49.
While we understand that this campground is an anomalous use at this site, we
think moving it to Foresta is a mistake. People who are volunteering their free
time to work in the Valley should be allowed to stay in the Valley, and a well
designed volunteer campground that does not reduce the number of sites available
to paying campers should be sited in a pleasing Valley location. Foresta is not
particularly convenient for people working in the Valley, and it is not very
scenic, particularly after the fire destroyed all the large trees there. The
Plan seems to be saying that people who don't pay to be in the Valley, even
those devoting their free time to hard labor in service to the park, don't
deserve to stay in the Valley overnight. We think just the reverse is true, and
that the Plan should accord the highest priority to the siting and amenities for
the volunteer campground. The volunteer campground should be designed to
encourage and reward people for working in the park, not discourage them, as the
Foresta location would do.
Proposed New Campgrounds: The Preferred Alternative proposes the construction
of new campgrounds east of Curry Village in the vicinity of Upper Pines
Campground. These include 45 walk-in sites north of Upper Pines; South Camp,
with 10 new group walk-in sites; and Backpackers at South Camp, with 30 new
walk-in sites along the base of Glacier Point Apron. Plan at 2-39, Plate
2-5.[11]
The walk-in sites proposed for the area north of Upper Pines appear to be sited
on the two largest of the five "islands" that lie above the floodplain north and
east of Upper Pines, as shown on the flood maps. The other three islands, each
big enough to accommodate about half of one of the loops in the existing Upper
Pines campground, have been omitted from the campground development proposal.
These islands appear to have room for another 50 or so walk-in sites, while
there is space along the north side of the access road in Upper Pines for
parking outside the floodplain that would serve these campsites. It seems to us
that these additional sites could be developed with little alteration of the
current proposal in the Preferred Alternative, just as they are in Alternative
5. See Plate 5-2. We urge you to consider and implement this proposal.
The proposed new South Camp campgrounds extends eastward along the base of
Glacier Point from Curry Village until it reaches the Base of Talus line, at
which point it stops. Plan at Plate 2-5. Relatively level ground suitable for
campsites continues eastward past this point, however. A substantial portion of
the development in Curry Village and portions of the existing Upper Pines
Campground is within the Base of Talus line. Id. This suggests that while
there may be some risk associated with development within this line, on balance
the level of risk is considered acceptable given the totality of circumstances.
Please explain why a similar analysis would not apply to extending the proposed
South Camp eastward into the Base of Talus line.
The Preferred Alternative also proposes to locate a private, day-use staging
stock corral with parking for five stock trailers in the middle of the new South
Camp. Plan at 2-38, 2-48, Plate 2-5, as well as the 150-car wilderness parking
area, Plan at 2-170. We are opposed to the location of these space-consumptive
uses in the middle of this proposed new campground, particularly when, as we
have shown, there is already a tremendous shortfall of campsites in the Valley
and space for campsites is at a premium. These uses should be moved to a
location that does not conflict with campground development--either to the east,
within the Base of Talus Line, or at formerly disturbed areas in Curry Village.
We would be pleased to discuss these proposals with park planners at more
length.
--------------------------------------------------------------------------------
[1] We note that in Alternative 3 (Taft Toe Parking), Camp 4 would be expanded
to 50 sites, Plan at 2-69, and the Swan Slab area north of existing North Side
Drive preserved from development, Plan at Plate 3-3. Under Alternative 4 (Taft
Toe and Out of Valley Parking), Camp 4 would remain at 37 sites, Plan at 2-98,
while the Swan Slab area would also be preserved from development, Plan at Plate
4-3. Under Alternative 5 (Yosemite Village, Curry Village, and Out-of-Valley
Parking), Camp 4 would remain at 37 sites, Plan at 2-128, while new lodging
units would be built near Swan Slab in the area north of North Side Drive. Plan
at Plate 5-3.
[2] We do note with some concern that under the Preferred Alternative, the Camp
4 parking lot would be "combined" with employee and bus parking. Plan at II-31.
The Camp 4 parking lot has traditionally been an integral part of the campground
and its distinct culture, including its identity as the climbers campground in
the Valley. A good deal of informal socializing, as well as serious ascent
planning, has always taken place in the parking lot, and this is an aspect of
Camp 4 worth preserving. Therefore, we would ask that the parking for the
expanded Camp 4 be configured to support the continued integral nature of the
parking lot with the campground and the continuance of this tradition. Is there
any reason why this cannot be accomplished?
[3] Sadly, however, camping has been allowed to become the lowest form of
overnight accommodation in the Valley, a status reflected by the low standard of
amenities and maintenance in the Valley's campgrounds. Compared to the
campgrounds provided by other land management agencies in North America, and
given Yosemite's prominence as the flagship of the National Parks system, the
campgrounds in Yosemite, and especially the toilets, are a national disgrace.
While this may be the result of years of inadequate funding, we cannot help but
believe it also reflects the dominance of commercial values in the thinking of
park management. Would the park ever have allowed the Ahwahnee Hotel to sink
this low, we ask. We are sure it would not--regardless of whether the hotel was
under the management of the park or the concessionaire. And if adequate funding
was only to be had by the concessionaire, then why didn't the park transfer the
campgrounds to the concessionaire to manage, maintain, and fund? Figures for
campground reservations and usage in the Plan at pages 3-82 - 83 suggest that
the Valley's campgrounds must produce an income of about $1.5 million a year.
It is inconceivable that anything like this amount of money is spent on
campground maintenance. Where does this money go, and why is it not being spent
to maintain and improve the campground facilities that generate this revenue?
What funds are allocated in the Plan for the rehabilitation of existing
campgrounds, especially the toilet buildings?
[4] In addition to the loss of campsites within the park, perhaps as many as 50
formal and informal campsites have been lost along the Merced River due to
flooding and closures by the Forest Service.
[5] As reported in the Plan, currently proposed development would add 1,217 new
guest lodging units outside the park, presumably within the next three years or
so. The proposed developments are: 141 motel units at Yosemite View Lodge in El
Portal, 250 guest rooms and 50 tent cabins at Hazel Green Ranch, 177 hotel rooms
and cabins at Silvertip Resort in Fish Camp, 22 rental cabins at Double Eagle
Resort in June Lake, 120 hotel rooms at Tioga Inn in Lee Vining, 113 condominium
units at June Lake Highlands, 88 new guest units at Evergreen Lodge near Camp
Mather, 144 Guest units at Rush Creek Lodge at the intersection of Hardin Flat
and Highway 120, and 112 motel units in Second Garrotte near Groveland. Plan at
II-55 - II-57.
[6] We believe that the Ahwahnee Hotel, a commercial enterprise whose rooms are
economically beyond the reach of 90% or more of Americans, is an inappropriate
use to be operating under federal license in a national park. To those who say
that a flagship park needs a signature hotel, we say that what it needs is to
provide a quality experience for all visitors, not simply for the minority who
can afford to pay for it. The Ahwahnee is a monument to the Teddy Roosevelt
legacy, when the nation's wealthy elite embraced the great outdoors and
reinterpreted its beauty through their architecture. It should not continue to
perpetuate the social distinctions of the era that brought about its creation,
however. This building could not be built in the park today, and that
realization should color the park's plans for its future. The Ahwahnee is a
marvelous piece of architecture, and it should be devoted to a use that welcomes
everyone. One such use would be as a non-profit institute for the study of the
ecology of the Sierra Nevada, a use that could particularly serve the young and
those in later life with time to improve their knowledge of the environment.
The Plan should initiate the process for rethinking the future of this building,
not simply perpetuate its role as a symbol of a value system that is no longer
appropriate in America's great parks.
[7] The problem the park created by doing so is not remedied by simply showing
the Rivers Campgrounds as "existing development" on the Plan maps. See, e.g.
Plates 1-2 and 1-5, since there is no environmental analysis of the effects of
their loss in the Plan, nor any attempt at mitigating the effects of their
removal.
[8] The actual number of campsites lost either in the flood or to Park Service
demolitions and abandonment includes 276 sites at the Rivers campgrounds, 95 at
Lower Pines, 15 at North Pines, and 11 at Group Camp, for a total of 397, not
the 284 reported in the Plan. See Plan at 4.2-87. If you believe this figure
is incorrect, please explain.
[9] In regard to the demolition of these campgrounds, the Plan states
euphemistically that the sites "were not rebuilt, since some plan alternatives
called for their elimination." It seems the more correct statement would be
that they were demolished because some plan alternatives called for their
elimination, including the Preferred Alternative in the predecessor plan, the
1997 Valley Implementation Plan ("VIP"). See VIP at 45.
[10] The Plan states that "sites [for campgrounds] within the floodplain have
been carefully analyzed to distinguish between areas that were only
flooded--inundated with still or slow-moving water--as opposed to those sites
that were ravaged by fast-moving, high-energy water," which are limited to
non-overnight use. Plan at III-76 - 78. Why doesn't the Plan include a map
that shows these different floodwater velocity areas, since this parameter is
critical to the determination of what sites are suitable for campground
development? Without this information, how do you expect the public to comment
intelligently on the plan's proposal for campground siting? The flood maps show
almost all the campground areas as inundated with slow-moving water. Yet, the
plan proposes campground removals that appear to have no relation to flood
velocities. Why is this?
[11] Please note that Plates 2-2 and 2-5 are inconsistent as to the location of
parking in this area.
Julie
>
> If anyone wants to read a digest of the plan where it is likely to
> impact the climbers the most, the Access Fund has written this
> document.
>
>
Wow - that was carefully constructed and very well written. Makes me
glad I send them $$!
Thanks for posting it, Melissa.
JSH
nafod40
That's worth joining for. I agree, a well-written tome.
Fred
> I think that the best way to voice opposition is to follow the "TODO"
> section in the update: write letters (historical evidence suggests that
> a handwritten letter is best, faxed next, email least effective) to your
> congresscritters.
>
> If you don't know how to reach your Congressional Representatives, you
> can find their names, contact info and key voting history at
> http://www.congress.org/congressorg/home/ ...
And how about us non-Americans who'd like to do something? I'm going for a
third time in a few months, but I'm not sure I'll go back a 4th time if all
what's in the plan becomes reality...
Thanks,
--
Marc from Quebec
http://pages.infinit.net/emah
Home of the Rec.climbers' Personnal Pages Directory
and the Climbing in Québec Page.
Chris Kantarjiev
Um, which plan did we get tossed out? Last I heard, the NPS is seeking
funding for the Preferred Alternative as expressed in the most recent
plan. FoYV has mounted some successful court challenges relating to the
Merced that affect the Valley Plan, but the success of those challenges
has not yet stopped the NPS (even though that is the Court's
intention)...
Chris Kantarjiev
Yes. Carefully constructed, well written, almost four years old, and
ultimately ineffective. The comment period was a sham. The NPS chose the
Preferred Alternative pretty much right down the line.
That said - it's a good source of material for letters to members of
congress and newspaper editors...
chris
melissa
>> "melissa" <melissa...@newsguy.com> wrote
>> >
>> > If anyone wants to read a digest of the plan where it is likely to
>> > impact the climbers the most, the Access Fund has written this
>> > document.
>> >
>> > http://www.uweb.ucsb.edu/~kmhay/valley_plan.htm
>
>Yes. Carefully constructed, well written, almost four years old, and
>ultimately ineffective. The comment period was a sham. The NPS chose the
>Preferred Alternative pretty much right down the line.
Chris,
Do you know of any other more recent reports the NPS's plans? I hear a lot of
talk about it but your post and this one from the Access Fund are all that I've
seen in print with specifics.
Mad Dog
>Um, which plan did we get tossed out?
What I'm talking about are various parts of the old plan to make a bus
turnaround near Swan Slab, huge hotel development, more employee housing, etc.
The email I got from FOYV celebrated our victory, right?
Chris Kantarjiev
> Chris,
>
> Do you know of any other more recent reports the NPS's plans? I hear a lot of
> talk about it but your post and this one from the Access Fund are all that I've
> seen in print with specifics.
The only regular news that I see is the NPS planning propoganda, err,
newsletters. I got myself on a mailing list some years back, and I get a
quarterly status newsletter describing what's going on in the Valley
construction projects.
Take a look at http://www.nps.gov/yose/planning/ for starters. There's a
ton of info there - from the NPS slant.
chris
Chris Kantarjiev
>
> Chris Kantarjiev wrote:
>
> > I think that the best way to voice opposition is to follow the "TODO"
> > section in the update: write letters (historical evidence suggests that
> > a handwritten letter is best, faxed next, email least effective) to your
> > congresscritters.
> >
> > If you don't know how to reach your Congressional Representatives, you
> > can find their names, contact info and key voting history at
> > http://www.congress.org/congressorg/home/ ...
>
> And how about us non-Americans who'd like to do something? I'm going for a
> third time in a few months, but I'm not sure I'll go back a 4th time if all
> what's in the plan becomes reality...
>
I guess you could contribute money to FoYV :-)