EPA slams winter plan
Comments call for revised analysis, question 7-to-1 ratio.
By Mike Koshmrl, Jackson Hole, Wyo.
September 5, 2012
Calls for a longer comment period and allegations of insufficient and faulty information have delayed the release of a much-debated winter-use plan for Yellowstone National Park.
The park announced Friday it will extend the interim operation that allows up to 318 snowmobiles and 78 snow coaches daily. It will hold off on finalizing the new plan that proposes increasing snowmobile traffic by 10 percent and reducing snow coach traffic by 23 percent.
The proposed new travel plan, a 400-page supplemental environmental impact statement, is now reopened to public comment. The original 45-day comment period closed Aug. 20.
Because the draft statement proposed a two-year transition phase, the delay doesn’t change vehicle limits in the park this winter. It’s yet to be seen if the delay will push implementation of the new travel proposal back for an entire year.
Yellowstone received nearly 12,000 comments on the plan, though no single comment keyed the decision to hold the release of a final document, Superintendent Dan Wenk said in an interview.
“We had various groups ask for more time,” Wenk said. “Because we changed the whole way that you think about winter use, we thought it would be prudent to grant the request.
Yellowstone officials propose to manage over-snow vehicles by what are called “transportation events,” which they define as a single snow coach or a group of an average of seven snowmobiles.
Managing winter use with transportation events, park officials say, will simultaneously allow for an increase in visitors while decreasing impacts on wildlife, sound and air pollution.
In a comment letter obtained by the News&Guide, the Environmental Protection Agency questions the underpinnings of the analysis that supports the 7-to-1 ratio. The EPA’s concerns echo those conveyed by the Greater Yellowstone Coalition, Coalition of National Park Service Retirees and other anti-snowmobile groups.
Plan has ‘insufficient information’
Pro-access groups such as the Blue Ribbon Coalition and International Snowmobile Manufacturers Society have generally supported the plan.
In an interview Friday, Jack Welch, a Blue Ribbon Coalition consultant, said he heard from the park superintendent that the EPA’s comment was to blame for the delay.
Wenk clarified that claim.
“I absolutely did talk to Jack Welch about the EPA letter,” Wenk said. “I also talked to him about the letters from the environmental community, and I also talked to him about letters from the general public. All of those reasons were reasons that we chose to extend. It’s very important to us that we get this right.”
In its comment, the EPA rates Yellowstone’s environmental document “EC-2,” which means “environmental concerns, insufficient information.”
A “ratings criteria” attached to the comment further defines the EC-2 rating.
“The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment,” the criteria reads. “The identified additional information, data analyses or discussion should be included in the final EIS.”
In an introduction section of the comment, the EPA identifies three “key recommendations” to the park.
One of the recommendations calls for the park to better explain its “resource-protection goals” and to define the “minimum desired environmental conditions in the winter-use area of the park.” It also calls for Yellowstone officials to clarify how they intend to monitor air emissions, noise, wildlife disturbances and the visitor experience.
“To support the statement that the preferred alternative will result in a ‘cleaner and quieter park,’ we suggest the NPS establish an adaptive management strategy goal of striving to sustain or improve current winter season environmental conditions,” the EPA comment reads.
A second recommendation seeks additional rationale on the “basis for the transportation event limits.”
“The EPA was unable to determine how the NPS established thresholds for the maximum number of transportation events per day for the preferred alternative,” the comment reads. “Additionally, we could not ascertain the basis for establishing the maximum number of 10 snowmobiles per event.”
Lastly, the letter recommends the Park Service revise or provide additional discussion for its “modeling,” or emissions testing, for the snowmobile fleet.
The comment also suggests the park redo its emissions analysis for “best available technology” snow coaches by removing from calculations one of the four mode ls tested. The model, a 2008 Chevy Express, “significantly increases” emissions projections, especially carbon monoxide, but would be exiting the snow coach fleet by 2018, the EPA comment reads.
Emission tests questioned
Both the EPA and the International Snowmobile Manufacturers Society have challenged the accuracy of Yellowstone’s snowmobile emissions tests, which were conducted in March. Data posted to the park’s website show that snowmobiles were markedly dirtier than they were when similar tests were conducted in 2006.
The data, part of the supplementary analysis released separately from the SEIS, shows surprisingly high contributions of pollution from snowmobiles versus snow coaches.
Under the maximum allowable levels in the proposal, snowmobiles account for 67 percent of all carbon monoxide, 68 percent of hydrocarbon, 86 percent of nitrous oxide and 87 percent of particulate matter.
Park officials ran two machines: an Arctic Cat TZ1 and a Ski-Doo Bombadier. The results show that the Ski-Doo performed about the same, but the Arctic Cat performed drastically worse than similar models tested in 2006.
The 2012 TZ1, data shows, produced nearly 23 times more carbon monoxide than the 2006 model of Arctic Cat that was tested.
The EPA showed concerned with the accuracy of the findings.
“It is our understanding that the TZI makes up about two-thirds of the current fleet, increasing the importance of assuring the model is using accurate emissions factors,” EPA officials said in the comment.
Ed Klim, the International Snowmobile Manufacturers Society’s executive director, said that part of the reason for the high numbers is because Yelllowstone tested a single machine that was broken.
“Obviously this vehicle wasn’t running properly,” Klim said. “It was running on one or two cylinders, and it’s a three-cylinder vehicle. That was the only vehicle they tested.”
Klim and Jack Welch, of the Blue Ribbon Coalition, also took issue with the park’s method of testing.
“They had a test where they had a sensor bag that was behind the snowmobile that picked up emissions as it traveled, which is unacceptable,” Welch said. “It’s not good science. I don’t know where they came up with it.”
The park’s method of testing, Klim said, didn’t account for important variables, such as temperature, snow conditions, weight of the driver and other factors.
“The EPA test is a five-mode test procedure that took five or six years to get approved,” Klim said. “It’s designed to depict the way a person rides a snowmobile.
“They should follow the U.S. EPA testing procedures,” he said. “When I read [the park’s report]. I just scratched my head. It’s a mystery test. It doesn’t follow any of the testing parameters or guidelines that anybody has ever used.”
Both Wenk and Wade Vagias, Yellowstone’s management assistant, refuted the claim that the park pioneered a test.
The park contracted North Carolina State University graduate students to conduct the test, which was “quite similar if not identical” to what Yellowstone did in the past, Vagias said.
“We think it’s more representative than the results you get in a laboratory setting,” he said. “I would argue it’s more accurate.”
The EPA did not state in its letter if it would require Yellowstone to redo all of its emissions testing or delay the plan’s release. In an email, Phil Stobel, the deputy director of the agency’s National Environmental Policy Act compliance program, suggested that’s not the case.
“I wanted you to know that EPA did not request an extension of the comment period,” Stobel said. “Further, I am confident EPA’s comments could have been addressed within the original schedule.”
Group commends delay
The Greater Yellowstone Coalition, a group that has criticized the park’s proposal, applauded news of the delay when it was announced last week.
“We certainly want them to get it right,” said Mark Pearson, the coalition’s conservation program director. “If taking more time means they’ll come up with the best scientifically defensible plan, that’s great.”
After reviewing the comments, Pearson said he interpreted the EPA’s letter as challenging the rationale for the 7-to-1 ratio of snowmobiles to snow coaches.
“The explanation for the 7-to-1 thing kind of has everybody scratching their heads,” he said. “The numbers in the SEIS don’t make any sort of case for 7-to-1.”
A reconfigured timeline for release of the final document and rule are still in flux, Wenk said. The park will “move forward as expeditiously as practical” in releasing the final environmental document, he said
“We want to get everything right,” Wenk said. “I anticipate late 2012 or early 2013 the draft will come out. We’re not talking about a major delay.”
The superintendent said he’s “very confident” the final document and rule will be based on three principles, which he listed as sound science, the best long-term interest of the public and the law.
Wenk also stood behind the park’s preferred alternative and the “transportation event” approach to winter-use management.
“I really feel quite confident in the basis for the 7-to-1,” he said.