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Director Bomar: Let Science, Not Politics, Decide the Yellowstone Snowmobile Issue


The pledge by Interior Secretary Dirk Kempthorne and National Park Service Director Mary Bomar to let science prevail in national park management decisions is nearing its defining test. If science is not supported in Yellowstone, where else in the park system will it have the final say?

In his cover letter to President Bush on the Centennial Initiative, Mr. Kempthorne promised that stewardship and science will guide decisions. Director Bomar reiterated that point to me last week in Texas, where she appeared at the National Park Foundation's Leadership Summit on Partnership and Philanthropy.

"When I came into the National Park Service, I didn't realize the in-depth that the good stewards in the national parks went to. Often, we'd be accused of studying things to death. If you didn't like the answer we'll do another study," she said. "But I will say over time that I've come to really appreciate that, that we make good decisions based on good information."

Perhaps tellingly in relation to the decision-making ongoing in the Yellowstone snowmobile issue, the director went on to say that throughout her Park Service career she has "worked with archaeologists, historians, biologists ... and often we don't sit down and listen to their information that they've gathered."

In the case of Yellowstone and snowmobiles, the science has time and again illustrated that the park's resources would be stewarded better by phasing recreational snowmobiles out of Yellowstone and relying on snow coaches to move visitors about the park. Unfortunately, as the scientists themselves pointed out on page 20 of their report on how snowmobiles affect Yellowstone's wildlife, politics can at times trump science.

What's so striking in the Yellowstone matter is how strongly worded the science is in terms of what's best for the park's resources, its visitors, and its employees. Even after park officials retreated a bit from their initial preferred alternative, which would have allowed for up to 720 snowmobiles per in in the park, down to 540 a day, impacts stand to be felt across Yellowstone.

In their report, "Behavioral Responses of Wildlife to Snowmobiles and Coaches in Yellowstone," the wildlife biologists came to the conclusion, after monitoring winter conditions in Yellowstone from the winter of 2002-03 through the winter of 2005-06, that wildlife would best be served by over-snow traffic with 250 or fewer snowmobiles per day.

“…we suggest regulations restricting levels and travel routes of OSVs [over-snow vehicles] were effective at reducing disturbances to these wildlife species below a level that would cause measurable fitness effects. We recommend park managers consider maintaining OSV traffic levels at or below those observed during our study.”

However, the latest preferred alternative supported by Yellowstone Superintendent Suzanne Lewis more than doubles the allowable traffic levels from where they've been when those studies were conducted. In a letter sent this past week to Director Bomar, the presidents and executive directors of the Greater Yellowstone Coalition, National Parks Conservation Association, Natural Resources Defense Council, Sierra Club, The Wilderness Society, and the Winter Wildlands Alliance urged the director to reject Superintendent Lewis's course of action.

The choice made in the new 'Preferred Alternative' is thus to exceed—by over 100 percent—the traffic threshold at which Yellowstone’s wildlife experts stated that over-snow vehicles could become a more severe or prolonged 'stressor' to Yellowstone’s wildlife, with the potential to adversely affect the fitness of the park’s animals.

In contrast, the Snowcoach Alternative in the Final Environmental Impact Statement emphasizes a mode of access that results, according to NPS statistics, in one vehicle for every 7.7 visitors, rather than one vehicle for every 1.3 visitors. It would thus allow 960 visitors to access and enjoy Yellowstone’s attractions each day with just 120 vehicles. This would be well within the traffic level recommended by wildlife scientists and just one-fifth the level of over-snow traffic that would move through habitat used by bald eagles, bison, coyotes, elk and trumpeter swans under the new 'Preferred Alternative.'

More so, the groups told Director Bomar that Yellowstone officials resorted to a weakening of existing regulations pertaining to the protection of the park's natural resources so they could justify their preferred alternative.

In effect, what NPS has done is justify degradation of resources by changing the standards of measurement at the end of the process. As an example, the FEIS merely states that the “Desired Condition” for wildlife is: “Impacts to wildlife are mitigated, and effective wildlife habitat is protected.” Mitigation of impacts to wildlife does not, obviously, define a condition. It simply states that there will be an effort to make the harm caused to wildlife by over-snow vehicles less severe or serious. Historically, NPS has acknowledged that its legal responsibility in regards to protecting wildlife is established through regulations and Executive Orders that prohibit disturbance of wildlife. Thus, under the new “Desired Condition” standard, the Park Service makes it acceptable to allow ongoing disturbance of wildlife whereas previously the agency has deemed such disturbance unacceptable and illegal. It is now okay under this definition to simply lessen the impacts to Yellowstone’s wildlife, rather than adopt policies that don’t allow it. Similarly, this new standard reduces habitat protection by eliminating the historic goal of minimizing “to the greatest degree practicable” adverse impacts.

The science speaks for itself. Hopefully, Director Bomar will have an opportunity to personally look at that science before she signs off on Superintendent Lewis's preference when it comes to snowmobiles.

"I do feel the Park Service has always monitored, inventoried, and studied their resources and know more about their resources than we've ever know," Director Bomar told me last week in Austin. "We just need to listen and we need to implement their recommendations."

In the case of Yellowstone snowmobiles, the recommendations are to ease back on snowmobiles in the park, not throttle forward.

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Posted October 16th, 2007:
"I support the superintendent (Suzanne Lewis). I wanted to be supported as a superintendent. I feel that she’s been in the field, she's an expert in that area," Director Bomar told National Parks Traveler while in Austin, Texas, attending the National Park Foundation's Leadership Summit. "She feels that the science supports her decision. In fact, very strongly supports her decision."

Posted October 22nd, 2007
...the latest preferred alternative supported by Yellowstone Superintendent Suzanne Lewis more than doubles the allowable traffic levels from where they've been when those studies were conducted.

"But I will say over time that I've come to really appreciate that, that we make good decisions based on good information." ...the director went on to say that throughout her Park Service career she has "worked with archaeologists, historians, biologists ... and often we don't sit down and listen to their information that they've gathered."

Either this poor excuse of a person possesses the world record for short-term memory loss, or is guilty of purposefully misleading the public, and most likely her departmental subordinates, or she is just plain goofy. Mary, PLEASE explain to me how, in the course of the same interview conducted on the same day, you can make ANY sensible case for speaking literally out of both sides of your twisted mouth when you first say you make "good decisions based on good information", which granted is a relative and subjective determination most often gathered in good old 20/20 hindsight, while in the same breath and with what appears to be all sincerity, you "often don't sit down and listen to the information they've gathered"? My God woman, you should run for President! Are you sure your first name isn't Hillary, or Bill?

Is it any wonder at all why and how the NPS is totally screwed, with this prime example of universally flawed, convoluted, or as we used to refer to it, "pretzel logic" propagated from its' very own Director? It's truly a dark, dark period for leadership, and for the future concerns of the National Park Service.

Just one other little thing.....

"I do feel the Park Service has always monitored, inventoried, and studied their resources and know more about their resources than we've ever know," Director Bomar told me last week in Austin. "We just need to listen and we need to implement their recommendations."

Two-part boneheaded response but highly inter-related. First, as the Director, if not your's, then whose ultimate responsibility would it be to familiarize themselves with the Park Service studies, and fully comprehend the resulting data and thereby the implications and possible impact resulting from interference or alteration of the local environmental factors pertaining to the system's resources? And and even more troubling and telling comment pertaining to you just being a good little peon and following orders......yup, just what we need from Director-level administration. You should pin that gold badge through your nose to facilitate being more easily lead. Oh, that's right, you're easily enough lead already........maybe the sky IS falling around the NPS.

Lone Hiker, you're right on the money. Such double speak from Bomar! The NPT editors are also right on the money that science, not politics, should guide decisions.

I've got an observation based on the following:

Historically, NPS has acknowledged that its legal responsibility in regards to protecting wildlife is established through regulations and Executive Orders that prohibit disturbance of wildlife.

Regulations and Executive Orders? Why do we need more red tape when it is in the Organic Act:

which purpose is to conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.

Wouldn't it be nice if, like an Etch-a-Sketch, we could turn the system upside down, shake it, and start over again with a new charter--based on science--that is simple, explicit, and doesn't prompt politicians and bureaucrats to write hundreds and even thousands of pages interpreting/distorting that charter?

Frank, wouldn't it be nice if we could start all over again and have a republic based on the Constitution that is simple, explicit and limited in scope that doesn't prompt politicians with too much power and career-centered bureaucrats to write hundreds of thousands of laws and regulations that interpret and distort that original charter?

The federal system is the problem. Forget shaking the Etch-a-Sketch. It now needs to be hauled off to the landfill.

Until the parks are freed from this corrupt system of political spoils and bureaucratic ineptitude these types of things will continue to be par for the course.

I want to applaud Kurt and Jeremy for bringing to light these issues and keeping us posted on up to the minute management decisions that were formerly shrouded in the mists of departmental memos and obscure press releases. With the advent of the internet and newly opened access to the shenanigans of these insulated bureaucrats we can now go a long way towards at least exposing the low grade administration our national treasures are currently receiving.

If the national parks ever do emerge from their current management morass with a brighter future and more resource focused decision making, Kurt and Jeremy will be able to take a lot of the credit for providing a valuable forum for the OPEN exchange of ideas and solutions to the problems vexing our valuable park lands.

Take a bow gentleman.

Bureaucrats operating without an encyclopedic charter? Sorry, those two things just can't co-exist Frank. If management were to seriously attempt to exist without the ability to deflect culpability (a.k.a. responsibility), where would they be? It reminds me of an old comedy routine explaining the difference between accepting responsibility and accepting blame. "People who are responsible lose their jobs, people who are to blame don't." That should give everyone a good enough explanation of why higher-ups aren't EVER responsible, they're only the ones to blame.

I know all too many of my research bretheren will castigate me for this one, but a simple scientific charter? That's akin to being a little bit pregnant, or creating a small nuclear accident. Spectacular notion, but in reality the practice might prove a tad difficult to implement. The reason for this is that in "good" science, contrary to conventional wisdom, science has three "nevers". 1) Scientists don't deal in "facts", we deal in EVIDENCE. Facts, by definition, refer to something that can be tested and repeated over time, and under any set of circumstances. Since we obviously cannot go back or forward in time, nor can we much influence the environmental conditions under which experimentation is conducted, we therefore cannot determine whether or not a specific circumstance would be repeatable over time, therefore "facts" are virtually non-existant. Not completely, but virtually. 2) It is never the object of scientific experimentation to "prove" anything, nor do we attempt to "disprove" anything. Evidence, either supporting or refuting any set of conditions, is gathered via the scientific method, and unless gathered impartially and totally objectively, these data are almost completely useless. If you set out to "prove" something, you most likely will, based purely on your experimental design, by limiting factors or variables that would "disprove" your hypothesis. What the hell good is that? Much to our profession's chagrin, good science is not always practiced however. And the old adage, "figures don't lie, liars figure" does indeed ocassionally apply. This is exactly how the American public can be SO easily drawn astray. Complex issues require complex analysis, and who among the general public has time (or the ability) to understand the root causes, possible courses of action, and can properly analyze the resulting data sets? 3) Science does not deal in "truths". Again, we deal in the practice of gathering and analyzing data, and our research efforts are guided by impartial dissemination of these data and the corresponding evidence to which they point. Truths aren't the basis for scientific evaluation, they pertain more to what an individual or group or population believes someting to be......with or without a supporting body of evidence. Truths exist in man's mind only. Nature allows us to seek and find evidence of what may or may not be. Anything can be viewed as truth in the eyes of man, depending on who it benefits to convince and who becomes subjected by what a given truth may be. Laws governing our existence are truths. Religious beliefs are truths. They exist with or without a supporting body of evidence because man says they do, and for no other reason. Science cannot afford the luxury of beliefs without supporting evidence, nor can we reject a hypothesis without evidence supporting another option to the contrary.

I'm a big believer in sample size. No competent determination can be reached pertaining to ANY issue based on a small sample, no matter how competently collected. The term small here is relative however, and is in direct relationship to the impact of the issue at hand. Environmental issues are indeed complex, but we do have more evidence and data sets than are currently available for say, a developmental chemotherapeutic agent and its ability to regulate or suppress any given carcinoma, which also happens to be a far more complex issue, with poorly understood mechanisms of action and the resulting reactions. So the place the entire burden of the future regulation and health of the park system within the scope of science is a somewhat dicey proposition, but one to which I would gladly lend whatever assistance I could manage. What the public could expect short-term is little improvement or dramatic change, and more tax dollars spent on surveys and environmental impact studies regarding lesser-understood and poorly researched aspects of the long-term health of the system. Maybe some issues could be dealt an immediate and temporary blow based on the accumulation of current data, such as the snowmobiles in Yellowstone, various animal slaughters, unrequired damming of rivers, development of certain lands surrounding historical sites, etc. but only time would tell if these actions were to become a perpetual change on the landscape, and to what eventual benefit or detriment would have to be deterimined only through the course of time.

And for what it's worth, my notion of research is based in no small manner on the input of those who managed these lands generations before we assumed control, and parks weren't even in existence. This period was indeed the "golden age" of these lands, as they were under the stewardship of various peoples who understood far better the relationship between all creatures and objects on Mother Earth. And for my money, placing them back into their rightful position of stewards could only be a tremendous benefit to us as a population and the environment as a whole. There comes a time, after the management of successful endeavor has been driven into the ground by a change in ownership, the new owners must be objective enough to see that to best benefit the program, another change is mandated. Such is the case with our current management of these resources.

So much for a simple explantion. You might want to try your Etch-A-Sketch theory on my post.

First a scientific question. Do snowcoaches actually reduce pollution? I keep reading on another blog of someone who studies this stuff that they don't. Her preference: plow the roads.

Secondly, an ethical question. Do we really want scientists making value-laden decisions? Does science ever answer values questions?

And, having said that, I'm not fond of snowmobiles in Yellowstone, or snowcoaches, or cars, but I'm less fond of a winter playground monopolized by the rich and argued over by the rich. The snowmobile issue points to so much else, but don't we trivialize it to see this as simply science versus policy? It's ethics and values; the science only clarifies the values questions. Setting science up as a value arbiter is neither scientific nor sound. I guess I answered my own question 2 (still would like to understand question 1 more), but I'm curious why science is thrown around like it is as the panacea for all environmental questions (and politicization of science the greatest evil).

Jim Macdonald
The Magic of Yellowstone
Yellowstone Newspaper
Jim's Eclectic World

Jim, in answer to your first question, yes, snowcoaches would be less-polluting than snowmobiles. According to the EPA, the initial preferred alternative to allow up to 720 snowmobiles per day into Yellowstone, when compared to the snowcoach only alternative, "would result in five times more carbon monoxide emissions and 17 times more hydrocarbon emissions," according to Kerrigan Clough, the deputy regional administrator of EPA Region 8. "This alternative also would double the acres in Yellowstone impacted by over-snow vehicle noise for more than 50 percent of the day."

You can find the rest of that story here.

Now, under the currently preferred alternative, which would allow upwards of 540 snowmobiles into the park, those numbers would change a bit, but snowcoaches still would be cleaner. Would they be cleaner than plowing the roads and letting folks drive in? I can't answer that question right now. But the aesthetics would certainly change, and I think part of the joy of visiting Yellowstone in winter is coming in over snow, as opposed to driving in on pavement.

Plus, I think if you opened that door you'd have to open more, such as turning the lodges into year-round destinations, and that certainly would add more (if not overload) the system.

Now, your latter pondering isn't easily answered. Who's values are we holding decisions up to? Those of the rich? Of the middle class? Of any other social or cultural group?

Science, though not always an absolute, serves as an emotionless arbiter (or it should). If the science is good and proven, I believe it should guide questions that involve (at least) the environment. Should it be the final arbiter or considered a panacea? I don't think so, not in all cases. I still believe we have to add the human factor into the equation.

But in the case of Yellowstone and snowmobiles and snowcoaches, phasing out snowmobiles by itself does not deprive anyone of visiting the park (although mounting costs of visiting surely does) and it lessens the impacts on the resources -- the wildlife, the air, the soundscapes, the visitors, the employees. In this narrow instance -- which is better for Yellowstone's resources, snowmobiles or snowcoaches? -- I don't believe science, or relying on science, trivializes any larger questions.

What amazes me, this big beautiful country called Yellowstone, is why would anybody want to bring all this motorized crap into the park during the winter. There's something very peaceful and full of blessed solace about Yellowstone in the winter, but why can't we leave it that way, and just enjoy the simple things that the park has to offer. Such as snowshoe hiking, snow camping, skiing and outdoor photography...and many other healthy activities. Why does it have be this thing about a faster, easier and sedentary way of activity in traveling in your own personalized highly mechanized snowmobile (and forgetting you have two legs to exercise and walk on). This is not a elitist attitude, but a attitude that we need to address to are younger generation the critical importance of good wholesome rugged exercise that Yellowstone has to offer. What I see in are younger generation today, and this greatly alarms me, is the huge obesity problem in this country (did you check your own weight and blood pressure lately...and your kids?)'s a major catastrophe waiting to having diabetic and heart problems before there twenty. The message should be, less mechanized toys, such as snowmobiles and more snowshoes and hiking...etc...This is a far better trade off then having just "one snowmobile" in the park.

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