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

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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.


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 Yellowstone...like 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?)...it's a major catastrophe waiting to happen...kids 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.


I don't particularly have a strong opinion on the science because I'm woefully ignorant of those things. It is interesting to read the conflicting views on the science, but I'm usually not in the business of arguing about things I don't pretend to know. This is helpful information.

Now, on the second question, you say first that science serves as an "emotionless arbiter." First, I think that's something of a false dichotomy. Rather than say that any judgment is without emotion, it is more precise to say that any sound judgment is true regardless of emotion. That distinction might be subtle, but we have to be careful. A triangle, for instance, has three sides regardless of whether it is equilateral, scalene, or isosceles. However, there is no such thing as a triangle that is not either, equilateral, scalene, or isosceles. There is no such thing as a scientific judgment that is uttered without emotion, unless judgments can exist without judges. However, that something is a triangle does not depend upon the type anymore than a sound judgment depends upon emotion.

The point in all of this is that people with emotional biases are not necessarily acting without sound science. The science should be able to stand on its own regardless of what someone believes, and sound science, if there is such a thing, does not require arbiters who don't have opinions and emotions about things. The reason we seem to care about this and become cynical and suspicious, for instance, of an oil industry study on climate change, is because very few of us understand the science enough in order to come to our own conclusions. In that case, we are not judging science but whether we trust a source. Many of us who are not scientists end up basing our judgments about these matters not on science but on trust; in many cases, that is a reasonable response because so often our suspicions turn out to be right.

You go on to assert that science should at least guide questions that involve the environment. I don't think I'd dispute that, but the question is how so. What does science actually show? Science can show, perhaps, that a certain number of snowmobiles will pollute the air in a certain way and will have such and such effects on various features and wildlife. That's certainly very useful information when we are presented a question of whether snowmobiles should be allowed because it clarifies the shared reality in which we make value judgments. However, it is not science that answers the "should"; it only does so assuming that people have the same set of shared values and the same interpretation of those values to the specific situation in which the science applies. What should govern those values? And, even if we can determine those (for instance, one answer might be the laws that currently govern Yellowstone), the application of those values to a specific situation is always going to be subject to further value judgment. These are not scientific questions.

I think one can make a scientific case (that is observe, measure, and document) that the disputes about snowmobiles in Yellowstone are only secondarily questions of science but foremost questions of values. Though there seems to be some dispute over the science (for instance, snowmobiles versus snowcoaches), there is greater dispute on the purpose of national parks, specifically Yellowstone National Park, and more specifically the best way to use and regulate use of Yellowstone National Park in the winter. Even you resort not to science but rather an aesthetic argument at one point to justify keeping this argument about over-the-snow vehicles rather than automobiles.

I don't believe we will move forward in this until people stop using science as a smokescreen (a snowstorm?) blocking our view from the critical values issues that have to be tackled, and beneath those, the ontological assumptions behind them that drive values discussions. When it comes down to it, this is not really about science. This is about how well science conforms to values. That doesn't make science irrelevant; it just means that from a policy standpoint, it is not ultimately the scientists as scientists who should make these decisions.

However, if it's not scientists as scientists, and the political system is not responsive to the value judgments of the people whom they represent (and no way of knowing whether those value judgments are in any way sound), what is there to be done?

Now, that's getting ahead of ourselves; if people don't follow my points that far, there's no way to get at the larger social implications.

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


Science can indeed be classified as either good, insofar as being soundly researched and executed, or poor, referring to it being targeted toward a specific agenda or hypothesis, but I would tread lightly around the term proven. Even a preponderance of evidence doesn't automatically qualify as proven beyond a given measure. At best, it lends credence to one's position, but the meaning of the term proof is something science prefers to leave in the courtroom environment, to be bandied about and abused by the legal profession. The entire purpose of research is to gather data and let those data guide the investigation to its' eventual end, be it in support of the original hypothesis or not. If the weight of these data support the hypothesis, and the experimental protocol can be duplicated over time by independent researchers or teams, only then does the hypothesis evolve into an accepted theory. If the evidence serves not to support the intent of the experimentation, so be it. You then follow the new course that the data charts for you, and follow IT until you have enough evidence to support the new hypothesis. The true purpose behind any scientific exploit is discovery, whether it follow the original intent of the process or not is completely irrelevant. It's always nice to be correct in your initial assumptions, but it's also a far cry from the norm. The term serendipity best describes how the majority of discoveries were and are found throughout the history of most branches of science. That's why we're taught that Rule #1 is "always keep your eyes and mind open", as observation and conclusion are the mother of all discovery. Any idiot can find what they're looking or manipulate data sets to support poor experimental design that allows them to "discover" that which they seek if they follow the poor science methods. Such are the fantasies of the closed mind. But most often the clues are subtle at best and hidden at worst, and without the ability to dig beyond the obvious and truly see all that is presented, most of what would be the more noteworthy accomplishments and greatest discoveries would have remained forever lost.

Should it be the sole arbiter? God forbid! Not in ANY instance, nor should be the sole determinant for ANY issue. But the service that it can lend should neither be completely ignored. In our modern world, science functions as a tool, an aide, a crutch, a compass, an additional source of information from which conclusions can be drawn. Unless, of course, you're Director Bomar, and you're too busy to read that which was commissioned specifically for your very benefit. Science was never intended to serve as the "be all, end all" in any forum. But what other method of gathering information is currently available that serves the same purpose as scientific research, and if they exist, are they any more reliable than the current methods?

For the record Jim, the politicization of science is the worst form of evil, as it subscribes to the "poor" scientific methods that are an abomination to the field as a whole. Science and politics cannot co-exist. Science is the elimination of specific agenda, which is the diametric opposite of politics. It's oil and vinegar, night and day, positive and negative poles of the battery. Politicos not only seek but require justification, science seeks NOT to justify, but hypothesize and investigate. The last time anything was deeply investigated on the Hill was during the Watergate era, and where did that get us? Science in politics equates to a Surgeon General, who cautions against smoking, trying miserably to save face for a government who lives off the revenues generated by, while simultaneously fiscally supporting that very same industry that the "official chief government scientist" abhors. Politicization of science is an FDA who protects the Big Pharma more than it does the American consumer. Countless times in just the past 2-3 decades, drug discoveries that were made in other countries were put on the FDA "banned" list, not due to any factor except that which allowed for profits to be made by overseas research firms. But yet, who allowed Big Pharma to be the first to jump on the "generic equivilent" knock-offs once the initial proprietary periods had expired? Our same two-faced FDA. Yet at the same time, do I need to mention either the company names or the compound names that was forcibly removed from circulation due to an accumulation of patient deaths, due SOLELY to improper clinical trials and manipulated data by the manufacturer? Did anybody bother to print the "behind the scenes" story of why these clinicals were rushed through the system? Did anyone bother to investigate and discover that again, Big Pharma was about to be beaten to the punch by off-shore competition, and stood to lose BILLIONS in R&D and God forbid, future profits, had they completed their studies "by the book", so instead the FDA allowed, nay, FACILITATED their gamble and approved experimental drugs that were responsible for the deaths of DOZENS of patients world-wide? I could carry on, but this should give you a pretty good idea why the marriage of science with politics makes for a nuclear meltdown waiting to happen.


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