bigwalls.net

Set out below are the Access Fund's Yosemite VIP comments. Please feel

free to distribute or comment. There is an executive summary and statement

of the unique needs of climbers at the beginning, if you don't care to wade

through the 17 pages of the full text.

 

 

Superintendent Stanley Albright

Yosemite National Park

P.O. Box 577

Yosemite National Park, CA 95389

 

Attention: VIP Planning

 

 

Dear Superintendent Albright:

 

Comments on the Valley Implementation Plan

 

This contains the comments of The Access Fund on the Draft

Yosemite Valley Implementation Plan and Supplemental Environmental Impact

Statement ("the VIP"). 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 containing 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.

 

 

EXECUTIVE SUMMARY

 

The Access Fund is concerned that the VIP does not

adequately consider the particular needs of special user groups, including

climbers. Climbers have unique patterns of visitation and use in the

Valley, and these give rise to particular needs. For example, climbers

tend to spend more time in the Valley than members of most other user

groups; climbers' use is more dispersed throughout the Valley, with

climbers using areas in the western part of the Valley seldom frequented by

others; climbers often begin ascents before sunrise and finish after

sunset; and climbers pursue their sport into the off-season, and even into

the winter. Climbers spend much of their time right at the edge of the

Valley's wilderness, where the noise and crowding of the Valley floor have

a particularly negative effect on the wilderness experience many climbers

seek on Valley walls. Finally, climbers enjoy a special camaraderie and

society in the Valley, one that is centered on Camp 4.

 

Climbers' unique access needs in the Valley include the

need for off-season and off-hour auto and parking access to climbing

approaches in the East Valley when the regional transportation service and

shuttle service will not be available; the need for continued auto and

parking access to climbing destinations in the West Valley that will not be

served by a shuttle; the need for access to the Camp 4 campground without

advance reservations; and the ability to access climbing approaches in the

East Valley that are remote from popular tourist attractions when access to

these tourist attractions has been curtailed because their carrying

capacities have been reached. Many of climbers' needs have already been

identified in the draft Yosemite Climbing Management Plan. This plan

remains in draft form and should be adopted as part of the overall planning

process for the Valley.

 

As a conservation organization, we support the central goal

of the VIP, which is to reduce automobile use in the Valley. However, we

believe that the transportation and parking portion of the VIP has not been

sufficiently well thought out. It focuses narrowly on the peak season/peak

hour visitor who enters and exits the park from the same direction,

ignoring off-season and off-hour visitation patterns and the needs of

visitors to the Valley who plan to enter and exit the park in different

directions. Consequently, we do not believe that the transportation and

parking scheme in the VIP is either realistic or workable, at least at the

present stage of development. In regard to the transportation components

of the VIP, we recommend that the NPS adopt Alternative IV, the Minimum

Requirements alternative, pending further progress in developing the

Regional Transportation System and a more balanced and in-depth

consideration of how to meet the transportation needs of all Valley

visitors.

 

Since the VIP will provide the NPS with the means to impose

limitations on day use visitation to the East Valley, while eliminating

much of the parking which formed the basis for the present limitations on

day use visitation, the VIP should clearly present the basis for either

continuing the present limitation on day use or establishing any new

limitations on day use visitation to the East Valley and analyze the

environmental impacts on the recreation experience, including climbing, of

doing so.

 

We also believe that the number of campsites in the Valley

should be retained at levels prescribed in the 1980 GMP, not reduced, with

additional walk-in campsites developed to achieve GMP levels, and that any

further reductions in Valley overnight accommodations should come from

developed lodging, not campsites; that RV access to scarce Valley campsites

should be limited to provide for greater access by tent campers; that a new

picnic ground should be developed at Ahwahnee Row to mitigate the loss of

other picnic grounds under the VIP; that auto access to the East Valley by

lodging guests should be restricted to the same extent as auto access by

day users; and that more asphalt roadways should be removed from the East

Valley than the VIP calls for.

 

 

I.THE UNIQUE ACCESS NEEDS OF CLIMBERS AND OTHER USER GROUPS SHOULD BE

ADDRESSED IN THE VIP.

 

Climbers are one of a number of user groups with special

patterns of visitation and special access needs. One of the great

weaknesses of the VIP, and particularly of its transportation and parking

components, is the failure to consider the use patterns and access needs of

such particular user groups. These include backpackers, equestrians,

cyclists, photographers, and weekenders of all types. The particular use

patterns of climbers are described below, followed by a discussion of the

particular needs of climbers as they relate to the VIP.

 

Climbers visit and use the Valley in ways unlike any other

user group that we are aware of. For one thing, individual climbers tend

to spend a lot of time in the Valley. Many climbers stay in the Valley for

extended periods. Others, typically weekender climbers, return to the

Valley repeatedly over the course of a season, often for years on end. As

a consequence, climbers tend to develop a keen awareness of the Valley

environment and of those aspects of the Valley infrastructure and services

that do and do not work for them.

 

Climbers use of the Valley is much more dispersed than that

of most other visitor groups. Most day use visitors will stay on the

Valley floor or take one of the trails to the Valley's principal water

features, while most backpackers use only a few Valley trailheads. Yet

climbers use the entire Valley, from Parkline Slabs in the west to Mount

Watkins and Half Dome in the east. In fact, relatively few climbs are

accessed by the Valley trails most popular with tourists--those leading to

Upper and Lower Yosemite Falls, Mirror Lake, and Vernal and Nevada Falls.

Most climbing in the eastern end of the Valley takes place on the walls on

the north side of the Valley between the Ahwahnee Hotel and El Capitan, at

Glacier Point Apron, and at the Cathedral Rocks, places little visited by

others.

 

Climbers also tend to keep longer hours than other types of

visitors. The Valley's many long climbing routes mean that climbers often

must start climbing in the early hours of the morning and descend in the

late hours of the night. Many long free climbs or big wall aid climbs

require climbing teams to make an "alpine start" well before sunrise in

order to summit or to reach a bivouac ledge before nightfall. Many long

climbs also necessarily involve a descent after dark and a return to the

trailhead late at night.

 

Climbers enjoy a longer season in the Valley relative to

many other types of visitors. Because of the Valley's low elevation and

the fact that many of the more popular climbs are on walls that face south,

climbing is possible year-round in the Valley, although little climbing

takes place in the months of December, January and February. Nevertheless,

climbing in the Valley is popular in many "off-season" months, particularly

since many climbers find the peak summer season too hot and too crowded for

their taste.

 

Because climbing tends to take place at the very border of

wilderness, many climbers also experience a continual sense of frustration

at the inability to have a wilderness experience in the Valley. Climbers

in the Valley lead a particularly dichotomous existence, spending most of

their days on the Valley's walls, where many seek a wilderness

experience--and are held to wilderness standards of conduct by the

NPS--only to return at days' end to the mechanized, urbanized, and often

crowded world of the Valley floor. Many climbers find the noise of

vehicles--particularly buses, motorcycles, and the loud-speaker Valley

tour--which reach even the most remote walls, the inability to camp

overnight in an environment remote from Valley development, and the whipsaw

effect on their sensibilities of the daily transition from Valley walls to

the Valley floor, substantially reduces their ability to appreciate the

natural qualities of the Valley. Backpackers, by contrast, typically pass

out of the heavily impacted area of the Valley within a few hours, while

day hikers, who may have an experience similar to that of climbers, are

unlikely to spend many days in the Valley.

Climbers, like the enthusiasts of any sport, enjoy the

companionship and camaraderie of their own kind. The bond between members

of a climbing team is strengthened by the fact that each relies on the

other for his very survival in the climbing environment. A climber is by

definition a person both willing to entrust his personal safety to another

and willing to assume responsibility for another's safety. Knowing this

about each other strengthens the sense of camaraderie that climbers

naturally share. In Yosemite Valley, this natural camaraderie among

climbers is enhanced by the shared enjoyment of one of the world's great

climbing areas. This sense of camaraderie is part of the climbing

experience in Yosemite and is best reflected in the society of Camp 4, the

Valley's traditional climbers' campground, where climbers (and other

campers) can find a campsite without an advance reservation, and where,

because campers are packed in six to a campsite without regard for group

size or identity, there exists the ever present possibility for new

friendships and associations. Thus, the society of climbers and the

"scene" at Camp 4 are very real parts of the climbing experience in

Yosemite Valley.

 

We now turn to the particular needs of climbers as they are

affected by the VIP.

 

A.Climbers' auto access to the West Valley should be preserved and enhanced.

 

Under the VIP, climbers should continue to have automobile

and parking access at West Valley climbing sites. The Proposed Alternative

envisions a regional transportation system that would intercept

Valley-bound day use visitors, transfer them from their cars to buses,

transport them to Taft Toe, and then transfer them to the Valley Tour or

Valley Shuttle. VIP at 43; See also Appendix D: Summary of the

Transportation Study. This scheme appears intended to address the majority

of day use visitors to the Valley, who will be headed to the popular

tourist attractions at the Valley's eastern end.

 

Many day use climbers will probably prefer to avoid this

cumbersome system and climb at West Valley sites, however. We predict that

one effect of implementing the VIP will be increased day use by climbers of

climbing areas west of the East Valley Checkpoint at Taft Toe. Many

climbers without Valley campground reservations (or day use reservations,

if a day use reservation system is implemented) will prefer to climb at

locations west of the East Valley Checkpoint rather than take the trouble

to pack their gear for a whole day, leave their car at an out of Valley

intercept point or at Taft Toe, and wait for a shuttle to take them into

the East Valley. Consequently, climber parking at west Valley climbing

sites should be retained and, if necessary, expanded.

 

This particularly applies at El Capitan, since it is

outside the day use vehicle restriction area, and it has popular short

climbs in addition to its well-known overnight big wall routes. The

Proposed Alternative would redesign the parking area facing El Capitan

along North Side Drive to provide areas for day use parking and to

accommodate a turnout for the Valley tour. See Valley View and Valley

Circulation Maps; see also VIP at 40, stating that vista points and picnic

areas will be built along the Old Big Oak Flat Road for viewing climbers on

El Capitan.

 

No mention is made in the VIP of climbers' need for

both day use and overnight parking while climbing on El Capitan, however.

(But note that the need for climber parking at El Capitan is acknowledged

in Appendix D, Summary of the Transportation Study, at 277.) The VIP

should be revised to explicitly state that the existing day use and

overnight parking for climbers on El Capitan on North Side Drive will be

retained.

B.Off-hour and off-season auto access to the East Valley and adequate East

Valley trailhead parking should be provided.

 

We are also concerned that climbers continue to have

off-hour and off-season access to and around the East Valley for very early

morning ascents or very late night descents from Valley walls, particularly

at major formations such as Sentinel Rock, Half Dome, Washington Column,

and Mount Watkins. We think it unlikely that either the regional

transportation system or the Valley shuttle would be operating with any

regularity at these small hours of the night, particularly in the

off-season, and the VIP does not explain what provision will be made for

climbers and others wishing to enter or move around the East Valley at such

times.

 

Climbers who approach the park in the middle of the night

should not have to wait until daybreak at an out-of-park transfer station

for a bus to arrive to take them to the Valley. Similarly, climbers

arriving at the Valley checkpoint in the early morning should not have to

wait for the shuttle to begin running so they can reach their trailhead.

Rather, they should be able to proceed directly to their trailhead if the

regional transportation system and the shuttle are not operating. This is

likely to be a common situation for climbers arriving late Friday night for

a weekend of big wall climbing. Also, climbers descending to the Valley

floor late at night, possibly with enormous haul bags, should not have to

wait till the morning shuttle or have to hike several miles along a road to

the Taft Toe parking lot to find their car and leave the Valley; they

should be able to return to their car at their trailhead.

 

Given the likelihood that it will not be economical to

operate the regional transportation system in the off-season or during

off-hours, or to operate the Valley shuttle during off-hours, auto access

to the Valley under the VIP should follow the pattern established at

Devil's Postpile National Monument, in which use of the shuttle is required

during normal daylight hours in the peak season, while auto access is

permitted at all other times. In this way, climbers and others needing to

park at trailheads or climbing approaches can schedule their arrival at a

time when the shuttle is not operating or at least when its use is not

mandatory. This would also mean that adequate parking should be retained

at East Valley trailheads and other appropriate locations.

 

 

 

 

C.Access restrictions designed to protect Valley tourist attractions should

be trailhead-specific.

 

With implementation of the VIP, traffic and parking

congestion will no longer be the primary focus of concern regarding the

impacts of day use visitation in the East Valley. Attention will shift to

the carrying capacity of the East Valley's major attractions, particularly

the Upper and Lower Yosemite Falls trails, the Vernal and Nevada falls

trails, and the Mirror Lake trail. The VIP indicates that visitation has

already reached the levels prescribed for these areas in the GMP.

As discussed in more detail below, we believe that any new

day use restrictions should be fully clarified and their impacts on the

recreational experience fully analyzed. We also suggest that any system of

day use limitations or reservations that the NPS imposes to prevent overuse

of the most popular Valley tourist resources be trailhead-specific, rather

than Valley-wide, so that climbers and others willing to visit less heavily

impacted resources will be able to do so. If instead, restrictions on

day-use are imposed on a Valley-wide basis, then climbers and others who do

not intend to visit the heavily-impacted tourist areas will be needlessly

barred from reaching their destinations.

 

D.Camp 4 must be kept available on a non-reservation basis.

 

Camp 4 currently operates on a non-reservation basis and

must continue to do so under the VIP. The thrust of the VIP is to separate

visitors to the East Valley into two categories: day use visitors and

overnight visitors with reservations. Under the Proposed Alternative,

these two categories of visitors will be processed separately at the East

Valley checkpoint, with those having reservation allowed to proceed in

their vehicles to their campground or lodging. VIP at 39, 41.

 

The VIP does not propose to convert Camp 4 to a

reservation-only campground, like all other Valley campgrounds.

Nevertheless, we believe that implementing the VIP will lead the NPS to

consider doing so to simplify the processing of visitors at the East Valley

checkpoint. It is essential, however, that Camp 4 be retained as a

non-reservation, space-available campground, as it has traditionally been.

This makes it available to the young and young at heart, who prefer to

travel more spontaneously than others, and to campers and climbers from

other parts of the country or from other countries, who should not be

expected to make reservations far in advance to accommodate the

uncertainties of long travel itineraries. This may mean that the

allocation of Camp 4 sites would have to be handled from the East Valley

Checkpoint. In any case, Camp 4 should continue to accommodate the needs

of these special populations, as mandated by the General Management Plan.

See GMP at 23.

 

Conversely, converting Camp 4 to a reservation-only

campground, like all the other Valley campgrounds, would tend to convert it

into a family-oriented campground catering to those with the time, leisure

and foresight to make camping reservations months in advance. Few of these

people are likely to be the young or climbers, and the society of climbers

for which Camp 4 has long been famous, and which is a vital component of

the climbing experience in the Valley, would be irretrievably lost.

 

E.The NPS should adopt the draft Yosemite Climbing Management Plan

as part of the overall planning process of which the VIP is a part.

 

Because climbers are a sizeable and distinct user group,

the NPS initiated a process to develop a management plan specifically to

address the impacts of climbing on the Valley environment, the particular

needs of climbers as a group, and the impacts of Valley visitation and

development on the climbing experience. While considerable NPS staff and

climber time has been devoted to the development of this plan, it remains

in draft form and has not been adopted by the NPS. We feel strongly that

with the development of the Lodge Plan and now the VIP, it is time for the

NPS to finalize the Yosemite Climbing Management Plan and integrate it into

the planning process for Yosemite Valley.

 

 

II.THE VIP'S TRANSPORTATION AND PARKING PROPOSALS ARE INADEQUATE TO ADDRESS

THE FULL RANGE OF VISITOR NEEDS.

 

Two central premises of the Preferred Alternative are that

if a regional transportation system can be developed to serve the Valley,

such a system would make a parking lot at Taft Toe unnecessary, VIP at 43,

and that with either development of a regional transportation system or a

parking lot at Taft Toe, substantially all existing day-use parking in the

East Valley (some 2,300 spaces) could safely be eliminated, VIP at 41.

Both of these assumptions are groundless; we believe that some day use

parking will be required at both the Taft Toe and the East Valley in order

for the transportation scheme proposed in the VIP to work. The assumptions

in the VIP appear to be based on a very narrow vision of how people visit

Yosemite, a vision limited to the peak season, peak-hour, single point of

origin and return excursion day visitor. This vision fails to consider the

full pattern of day use visitation, or the realistic needs of all East

Valley visitors, including off-season and off-hour visitors, visitors

planning to proceed to other destinations in or out of the park after

visiting the Valley, and visitors who are not one-time tourists, all

categories that will frequently include climbers.

 

The VIP completely ignores the wide variation in day use

visitation between the six-month peak season and the remainder of the year.

Nowhere in the VIP is there any consideration of the questionable economic

feasibility of operating a regional transportation system to serve Yosemite

in the winter, when system patronage would doubtless be very low,

particularly on weekdays. If a regional transportation system were

developed but was found to be uneconomical for serving off-season use, as

seems very likely, the NPS would have to either build the Taft Toe parking

lot or allow visitors continued direct access to day use parking in the

East Valley. Hence, the mere existence of a regional transportation system

that is successful at serving peak season use does not automatically

preclude the need for a parking lot at Taft Toe or continued day use

parking in the East Valley to serve off-season use.

 

The same holds true for off-hour use. While a regional

transportation system might be effective at serving peak hour day use, it

seems doubtful that it could economically serve visitors wishing to access

the East Valley late at night or early in the morning. Such visitors would

include climbers and backpackers travelling to approaches or trailheads in

the East Valley, particularly on Friday nights. They should not have to

wait until daybreak at an out of park transportation staging area to take

the regional transportation system into the Valley. They should be able to

drive directly to either Taft Toe or to their trailhead in the East Valley,

depending on the availability of the Valley shuttle at the time they

arrive. Hence, if the regional transportation system does not effectively

serve off-hour visitors, it will not obviate the need for in-Valley parking

to serve them, both at Taft Toe and in the East Valley.

 

There are also very real questions as to the ability of a

regional transportation system to serve park visitors that the VIP should

acknowledge. The transportation study summarized in Appendix D of the VIP

raised serious concerns as to the amount of day use automobile traffic that

could successfully be intercepted outside the park. As noted in the VIP,

almost 60% of visitors enter and leave the park via different entrance

stations. VIP, Appendix D at 269. Only 21% enter and exit through the

same station. Id. Thus, visitors planning to enter the park at Wawona,

visit the Valley and exit through Tuolumne Meadows, and who are compelled

to use the regional transportation system, would have to cover the mileage

between Wawona and the Valley three times. And after returning to Wawona

on the regional transportation system, they might feel compelled to take

local overnight lodging rather than face the daunting task of driving to

the Valley again on their way to Tuolumne Meadows over a route they had

already traversed twice that day. It seems very likely that compelling a

significant percentage of Valley visitors to travel three times over a

route that they would otherwise have traversed only once, in circumstances

that could require them to pay for overnight lodging for the privilege of

doing so, will generate vociferous opposition. In the face of such

opposition, the NPS might well invite through-park visitors to park at Taft

Toe instead. If so, this is yet a third circumstance in which the mere

existence of a functioning regional transportation system would not obviate

the need for parking at Taft Toe.

 

Even though the VIP does not propose to implement a

regional transportation system, if the VIP is to have any meaning or

integrity as a transportation planning document, it must give adequate

consideration to how such a system would serve Valley visitors and be

integrated with the transportation and parking system the NPS proposes for

the Valley. Otherwise, the VIP simply misleads its readers into believing

that the Taft Toe parking lot need never be built, or that auto access to

the East Valley or day use parking there can be eliminated without

substantial dislocations to current patterns of visitation that are certain

to generate public protest.

 

Because the description and functional analysis of the

transportation and parking elements in the VIP are so glaringly incomplete,

we believe that the NPS should adopt the transportation components of

Alternative IV, the Minimum Requirements alternative, for the time being,

until further progress is made in implementing the Regional Transportation

System and more detailed consideration can be given to how to serve the

realistic needs of all Valley visitors at all times and seasons of the

year. We also think that the implementation of the transportation and

parking portions of the VIP should be as flexible as possible, with parking

retained in the East Valley for off-season and off-hour use until it is

clear whether the transportation system and shuttle are able successfully

to handle the full range of visitor needs.

 

 

III.THE VIP SHOULD CLARIFY THE BASIS FOR, AND THE ENVIRONMENTAL IMPACTS OF,

ANY NEW LIMITATIONS ON THE NUMBER OF DAY USERS TO THE EAST VALLEY.

 

The VIP establishes the means for the NPS to control the

numbers of day use visitors to the East Valley. Once the East Valley

Checkpoint is in operation, it will be a relatively simple matter for the

NPS to monitor the number of day use visitors who have passed through, note

when a prescribed number has been reached, and shut off access to the East

Valley to all subsequent day use visitors, who would then be diverted to

other park destinations.

 

A maximum number of day use visitors for the Valley has

already been established by the 1980 General Management Plan ("GMP") for

Yosemite. This number is 10,530 people. GMP at 17, VIP at 9. This figure

was derived primarily from the number of Valley parking spaces available

for day use visitors, although consideration was given to tour bus visitors

as well. See GMP at 15.

 

The VIP notes that it does not plan to change this number.

VIP at 6. Hence, under the VIP, the maximum number of day use visitors

allowed into the Valley (or at least into the East Valley) would remain at

10,530. This number is already frequently reached or exceeded in the

summer. VIP at 6, Appendix D at 268. In recent years, the NPS has closed

off access to the park on certain summer weekends as a consequence. VIP at

6.

 

The problem with enforcing the GMP day use limits under the

VIP is that the basis for the GMP day use limits will no longer exist under

the VIP. The VIP plans to eliminate all, or at least nearly all, day use

parking in the East Valley. See VIP at 41. In doing so, it will also

eliminate the rationale for the day use visitor maximum of 10,530 people

established in the GMP.

 

If the Park Service expects to enforce the old GMP

numerical limitations on day use in the East Valley after day use parking

has been eliminated in the East Valley and before a day use reservation

system is in place, as the VIP indicates, or if the NPS anticipates

establishing new day use limitations, then in either case the basis for

these limitations should be clearly set forth in the VIP and the

environmental effects of imposing these limitations, including the effects

on the recreational experience of all types of users, including climbers,

should be analyzed in the VIP.

 

 

IV.THE NUMBER OF CAMPSITES SHOULD BE RETAINED AT LEVELS PRESCRIBED IN THE

GMP AND MORE WALK-IN SITES DEVELOPED.

 

The 1980 General Management Plan ("GMP") called for the

number of Valley campsites to be reduced from 872 to 756, a reduction of

116 sites, or 14%. GMP at 35, 43. The VIP proposes to further reduce the

total number of campsites from the GMP proposed level of 756 to 675, an

additional reduction of 81 sites, or 11% more than the reduction prescribed

in the GMP. VIP at 30, 45. The combined GMP/VIP reduction in campsites

would thus be 197 sites, or a 23% reduction from 1980 levels.

 

We support the goal of the 1980 GMP to reduce the numbers

of all types of lodging in the Valley, including campsites, in order to

reduce visitation impacts. However, the VIP's proposed further reduction

in campsites is a very substantial reduction in the number of people who

would otherwise have access to camping in the Valley. Taking the VIP's

180-day camping season, 95% occupancy rate for campsites, and average of

3.8 people per campsite group (see VIP at 165), the additional loss of

these 81 sites would mean that 52,634 people would be denied access to the

Valley each year (81 x 3.8 x 180 x .95 = 52,634). (The VIP erroneously

puts a dollar figure before this number of campers, thereby confusing the

reader. See VIP at 166.) The VIP also miscalculates the loss in revenue

to the NPS from this reduction in campsites as $13,851, using a figure of

$1 per night for camp fees, rather than the correct figure of $15 per

night. See VIP at 165. The actual loss to the NPS in camp fees is

therefore 15 times the amount stated in the VIP, or $207,765. These errors

and oversights should be corrected in the final EIS and the document

recirculated for comment.

 

The VIP acknowledges this reduction of campsites as a

"significant decrease in the park's lodging capacity," VIP at 165, but

offers absolutely no analysis of the impacts of this decrease on the

recreational experience. See VIP at 162-164. Instead, the VIP simply

notes laconically that "considerable unmet demand for in-park camping would

be anticipated," VIP at 165, and then concludes brightly that "most of the

excluded campers would readily accept local (out of Valley) accommodations

as an acceptable substitute," VIP at 166. As frequent in-Valley campers,

we vociferously disagree with this statement. It blithely overlooks a

number of crucial facts: 1) many out of Valley campgrounds are already full

during the peak season, 2) out of Valley campers would have to rely on the

regional transportation system to get into and out of the Valley, a

substantial expenditure of time and an inconvenience that in-Valley campers

would be able to avoid, 3) out of Valley campers could be barred from

entering the East Valley altogether by a day use limitation or reservation

system; and 4) for climbers contemplating one of the Valley's longer

climbs, considerable inconvenience would be involved in reaching the start

of the climb early and returning late. Certainly from our perspective as

climbers, out-of-Valley camping is a completely unacceptable substitute for

in-Valley camping. It is our unshakable conviction that if in-Valley

overnight accommodations are to be further reduced from GMP levels, these

reductions should come from developed lodging facilities, not from

campsites.

 

According to the VIP, the purpose of the proposed reduction

in campsites is to remove campsites from areas prone to flooding, reduce

campsite density, and improve circulation. VIP at 45. While these are

worthy goals, no data is presented in the VIP to show that additional

campsites could not be built in the Valley while still achieving these

purposes. In particular, the higher areas of the Medial Moraine between

Tenaya Creek and the Merced River, the area east of the proposed Lamon

Campground, the area surrounding the Tenaya Creek walk-in backpackers camp,

and the area east of the Ahwahnee Hotel are all possible sites for

campground development.

To bring the total number of campsites up to levels

prescribed by the GMP, additional campsites could be designed as walk-in

sites. Under the Preferred Alternative, walk-in sites constitute only 10%

of Valley campsites. Yet, such sites need less space than drive-in sites,

bring the visitor into a closer relationship with park resources, and make

the visitor less dependant on buildings, vehicles, and other forms of

modern technology than any other form of overnight lodging in the Valley.

As such, walk-in camping should be considered the "highest" form of

overnight lodging in the Valley and accorded the highest priority for

overnight accommodations in the VIP.

 

To work successfully, walk-in campsites must have adequate

parking to accommodate the likely numbers of campers in each site. Under

the Preferred Alternative, however, only 40 parking spaces are provided for

the 30 walk-in sites at the Tenaya Creek Campground, in contrast to the two

parking spaces provided at current tent sites. NPS studies cited in the

VIP indicate that a typical camping group consists of 3.8 people, and most

groups of this size using walk-in sites will be adults who, with all their

gear, will not fit into a single car. Consequently, each walk-in site

should have parking for two cars. Parking for the Tenaya Creek campground

should therefore be increased to 60 spaces.

 

In addition, since parking for walk-in sites can be located

somewhat apart from the campsites themselves, the parking for walk-in sites

could be located in the flood plain, if necessary, while the sites

themselves are located further away from the rivers. This is how parking

was sited at the Yosemite Lodge under the new Lodge Plan. In sum, the

project description in the VIP should state that new walk-in campsites will

be developed, and the total mix of Valley campgrounds altered to

incorporate more walk-in sites, so that the total number of campgrounds in

the Valley can be maintained at the levels prescribed in the GMP. The VIP

should also clearly state that no reductions in the number of campsites

from GMP levels will be considered except in the context of a comprehensive

review of all types of overnight lodging facilities in the Valley.

 

 

V. THE NUMBERS OF RV CAMPSITES SHOULD BE RESTRICTED.

 

The 1980 General Management Plan proposed to "restrict

self-contained vehicle [recreational vehicle, or RV] camping and separate

tent camping from vehicle camping." GMP at 43. The NPS subsequently

considered this goal of the GMP to be "accomplished" when it designated

Upper River campground as tent-only camping. See NPS, The 1980 GMP: A

Draft Analysis of Accomplishments to Date (1989) at 20. In effect, this

action simply provided tent-only camping in the one campground with the

smallest and most cramped sites, while RV camping was allowed in all other

drive-in campgrounds. For practical purposes, RV camping continued

unrestricted.

 

The VIP proposes to continue this pattern of unlimited RV

access to campsites. Under Alternatives 2, 3, and 4, there would be 443 RV

sites, 169 tent sites, and 68 walk-in sites in the Valley. VIP at 40,

45-46; See also maps for Alternatives 2-4, Ahwahnee Hotel & Campgrounds.

This means that 67% of Valley camp sites would be accessible to RVs. Given

that RVs never appear to constitute more than 50% of all camp site use in

the Valley, it seems obvious that the VIP proposal would simply continue

the present pattern in which RV's are subject to no meaningful restrictions

on campsite access. This is contrary to the mandate of the GMP.

 

To bring campsite use under the VIP in line with the

General Management Plan mandate to reduce self-contained vehicle camping,

camp sites available to RVs should be subject to meaningful limitations

under the VIP. There are good reasons for doing so. RVs allow the visitor

to remain almost completely detached from park resources while inside the

vehicle preparing food, eating, sleeping, and attending to personal

hygiene. Given the limited number of Valley campsites, and the fact that

demand for these sites greatly exceeds availability throughout the entire

peak season, preference in access to campsites should be given to those who

come to the park to live as close to park resources as park regulations

allow. Those who choose to use campgrounds as places to park their

moveable lodgings should be accorded a lower priority in access to scarce

Valley campgrounds.

 

RVs should also be separated from tent campers, since RV

uses tend to conflict with tent camping. Campers tend to resent RVs' great

bulk, the noise of their generators, the hermetically sealed nature of

their living environment, and the intrusion of modern technology, including

electricity and television, into an environment in which tent campers have

deliberately chosen to renounce these conveniences.

 

The VIP presents an opportunity to correct this problem and

should do so by imposing meaningful limitations on the number of campsites

available to RVs. Thus, we recommend that RVs be limited to the 71

campsites in Lower Pines Campground. This would provide RVs with access to

over 10% of Valley campsites, while at the same time isolating the RV

campground from tent campers.

 

 

VI.NEW VALLEY PICNIC GROUNDS SHOULD BE DEVELOPED TO MITIGATE THE LOSS OF

EXISTING PICNIC GROUNDS TO CAMPERS.

 

The Valley's picnic grounds are valued by climbers and

other campers as places to enjoy quiet breakfasts and dinners away from the

Valley's campgrounds, which can be dark, cold, smoky, crowded and noisy.

The VIP states that under all alternatives, no changes would be made to

existing picnic facilities. VIP at 26, 41, 55, and 64. Yet, the maps for

Alternatives 2-4, Valley Overview, show the picnic grounds at Cathedral,

Sentinel, and El Capitan (Manure Pile Buttress) being restored to natural

conditions. The VIP does not state exactly what is to be restored at these

picnic grounds, and this should be clarified. If in fact these picnic

grounds are to be eliminated, an environmental analysis of the

environmental effects of such action on recreational resources should be

included in the VIP.

 

The VIP should also describe the substantial reduction in

the use of Valley picnic grounds, and the resultant impacts on the

recreational experience, that is likely to result from the proposed

limitations on auto access and circulation in the Valley. For example,

under Alternatives 2-4, in which North Side Drive is closed to traffic east

of El Capitan, the El Capitan picnic area would be accessible only to

people on bicycles or on foot. This would make it essentially useless for

those seeking an alternative to the campgrounds for cooking breakfast or

dinner, since it would be impossible or at least unfeasible to bring

cooking gear, groceries, coolers, and firewood to this picnic ground.

 

Nor is the El Capitan picnic area likely to get much

mid-day use by walkers or cyclists. Given the short distances available

for bicycling in the Valley, few cyclists are likely to consider it a

viable lunch destination, and few walkers are likely to choose a site with

tables and barbecue pits simply to eat their sandwiches, particularly when

other sites offer better views, access to water, and a less impacted, more

natural and more private environment. In short, it seems unlikely that

anyone would find much use for this picnic ground, and that under the VIP

it would soon be abandoned. The VIP should note this very real possibility

and consider alternate means to meet the demand for picnic facilities.

 

Similarly, it seems likely that the Cathedral picnic area

will become an adjunct of the Taft Toe parking lot, presumably a place for

people to cool their tempers while they wait for problems with their

reservations to be worked out or for a cancellation to become available at

one of the lodgings or campgrounds. No one staying at a campground would

choose to go there because the environment would be dominated by the

enormous parking lot and the noise and fumes of traffic on South Side drive.

 

Sentinel picnic area might remain of some interest to the

camper seeking relief from the campgrounds, but only if the shuttle buses

take the access road into the picnic area itself, so that campers can bring

their coolers, stoves, and cooking gear. Without direct shuttle service,

this picnic ground would have little purpose, because no one would carry

coolers and stoves down the access road if the shuttle bus just stopped on

South Side Drive, and cyclists and day hikers looking for a place to eat a

sandwich have no need for picnic tables and fire pits and are more likely

to disperse themselves along the river and in meadows where the shade is

less deep, the views better, and the environment less impacted.

 

With the Cathedral and El Capitan picnic grounds

effectively lost to Valley campers seeking alternative locations to enjoy

breakfast or dinner, and access to the Sentinel picnic ground in question,

the VIP should propose the creation of one or more new picnic grounds in

the developed area of the East Valley to mitigate this loss. The

demolition of the concessionaire houses on Ahwahnee Row provides a rare

opportunity for the NPS to create a picnic ground looking out over Ahwahnee

Meadow with spectacular views of Half Dome and early morning sun--two

things that the camper sorely welcomes after a few days in the gloom of the

campgrounds. This location would also be easily accessible to campers by a

short shuttle ride. This location should be developed as a new picnic

grounds to mitigate the loss of El Capitan and Cathedral picnic grounds to

Valley campers.

 

 

VII. GUESTS AT OVERNIGHT LODGING SHOULD ARRIVE BY TRANSIT.

 

Under the Proposed Alternative, all visitors with overnight

lodging or camping reservations would be allowed to drive their vehicles

directly to their place of lodging or to their campsite. VIP at 39. They

would not be allowed to use their vehicles for touring in the Valley,

however, and would be required to use the Valley shuttle for this purpose.

VIP at 40.

 

It is understandable that campers would need to be able to

drive directly to their campsites, since their vehicles would be filled

with gear and food. There appears to be no reason why lodging guests

should be allowed to drive to their lodgings, however. Most of these

people will be staying for one, two, or three nights and taking their meals

in Valley restaurants, and they can easily carry everything they need in a

few pieces of luggage. Their cars will be useless to them while they are

in the Valley anyway, so there is no reason that their cars could not be

parked at regional transportation stations out of the Valley or at Taft Toe.

 

The resource benefits of this course of action would be

substantial. The Valley presently accommodates 860 overnight lodging

units. VIP at 18. Assuming that at least one overnight parking space is

allocated for each of these 860 units, then approximately 860 parking

spaces and their access drives could be removed from the East Valley,

resulting in the elimination of 8-10 acres of asphalt. Some overnight

lodging parking may have to be retained for off-season lodgers or off-hour

arrivals. Nevertheless, the restriction on auto use should be extended to

overnight lodgers to the maximum extend feasible.

 

 

VIII.MORE ASPHALT SHOULD BE REMOVED FROM THE EASTERN END OF THE VALLEY.

 

None of the transportation maps in the VIP show the

existing asphalt road to Mirror Lake. The Valley Circulation Maps for both

the No Action Alternative and the Proposed Alternative show only a bike

path crossing Tenaya Creek and then a footpath and equestrian trail

continuing to Mirror Lake. While we agree with this trail configuration,

the VIP should also propose the removal and restoration of the asphalt road

to Mirror Lake.

 

In addition, all alternatives show a shuttle loop from

Curry Village to Happy Isles that circles around Upper Pines campground and

crosses the Merced twice before returning to Curry Village. Most of this

loop could be eliminated. The shuttle should run to the NPS stables/old

Curry dump, turn around and go to Lamon Orchard, and then turn around and

return to Curry Village. In this way, the remainder of this loop,

including the section of road between the stables/dump and Happy Isles, as

well as the section east of the Merced, including the Happy Isles bridge,

could be removed and this section of roadway restored. Hikers would only

have to walk a few more minutes to get to Happy Isles or Mirror Lake, and

campers in Upper Pines would suffer only minor inconvenience in getting to

the shuttle. The remainder of the shuttle loop east of the Merced River

seems to serve little purpose and could easily be eliminated. This would

also free up more space for new campsites.

 

The Access Fund appreciates this opportunity to contribute

to the development of the VIP and the planning process for Yosemite Valley.

Please do not hesitate to call me with any questions regarding these

comments on the VIP.

 

 

Yours very truly,

 

 

 

Paul Minault

Regional Coordinator

 

 

Armando Menocal

amenocal@earthlink.net

(307) 734-6034 (ph/fax)

Box 414

Wilson, WY 83014-0414