| Table of Contents | Introduction |
| Chapter 1 | Chapter 2 | Chapter 3 | Chapter 4 | Chapter 5 | Chapter 6 | Chapter 7 | Chapter 8 | Chapter 9 |

Agencies have a responsibility, under the National Environmental Policy Act (NEPA), to first "assess and consider comments both individually and collectively" and then to "respond…, stating its response in the final statement." The content analysis process used by the U.S. Forest Service Content Analysis Enterprise Team (CAET) documented here and in their report, Summary of Public Comment: Yosemite Valley Plan Draft Supplemental Environmental Impact Statement (USFS 2000c), considers all comments received "individually and collectively" and equally, not weighting them by the number received or by organizational affiliation or other status of the respondent. However, beside the public concern statements developed by the Comment Analysis Enterprise Team, comment letters are considered in several different ways by park staff.

Public concern statements and supporting quotes form the basic summary of public comment and are the primary focus of park management when considering public comment collectively. These statements are formulated by reading each individual letter, coding each identifiably different concern in each letter to a topical database, and then using that database to identify the range of public concerns in the whole body of public comments. This process treats all comments equally.

Demographic information gathered from responses is another way of looking at comment letters collectively, allowing park planners to obtain a picture of certain general aspects of the responding public, like the geographic distribution of commenters, their affiliation with a government agency or private organization, and how different members of the public chose to offer their comments (e.g., by letter, fax, email, public testimony, etc.).

Finally, park managers and planners are informed by the Comment Analysis Enterprise Team of all letters from government agencies and American Indian Tribes, from nongovernmental organizations (NGOs), and of particularly informative and well-written letters from individuals. The National Environmental Protection Act mandates that managers consider (and print in the final document) all letters received from the first two types of commenters (see Volume IB, Chapter 5, Consultation and Coordination, for copies of these letters). On the other hand, nongovernmental organizations typically represent a number of people, often with pertinent perspectives on one or more aspects of planning for Yosemite National Park and their letters are of interest to managers in making decisions.

Public concern statements coded by subject and demographic information may be used in combination by park planners and managers to seek a clearer picture of certain issues, such as what range of issues particular groups are commenting on or, conversely, what different groups are commenting on a particular issue, such as camping. All of these methods together are used to ensure that the National Park Service assesses and considers public comments "both individually and collectively."

The National Environmental Protection Act requires that after the National Park Service considers comments, they respond to those comments. However, the type of response depends on the type of concern identified.

Comments, or the concerns identified from them, are typically classified as those that fall within the scope of decision making for the plan in question and those that fall outside that scope for any number of reasons. Counsel on Environmental Quality regulations define "scope" and require the National Park Service to explain why comments are determined to be out of scope. Generally, the scope of a plan is the range of connected, cumulative, or similar actions, the alternatives and mitigation measures, and the direct, indirect, and cumulative impacts to be considered in the environmental impact statement.

If a concern was considered out of scope, the explanation of why is provided by the staff response to it in Chapter 2, 3, 4, or 5. Generally, the types of comments received, and concerns identified, that are considered out of scope include those that:

• Do not address the purpose, need, or goals of the Yosemite Valley Plan (e.g., propose an action in areas of the park beyond Yosemite Valley or that are not directly related to an action proposed in the plan, or relate to day-to-day operational issues such as law enforcement procedures or road maintenance)
• Address issues or concerns that are already decided by law or national policy
• Suggest an action not appropriate for the current level of planning (e.g., architectural character of a building, which is a design level consideration)
• Propose untenable restrictions on management of the park or conflict with approved plans not being revised by the Yosemite Valley Plan
• Did not consider reasonable and foreseeable negative consequences
• Point to only minor editorial corrections

Comments within the scope of the plan are typically classed as either substantive or nonsubstantive. As defined in the National Park Service’s NEPA guidance (Director’s Order #12) and based on Council of Environmental Quality regulations, a substantive comment is one that:

• Questions, with reasonable basis, the accuracy of the information in the environmental impact statement
• Questions, with reasonable basis, the adequacy of environmental analysis
• Presents reasonable alternatives other than those presented in the environmental impact statement
• Causes changes or revisions in the proposal

Nonsubstantive comments include those that simply state a position in favor of or against the proposed alternative, merely agree or disagree with National Park Service policy, or otherwise express an unsupported personal preference or opinion. Although a commenter’s personal opinions on a subject may influence the development of the final plan, they generally would not affect the impact analysis.

The agency is required to respond only to substantive comments. However, to fully inform the public, Yosemite management has asked planning staff to respond to all public concerns identified during content analysis, within and out of scope, substantive and nonsubstantive alike. Responses to out of scope concerns are typically restricted to describing why it is out of scope and does not merit further consideration, although a more elaborate answer may be provided. Responses to substantive concerns are typically more extensive and complete and, more importantly, often result in changes to the text of the final environmental impact statement, for purposes of clarification, if nothing else. Reference to the part(s) of the final document influenced by a concern may constitute or supplement the response. If several concerns are very similar, they may be grouped, with a single answer for the group.

Screening Public Concerns — Identifying Planning Issues

Overview

For the Draft Yosemite Valley Plan/Supplemental Environmental Impact Statement (Draft Yosemite Valley Plan/SEIS), an extensive process of screening public concerns and identifying planning issues was undertaken. This process involved methodically: 1) categorizing the public concern statements and supporting quotes received in regular updates from the U.S. Forest Service Content Analysis Enterprise Team; 2) sorting them based on whether they needed to be reviewed by management or could be sent directly to staff for a response; 3) identifying issues raised by the concerns; then 4) organizing and tracking those concerns, based on the sorting criteria, through regular reports to the Yosemite staff responding to comments and the park management review team. This process, described in detail below, was used to effectively manage and respond to the 693 public concerns derived from the 10,240 public comments received on the Draft Yosemite Valley Plan/SEIS, and the 178 public concerns related to Yosemite Valley planning derived from the analysis of public comment on the Draft Merced Wild and Scenic River Comprehensive Management Plan/Environmental Impact Statement (Draft Merced River Plan/EIS) so as to ensure that the Final Yosemite Valley Plan/SEIS addressed the full scope of public comment.

Groups Working on the Process of Screening and Responding to Public Comments

U.S. Forest Service Content Analysis Enterprise Team (CAET)–Based in Missoula, Montana, the CAET was responsible for coding and analyzing all public comment on the Draft Yosemite Valley Plan/SEIS. All comments were received by Yosemite National Park staff, logged, copied, and then forwarded to the Comment Analysis Enterprise Team. Responses were in the form of letters, email, faxes, comment forms, and statements recorded at public hearings. Between the beginning of May and July 24, 2000, the Comment Analysis Enterprise Team regularly produced and delivered three comment analysis products to Yosemite for use by the National Park Service and consultant staff: 1) Immediate Attention Reports (weekly); 2) Information Request Reports (weekly); and 3) the Public Concern Database (weekly until July 5, 2000, then daily through July 12, 2000, then weekly through July 24, 2000). As described in Chapter 8 of this volume, Yosemite planning staff worked in Missoula assisting the Comment Analysis Enterprise Team with comment analysis between June 26 and July 21, 2000. Additional comments were read and analyzed the week of August 21, 2000 (see Volume Ib, Chapter 5, Consultation and Coordination).

Concern Screening Coordinating Group–This group included Yosemite National Park planning staff and the park’s primary consultant assisting with preparation of the Draft and Final Yosemite Valley Plan/SEIS. This team was responsible for categorizing and sorting concerns based on the type of response needed, whether or not they could be sent to the Comment Response Team (see below) without further delay or raised a planning issue they identified as needing to be reviewed by the Management Team (see below).

Comment Response Team–Yosemite National Park and consultant subject matter experts worked in this group and were responsible for writing the responses to all public concern statements.

Management Team–This group included the Yosemite National Park Superintendent, Deputy Superintendent, Division Chiefs, the Western Regional Director, a Department of Interior solicitor, a representative from the Secretary of the Interior’s office, and primary project managers for the Draft and Final Yosemite Valley Plan/SEIS. They were responsible for investigating, discussing, and making decisions about issues raised during public involvement and agency consultation that might require a change in plan direction or significant further analysis while preparing the Final Yosemite Valley Plan/SEIS.

Final Yosemite Valley Plan/SEIS Production Team–This group included National Park Service and consultant staff responsible for taking finished staff responses and text edits and incorporating them into the Final Yosemite Valley Plan/SEIS.

Public Comment Processing

Receipt of Comments–Yosemite National Park staff received all comments, including letters, email, faxes, and comment forms. Each was stamped with a received date, given a unique number, and pertinent data entered into a log. Copies were made and the original was forwarded to the Comment Analysis Enterprise Team for analysis. One set of copies was kept for use at Yosemite and one set sent to park contractors for processing information requests. Comments received at open houses and transcripts of public hearing testimony were numbered, logged, and copied by Yosemite staff and mailed immediately after each public meeting, directly to the Comment Analysis Enterprise Team and park contractors.

Coding Comments–The Comment Analysis Enterprise Team received letters from Yosemite and read and coded them according to the categories listed on their coding structure. They entered this information into a master database. From this database, three separate databases were created for the following items: Public Concern Statements, Immediate Attention Items, and Information Requests. The screening and tracking process for Immediate Attention Items, Information Requests, and Public Concern Statements each followed a different process, described below. For a more complete description of the CAET content analysis process, see Chapter 8 of this volume.

Responding to Information Requests and Immediate Attention Letters–The Comment Analysis Enterprise Team sent weekly reports to Yosemite and park contractors identifying letters with a request that seemed to require a response from Yosemite. Park contractors screened these "Information Request Reports" to determine if, from the perspective of the National Environmental Policy Act, a response was actually needed, and if so, what type of response. This information was then passed on to Yosemite staff for an appropriate response. Most of these requests were for copies of the Draft Yosemite Valley Plan/SEIS or to be added or removed from the park’s planning mailing list. A few required a more elaborate response.

Using criteria supplied by the National Park Service, the Comment Analysis Enterprise Team identified, in weekly "Immediate Attention Reports," letters needing to be seen quickly by park staff. Using these reports, letters falling in this category were pulled from the reference file, copied, placed in binders by type, and presented to the management team for review and reference. The types of letters identified in the Immediate Attention Report include:

• A notice of appeal or litigation, or a threat of harm
• A Freedom of Information Act request
• A proposal for a new alternative
• An excellent review of an issue, or one that was particularly informative and well written
• From a government entity (federal, tribal, state, county, city elected official or agency)
• Requests for an extension of the public comment period
• Comments on the compliance and or compatibility between the Draft Merced River Plan/EIS and the Draft Yosemite Valley Plan/SEIS
• Complaints or concerns about the cost, size, or receipt of the Draft Yosemite Valley Plan/SEIS
• From a nongovernmental organization (defined broadly)

Public Concern Statement Screening–Using the criteria described below for each of the four screening levels (screens #1, #2/3, #4 and #6), concerns were classified to direct them to the appropriate team for response or deliberation. Information regarding the classification and assignment of each concern was entered into a database for tracking.

Screen #1 identified concerns that were out of the scope of the Draft Yosemite Valley Plan/SEIS planning process, or were nonsubstantive, and therefore did not warrant further consideration. These concerns were then sent to the Comment Response Team without further delay for a simple response. Any concern for which an affirmative answer could be given to one of the following questions falls in this category:

• Is the concern outside the scope of the proposed action?
• Is the concern already decided by law or policy?
• Is this the wrong planning level for a decision on this concern?
• Would acting on the concern place untenable restrictions on management, conflict with approved plans, or entail reasonable and foreseeable negative consequences?
• Is the concern a simple editorial correction?
• Is the concern an unsupported personal opinion? (A nonsubstantive concern)

Concerns not matching any of the above criteria are within the scope of the Draft Yosemite Valley Plan/SEIS, possibly substantive, and were passed on to screen #2/3.

Screen #2/3 again determined, in part, if the concern and supporting quotes could go to the Comment Response Team without further delay. These concerns required simple technical or textual edits, or demanded more complex responses and extensive clarification, meaning larger sections of the plan needed to be rewritten. However, changes stemming from these concerns would not require a change in plan direction. Screen #6 was applied at this stage of the screening process, meaning that if a screen #2/3 concern related to one or more of the topical issues areas needing review by management, it was identified in the database as also needing to be directed to the management team, to provide context for their consideration of the screen #4 concerns in that related issue area (see Issue Development, below).

Responding to concerns that did not fall out at Screen #2/3 required a possible change in plan direction or significant further analysis, and hence a decision by the Management Team. Such concerns were passed through Screen #4, Issue Development.

Issue Development–Screen #4 involved the evaluation of those concerns raising an issue that implied a change in plan direction. Although there were hundreds of concerns, it was soon clear that such concerns fell into a relatively small number of topical issue areas, many related to each other. Eventually, thirty-three topical issue areas were identified. As concern screening proceeded, each concern reaching this level was assigned to one or more of the topical issues areas. Most were assigned to several. Then, using the database of screened concerns, briefing reports were prepared for the Management Team for each topical area, consisting of all concern statements and their supporting quotes falling into that topical issue area. Also, as noted above, many of the Screen #2/3 concerns being passed directly to the Comment Response Team had some bearing on one or more of the topical areas, even though they could be responded to without causing a change in plan direction. These latter concerns were given a unique identifier (screen #6) in the concern database that caused them to be included as information items in the Issue Briefing Reports sent to the Management Team.

Concerns forwarded to the Comment Response Team for which they felt unable to prepare responses were returned to the Coordinating Group for further clarification and, if necessary, forwarded to the Management Team for review.

Comment Response–As they received the public concern statements that did not raise issues needing management review, the Comment Response Team began to identify the changes needing to be made to the text of the Draft Yosemite Valley Plan/SEIS and the location of these changes. They also began writing the responses that accompany each concern in this volume. After deliberation, the Management Team forwarded the concerns that generated issues, along with their decisions and planning directions, to the Comment Response Team and other technical staff for further analysis, revision of planned actions, reordering or rewriting the draft’s alternatives, and writing specific responses for each concern statement. Summarizing briefly, there were five general types of National Park Service responses to public concerns:

• Simple text revisions and technical edits of the Draft Yosemite Valley Plan/SEIS for the Final Yosemite Valley Plan/SEIS
• Complex or extensive revision of text to more clearly explain goals, proposed actions, or environmental impacts analysis
• Revision of the plan’s alternatives or impact analysis based on new ideas, information, or analysis
• The brief explanation, included in this volume, of how and why the National Park Service dealt with each public concern that was identified
• Responses to requests for documents or information compiled in the weekly Information Request Reports

Screening Schedule–Concern screening began in May 2000, around the middle of the comment period, as concern reports began to be received from the Comment Analysis Enterprise Team in Missoula. During the last week of the comment period, comment letters were being shipped daily by airfreight to Missoula. Conversely, concern reports were received electronically by the planning team each afternoon, screened, and topical concern reports prepared daily. This daily schedule continued through the end of the week after the close of the public comment period, and then was repeated on July 17 and 24 for the last two concern report updates from the Comment Analysis Enterprise Team. Further details on the use by management of the topical concern reports is outlined in the section Management Deliberation on Issues, below.

Diagram III.1.1 is a graphic depiction of the process used to identify and screen public concerns, and to identify issues for management deliberation and staff response.

Diagram III.1.1
(click on thumbnail to see a larger view)

Issues Identified from Public Concerns

The process of screening public concerns identified many that required decisions by park management about possible changes to the Preferred Alternative before staff could prepare responses. Such concern statements fell into thirty-three topical issue areas. Those concern statements and their supporting quotes, the input from consultation between park staff, government agencies, and Native American Tribes, and results from several additional impacts analyses were used by management in their deliberations while shaping the Preferred Alternative in the Final Yosemite Valley Plan/SEIS (see Volume 1A, Chapter 2, Introduction). The thirty-three topical issue areas considered were:

Each of the thirty-three issue areas is described briefly below. For a more complete understanding of each issue, refer to the concern statements, supporting quotes, and staff responses in the appropriate topical areas of Chapter 2, 3, 4, and 5 of this volume.

Air quality–Included here are concerns about the effects on air quality of various proposals, especially the use of diesel buses and moving employee housing out of Yosemite Valley, moving toward use of clean, alternative fuels or transportation modes, and the effect of diminished air quality on vegetation, wildlife, and humans.

Alternative 2–Comments specifically supporting or rejecting the Preferred Alternative as a whole or weighing in–positive, negative, or suggesting specific changes–on its various elements.

Balance–Concerns about the balance or lack of balance of the Preferred Alternative relative to such issues as resource protection and visitor experience, restoration and development, often with reference to timing (i.e., priority), cost, or the number of people believed to benefit from a proposed action.

Bridges–The proposed removal of four historic bridges in Yosemite Valley generated many comments, both pro and con, often with suggested alternatives to mitigate impacts.

Camping–Included here are comments about the number, location, and type of campgrounds, campground facilities, the role camping plays in the visitor’s experience, and camping as an affordable form of overnight lodging.

Circulation–Comments about the circulation patterns, existing or desired, of vehicle roadways in Yosemite Valley and how proposed construction or closure of roads, parking lots, and bridges affect them.

Compliance–If someone questioned, directly or indirectly, the adequacy of the plan’s impact analysis, range of alternatives, or some other aspect of its compliance with the National Environmental Policy Act or other relevant legislation, that concern was placed into this issue category.

Congestion–Concerns focusing on the perceived level of traffic congestion, or lack of congestion, in Yosemite Valley, its effect on visitor experience, how proposed actions would affect it, and suggestions about alternative actions to address it.

Cost-Benefit–Comments about the cost-benefit ratio from the perspective of the commenter, or specifically asking that a cost-benefit analysis be done for the different alternatives or a particular proposed action.

Development–The level of development in Yosemite Valley was the focus of many comments; there were calls for both more and less development, and a wide variety of sentiments were expressed about the appropriateness of the type, location, density, and design of existing and proposed development, its effects on natural and cultural resources and visitor experience, and how the development of Yosemite Valley relates to the mission of the National Park Service.

El Portal–Comments about existing conditions and proposed actions in the El Portal administrative site, their effects on the natural environment or community character, and suggestions to locate functions and infrastructure proposed to be removed from Yosemite Valley in, or somewhere besides, El Portal.

Equity–Two areas of concern were related to equity: 1) the affordability of overnight accommodations (camping and lodge, including Housekeeping Camp) and of a visit to Yosemite for all income groups; and 2) the accessibility of Yosemite Valley, its services and facilities, to all people, not any particular group or class of people.

Foresta– Comments about existing conditions and proposed actions in Foresta, their effects on the natural environment or community character, and suggestions to locate functions and infrastructure proposed to be removed from Yosemite Valley in, or somewhere besides, Foresta.

Health and Safety–This issue includes concerns about the positive or negative effects of existing conditions or proposed actions on human health and safety, including property.

Historic–Comments on the historic and cultural value of structures (apart from historic bridges), sites, districts, and landscapes in Yosemite Valley, their need for protection, and how proposed actions would protect or degrade their historic value.

Housing–Employee housing, as distinct from guest lodging, generated comments about the type and number of units to be provided in different locations in Yosemite Valley, other areas of Yosemite National Park (i.e., Wawona and Foresta), the El Portal Administrative Site, and surrounding communities outside the park.

Lodging–Comments were received on many aspects of guest lodging, including type, cost, and the mix of units of different type and cost, its location and the overall characteristic or experience provided by the lodging in that area, the appropriateness of these various factors based on whether the lodging is inside and outside of Yosemite Valley, and how these different factors influence the effect of lodging on natural and cultural resources and visitor experience.

Merced River Plan–Concerns on this issue were about the ability of the National Park Service and the public to evaluate the potential environmental impacts of the Draft Yosemite Valley Plan/SEIS without a completed Merced Wild and Scenic River Comprehensive Management Plan (Merced River Plan), the relationship of certain actions, proposed or absent, to the Merced River Plan, and included requests to stop work on the Draft Yosemite Valley Plan/SIES until the Merced River Plan was completed.

No Action–Comments about approving or disapproving the No Action alternative or opting for the status quo with respect to a proposed action or alternative element.

Noise–Gathered here were concerns about the noise generated by vehicles and activities and how proposed or suggested alternative actions might influence noise level and thus affect visitor experience or wildlife.

Other Alternatives–Comments, pro and con, about the action alternatives other than the Preferred Alternative (i.e., Alternatives 3, 4, and 5), in whole or in part.

Park/Community–Concerns important to some commenters, especially residents of Yosemite Valley, Wawona, Foresta, and El Portal, included the need for various community services and facilities and their relationship to community character and quality of life.

Park/County–Falling in this category are comments about proposed actions, or that suggest alternative actions, that would trigger or affect the relationship(s) between Yosemite National Park and one or more of its government agency (federal, state, or county) neighbors.

Parking–Any of the numerous concerns relating to the size, type, or location of parking and its suitability in a variety of locations in Yosemite Valley, outside the Valley, but inside Yosemite National Park, or outside the park, and how that parking would affect natural and cultural resources, visitor experience, and whether it supported the goals of the Draft Yosemite Valley Plan/SEIS).

Regional transportation–Comments in this area were about Yosemite Area Regional Transportation System, other nonpark supported public transportation services, including rail, commercial tour buses, and their impacts on natural and cultural resources and visitor experience.

Shuttle Buses–Comments about the buses that would transport park visitors between Yosemite Valley and out-of-Valley parking lots, and around the Valley, the kinds of facilities they should be equipped with, and how the operation of these buses might affect natural and cultural resources and visitor experience. Does not include comments on tour or regional transportation buses.

Special Populations–Comments about the needs of or the effects of proposed actions on people that are mobility-, sight-, or hearing-impaired, the elderly, ethnic minorities, families with young children, and other groups that may have special needs.

Stock use–Concerns in this category refer to commercial horseback rides, private stock use and facilities to support it, including trails, and their effects on natural and cultural resources and visitor experience.

Timing/Phasing–This issue includes comments about implementing the Yosemite Valley Plan, including prioritizing, funding, and scheduling actions; the need to identify which actions would require further compliance and public involvement; comments that suggest the need to take some action that is not proposed before implementing proposed actions, and comments that request an extension of the public comment period or the date for release of the Final Yosemite Valley Plan/SEIS or Record of Decision.

Utilities–Water, sewer, electrical service and facilities; concerns about the condition and impacts of existing utilities, the effect of proposed actions on utilities, especially on capacities, and the effects of utilities, existing or proposed, on natural and cultural resources and visitor experience.

Visitor Experience–While concerns frequently identified effects on visitor experience from proposed actions affecting camping, lodging, picnic areas, trails, and transportation modes, as might be expected, commenters also made a connection between visitor experience and proposed actions influencing virtually every other issue area, including air quality, congestion, development, health and safety, historic resources, especially bridges, noise levels, stock use, visitor services, and visitor use.

Visitor Services–Comments on services other than camping, lodging, and transportation, such as retail and food service, the ice rink, swimming pools, commercial trail rides and rafting, and other recreation services, automotive services (including gasoline), and orientation and interpretive services.

Visitor Use–This issue area dealt with concerns about limiting access to Yosemite Valley or Yosemite National Park, including comments about specifically limiting vehicles or people, along with general references to carrying capacity and reservations systems.

Management Deliberation on Issues

The vast majority of comments on the Draft Yosemite Valley Plan/SEIS were received the week ending July 7. The management team began to discuss and deliberate on concerns and issues raised in the public comment period in a weeklong facilitated workshop the week of July 10, 2000. During this workshop, public concern and issue reports were provided to management daily. This process of review, analysis, and discussion, while largely complete by early August, continued through to the beginning of September before all issues were resolved to the satisfaction of the Management Team and the final document turned over to the National Park Service consultant to prepare for printing.

Management deliberation included all aspects of the plan and all issues raised by public concerns. It also included input from consultation between park staff, government agencies, and Native American tribes. In many cases, staff was asked to undertake additional analysis to support these management discussions. There were a number of important changes made to the Preferred and other action alternatives presented in the Draft Yosemite Valley Plan/SEIS in preparing the Final Yosemite Valley Plan/SEIS. These changes are discussed at the beginning of Volume Ia, Chapter 2.

| Table of Contents | Introduction |
| Chapter 1 | Chapter 2 | Chapter 3 | Chapter 4 | Chapter 5 | Chapter 6 | Chapter 7 | Chapter 8 | Chapter 9 |

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