Response to High Sierra Hikers Association Urgent Action Alert
High Sierra Hikers Association:
The National Park Service has received a copy of your Urgent Action Alert regarding the proposed Vogelsang Backcountry Utilities Improvement project. We appreciate your effort to engage a clearly interested and invested group of stakeholders, and welcome your participation in the process. In the spirit of dialog, and to provide you with a more firm foundation from which to weigh the project’s merits, we would like to correct some inaccuracies we found in the information provided to your members regarding the project’s scope and the history of infrastructure at the camp. To aid in this dialog, we would like to invite representatives from your organization to participate in a meeting or conference call to discuss the issues. If it can be arranged, such a conversation prior to closing of public comment on February 15, 2008 would provide you with the opportunity to submit comments with the benefit of any greater understanding that might come out of such a meeting; if this is not possible, we are happy to talk with you at a later time.
The purpose for the Vogelsang Backcountry Utility Improvement project is to address public health and safety issues and utility deficiencies at the Vogelsang High Sierra Camp and Backpacker’s Camp. The deficiencies exist for a variety of reasons, including new state and federal regulatory requirements and age and deterioration of existing facilities.
Operation and maintenance of the utility systems that serve Vogelsang High Sierra Camp and the adjacent Backpacker’s Camp have proven challenging. These facilities are subject to many increasingly stringent public health, water quality, and safety regulations. Compliance with these regulations is complicated by the remoteness of the facilities and designation of the High Sierra Camp as a potential wilderness addition. Projects must be in compliance with the regulations and policies established to protect Wilderness values including meeting the minimum requirements for the administration of the area.
The primary objectives of this project are to address public health and safety issues in order to meet state and federal regulatory standards for public drinking water supplies and wastewater treatment while protecting and enhancing wilderness character. So as not to preclude any future decisions regarding camp status, the park’s interdisciplinary team will be considering reversible solutions, such as relining the existing storage tank or replacing the existing tank with a metal tank that could be removed easily. The park will not consider adding services to the camp and will look at options that would result in minimal, if any, expansion of the existing footprint. The park will also consider removing non-functioning structures such as the septic tank that was built in 1963. The overall goal is to improve conditions, including water quality, within the potential wilderness addition.
The Action Alert states that there are "no water or wastewater treatment plants" at Vogelsang and that the National Park Service is proposing construction of "a massive new sewage treatment facility." There have been wastewater facilities at Vogelsang since the camp’s inception in 1923. Originally the wastewater facilities at Vogelsang consisted of pit toilets. These were replaced by flush toilets with cesspools. In 1963, a septic tank and leach field system were constructed. In the late 1960’s this leachfield failed and an oxidation pond was constructed to process the gray water from the camp. In the early 1970’s four "Jet Johns" were flown in by helicopter. In 1987, the wastewater system was upgraded to include a new septic tank, dosing tank, and mound leachfield. Wastewater from the kitchen, staff showers, and guest hand washing stations is discharged to the septic tank and mounded leachfield system while human body waste is treated by the four Phoenix composting toilets completed in 1993. Thus there is a long history of water and wastewater treatment at Vogelsang, and as noted above, the National Park Service is proposing to rehabilitate the existing facilities at the camp.
For more than 20 years, the concessioner has been under strict water conservation requirements, in part to reduce the amount of wastewater requiring treatment. The camp is allowed to use up to 700 gallons of water per day and averages between 250 to 500 gallons per day. Water usage has been limited by reducing services at the camp including elimination of guest showers and switching to paper plates.
The Action Alert also states that the vast majority of stock use in Yosemite backcountry is to maintain and supply the High Sierra Camps. In 2001, the National Park Service did a detailed analysis of stock use. While actual use numbers vary with the length of season, which is dependent on snowpack, the percentages should be fairly consistent from year to year. This analysis showed that stocking the High Sierra Camps constituted only 12% of stock days and 9% of stock nights for 2001. This does not constitute a majority of stock use in the park’s wilderness.
Public Water Supply
The Action Alert states that "the underground spring that has been the camp’s water supply since it opened in 1923 apparently has been threatened by the camp itself, and the water will now have to be filtered and disinfected." From the time the camp was established, water has been supplied by a spring. Use of the original spring was discontinued in the 1960’s due to its susceptibility to wildlife-related contamination in surface water runoff; the camp was not the contamination source. Additionally, the spring dried out on a number of occasions and was not considered a dependable water source. A new spring source was developed at the base of Fletcher Peak in 1963. This development included the construction of a 2000 gallon concrete storage tank. This system served the camp adequately, only requiring the replacement of supply lines, until 2000 when the storage tank began to leak.
The spring is located approximately 1400 feet up-gradient from the camp and does not receive runoff from the camp. For regulatory purposes, this public water supply is considered ground water by the California Department of Health Services. Filtration is not required for ground water unless it is found to be under direct influence of surface water. For example, large rain events could result in surface water entering the infiltration gallery. No impermeable barrier was installed over the infiltration gallery to prevent stormwater from infiltrating the spring. The National Park Service monitors the spring daily for turbidity and monitors for coliform bacteria contamination monthly to determine if surface water contamination is an issue. Rain events are noted and, thus far, no surface water influence has been detected. NPS continues to conduct monitoring. If, in the future, it is determined that the spring is under direct influence of surface water, CDHS would require installation of a filtration system or construction of an impermeable barrier around the water intake gallery. It is also possible that future regulations could result in the need to add filtration. Hence, the camp is not adversely impacting the water supply; rather additional treatment of the public water supply is the result of increasing federal and state regulatory requirements.
California Wilderness Act
Vogelsang High Sierra Camp was designated as an enclave of potential wilderness addition (PWA) by the California Wilderness Act of 1984. Sec. 108 of the Act states that "lands designated as PWA shall be managed by the Secretary insofar as practicable as wilderness until such time as said lands are designated wilderness." Therefore, any proposed actions at this camp must be in compliance with the regulations and policies established to protect Wilderness values and must meet minimum requirements for the administration of the area.
The 1980 Yosemite National Park General Management Plan (GMP)
An Environmental Assessment (EA), tiered to the GMP’s Environmental Impact Statement (EIS), is being conducted in conjunction with this project. Section 102(2)(E) of the National Environmental Policy Act requires an agency to "study, develop, and describe appropriate alternatives to recommended course of action in any proposal which involves unresolved conflicts concerning alternatives uses of available resources." The EA will also provide the necessary analysis to determine the level of impacts for each of the alternatives.
The GMP’s EIS included an analysis of the impacts of continued operations of the camps within the proposed potential wilderness additions. While the HSC were proposed for reclassification as PWA, the GMP provided for their continued use stating that "the High Sierra Camps will be reclassified as potential additions to wilderness. They will continue to be available for public use; if, however, they are eliminated, the areas proposed for potential wilderness additions will be managed as wilderness." The GMP noted that "The concession-operated HSC offer opportunities for people who desire a different kind of backcountry experience. These camps will continue to be used. If, however, the camps are eliminated in the future, the areas will be managed as wilderness." (GMP page 77)
The GMP also addressed management of PWA, stating that "The National Park Service has recommended to Congress that certain lands be reclassified as wilderness or potential wilderness additions, changing the management policies for the areas. Potential wilderness classifications will prevent any further development of facilities or services; should existing developments be removed, there will be no reconstruction of facilities." The proposed improvement to Vogelsang’s utilities would work to improve existing facilities and would not result in additional development of services.
Again, we thank you for your participation, and hope that by trying to better ground the discussion in the facts of the project we can help foster a more rich dialog. As this is the beginning of the planning process we do not yet know what the solutions at Vogelsang will be, but look forward to exploring them with your organization and other interested members of the public. If you would like additional information, or to set up a meeting, please contact me by phone at 209-372-0249 or email at firstname.lastname@example.org.
Management Assistant to the Superintendent
Branch Chief, Public Involvement & Outreach
Yosemite National Park
PO Box 577
Yosemite, CA 95389