Appendix F: Summary of Public Comments and Responses

Introduction

Public Comments and Responses

Results of Draft Review Comments

How To Use This Document

Concerns, Comments, and Responses

Planning Process and Policy

Planning Process

Clarity of Planning Documents

Planning Goals

Criteria for Selection of Planning Goals

Science/Resource-Based Decision-Making

Relationship to Other Planning Efforts

General Management Plan

Yosemite Valley Plan

Implementation Plans and Projects

Lower Yosemite Fall Project

Yosemite Lodge Area Redevelopment Project

Applicable Laws and Regulations

Applicable Laws, Executive Orders, Policies, Guidelines

National Environmental Policy Act and CEQ Regulations

Wild and Scenic Rivers Act

Consultation and Coordination

Public Involvement

Written Comments

Public Meetings

Alternatives

Alternatives - Development Considerations

Range of Alternatives

Alternative 1-- No Action Alternative

Alternative 2--VERP Program with Interim Limits

Alternative 3-- VERP Program with Segment Limits

Alternative 4-- VERP Program with Management Zone Limits

Multiple Alternatives

Other Alternatives

Alternatives Not Considered in the Planning Document

Alternatives Considered but Dismissed

New Alternatives

Cumulative Effects Analysis

Park Resources

Conflicts Between Resources

Ecosystem Processes

Water Resources

Wetlands

Vegetation (not rare, threatened, nor endangered)

Exotic Species

Human/Wildlife Conflicts

Rare, Threatened, and Endangered Species

Air Quality

The Sound Environment

Scenic Resources - Visual Quality

Cultural Resources

Visitor Experience and Resource Protection (VERP)

Special Land Designations

Outstandingly Remarkable Values

Boundaries

Management Zones

Wawona/Section 35

Visitor Experience

Visitor Use Management

Visitor Activities

Carrying Capacity

Access

Limiting Access

Reservation System

Special Populations Access

Environmental Justice

Special User Groups

Recreation

Climbing and Mountaineering

Visitor Services

Site Design and Landscaping

Health and Safety

National Park Service Interpretive Services

Other Services and Facilities

Transportation

Traffic Condition

Traffic Management Operations

Roads, Trails, and Bridges

Parking

In-Park Transportation Services and Facilities

Socio-economic Environment

Concession Services

Employee Housing

Introduction

This Appendix summarizes public comments submitted on the Draft Merced Wild and Scenic River Revised Comprehensive Management Plan and Supplemental Environmental Impact Statement (hereafter referred to as the Revised Merced River Plan /SEIS). The Revised Merced River Plan/SEIS was released for public review on January 14, and the National Park Service accepted comments through March 22, 2005. Written public comments were received at public meetings, by fax, email, and U.S. mail. During the comment period, 147 public comment letters were received. This report provides (1) a summary of public concerns expressed in the public comments received; and (2) a specific response to each identified concern.

Public Comments and Responses

Public comments received during the public comment period were reviewed and analyzed using the park's Comment Analysis and Response Database system. Analysis of public comment letters is comprised of a series of stages which require review by staff and members of the Management Team during review and processing. For example, each letter received is read to determine the discrete points the author is expressing. Each discrete sentence or paragraph is then "coded" in order to associate that "comment" with a particular resource topic or element of the plan (such as air quality or the plan's relationship to other projects).

Once all letters have been coded for individual comments, similar comments are grouped together and a "concern statement" is generated, which is intended to capture the main points of what the comments are addressing. Concern statements are worded in a way that affords the National Park Service the opportunity to respond to a requested action. Concern statements are then screened to determine whether or not further clarification needs to be made in the document or whether they call for a modification of the proposed action. In the case of the later, these types of concerns would be brought to park management for deliberation. Finally, the planning team prepares responses presenting the National Park Service's reasoning as to how and why public concerns will be incorporated into the planning process.

As a direct result of public input, all comments are made available for review on the park's web site. The posting of public comments is a result of requests made during the scoping process for this planning effort, and will continue for future planning efforts. The Comment Analysis and Response Report generated through the comment analysis and response process is included in this appendix.

For further information about how the Final Revised Merced River Plan/SEIS changed between Draft and Final, please see "Summary of How This Document Has Changed In Response to Public Comment" following the Abstract of this document.

Results of Draft Review Comments

As a result of the public comment period, the park received comments from 114 individuals, 25 organizations, 6 government agencies, 2 tribes and 1 university, including public testimony given by individuals at public meetings. A total of over 900 separate comments were received. The analysis of these comments generated about 400 general concern statements, which were categorized and considered for incorporation in the planning process. Some of the main concerns raised during the public comment period and addressed in this Final Merced River Plan/SEIS include the following:

·       The relationship between the General Management Plan and the Merced River Plan in the context of proposed user capacity limits.

·       The process for ensuring that the Yosemite Valley Plan and projects associated with it are reviewed for compliance with this Revised Merced River Plan/SEIS.

·       The relationship between existing elements of Yosemite National Park's User Capacity Management Program, proposed visitor limits, and the Visitor Experience and Resource Protection component.

·       Criteria used for the selection of Visitor Experience and Resource Protection indicators and standards and suggestions for additional indicators and standards.

·       Clarification of what types of management actions would be implemented associated with the Visitor Experience and Resource Protection and what management actions would require further National Environmental Policy Act review and public involvement.

·       Clarification on how visitor use limits would be implemented.

·       Clarification regarding the interim facility limits and how the park would make a determination on maintaining or removing these limits.

·       Concerns from culturally associated American Indian groups relating to continued access within the river corridor for traditional practices, as well as protection and enhancement of important natural and cultural resources within the entire corridor.

·       Concerns from residents in local communities and American Indian groups regarding management zoning prescriptions that allow for placement of administrative facilities within El Portal and Wawona.

·       Specific and general desires relating to management of Yosemite National Park's natural, cultural, physical, and social resources.

·       Concerns regarding the complexity of the document and the user capacity program in particular.

The issues and concerns not addressed in this document include the desire to have the Revised Merced River Plan/SEIS address all elements of the existing Merced River Plan, the desire to have the document address specific projects, such as campgrounds or road realignments, the desire for the National Park Service to commit to a day use reservation system or other specific management actions in this document, and support or opposition of numerous specific activities or park implementation projects. All comments received during the comment period have been duly considered and are now part of the administrative record for this project.

How To Use This Document

This Response to Public Comments summary is divided into sections based upon the topics identified in the Table of Contents.

Each section includes one or more statements of public concern. These public concerns attempt to present common themes identified from comments in a statement that captures what action the public feels the National Park Service should undertake. [Note: Because all public concerns are presented, oftentimes these statements may offer contradictory direction.] Each public concern is, in turn, followed by supporting quotes from public comments referenced to original letters.

Each supporting quote is followed by an attribute which identifies the number assigned to the original letter it came from, whether the comment was made by an individual or an organization, a general description of the organization type, and a reference to the letter number and the comment number within the letter. This information appears as a parenthetical clause in the following format: organization or individual, city and state of letter - relevant planning effort - letter number. For example, "(Individual, Merced, CA - #7-3)" is a letter from an individual in Merced, California, and assigned the letter number 7; the supporting quote is from the third coded comment in the letter.

Finally, each public concern statement, and its supporting quote, is followed by the National Park Service Response.

Concerns, Comments, and Responses

Planning Process and Policy

Concern 135: The Revised Merced River Plan user capacity program should be revised to be conceptually valid and legally sufficient.

"...[National Park Service] alternatives are not conceptually valid or legally sufficient in terms of addressing visitor capacity in the Merced WSR area."

(Individual, Fort Collins, CO, Comment #73-5)

Response: The Final Revised Merced River Plan/SEIS has identified and evaluated a range of reasonable and feasible alternatives to address user capacity in Yosemite National Park based on the VERP framework. The VERP framework is a tool developed by the National Park Service to address user capacities and ensure the protection of natural and cultural resources and the visitor experience (Hoff and Lime 1997). The action alternatives evaluated in this document all adopt quantitative measures considered to be sufficient to ensure the program's effectiveness as a current measure of user capacities, consistent with the requirements of the Wild and Scenic Rivers Act. They are also intended to address the issues outlined in the Ninth Circuit Court of Appeals October 2004 ruling.

Concern 61: The National Park Service should include the issue of day use parking and campground restoration in the Revised Merced River Plan.

"In a letter (August, 2004) responding to the Scoping of the Revised Merced River Plan / EIS (RMRP), the Board of Directors of the Yosemite Sierra Visitors Bureau (YSVB) advised you (NPS) that the scope of this plan should not be so narrowly defined as to exclude the issues of adequate parking for a growing day use visitor experience and restoration of low cost, low impact campgrounds in previously disturbed areas of Yosemite Valley."

(Individual, Oakhurst, CA, Comment #49-1).

Response: The 2004 Court Order directing this revision of the Merced River Plan specifically requires the National Park Service to revise the plan to (1) address user capacity in the river corridor, and (2) reassess the river corridor boundary in the El Portal Segment based on the location of Outstandingly Remarkable Values. This Revised Merced River Plan/SEIS is intended to correct the deficiencies in the original Merced River Plan/FEIS. As such, the capacity of campgrounds in the Merced River corridor has been considered within the alternatives. However, this document along with the original Merced River Plan, are programmatic plans that do not dictate any specific actions. Together, these plans will serve as a working manual for guiding decisions relating to land use and activities in the river corridor. Based on the above, the specific issues raised in this concern are at the wrong planning level for this document.

Concern 276: The National Park Service should accurately state the purpose and need of the Revised Comprehensive Management Plan.

"The purpose and need of the alternatives is inaccurately stated. The D. R. MRP does not tie user capacity to protecting and enhancing Outstandingly Remarkable Values. The premise of the whole plan is flawed and violates WSRA."

(Conservation Organization, Yosemite, CA, Comment #111-59)

Response: The purpose and need for the Revised Merced River Plan/SEIS is clearly articulated in Chapter I of the document. Each of the action alternatives identified and discussed in the document have been developed to specifically address the 2004 Court Order directing the National Park Service to revise the original 2000 Merced River Plan to (1) address user capacity in the river corridor, and (2) reassess the river corridor boundary in the El Portal Segment based on the location of Outstandingly Remarkable Values. In addition, each of the action alternatives evaluated in this document incorporate measurable indicators and standards that will be monitored to ensure that the Merced River's Outstandingly Remarkable Values will be enhanced and protected.

Concern 222: The National Park Service should focus on redeveloping existing infrastructure, or place new development in already developed sites, over developing new sites.

"Human population is increasing, thus leading to inevitable development. However, the key issue is HOW this development takes place. ...I do know that it is not always necessary to build MORE, but rather build SMARTER. By this I mean, rather than dozing for more sites for structures and pavement, affecting the vitality and beauty of the valley, why not remodel the existing infrastructure?"

(Individual, Sonora, CA, Comment #90-1)

"Please ensure that your final plan restricts future development in the El Portal area to already developed sites (ie, Rancheria, Trailer Court, Motor Inns, & "downtown" by the Post Office."). In keeping with our unique "small-town" lifestyle, future development should be small scale, locally-owned, and primarily geared towards the needs of residents."

(Individual, El Portal, CA, Comment #132-5)

"Add housing and administrative units at the trailer court, the sewer plant/warehouse, and by in-filling already impacted available space in Rancheria Flat and the Motor Inns. There may also be a few existing lots in old El Portal that could be made available for long-term employees to build new homes, compatible, of course, with the cultural landscape of the area."

(Individual, El Portal, CA, Comment #132-8)

Response: The Revised Merced River Plan was directed by the court to address the El Portal boundary and a user capacity program. The plan is programmatic and will guide future planning efforts, but does not specify the removal or construction of specific buildings. Potential decisions on redevelopment and locations for new development will be evaluated in future project implementation plans.

Concern 230: The National Park Service should continue to remove facilities out of the Valley.

"This combined with the continued removal of certain facilities out of the Valley would lessen the pressure on the river corridor."

(Conservation Organization, Oakland, CA, Comment #75-3).

Response: The National Park Service's long-term goals as outlined in the General Management Plan include the relocation of non-essential offices and housing from Yosemite Valley. The Revised Merced River Plan, however, is a programmatic plan that will guide future planning efforts, but does not dictate any specific action. The Revised Merced River Plan was directed by the court to address the El Portal boundary and a user capacity program. The plan is programmatic and will guide future planning efforts, but does not specify the removal or construction of specific buildings. Potential decisions on the removal of facilities from Yosemite Valley and locations for new development will be evaluated in future project implementation plans.

Concern 236: The National Park Service should reduce development and emphasis on commercial interests in order to protect the visitor experience and natural resources.

"The amount of people using the river corridor seems to be the center issue. The easiest example of how the river is NOT protected is the rafting that is a major abuse of this fragile stretch of the Merced River (ORV) with actual impact to the river banks, the river bottom (walking rafts thru shallow areas stirring up natural sediments) as hundreds of colorful rafts and people parading by create an absence of the natural beauty and peace that I expect to find at a river in a National Park."

(Individual, El Portal, CA, Comment #72-4)

"[M]ore thought [should be] put into what we really need to have a visitor friendly Yosemite National Park. I would like better alternatives that will address the need to preserve and protect the park without the enhanced commercial aspects."

(Individual, El Portal, CA, Comment #72-8)

"Yosemite is one of the most visually and aesthetically stunning locations in the world--the Merced River one of the most treasured Rivers. Yet this plan reflects that the Park Service does not understand the special values and the special experience to be had. Instead, the Park Service continues to treat the Merced River Plan as a bureaucratic annoyance to get out of the way so it can proceed on the continuing juggernaut of construction, commercialization, and pavement."

(Conservation Organization, Yosemite, CA, Comment #111-6)

Response: The 2004 Court Order directing this revision of the Merced River Plan specifically requires the National Park Service to revise the plan to (1) address user capacity in the river corridor, and (2) reassess the river corridor boundary in the El Portal Segment based on the location of Outstandingly Remarkable Values. This Revised Merced River Plan/SEIS is intended to correct the deficiencies in the original Merced River Plan/FEIS. This document along with the original Merced River Plan, are programmatic plans that do not dictate any specific actions. Together, these plans will serve as a working manual for guiding decisions relating to land use and activities in the river corridor. Based on the above, the specific issues raised in this concern will be evaluated in future implementation plans to the extent applicable.

Concern 238: The National Park Service should chose user capacity management actions which involve less construction.

"Solution which involve less construction are better."

(Individual, Fresno, CA, Comment #78-4)

Response: The actual management action(s) selected would depend on the particular setting and situation encountered and may or may not involve construction activities. The selected management action(s) would be subject to the appropriate level of environmental review and public involvement, as well as going through public involvement processes, such as VERP quarterly updates and annual report. However, the 2004 Court Order directing this revision of the Merced River Plan specifically requires the National Park Service to revise the plan to (1) address user capacity in the river corridor, and (2) reassess the river corridor boundary in the El Portal Segment based on the location of Outstandingly Remarkable Values. This Revised Merced River Plan/SEIS is intended to correct the deficiencies in the original Merced River Plan/FEIS. This document along with the original Merced River Plan, are programmatic plans that do not dictate any specific actions. Together, these plans will serve as a working manual for guiding decisions relating to land use and activities in the river corridor.

Concern 300: The National Park Service should not allow commercial development in El Portal.

"I would not like to see any more commercial development here [in El Portal]. I feel that it would irreparably change the quiet undiscovered nature of El Portal and the river corridor here. We have something so special here; it is like no place in the world in its lack of commercial offerings. I would like to see more protection for El Portal specifically and for the whole River Corridor in general."

(Individual, El Portal, CA, Comment #133-4).

Response: The National Park Service is committed to working with the community in El Portal to determine potential development actions. The National Park Service will work to balance values important to the community while providing for the administrative needs of Yosemite National Park, for which the El Portal Administrative site was established. Paramount in this decision-making process will be protecting and enhancing the outstandingly Remarkable Values of the river. The Revised Merced River Plan is a programmatic plan that will guide future planning efforts, but does not dictate any specific action. The National Park Service was directed by the court to revise the El Portal boundary and to address a user capacity program. The El Portal boundary will guide future planning efforts by designating management zones where development would be allowed to occur within the Wild and Scenic River boundary provided that Outstandingly Remarkable Values are protected. Areas zoned 3C (park operations and administration) indicate areas that allow for development, but this does not necessarily mean all of those areas will actually be developed. More specifically, the plan does not outline specific types of development that will occur in El Portal. Specific decisions on potential commercial development in El Portal will be evaluated in the El Portal Concept Plan. This plan will require an Environmental Impact Statement, which will include public involvement through the public scoping and comment period process.

Concern 304: The National Park Service should move non-essential offices and housing from the Valley to gateway communities, rather than to El Portal, to avoid adverse impacts to Outstandingly Remarkable Values.

"Keep truly essential employee offices and housing in Yosemite Valley, but move the rest to gateway communities that are more appropriate for expansion and development...Cramming more housing, administration, commercial services, and parking lots into this narrow corridor is not compatible with a Wild and Scenic river, and would certainly impact the river's Outstandingly Remarkable Values. The limits on the numbers of employees and residents within the El Portal protection boundary should remain at or near their present levels."

(Individual, El Portal, CA, Comment #132-9)

Response: The National Park Service's long-term goals as outlined in the General Management Plan include the relocation of non-essential offices and housing from Yosemite Valley. The Revised Merced River Plan, however, is a programmatic plan that will guide future planning efforts, but does not dictate any specific action. It is a working manual for guiding decisions relating to land use and activities in the river corridor. More specifically, the Revised Merced River Plan was directed by the court to address the El Portal boundary and a user capacity program. As such, the plan does not specify the removal or construction of specific buildings. Potential decisions on the removal of facilities from Yosemite Valley and the consideration of gateway communities for their relocation will be evaluated in future project implementation plans.

Concern 313: The National Park Service should develop other areas of the park besides the Valley and Wawona.

"Develop other areas besides Valley and Wawona."

(Individual, Saratoga, CA, Comment #122-4)

Response: The Revised Merced River Plan is a programmatic plan that will guide future planning efforts for the Merced River corridor. It does not dictate any specific actions, nor does it guide actions in areas that are distant from the corridor. It is a working manual for guiding decisions relating to land use and activities in the river corridor. More specifically, the Revised Merced River Plan was directed by the court to address the El Portal boundary and a user capacity program. As such, the plan does not specify the removal or construction of specific buildings. Potential decisions on the development of areas outside of Yosemite Valley and Wawona are not assessed in a programmatic plan such as this one. Development considerations will be evaluated in future project implementation plans.

Concern 336: The National Park Service should remove the golf course in Wawona and other unnatural lawns.

"The golf course in Wawona should be removed. Pesticides are used to maintain a golf course. Golf courses are the ultimate boo boo for resource protection. These chemicals (purported to be natural and safe - c'mon folks, get into the water systems. Pesticides and rivers and streams do not go together."

(Individual, Fresno, CA, Comment #128-15)

Response: The 2004 Court Order directing this revision of the Merced River Plan specifically requires the National Park Service to revise the plan to (1) address user capacity in the river corridor, and (2) reassess the river corridor boundary in the El Portal Segment based on the location of Outstandingly Remarkable Values. This Revised Merced River Plan/SEIS is intended to correct the deficiencies in the original Merced River Plan/FEIS. This document along with the original Merced River Plan, are programmatic plans that do not dictate any specific actions. Together, these plans will serve as a working manual for guiding decisions relating to land use and activities in the river corridor. Based on the above, this concern is not within the scope of this document. Potential decisions on the management of the Wawona Golf Course may be evaluated in future project implementation plans.

Concern 353: The National Park Service should focus its efforts on restoration projects which enhance the environment over projects that degrade the environment.

"I was horrified to see the trees cut next to the Yosemite Lodge and at the front of the Upper Pines campground last spring. These projects seem senseless to me, especially when other projects can be implemented that enhance the environment, rather than destroy it."

(Individual, San Francisco, CA, Comment #121-6)

"[I]n the flood plain, restoration of the permanently lost campgrounds there has progressed at a snail's pace. The area has looked like a waste land. Why has the park service not focused on restoring this area to its most natural condition, especially given that this is a great opportunity to have a development-free area that shows off beautiful riparian and meadow habitats that attract a diversity of birds and other wildlife?"

(Individual, San Francisco, CA, Comment #121-7)

Response: The National Park Service is committed to restoration efforts throughout the park. Recent projects include the restoration of Cook's Meadow, the Merced River at Eagle Creek, and the Happy Isles Fen, as well as the removal of Cascades Diversion Dam and the Happy Isles Gauging Station Bridge. Ongoing restoration projects include the removal of exotic species and bank stabilization efforts within the Merced River corridor.

The Revised Merced River Plan is a programmatic plan that has, and will continue to, guide future planning efforts, but it does not dictate any specific action. It is a working manual for guiding decisions relating to land use and activities in the river corridor. More specifically, the Revised Merced River Plan was directed by the court to address the El Portal boundary and a user capacity program. Potential decisions on upcoming restoration projects will be evaluated in future project implementation plans.

Planning Process

Concern 245: The Revised Merced River Plan should disclose that Outstandingly Remarkable Values, such as biologic and hydrologic, are not discrete and are dependent on the larger surrounding ecosystem.

"In addition, it is important to disclose that ORVs, such as biologic and hydrologic, are not discrete. Many are dependent upon the larger surrounding ecosystem and/or species for their health and existence; and therefore need to be protected and managed as such."

(Individual, Comment #93-13).

Response: Although Merced River Plan, as amended by this document, focuses on the river, the National Park Service recognizes that in some instances issues affecting the river's Outstandingly Remarkable Values may not start and stop at the river corridor boundary. In some instances management actions will be designed to address Outstandingly Remarkable Values both inside and outside the corridor. As a result, the VERP program has been designed not only for application in the river corridor but for the park as a whole, since this is eventually how user capacity management program will be applied throughout Yosemite.

Concern 306: The Revised Merced River Plan should clearly address User Capacity to meet the requirements of the Wild and Scenic Rivers Act.

"The DRMRP does not fulfill the court's directive to clearly address User Capacity and thus meet the requirements of the Wild and Scenic Rivers Act."

(Individual, Merced, CA, Comment #117-1)

Response: The action alternatives identified in this Revised Merced River Plan/SEIS have been developed to satisfy the 2004 Court Order requiring the National Park Service to revise the original Merced River Plan to (1) address user capacity in the river corridor, and (2) reassess the river corridor boundary in the El Portal Segment based on the location of Outstandingly Remarkable Values. These alternatives identified and evaluated in this document have been developed as a means to achieve this directive, compliant with the requirements of Wild and Scenic Rivers Act, and relevant National Park Service management policies and procedures.

Clarity of Planning Documents

Concern 7: The Revised Merced River Plan should be revised to improve consistency and clarity.

"After many hours of study and review I have found this document extremely difficult to comprehend. Pertinent data comparing the alternatives are inconsistent, scattered in tables, footnotes and appendices and are almost impossible to decipher. The comparisons may be in there somewhere embedded in a two-inch thick document but I believe they are not presented in a manner suitable for meaningful public review."

(Individual, El Dorado Hills, CA, Comment #27-1)

"Overall, our central belief is that the final plan should provide greater clarity and specificity than what is now provided in the draft plan. No matter how good the intentions of Park management are (and we believe they are good), much of the public that is concerned with this plan is inherently suspicious of Park management and will likely oppose any plan unless it clearly specifies or limits future management actions. The public fears a worst case scenario - a crowded, over-developed Merced River corridor, where Nature takes second place to visitor capacity. Your burden with this plan is to clearly demonstrate how the worst case scenario cannot come true."

(Conservation Organization, Twain Harte, CA, Comment #29-1)

"The Draft Merced River Plan is a mass of contradictions, illogical statements, confusing and inconsistent jargon, and so-called "information" presented in such a way as to defy analysis. The document is internally inconsistent, rendering meaningless any public attempt to comment on content."

(Conservation Organization, Fresno, CA, Comment #30-1)

Response: The Final Revised Merced River Plan/SEIS has been revised to address concerns regarding clarity and consistency. The document has been reorganized to provide a separate background chapter on user capacity and elements common throughout the park's user capacity management program, followed by a chapter presenting the alternatives. The terminology in the document has also been clarified to more simply convey the information. However, it should be noted that this plan addresses a complex issue--user capacity--in a park that is equally complex. In Yosemite National Park, a spectrum of uses occurs in widely diverse areas resulting in varying environments being affected throughout the Merced River corridor.

Additionally, some concerns were raised over the perceived lack of comparability of the alternatives. The Revised Merced River Plan/SEIS proposes different approaches to addressing user capacity. Yosemite's existing user capacity tools and the VERP program are common to all of the action alternatives, yet some of the new proposed limits (and methods) vary among the alternatives. In accordance with the National Environmental Policy Act, the environmental effects of the alternatives are comparable and are analyzed and presented in the document in comparative form. Readers can understand from the environmental consequences discussions in Chapter V the differing effects of each of the alternatives on various aspects of the human environment.

Concern 12: The Revised Merced River Plan should be revised to improve the clarity of the Visitor Experience and Resource Protection component within each Alternative.

"God knows you are really trying to keep us informed and I do thank you for the attempt, but the February 2005 edition trying to explain the alternatives for the VERP whatever is really not helpful. It is crouched in the language of bureaucracy that drives me nuts -- trying to say something and not saying anything. You ask US to be specific in our responses and you feed us this mumbo-jumbo."

(Individual, Comment #3-1)

Response: The Final Revised Merced River Plan/SEIS has been revised to address concerns regarding clarity related to the user capacity component of the alternatives. The draft plan presented a detailed discussion of the user capacity issue within the alternatives chapter. As a result, the alternatives chapter was long, which made this chapter difficult to grasp for some readers. In response to this concern, the Final Revised Merced River Plan/SEIS has separated out the user capacity discussion--including the user capacity elements common to all action alternatives-- into its own stand-alone chapter (Chapter II). Thus, the alternatives are now presented on their own in Chapter III. The terminology in the document has also been clarified to try to more simply convey the information.

Concern 13: The Revised Merced River Plan should include a summary to clearly explain the alternatives and crucial elements of the plan.

"While I appreciate the in-depth effort performed by Yosemite National Park (YNP or NPS hereinafter) to meet the 9th Circuit Court of Appeal's concerns and instructions, it is essential to clearly explain in an Executive Summary those crucial elements that will inform commentator's consideration and opinions.

The key YNP zoning definitions that apply to the Merced River Corridor and that permit the reader to understand and compare the four Alternatives (as they view the maps on pages 85, 91, 97, and 105 of the pdf) are unfortunately absent from the Executive Summary -- and from the entire text and glossary. I finally found the zone definitions in Appendix A - it would have been helpful to state that location very early in the Executive Summary."

(Individual, Berkeley, CA, Comment #4-1)

"[T]he document in its present form requires at least a brief supplemental summary comparing the alternatives in a more easily understandable manner. A clearly stated summary statement comparing alternatives...would insure a more meaningful public review process."

(Individual, El Dorado Hills, CA, Comment #27-2)

"In the future, is there any possibility of providing Plans for Yosemite in 100 pages or less, such as a Summary of the various Alternatives?"

(Individual, Lincoln, CA, Comment #131-2)

Response: The Final Revised Merced River Plan/SEIS has been revised to address concerns regarding the clarity of the document. The Executive Summary in the Final Revised Merced River Plan/SEIS has been rewritten. It now captures a more complete overview of the approach taken in the alternatives, as well as summarizing their crucial elements and differentiations. The user capacity elements of the plan contains many components The Final Revised Merced River Plan/SEIS has been revised to make the text and the tables for the user capacity element more concise and clear. The tables and figures from the alternatives chapter were repeated in the Executive Summary in order to provide greater clarity and detail. The Executive Summary also presents the rationale for selecting the environmentally preferable alternative.

Concern 30: The Revised Merced River Plan should more clearly present the assumptions used for calculating daily use limits.

"As to the 18,241 figure in the 1980 GMP being used as a target, it is my understanding that figure was arrived at by counting sleeping and parking spaces in 1980. The figures for both are substantially lower now than they were then, so the 18,241 is no longer relevant. Logically, the corresponding number would be much smaller now, unless a larger number of day users being brought in by bus were assumed. (The YVP did indeed make that assumption. It is unclear what the MRP is assuming.)"

(Individual, San Francisco, CA, Comment #31-5)

Response: The Final Revised Merced River Plan/SEIS has been revised to more clearly present the assumptions used for calculating daily use limits in the tables in Appendix C. Assumptions presented with regard to interim facility limits, segment limits, and management zone limits are presented in the footnotes of each table in Appendix C. Additionally, clarification of the relationship between the 1980 General Management Plan, existing conditions, and the use limits presented in the Revised Merced River Plan has been clarified in the tables in Chapter III, in Chapter V, and in Appendix C.

Concern 34: The National Park Service should provide consistent information between fact sheets and the Revised Merced River Plan document regarding potential gate closures when use limits are reached.

"I found a fair amount of reference to the possible need to impose "restrictions" and "limits", but scant reference to a day use reservation system. Specifically, the NPS new Fact Sheet which is intended to provide an "overview" of the MRP, issued February, 2005, poses the hypothetical question, "Will the park dose the gates if limits are reached?" It responds to the question by saying, "Turning people away at entrance gates or otherwise closing park entrances is NOT being proposed in the preferred alternative" Yet in Table 11-9 (page 11-52) of the preferred alternative, under "Rationing and Allocation", one "tool" listed is "Limit overall number of users through entrance station quotas" Their appears to be a substantial conflict between the statement in the Fact Sheet and the statement in the MRP."

(Individual, San Francisco, CA, Comment #31-9)

"And one quick example, a fact sheet issued in February 2005, providing an overview of the MRP poses a hypothetical question. "Will the park close the gates if limits are reached?" In response to the question by saying, "Turning people away at entrance gates, or otherwise closing park entrances, is not being proposed in the Preferred Alternative." Yet on table 29, page 252 of the Preferred Alternative, under rationing and allocation, one tool listed is: "Limit overall numbers of users through entrance station quotas."

(Individual, Ahwahnee, CA, Comment #41-2)

"In some cases there are contradictions between the fact sheets and the draft plan. There are several instances when it is very difficult to cross-reference the fact sheets to the draft plan. When there are discrepancies, should people be commenting on the fact sheet or the plan? Also these sheets were discovered on a table during the road show. Since they were not mailed out how are we sure that the people who received copies of the draft plan via mail were even aware that these fact sheets exist?"

(Conservation Organization, Oakland, CA, Comment #69-6)

Response: The National Park Service recognizes this public concern. Fact sheets on park planning projects are provided to briefly highlight and summarize some of a project's major elements. These 1- to 2-page informational hand-outs are intended only to summarize information that is presented in an Environmental Assessment or Environmental Impact Statement. All fact sheets are available to the public at monthly Open Houses and public meetings for park planning projects. The online link for fact sheets is posted prominently on the park's web site at www.nps.gov/yose/planning. The park's electronic newsletter and Planning Update newsletter often highlight where the public can go on the web site to receive additional information. While the fact sheets are intended to summarize key elements of a specific project and highlight planning or project timelines, it is the planning document itself (i.e., the EA or the EIS, for example) that must be the focus of public comment. In the future, the National Park Service will work to more closely articulate plan elements with consistency and accuracy.

Concern 57: The Revised Merced River Plan should use the term "limit" in place of "quota" in the final document.

"We suggest use of the term "limit" in place of "quota." While we acknowledge that one definition of "quota" is "the highest number of people permitted admission," we also feel that a more common use of this term is "a production assignment". We believe that using the term "limit," in place of "quota" throughout the document will be both more clearly understood by the public, and more consistent. Alternative 2 proposes "facility limits." Rather than using a different term for alternative 3 ("segment quotas") and alternative 4 ("management zone quotas"), "limit" should be used throughout ("segment limits" and "management zone limits")."

(Conservation Organization, Twain Harte, CA, Comment #29-10)

Response: The Final Revised Merced River Plan/SEIS has been revised to address this concern. Terminology in the Final Revised Merced River Plan/SEIS has been revised, where possible, to use more common descriptions. The term "limit" has been used in the place of the term "quota," except when referring to the Wilderness Trailhead Quota System, which is an existing program in the Yosemite Wilderness.

Concern 137: The Appendix A for the Revised Merced River Plan should be relocated to the introduction section of Chapter II.

"I recommend you relocate Appendix A to the introduction part of the alternatives section in the main body and then develop and contrast your alternatives around them. This approach would allow you to adequately and clearly focus on specific areas within the WSR, their special Outstandingly Remarkable Values and different uses and variation across the year, and the broader ecological environment which sustains them."

(Individual, Fort Collins, CO, Comment #73-9)

Response: The Final Revised Merced River Plan/SEIS has been revised to address this concern. The information on management zoning prescriptions and the maps detailing the management zones adopted in the 2000 Merced River Plan have been moved up into Chapter II. This information can now be found in Chapter II, User Capacity and the Visitor Experience and Resource Protection Framework.

Concern 138: The Revised Merced River Plan should be revised to display the management objectives for each zone in table II-14.

"Most importantly, I recommend you take your Table II-14 Comparison of Alternatives and list the management zones only for the Merced WSR area down the first column, and then display the alternative user capacities for each geographic unit or even subunits within. By displaying the management objectives for each management zone in this table and the significant Outstandingly Remarkable Values, the public could better track the logic and understand the close relationship between management objectives and user capacities."

(Individual, Fort Collins, CO, Comment #73-10)

Response: The Comparison of Alternative Key Assumptions table was table II-14 in the Draft Revised Merced River Plan/SEIS, and has been changed to table III-11 in the Final Revised Merced River Plan/SEIS. In addition, table II-2 shows the management zone prescriptions, including the objectives for each zone. Because management zone objectives are addressed in table II-2, it was determined to not include the same information in two tables as requested by the commentor.

Concern 140: The Revised Merced River Plan should clarify what is included in references to the Merced Wild & Scenic River area versus inside the park in general.

"It is difficult for the reader to keep track of when you are referring to inside the Merced WSR area versus inside the Park in general (e.g., wilderness trailhead quota). Is the river corridor you often refer to always in the WSR?"

(Individual, Fort Collins, CO, Comment #73-14)

Response: The Final Revised Merced River Plan/SEIS has been revised to address this concern. The National Park Service has revised the document, where appropriate, to provide better clarification between the Merced River corridor and Yosemite National Park as a whole.

Concern 141: The Revised Merced River Plan should remove information that is not direct and significant to the management of the Merced Wild & Scenic River area.

"Relatedly, it does not appear that many items in the Superintendent's Compendium, nor many of the trailheads in the quota system, apply to the WSR area. It may be possible to considerably enhance the clarity of the SEIS and its usability by removing the information that is not truly direct and significant to the management of the Merced WSR area."

(Individual, Fort Collins, CO, Comment #73-15)

Response: User capacity management in Yosemite National Park is comprised of many components, including the Superintendent's Compendium and the Wilderness Trailhead Quota System (though it is noted that not all trailheads listed in table II-1 are within the Merced River corridor). Although all of the information within each of those components may not directly guide management of the Merced River corridor, they do guide decisions within the larger ecosystem in which the Merced Wild and Scenic River is a part. They therefore indirectly play a role in the management of the river. The document has been revised, where possible, to address this concern.

Concern 142: The Revised Merced River Plan should use standardized and defined vocabulary when defining elements of alternatives.

"I find your choice of the phrases to define your alternatives to be curious and misleading: alternative 2 offers "interim facility limits", alternative 3 offers a "fixed user limit", and alternative 4 offers a "fixed maximum use level." These terms are not contrasted or defined in your glossary and can influence the public's understanding."

(Individual, Fort Collins, CO, Comment #73-16)

"Particularly curious to me is the difference between interim and fixed. In all three alternatives there is discussion that monitoring will be undertaken and mitigating management actions implemented. This is appropriate. With new information or circumstances gained from monitoring, I believe all decisions in this SEIS are interim in a literal sense. Thus, your "fixed" alternatives (3 & 4) are no more fixed than your "interim." I think these terms are confusing, do not add anything of substance, and should be dropped, or at least clarified and contrasted in detail in the main text and glossary. Otherwise, I suspect that the public reviewers will be drawn to the illusion that interim is a softer concept and allows more change than fixed."

(Individual, Fort Collins, CO, Comment #73-17)

Response: The Final Revised Merced River Plan/SEIS has been revised to try to more simply convey the information on the various measures include within each user capacity alternative. Additional terms relating to various user capacity components have been defined in the Glossary.

Concern 173: The Revised Merced River Plan should clarify the duration of "interim limits" and clarify when the Revised Merced River Plan is actually completed.

"'COMPLETION' NOT DEFINED. The Revised Merced River Plan is mired in double-speak. The Plan admits that the Park "is in the process of pilot-testing indicators and standards and gathering baseline data" (Page 11-21). It goes on to state that "Alternative 2 would set interim limits on visitor use through specific facility limitations and implementation of. . . VERP. . . These interim limits would remain in place for up to 5 years or until the National Park Service is confident that. . . VERP. . . Is providing sound guidance. . . " (Page II- 3 1). Yet the following statements are unclear as to when done is done: Page 1-6 states: "The National Park Service will fulfill its requirement to revise the. . . Plan for the Merced River when the Record of Decision [ROD] on the Final. . . Is signed. . . In 2005." . Page 1-8 states: "This Revised Merced River Plan/SETS amends the Merced River Plan and will provide a framework for decision-making on future management actions within the Merced Wild and Scenic River corridor." . Page 1-9 states: "The Yosemite Valley Plan was developed and adopted in accordance with the Merced River Plan. Upon completion of the Revised. . . SETS, the National Park Service will review actions approved in the Yosemite Valley Plan to determine whether any revisions. . .would result in any changes to the Yosemite Valley Plan." Does fulfilling a requirement by signing the ROD in 2005 mean the Revised Plan is "done?" Is the mere signing of the ROD the trigger that instantly amends the 2000 Merced River Plan and the 1980 General Management Plan (GMP)? What does "completion of the Revised" River Plan mean? A signed ROD? Or does "completion" follow the lifting of the 5-year interim facility limits with full documentation as to how VERP has provided the required guidance on visitor use levels while guaranteeing protection of the Merced River Outstandingly Remarkable Values? Without a clear understanding as to when done is done, it is impossible for the public to put this Plan in perspective with respect to its relationship to other plans."

(Individual, Oakhurst, CA, Comment #55-12)

"The DEIS is confusing relative to the duration of "interim limits." The quotes below illustrate this issue. The interim facility limits proposed will remain in place until VERP is fully implemented II-31 para 2. These interim limits would remain in place for up to 5 years or until the National Park Service is confident that the VERP program is providing sound guidance on appropriate visitor use levels within the river corridor II-31 para 4. Until the VERP program is fully operational, interim user limits expressed as facility constraints and bus quotas would be put in place to ensure protection of the river's Outstandingly Remarkable Values II-32 para 1. These facility limits would be put in place while the VERP program was being refined and implemented, a process which could take up to 5 years II-33 para 1. The interim facility limits established in Alternative 2 would remain in place for up to 5 years, until the VERP program is refined and provides robust data on desired conditions II-37 para 1."

(Individual, Fresno, CA, Comment #82-10)

Response: The National Park Service will fulfill its requirement to comply with the Ninth Circuit Court of Appeal's ruling that it "must prepare a new or revised CMP that adequately addresses user capacities and properly draws the river boundaries in El Portal" when the Record of Decision on the Final Merced Wild and Scenic River Revised Comprehensive Management Plan and Supplemental Environmental Impact Statement is signed by the National Park Service Pacific West Regional Director and it is subsequently published in the Federal Register in 2005. Language clarifying this issue has been added to text on page I-6.

This document also further clarifies concerns related to interim limits in Alternative 2. The document now states in Chapter III that the interim limits would last for the next 5 years, while the VERP indicators and standards continue to be field tested and improved. At the end of the 5-year interim period, the National Park Service would evaluate the VERP program's effectiveness in providing park managers with the information needed to manage visitor use in a manner that protects and enhances the Outstandingly Remarkable Values. Based on this evaluation, park managers would present a report to the public documenting how the VERP program has provided the required guidance on visitor use levels and whether facility limits should be continued, modified, or eliminated. If changes proposed at this time would result in substantially different environmental consequences than were identified in the Final Revised Merced River Plan/SEIS, an appropriate level of National Environmental Policy Act compliance would be completed.

Concern 175: The Revised Merced River Plan should include maps of all parking spaces considered in the plan.

"The DEIS claims there are 2,097 day use parking spaces in Yosemite Valley. The NPS should provide maps of all parking places considered in this total in the Draft SEIS... Details should be provided, even in this "interim" period, on what constitutes a sound parking space."

(Individual, Fresno, CA, Comment #82-12)

Response: The National Park Service recognizes this request and has made these maps available upon request.

Concern 177: The National Park Service should clarify why it selected specific months for determination of limits on buses.

"How did the NPS select the appropriate "interim limits" for commercial buses? The current number of bus parking spaces in Yosemite Valley (38) is used to manage 92 commercial or transit buses per day. Data from commercial bus use from August 1996, and transit bus use from August 2000 were used to determine the maximum allowable. Why were these months selected?"

(Individual, Fresno, CA, Comment #82-14)

Response: The Final Revised Merced River Plan/SEIS has been revised to more clearly present why specific months were selected to determine limits on buses in both the tables presented in Chapter III and Appendix C. The National Park Service has based Interim Facility Limits for buses on historic peak highs for visitor use associated with commercial and transit bus use because those levels can currently and have historically been accommodated in Yosemite Valley.

Concern 178: The Revised Merced River Plan should expand the information presented in Appendix D and bring a discussion forward in the text of the document including footnoted information.

"Appendix D (User Capacity Alternative Assumptions) must be made more accessible to the reader. The information in Appendix D is critical to an understanding of the proposed alternatives. The Appendix should be expanded and brought forward into the text of the SEIS. Tables D-1, D-2, D-4, and D-5 should all be in the same format, and should be set up alongside one another for easy comparison."

(Individual, Fresno, CA, Comment #82-15)

"Table D-1 presents Estimated Daily Visitor Capacity information. Footnote "f" in this table is confusing. Is this truly the AVERAGE occupancy of lodging and campsites or the MAXIMUM POSSIBLE? I suspect the latter. The text that is footnoted should not exceed the size of the table. Suggest putting important footnoted information in separate tables to increase readability."

(Individual, Fresno, CA, Comment #82-16)

Response: The Final Revised Merced River Plan/SEIS has been revised to more clearly present information presented in the tables in Chapter III and Appendix C (Appendix D has been changed to Appendix C in the Final Revised Merced River Plan/SEIS). In order to simplify and reduce the complexity of the information presented for each alternative, supporting references and details have been placed in the appendices. The footnotes for tables presented in Chapter III have been revised to provide clarity as to where the reader may find more information about the assumptions used for tables in Chapter III.

Concern 179: The Revised Merced River Plan should include source information on current capacity levels discussed in table II-7 and table D-3.

"Table II-7, page II-36 lists Current Capacity Levels for Yosemite Valley with a segment total of 20,569. What is the source of this number? How was it derived? This information is not contained in Appendix D as stated."

(Individual, Fresno, CA, Comment #82-18)

Response: The Comparison of General Management Plan Visitor Use and Employee Housing Levels (1980) with Existing Conditions (2004) as presented in table II-7 in the Draft Revised Merced River Plan/SEIS has been changed to table III-6: Comparison of Number of General Management Plan Facilities (1980) with Existing Conditions (Interim Facility Limits 2004) and General Management Plan Facilities in the Final Revised Merced River Plan/SEIS. This table, along with table C-3, has been revised to include source information.

Planning Goals

Concern 37: The National Park Service should only utilize newly constructed overnight accommodations once replaced facilities are no longer in service and eliminate the 18 month "transition period."

"It appears that the NPS intends, upon issuance of a Record of Decision (ROD) on the MRP, to proceed with the various construction projects which are presently enjoined. They would NOT immediately remove, upon completion of new construction, the units which were supposedly being replaced. In view of the extensive history of "temporary" facilities ending up being semi-permanent, this approach appears to be A BACK-DOOR WAY OF INCREASING OVERNIGHT ACCOMMODATIONS. THIS IS NOT AN ACCEPTABLE TACTIC."

(Individual, San Francisco, CA, Comment #31-6).

"Table D-2 footnote "d" should be clarified. What happens during this 18 month transition period? Will the stated maximum number of lodging units (1,262) and therefore the stated maximum number of overnight visitors is (4,213) be exceeded as a result of this "transition" period? These stated maximum levels should never be exceeded."

(Individual, Fresno, CA, Comment #82-17)

"Great concern about the transition time of 18 months that's listed for lodge unit or units when new units are instructed that the old units will remain in service for 18 months it doesn't seem reasonable that to allow -- It seems like a way to expand the amount of people that could be housed say, in the lodge. At least it isn't written in that there would be a limit on the number of people that, or number of rooms."

(Individual, Merced, CA, Comment #98-2)

Response: This concern has been clarified in the Final Revised Merced River Plan/SEIS. The language pertaining to an 18-month transition period as it relates to overnight accommodations has been changed. The National Park Service has committed to not using older facilities once newer ones are constructed and become operational.

Concern 38: The National Park Service should revise the entire Merced River Plan using User Capacity as a foundational element.

"Though the Federal Register Announcement focused on the two deficiencies, it recognized the "ENTIRE. . . CMP is INVALID" and referenced "Land management, user capacities, appropriate types and levels of recreation, and protection and enhancement of the Merced River's Outstandingly Remarkable Values" as integral to the total effort. However, when Yosemite announced the call for scoping they decidedly narrowed the focus claiming: "The Court's decision upheld the other elements of the plan, including boundaries for other segments of the river; classifications for all river segments; Outstandingly Remarkable Values; the River Protection Overlay; the Section 7 determination process, and the plan's management zoning program. As a result, these five elements are not being revisited in the SETS." Consequently, the document before us represents the Park's "spin" on the court order, making a mockery of the judicial system; it merely plugs in some interim numbers that have no environmental relevance while management charges forward with the Yosemite Valley Plan."

(Individual, Oakhurst, CA, Comment #55-2)

"User capacity including the all important types of uses (uses based on the natural and cultural values of Yosemite, versus resort/urban amenities and construction), are integral to a plan that protects the River's values, and cannot merely be slapped onto an already invalid plan -- unfortunately, that is just what NPS appears to be doing in the current release of the D. R. MRP."

(Individual, Comment #93-8)

"User Capacity: The D. R. MPR tries to address user capacity by layering it on top of the inadequate CMP. Adequately addressing user capacity must be accomplished in context of a CMP built on Outstandingly Remarkable Values, as an integral and integrated component. User capacity in this plan is not based on nor protective of Outstandingly Remarkable Values it is not adequate in any alternative."

(Conservation Organization, Yosemite, CA, Comment #111-82)

Response: The 2004 Court Order directing this revision of the Merced River Plan specifically requires the National Park Service to revise the plan to (1) address user capacity in the river corridor, and (2) reassess the river corridor boundary in the El Portal segment based on the location of Outstandingly Remarkable Values. The Ninth Circuit Court of Appeals found that the plan was invalid due to these two deficiencies. Other elements of the Plan (e.g., the River Protection Overlay, Management Zoning, Outstandingly Remarkable Values, river classifications, and river boundaries outside of El Portal) had been challenged in an earlier phase of litigation before the U.S. District Court in Fresno. The District Court rejected challenges to those elements of the plan, and the District Court's findings in this regard were never appealed to the Ninth Circuit. Therefore, the National Park Service considers the remaining elements of the Merced River Plan to be appropriate tools that can be used to further the mandates of the Wild and Scenic Rivers Act. When coupled with the remaining plan elements, the revised User Capacity Program and the revised El Portal boundary work synergistically. Together, they form a comprehensive framework for managing the river. Because the newly revised elements of the Revised Merced River Plan/SEIS can and do function with pre-existing elements in a comprehensive manner, the remaining management elements as described in the existing Merced River Plan/FEIS are not being revisited in this plan.

Concern 41: The National Park Service should reduce overnight accommodations before restricting day users when bringing the total daily maximum down on peak visitation days.

"Since NPS seems to be proposing a major increase in overnight accommodations, the only way I could visual that NPS could bring the total daily maximum down on peak visitation days would be through a drastic curtailment of day users. This would be a reversal of previous NPS policy to accept the shift in user demand away from overnight and toward day use. Also, while offering greater profit opportunities for Delaware North, it would take business away from the gateway communities."

(Individual, San Francisco, CA, Comment #31-3)

Response: Overnight accommodations in the park in general, and in the Valley in particular, are typically reserved by the general public well in advance of their visit to the park (up to a year in advance in many cases). In addition, the number of overnight accommodations are far less in terms of the percentage of total visitors to the park on peak visitation days. Given this, and the unpredictability when peak visitation days may occur, it is unrealistic to reduce overnight accommodations on peak visitation days before placing restrictions on day users.

Concern 446: The National Park Service should recognize that the introduction of facility limits necessitates comments on site-specific implementation plans or projects, and therefore should be considered in scope.

"PROGRAMMATIC vs. IMPLEMENTATION PLAN. The document clearly states that the Revised River Plan is a programmatic plan that establishes management direction. On the other hand, implementation plans, such as the Yosemite Valley Plan, "direct specific projects as well as ongoing management activities or programs." It would appear that in order to stay within the scope of this planning effort, comments from the public would need to address the programmatic aspect of the Plan and not become distracted by specific projects or site specific analysis. Yet by introducing interim facility limits associated with specific projects, this document misleads the public. The tendency will be to focus more on individual projects (e.g., campgrounds, lodging, day visitor parking, etc.) rather than what is intended to be a resource- based analysis. And, consequently, will such confusion render numerous public comments useless because they may be considered outside the scope of this planning effort?"

(Individual, Oakhurst, CA, Comment #55-15)

Response: The Revised Merced River Plan is a programmatic plan that will guide future planning efforts but it does not dictate any specific action. The court directed the National Park Service to revise the plan to address the El Portal boundary and user capacity. The court also stated that the National Park Service could adopt interim limits on use if the VERP program would not be fully operational immediately. The park has accepted and responded to comments regarding these interim limits.

Criteria for Selection of Planning Goals

Concern 25: The National Park Service should adopt an interim plan as described in the Madera County Supervisor's letter of June 27, 2000.

"The YSVB [Yosemite Sierra Visitors Bureau] also recommends adoption of the interim plan described in the Madera County Supervisor's letter of June 27, 2000 while re-tooling of the RMRP takes place."

(Individual, Oakhurst, CA, Comment #49-8)

Response: Because the "interim plan" as described in the Madera County Supervisor's letter of June 27, 2000 was not provided to the National Park Service during the public comment period for the Draft Revised Merced River Plan/SEIS, the National Park Service is unable to respond to this concern in its entirety.

Concern 43: The National Park Service should implement a legally sufficient User Capacity Program that more closely represents the definition of "user capacity" as described in the 1982 Wild and Scenic Rivers Guidelines rather than the Visitor Experience and Resource Protection framework.

"The 1982 [Wild and Scenic Rivers] guidelines define the concept as the quantity of recreation use which an area can sustain without adverse impact on the Outstandingly Remarkable Values and free-flowing character of the river area, without adverse impact on the quality of the recreation experience, and without adverse impact on public health and safety. Instead you've chosen to go with VERP-spin which claims user capacity is only about sustaining the desired resource and social conditions that complement the purpose of the park units and their management objectives. ". . . complement the purpose of the park units and their management objectives."

(Individual, Oakhurst, CA, Comment #28-2)

"The Ninth Circuit court order stated that the NPS is [not] precluded from using VERP to fulfill the user capacities requirement. . . ," as long as such limits "will not adversely impact the Merced Outstandingly Remarkable Values." Instead Park administrators chose to redefine user capacity as "the types and levels of visitor use that can be accommodated while sustaining the desired resource and social conditions that complement the purpose of the park units and their management objectives" (Page 11-17). Such terminology makes for warm and fuzzy language but blurs measurable objectivity and accountability."

(Individual, Oakhurst, CA, Comment #55-4)

"Astoundingly, User Capacity definitions in this D. R. CMP do not even use the operative 1982 NPS Fed Guidelines for user capacity for WSR def, instead use NPS management definitions. YVP plans to accommodate more visitors, yet no user capacity based on protection of Outstandingly Remarkable Values yet determined. That is pre-decisional."

(Conservation Organization, Yosemite, CA, Comment #111-83)

Response: Commenters refer to the 1982 National Wild and Scenic Rivers Guidelines, which define carrying capacity as "the quantity of recreation use which an area can sustain without adverse impact on the outstandingly remarkable values and free-flowing character of the river area, the quality of recreation experience, and public health and safety." Those guidelines go on to direct that "public use will be regulated and distributed where necessary to protect and enhance (by allowing natural recovery where resources have been damaged) the resource values of the river area. Public use may be controlled by limiting access to the river, by issuing permits, or by other means available to the managing agency through its general statutory authorities."

Managers are thus guided to maintain certain conditions on the river's Outstandingly Remarkable Values and free-flowing character. The guidelines also direct certain conditions on the quality of the recreation experience, and to public health and safety. To achieve this, park managers must first determine existing and desired conditions of the Outstandingly Remarkable Values and the recreation experience.

In the National Park Service, conceptual/programmatic plans such as general management plans and Wild and Scenic river management plans do this in a logical, trackable, transparent sequence of thinking and decision making. Park or river legislation, legislative histories, park service legislation, and other laws and regulations dictate the purpose, significance, and outstandingly remarkable values of the park or river. Based upon the purpose, significance, and Outstandingly Remarkable Values, management prescriptions or desired conditions are created. They establish the basis for determining the types, levels, and locations of recreation activities to achieve the goals or conditions. This is done with full National Environmental Policy Act and 106 compliance, and with extensive consultation with the public. This transparent and deliberate process documents decision making that is more accountable and responsive to legal mandates than previous carrying capacity techniques that relied on an "expert" to intuitively determine a number of people who should visit an area based on professional judgment.

The National Park Service adopted this technique in its 2001 Management Policies, which define and describe visitor carrying capacity as "the type and level of visitor use that can be accommodated while sustaining the desired resource and visitor experience conditions in the park. Managers will also identify ways to monitor for, and address, unacceptable impacts to park resources and visitor experiences.

The decision-making process must include the best-available science, and quality indicators and standards for resource conditions and visitor experiences. The level of analysis necessary to make decisions about carrying capacities is commensurate with the potential impacts or consequences of the decisions. The greater the potential for significant impacts or consequences to park resources and values (or the opportunities to enjoy them), the greater the level of study and analysis needed to support the decisions.

Concern 62: The Revised Merced River Plan should describe how impacts from buses will be mitigated in the final document.

"The plan does not adequately mitigate the impacts of buses during the hours when the greatest numbers of them arrive from 10 am to 12 pm and more broadly from 10 am until 2 pm."

(Individual, Fremont, CA, Comment #51-11)

Response: Visitation to Yosemite by bus peaked in 1996 with approximately 18,000 buses carrying approximately 450,000 visitors. Since that time, both the number of buses and the number of visitors traveling into the park by bus have declined to approximately 9,500 buses carrying 275,000 visitors in 2004 (see figure IV-2 and supporting text in Chapter IV). In addition, Yosemite Valley visitors arriving by bus tend to be concentrated in developed areas of the park that provide adequate space for bus parking and have hardened surfaces for walking to view popular features such as Yosemite Falls, Bridalveil Fall, Tunnel View, and the Yosemite Lodge area. Visitors in organized tour groups typically do not have the time to explore undeveloped areas and typically do not stray far from the tour guides or buses. Alternative 2, as presented in the Final Revised Merced River Plan/SEIS, proposes an interim limit of 92 buses per day entering Yosemite Valley and 28 per day in Wawona. Though no limits on buses are proposed for Alternatives 3 and 4; the daily segment or management zone limits, coupled with the annual corridorwide visitation limits would provide an overall limit on the number of visitors within the river corridor, including those who travel in by bus.

Concern 217: The National Park Service should base its planning on natural resource-based management rather than on existing and planned facilities.

"Alternative 1 is misleading because you equate average existing visitation with the visitor capacity. These terms are not the same. By analogy, the occupancy rate (i.e., visitation) in a hotel, restaurant, train, boat, or airplane is not the same as the visitor capacity in these examples. The occupancy or visitation rate of the Merced WSR is not its user capacity."

(Individual, Fort Collins, CO, Comment #73-4)

"The numeric capacity decision should duly consider the necessary information that effects a visitor capacity decision (see previous discussion in #1[comments 73-1, 73-2, 73-3]), not simply based on existing use or existing and planned facilities."

(Individual, Fort Collins, CO, Comment #73-13)

"NPS needs to stop basing its planning on existing facilities and purposed facilities to be developed; instead, natural resources based management is what WSRA requires."

(Conservation Organization, Yosemite, CA, Comment #111-68)

Response: The 1980 General Management Plan did, indeed, base carrying capacity decisions on the numeric carrying capacity of facilities. The proposed approach to carrying capacity in Alternative 2, the environmentally preferable alternative, would amend that portion of the General Management Plan for the Merced River corridor and replace it with the VERP framework. Implementation of Yosemite's VERP program will be more responsive to fulfilling and supporting General Management Plan objectives and the protection and enhancement of the Outstandingly Remarkable Values of the Merced River.

Science/Resource-Based Decision-Making

Concern 133: The National Park Service should consider recommendations from the 2002 Federal Interagency Task Force Report on Visitor Capacity when making decisions about visitor capacity.

"The 2002 Federal Interagency Task Force Report on Visitor Capacity, co-sponsored by the NPS, provides a fuller list of considerations towards making a reasonable visitor capacity decision (pg. 16): Inputs to a Capacity Decision. Sound professional judgment relies on many informational inputs. Those particularly relevant to a visitor capacity decision might include: management objectives (including all legislative and policy guidance); desired future conditions and quality standards (resource, social, management); current and future recreation demand (who, where, what, when, how, why); current resources, conditions, uniqueness, capability, and trends; current management capability and suitability; current type, amount, and design of facilities and infrastructure; appropriateness (compatibility) of current or proposed recreation opportunities; regional supply of the same and similar recreational opportunities; foreseeable changes in recreation and nonrecreational uses; existing allocations to permittees and other land uses/users; significance of the visitation issues and concerns; potential for natural or cultural resource impairment; type and amount of best available science and information; level of uncertainty and risk surrounding consequences of decision; and the expected quality of the monitoring program."

(Individual, Fort Collins, CO, Comment #73-3)

Response: During the writing of the document, the planning team reviewed the Interagency Task Force Report on Visitor Capacity. The National Park Service believes that the alternatives proposed in this document are consistent with the majority of the recommendation in the report. However, the agency does not agree with all of the report's recommendations. The National Park Service representative on the Task Force noted those disagreements in comments submitted on the draft report. The National Park Service believes that the VERP process is consistent with the current state of knowledge and best practices in managing user capacity on public lands.

Concern 156: The "Addressing User Capacity" section of the Revised Merced River Plan should be revised to accurately reflect the diversity of opinions of successes of developed user capacity programs.

"The section on "Addressing User Capacity" has little basis in fact. Your discussion of user capacity on pages II-16 and 17 is not complete, narrow, and has little basis in fact of the situation on the federal estate. The reader is left with the impression in reading this section that the question of user capacity is dealt with by a special process or approach such as LAC, VERP, VIM, or ROS. As part of the Task Force effort there was an in-depth survey done of 95 field units from around the United States that had decided upon a numerical user capacity for their managed areas. Participants were asked what decision process or steps were used. Seventeen (17%) percent of the respondents indicated they had used VERP (3%), LAC (11%), or ROS (3%), and no respondent indicated VIM. Most respondents indicated that they were addressing user capacity as one decision among many within a NEPA-compliant planning process, which in my opinion is exactly what is required on you in the Merced Wild and Scenic River SEIS. Your discussion [on "Addressing User Capacity"] also gives the sense of agreement and consensus in addressing user capacity. Not true. In the Sept 2004 issue of Parks and Recreation, I wrote the following (pg 109):

First, in the early 1980s, the recreation science community rightly disclosed that a numerical visitor capacity was an administrative decision and not a scientific finding. In the absence of a scientifically determined visitor capacity, the recreation science community began to develop alternative monitoring frameworks purporting to address visitor capacity. Some 10 monitoring frameworks have been published (e.g., VERP, LAC, VAMP, VIM, QUALs) that, for all practical purposes, are the same.

Unfortunately, these monitoring frameworks have fostered a number of misunderstandings among managers and researchers. For example, (a) a numeric visitor capacity is no longer an important and fundamental tool for resource planning and management; (b) monitoring enables a manager to circumvent his responsibility of deciding upon a reasonable numeric visitor capacity; (c) monitoring allows us to dispatch a visitor capacity decision to a future time and another person; or (d) a numeric visitor capacity can be determined with enough monitoring and, thus, there is no need for a manager to make a decision now or later.

This titanic myth is at the core of the National Park Service problem in the Merced River case. These monitoring frameworks may be good monitoring frameworks, but they do not replace the need for proactive numeric visitor capacity decisions. Monitoring and visitor capacity are two separate tools and decision points, they are not an either/or option, and both are important to good resource planning and management.

You need a more complete and factual presentation in this Section of how user capacity is being addressed nationally and acknowledge that there continues to be dialogue about how best to proceed."

(Individual, Fort Collins, CO, Comment #73-37)

Response: The user capacity issue is complex and continues to be intensely debated among academicians, scientists, and land managers. There are many methods for addressing user capacity on public lands--as well as many points of agreement and disagreement. The Final Revised Merced River Plan/SEIS has been revised to acknowledge that these areas of agreement and disagreement on user capacity management exist within the recreation management field. Additionally, the revised plan contains citations to various articles representing this debate.

Concern 157: The Revised Merced River Plan should be revised based on the best available science and information on visitor capacity, including the National Park Service sponsored "Visitor Capacity in the National Park System" September 2001.

"The inclusion of best available science and information needs expansion. Your literature review and the text of the SEIS appears that you have not considered all the best available science and information on visitor capacity. My concern is that institutions often entrap themselves into a phenomenon called "groupthink" and the quality of their decisions are lessened.

For example, the National Park Service commissioned a Social Science Research Review entitled Visitor Capacity in the National Park System that was published in Spring 2001 (Volume 2, Number 1). It was a two-year project and the paper was rigorously peer reviewed. There is also the 2002 Federal Interagency Task Force Report on Visitor Capacity sponsored by the NPS and participated in by many NPS professionals. A copy was personally mailed to you over 18 months ago. Based upon a lack of citation and reference, it appears that these recent NPS contributions were not duly considered in the SEIS.

While these and other publications are not hearty endorsements for VERP and may not support your pre-decisional stance, I think these would help to constructively challenge and clarify your thinking about user capacity, all for the purpose of making even better decisions and to fend against elements of groupthink."

(Individual, Fort Collins, CO, Comment #73-38)

Response: Creation and implementation of the VERP framework has included an exhaustive study of scholarly and scientific information, including the Federal Interagency Task Force Report on Visitor Capacity. While the report was sponsored in part by the National Park Service, and the National Park Service participants agree with many of the findings documented therein, the agency never adopted the report due to fundamental ongoing professional disagreements with key findings. This document does cite several of the elements within the above referenced publications that the National Park Service agrees with. Please refer to Chapter IX: Bibliography for more information on cited materials.

Concern 160: The Revised Merced River Plan should set baseline conditions for indicators reflecting river health with restored meadows and river banks, as opposed to current degraded conditions.

"Choose a more accurate baseline for river health. The Revised Merced River Plan necessarily chooses a baseline against which to measure changes in river health. But current river condition is not the best baseline, because the river is already ecologically stressed. A better baseline would include restored meadows and riverbanks, plus minimal intrusion by non-native species."

(Individual, Comment #81-5)

Response: Since the Merced River was designated a Wild and Scenic River by Congress in 1987, park managers in Yosemite have placed a strong emphasis on the restoration of meadows and those areas of the Merced River bank that experience heavy visitor use, particularly in Yosemite Valley. As examples, the park has undertaken several restoration efforts such as:

·       Restoration of riverbank and Devil's Elbow

·       Cook's Meadow Restoration

·       Stoneman Meadow Restoration

·       Sentinel Meadow Restoration

·       Merced River Restoration at Eagle Creek

·       Removal of the Happy Isles Gauging Station Bridge

·       Removal of the Cascades Diversion Dam

Many recent and ongoing restoration efforts have been listed in Chapter 3, Alternatives as part of the discussion under Alternative 1--No Action. Ecological restoration efforts in the river corridor have served to improve the overall health and free-flowing condition of the river since its 1987 designation and are indicative of current baseline conditions. Although resource managers recognize that there is still work to be done in some areas, the indicators and standards developed under the park's VERP program provide a sound mechanism for ensuring the ongoing protection of the Merced River.

Concern 171: The Revised Merced River Plan is incorrect in its assumption that current use levels are protective of Outstandingly Remarkable Values.

"Page II-35 para 3 states "Current park policies and existing use levels are considered to be protective of the Outstandingly Remarkable Values." I believe this is a subjective assumption that could lead to irreparable long-term harm to Outstandingly Remarkable Values of the Merced Wild and Scenic River. It is an assumption that should be substantiated (or refuted) with data...how do we know current levels of use of the Merced River corridor with all of the associated accoutrements needed to support those visitors (e.g., utility lines, roads, structures, employee housing, school, day care center, etc.) are not harming aquatic invertebrates, or changing the hydrologic regimes of the Valley?

(Individual, Fresno, CA, Comment #82-8)

Response: The Final Revised Merced River Plan/SEIS has included graphs that depict park visitation from 1985 through 2004 (see table III-3). As shown by this figure, overall visitation levels today are nearly the same as those experienced in 1987, the year Congress designated the Merced River as Wild and Scenic. Since 1987, park managers have undertaken numerous initiatives within the river corridor with the objective of protecting and enhancing the river's Outstandingly Remarkable Values. The analysis in the Final revised Merced River Plan/SEIS indicates that the river's Outstandingly Remarkable Values are being protected and enhanced.

Concern 189: The National Park Service's objective should be an overall improvement of conditions, rather than maintaining the status quo.

"The National Park Service's objective should be an overall improvement of conditions in the Merced River corridor, not maintaining the status quo or allowing further degradation to occur."

(Individual, Fresno, CA, Comment #82-34)

"Be proactive about protection and restoration. If we wait for conditions to get bad enough to register, we may wait too long. Besides, meadows are already trampled. Beaches and river banks are already heavily impacted. In other words, we've already passed "baseline" for ecosystem health. We should think in terms of restoring vitality, not preserving an unhealthy status quo."

(Individual, Emerald City, CA, Comment #85-4)

Response: The National Park Service's objective is to strive for an overall improvement of conditions within the Merced River corridor. Park managers have undertaken several restoration efforts in recent years, particularly in adjacent meadows and along the river's banks. Examples of some of these projects include:

·       Restoration of riverbank and Devil's Elbow

·       Cook's Meadow Restoration

·       Stoneman Meadow Restoration

·       Sentinel Meadow Restoration

·       Merced River Restoration at Eagle Creek

·       Removal of the Happy Isles Gauging Station Bridge

·       Removal of the Cascades Diversion Dam

Park managers have also developed a series of VERP standards and indicators that are designed to specifically focus on protecting and enhancing the overall environmental and ecological conditions in the river corridor. In addition, they have adopted a proactive approach for implementing management actions in the event VERP monitoring suggests conditions are approaching a specific standard (see figure II-3 and supporting text). This approach allows park managers to implement preventive measures before conditions reach levels where standards are being exceeded.

Concern 218: The National Park Service should develop adequate baseline data studies in order to develop user capacity.

"We filed numerous declarations from our experts which stated and laid out what surveys needed to be done, the kind of mapping for resources, and so on. We already presented NPS all this information which NPS is basically continuing to ignore. Baseline date, The Ninth Circuit said that NPS still has the duty to do develop adequate baseline date studies in order to develop user capacity. We herein incorporate those expert declarations."

(Conservation Organization, Yosemite, CA, Comment #111-69)

Response: The original Merced River Plan and this revision to the plan are based on large amounts of baseline data relevant to resource conditions within the park. Additionally, data was gathered during this plan revision, particularly in the El Portal area.

As part of the VERP program, still more baseline data are being collected and systematically analyzed and evaluated by park managers. As the VERP process continues to be implemented in the coming years, this data will be supplemented by additional information gathered during monitoring within the river corridor. This data will be used to continually fine-tune the VERP process.

Relationship to Other Planning Efforts

Concern 27: The Revised Merced River Plan should explain why lodging and campsite numbers have changed in comparison to the Yosemite Valley Plan and the General Management Plan.

"The NPS appears to be proposing a substantial increase in overnight accommodations of all kinds. Some of the proposed numbers are greater than present numbers, and most if them are substantially larger than called for in the 2000 Yosemite Valley Plan (YVP).Specifically, the YVP calls for 961 lodging units; the MRP calls for 1,262. The YVP calls for 500 campsites (presently 475); the MRP calls for 628. I could find no rationale for the larger numbers other than they are aiming for a total daily maximum of 18,241visitors, which is the number contained in the 1980 General Management Plan (GMP). If I have missed something I would appreciate being pointed to it, citing a specific page number reference."

(Individual, San Francisco, CA, Comment #31-2)

Response: The Final Revised Merced River Plan/SEIS has been revised to provide clarification between the numbers used for lodging and campsites in comparison to the General Management Plan and the Yosemite Valley Plan in the tables presented in Chapter III and Appendix C (Appendix D has been changed to Appendix C in the Final Revised Merced River Plan/SEIS). As presented in Alternative 2, interim facility limits for overnight lodging units are based on the number of existing units. As new units are constructed existing units will be eliminated from saleable inventory to ensure no net increase in the rooms available for occupancy, even temporarily.

The General Management Plan called for a reduction of 116 campsites from existing levels in 1980 which was 872 campsites, to the proposed level of 756 campsites in Yosemite Valley; most of them within the Merced River corridor. The Final Revised Merced River Plan/SEIS proposes 638 campsites for Yosemite Valley in Alternative 2, which is a further reduction from the General Management Plan proposed levels. However, the numeric approach to managing carrying capacity within the river corridor will be amended by this plan through the VERP program. Indicators and standards have been developed to monitor achievement of the desired resource and social conditions within the river corridor, and will continue to be refined over time. Adjustments to location, number, and infrastructure will be made when warranted. It is anticipated that relocation of certain campsites from sensitive areas will serve the resource goals of both the General Management Plan and the Merced Rive Plan, both of which provide guidance for the Yosemite Valley Plan. Therefore campsite relocation and expansion of the current inventory fulfills goals and works towards achieving desired conditions within the river corridor.

Concern 45: The National Park Service should develop a Revised Merced River Plan that takes precedence over previously determined Yosemite Valley Plan implementation projects.

"This River Plan serves the dictates of the predetermined Yosemite Valley Plan. The Management Zones continue to justify the build out plans, and more, of the YVP. On top of that, the Park Service continues to show a chart that purports to show the Yosemite Valley Plan is based on the River Plan. A valid finalized River Plan does not yet even exist, so it is obvious to anyone that the Yosemite Valley Plan is predetermining the zoning in the River Plan. Protection of the River's special values should be determining the River Plan; then and only then, should a plan, such as the YVP be put together. YVP projects should have been and should be based on whether or not they degrade River values. If they do degrade the River, then they should not take place."

(Individual, Comment #93-6)

"As long as the draft plan remains justification for Yosemite Valley protects, it cannot be a protective plan."

(Individual, Cupertino, CA, Comment #103-2)

"Your revised document does not alter the existing "zoning" mistakes that are being used to justify the development associated with the Yosemite Valley Plan. In fact this "revised" plan simply reinforces predetermined outcomes in the Yosemite Valley Plan. The degradation to natural resources, cultural resources, and visitor experience that will be caused by the Yosemite Valley Plan should have been stopped by the revised Merced River CMP not justified."

(County Agency, Groveland, CA, Comment #140-4)

Response: The El Portal boundary and user capacity management program elements contained in the Revised Merced River Plan/SEIS, combined with the elements of the existing 2000 Merced River Plan amend the park's General Management Plan, and take precedence over implementation plans such as the Yosemite Valley Plan. The Merced River Plan is a programmatic plan that guides management of the Merced Wild and Scenic River corridor. This issue is clearly presented in both text and graphics in Chapter I of the document. All future Yosemite Valley Plan projects will have to be reviewed to determine whether they comply with the revisions to this plan. Changes made to zoning in the El Portal area may result in revisions to the Yosemite Valley Plan in that area.

Concern 447: The Revised Merced River Plan should clarify the relationship between the capacity numbers used in the Revised Merced River Plan, the General Management Plan, and the Yosemite Valley Plan, and include a simple table in the document.

"The 1980 GMP claimed that within Yosemite Valley, the park would continue to "provide a variety of camping opportunities" while removing "facilities that are sources of impact on riparian areas" (GMP, page 43). To accomplish that goal, the GIVIP advocated removal of campground sites and other development closest to the Merced River--a total of 1 16 units. The plan would "retain and revegetate 684 drive-in campsites" out of a total 756 proposed campsites in Yosemite Valley (less than the 872 existing pre-1980). The Revised Merced River Plan wants us to believe it is working diligently to achieve the capacity goals outlined in the 1980 GMP. Examining that effort more closely: the interim capacity goals as outlined in Appendix D will result in 432 drive-in sites and another 194 group/walk-in/walk-to sites for a total of 626 (the Plan says 628 but there is discrepancy in the numbers). BUT a review of Appendix F 'Potential Cumulative Actions," page F-7 describes a project titled "Visitor Use and Floodplain Restoration Program" which discusses the ecological restoration of North Pines campground (86 sites) and the northwest end of Lower Pines Campground (16 sites) with an EA planned for release in 2005. The Yosemite Valley Plan is even more clear: "North Pines Campground, which was also affected by flooding. . . Would be removed to preserve and restore highly valued resource areas" and a "portion of Lower Pines Campground. . . Would not be reconstructed" (Final YVPIEIS, Volume 1A, page 2-68). Since interim capacity numbers include the sites at these two locations, we can only conclude that such sites will be temporary--a future loss of 102 existing drive-in sites. Meanwhile, Appendix D counts as part of the interim camping numbers the construction of 160 NEW sites (30 RV, plus 130 walk-in/walk-to/group)---sites outlined in the Yosemite Valley Plan and the Curry EA."

(Individual, Oakhurst, CA, Comment #55-17)

Response: The General Management Plan based visitor capacity on the capacity of facilities and infrastructure. Visitor capacity "goals" identified in the General Management Plan were based on facility levels well below the actual level of facilities in 1980. However, in the 1990s national scientific and scholarly research as well as National Park Service policy discussions resulted in the adoption a new methodology for determining visitor carrying capacity. This methodology--the VERP framework--is described in the 2001 National Park Service Management Polices and in new Park Planning Program Standards signed in August 2004. In order to meet the new policy standards, Yosemite National Park will amend the visitor capacity "goals" of the General Management Plan by translating the former carrying capacity approach to the more responsive VERP process through each new planning effort undertaken. Thus, the visitor capacity goals from the General Management Plan will not form the basis for carrying capacity decisions in Yosemite National Park as proposed in Alternative 2.

The National Park Service is not addressing how the numbers proposed in the user capacity alternatives compared to numbers in the Yosemite Valley Plan, because the Yosemite Valley Plan derives its guidance from and must tier off of the Merced River Plan, as revised in this document. Once the Revised Merced River Plan is complete, the National Park Service will evaluate the Yosemite Valley Plan to determine if it needs to be revised to comply with the Revised Merced River Plan and the General Management Plan, as amended by this Final Revised Merced River Plan/SEIS.

General Management Plan

Concern 93: The National Park Service should base a day use reservation system on the General Management Plan daily maximum of 18,241.

"I also believe that the NPS should adhere to the numbers prescribed in the GMP (18,241 for YV). That number can be the initial basis for a day use reservation system. Then, if future monitoring shows continuing degradation at this level, the number can be reduced [And, in the unlikely event that monitoring shows no problems, the number could be increased.]"