National Parks Conservation Association
Snowmobiles in National Parks
Before the Subcommittee on Tax, Finance and Exports House Small Business Committee
July 13, 2000
Mr. Chairman, members of the subcommittee, my name is Kevin Collins and I am a Legislative Representative for the National Parks Conservation Association. NPCA is America's only private, nonprofit advocacy organization dedicated solely to protecting, preserving, and enhancing the National Park System. NPCA was founded in 1919 and today has more than 400,000 members. Thank you for the opportunity to testify today on the subject of snowmobiles in the National Park System.
In addition to my own written testimony, I request that testimony from Peter Morton, Ph.D., a resource economist with The Wilderness Society, as well as that of several residents of West Yellowstone, Montana, be submitted into the record.
The question of whether snowmobiles should be used in the National Park System can be looked at from many different angles. Today's hearing looks specifically at the economic concern of small businesses that profit, directly or indirectly, from the use of snowmobiles in the parks. This is certainly a valid concern and one that NPCA takes seriously. Nevertheless, NPCA believes that the overriding concern must be for the health of the national parks themselves and the treasures they contain.
Our bottom line is whether snowmobiles present an acceptable or unacceptable impact on national parks. After a great deal of consideration, we have concluded that snowmobiles are not appropriate or acceptable in the National Park System. This was not an easy decision for us, and I'd like to explain how we reached it.
NPCA believes that the more people who experience the national parks, the greater public support there will be for protecting and preserving the entire National Park System. We do not take lightly charges that public "access" to the parks is being unreasonably restricted.
In this case, those who oppose the Park Service's decision have portrayed it as the worst kind of unilateral bureaucratic arrogance. NPCA believes that on the contrary, the Park Service has demonstrated an unusual willingness to assess its own actions and admit that it has been in the wrong. The agency's recent action is a commendable effort to come into compliance with important regulations it has ignored for too long.
In its April 26th announcement, NPS admitted that " . . . years of inattention to our own regulatory standards on snowmobiles generated the problem we have before us today." There is no question that for years the Park Service has been in direct violation of the two Executive Orders and the federal regulations that are supposed to govern snowmobile use in the national parks.
Executive Order 11644, signed in 1972 by President Nixon, states that, "Areas and trails shall be located in areas of the National Park system, Natural Areas, or National Wildlife Refuges and Game Ranges only if the respective agency head determining that off-road vehicle use in such locations will not adversely affect their natural, aesthetic, or scenic values." In the majority of cases, the Park Service appears to have made no such determination before allowing snowmobile use in national parks.
Over the years, the Park Service also ignored requirements to monitor the ongoing impacts of snowmobiles on park resources. That is one of the reasons their recent announcement came as such a shock to many people. Without any monitoring or assessments by the Park Service, there was little reason for people to suspect that snowmobiles might be a problem.
But snowmobiles are a problem. The snowmobiles of today are extraordinarily polluting and noisy machines. They are neither clean nor quiet, in spite of the manufacturers' claims. The air pollution from snowmobiles in Yellowstone is dramatic and disgusting. It is unacceptable that park rangers must have fresh air pumped into the West Entrance gatehouses because the snowmobile exhaust is so overwhelming.
It is equally unacceptable to allow into any national park machines that by their very design discharge raw gasoline and oil into the environment. Or machines that shatter winter quiet with high decibel noise. Or machines that disturb and harass wildlife. Or machines that make it impossible for other park visitors to enjoy the unique qualities of the park. This is obvious to most Americans.
The core mission of the National Park System is to preserve unique, nationally significant places, items, and experiences so that they will remain in their original, unimpaired condition for future generations to appreciate. Many recreational activities can be enjoyed in national parks without compromising that core mission. Unfortunately, snowmobiling is not one of them.
It is also essential to note that the mission of the National Park System is NOT to provide economic benefits to nearby communities and businesses. Having a national park nearby is an economic asset for which any community would be grateful. Nevertheless, this fortunate byproduct of the park's existence must not be allowed to dictate park management policy.
Snowmobiles in National Parks
Annually, there are over 180,000 snowmobiles that use 28 parks in the lower 48 states. The vast majority of this use is in just five parks: Yellowstone, 65,000 - 70,000; Voyageurs, 35,000; Rocky Mountain, 27,000; Pictured Rocks, 26,000; and John D. Rockefeller Memorial Parkway, 17,000. In most of the other 23 parks where snowmobile use is authorized, there is very little use.
On April 26, 2000, the Assistant Secretary for Fish, Wildlife and Parks issued a memo to the director of the National Park System that the Park Service had failed to comply with the various regulations, executive orders, and laws regarding snowmobile use. The memo also noted a "strong consensus within the National Park Service, shared by myself and others in the Department, that snowmobile use in most areas of the National Park System is not an essential or appropriate means of providing winter access to our national parks."
The memo directed parks that currently allow snowmobiles to "immediately review its existing special regulation, and within one year, amend, modify or replace the regulation as necessary to comply with this directive and with the existing Executive Orders and national rule standards, including the requirement for an on-going monitoring program." In a press release, the Park Service said, "The net effect of this renewed enforcement effort will be the significant reduction of recreational snowmobiling in most units of the system."
What Has the Park Service Really Done?
The April 26th announcement has been portrayed as a unilateral, blanket ban on snowmobiles in national parks. It is nothing of the sort.
First, the announcement specifically excluded Yellowstone, Grand Teton, and the John D. Rockefeller Memorial Parkway because those parks are already going through a public process to address winter use; and Voyageurs because that park is developing a general management plan that will include snowmobile use.
Second, the announcement noted that there would be several general exceptions under which snowmobile use could be appropriate, including: transit needed to access other areas where snowmobiling is permitted; access to private land in parks (limited to roads open to motor vehicles in other seasons) and; snowmobile use on roads that are outside the jurisdiction NPS.
Finally, NPS is planning to issue a proposed rule this August that would solicit public comments on when, where, and to what degree snowmobile should be allowed in national parks. My organization will be commenting on this proposal, as will the recreational snowmobiling community, snowmobile manufacturers, and affected small businesses. This public process is a reasonable and appropriate method of considering all aspects of this debate.
What Will the Real Impact Be?
There is substantial disagreement over the economic affects of any changes to the NPS snowmobile policy. I am particularly grateful for the help of the Greater Yellowstone Coalition in preparing the following testimony on the economic situation in West Yellowstone, Montana.
The community of West Yellowstone is clearly divided on the issue of phasing out snowmobiles from Yellowstone Park. Many business owners believe that removal of snowmobiles from the park will provide for much need economic diversification and allow for economic growth. The winter economy of West Yellowstone has been flat since the 1980s—a mass transit snowcoach system could allow for more visitors into the park with less impact, thereby leading to growth in the local economy. (Please see the comments of Doug Edgerton that I have submitted to the record.)
Over 150 business owners and residents in West Yellowstone signed a petition in support of the phase-out and asking for support during the economic transition. (the comments of Jackie Mathews and the petition in the record.) Dozens of letters from West Yellowstone business owners and residents send a clear message that a healthy park leads to a healthy economy. (See letters in the record.)
A snowcoach system will provide access for the same number, if not more, of winter visitors. There are also opportunities for expanding the season into late November and early December if rubber-tracked snowcoaches are used. This expansion of the fall shoulder season (currently one of the slowest periods) would greatly benefit the economy local. (See graph of Resort Tax Collections for the Town of West Yellowstone, 1995-2000 in the record).
Overall, the economic impact on a snowmobile phase-out from the park on West Yellowstone has been greatly exaggerated. The economist on contract with the Park Service for economic analysis for the EIS recently conducted an economic impact assessment for the five surrounding counties. He found that the impact to West Yellowstone would be barely perceptible, even without mitigating efforts such as expanded marketing to attract other winter visitors. (John Duffield, Bioeconomics, Inc.)
The economic analyses for the snowcoach only alternative (G) were computed in two ways. Each was based on an assumed 33 percent reduction in winter visitors, with 37 percent of nights spent in West Yellowstone (out of the five surrounding counties). Local multiplier effects are included. One method predicted an approximately $4.5 million impact.
A second method estimated an approximate $5.2 million impact. In economic terms, these two figures are so close as to be virtually the same.
The winter economy in West Yellowstone has been stable since the 1980s, with no significant growth. In contrast, the summer economy has been growing steadily within normal economic fluctuations. The local economy is driven by park visitors, and as a whole (summer and winter) has been growing at 10 percent per year because of summer growth.
Significantly, there have been fluctuations of up to 15 percent in one year from which the economy has recovered without adverse or lasting effects. For this reason, Duffield categorized the potential $5-million loss to West Yellowstone's winter economy as inconsequential to the economy as a whole and not involving adverse, lasting impacts. Furthermore, with an aggressive marketing scheme to attract new and replacement visitors and an expanded fall shoulder season, the dip in winter revenue can be mitigated further.
The key to transitional success for gateway communities after the phase-out will be to attract similar, or higher, levels of winter visitors. This can be accomplished through additional marketing and public education. The Park Service and state tourism boards should assist with this public education effort as they did following the 1988 fires. After the fires, some local business owners in West Yellowstone warned of impending economic doom. They were proved wrong. Yellowstone National Park is such a strong draw that people will continue to visit under most circumstances. Now we have the exciting opportunity to offer a less polluted, less congested and quieter Yellowstone to the public. I am convinced that any business initially lost will be quickly replaced and regained by winter visitors eager to see and hear Old Faithful erupt without the constant drone of snowmobiles.
How will restrictions on national parks affect other recreational snowmobiling opportunities?
According to the American Council of Snowmobile Associations there are approximately 130,000 miles of groomed and marked snowmobile trails in the United States. There are also thousands of square miles, such as national forest roads and state lands, that are open to snowmobiles but not explicitly designated for snowmobiles. In contrast, there are only about 700 miles of roads and waterways open to snowmobile in national parks—and 300 of those miles are excluded from the NPS April 26 announcement.
Many states have thousands of miles of designated trails for snowmobilers to enjoy. Promotional material from the state of Wyoming does not even mention Yellowstone National Park, but does promise that "with over 2,200 miles of snowmobile trails, you can access some of the most scenic back-country in the world."
Furthermore, a snowmobile promotional site on the Internet proclaims, "For the hardcore snowmobile enthusiasts, there are more than 900 miles of trails that are available from the West Yellowstone area. You can head north of town towards the town of Big Sky, Montana where the cornices are big and the powder is deep. Or continue west of West Yellowstone into one of the largest snowmobile valleys in the world near Island Park, Idaho and connect onto the Continental Divide Snowmobile Trail system in Wyoming." (http://www.sledcity.com/features/wyellowstone.cfm)
According to the American Council of Snowmobile Associations, recreational opportunities in other states include:
Colorado—over 3,000 miles of trails
Idaho—over 7,200 miles of trails
Maine—over 12,000 of trails
Michigan—5,800 miles of trails
Minnesota—20,000 miles of trails
Montana—3,700 miles of trails
National parks provide only a tiny fraction of the recreation opportunities available to snowmobilers, but snowmobiles contribute a disproportionate amount of noise, pollution, and congestion in Yellowstone and other national parks.
It is Reasonable to Regulate Harmful Activities in National Parks
It may be politically challenging to restrict snowmobile use in national parks, but it is not unprecedented. There are many things that we used to do in national parks but don't anymore: We don't feed garbage to the bears, dump burning logs off of cliffs to create a spectacular "firefall," break off stalagmites for souvenirs, or exterminate wolves as vermin. We learn as we go. And sometimes we learn that we've been wrong and we have to take painful steps to put things right. We're doing it in the Everglades right now and hoping we can get back a fraction of what we have lost. That is what we are trying to do at Yellowstone and elsewhere.
We should be striving to keep national parks extraordinary places, not convert them to the same busy, noisy, polluted places in which many of us live. Restricting snowmobiles in national parks will negatively affect only a few businesses, but it will be a huge step toward fulfilling our national pledge to keep our parks protected today and for future generations.
Thank you. I would be happy to answer any questions