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January 29, 2016 Grand Teton National Park ATTN: Moose-Wilson Planning Team PO Drawer 170 Moose, WY 83012-0170 Re: Comments on the Moose-Wilson Corridor Draft Comprehensive Management Plan/Environmental Impact Statement (DEIS) Dear Moose-Wilson Planning Team:

Please accept these comments on the Moose-Wilson Corridor Draft

Comprehensive Management Plan/Draft EIS from the Sierra Club’s Greater Yellowstone/Northern Rockies Campaign and the Wyoming Chapter of the Sierra Club (herein, combined as Sierra Club). Sierra Club’s Mission Statement is:

To explore, enjoy and protect the wild places of the earth; To practice and promote the responsible use of the earth’s ecosystems and resources; To educate and enlist humanity to protect and restore the quality of the natural and human environment; and to use all lawful means to carry out these objectives. We submit these comments on behalf of more than 3,000 members and supporters

in Wyoming and 2.4 million members and supporters nationwide who jointly own, appreciate, and care deeply about the management of Grand Teton National Park.

The Sierra Club agrees that Alternative C, the Environmentally Preferred and the Park Service Preferred Alternative, is the best plan to protect park resources and enhance visitor experiences. In addition, we recommend that the Park Service implement the following additions and modifications to Alternative C in order to better protect wildlife and other natural resources:

1. The Park Service should limit traffic to levels that will not adversely affect wildlife, including considering completely closing the road, during early

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morning and dusk time periods during peak use seasons when the timed sequencing techniques are in operation.

2. During winter, increase the length of the unplowed section of Moose Wilson Road as outlined under Alternative D (Granite Canyon Trailhead to Sawmill Ponds Overlook).

3. Cap use during non-peak periods at current levels (rather than allowing increased capacity of 550), to avoid any additional impacts on wildlife from increased human use of the corridor.

4. Consider creating fewer turnouts in the section of Moose Wilson Road between the Sawmill Ponds Overlook and Death Canyon Road junction.

5. Whenever vehicles enter the Moose-Wilson Corridor carrying appreciably

more than the “people per vehicle average of 2.7” (DEIS:639), the Park Service should account for that additional number of people in the corridor and debit a corresponding number of autos accordingly until that vehicle exits.

6. The Park Service should maintain the curvilinear characteristics of the

Moose-Wilson Road which encourage slow speeds, and also consider installing rumble strips or speed bumps to keep traffic speeds at or below 20 miles per hour.

7. During peak use times, when some autos may be queuing up, waiting to enter

the Moose-Wilson Road from either the south or north entrances, drivers should be required to shut off their engines and not idle in order not to contribute to pollution.

8. The Park Service should not allow motorcycles on Moose-Wilson road that

are so noisy as to disrupt the natural soundscapes and visitor experiences.

Further descriptions of some of the above recommendations are found in our comments below.

1. Introduction

The Moose-Wilson Corridor is a unique and ecologically and culturally valuable

part of Grand Teton National Park that deserves the highest levels of protection. (We agree with excerpts from the DEIS contained in these comments.)

“In addition to notable elevation changes, the vegetation, hydrology, and

geology also changes rather abruptly as one moves from the riverbed of the Snake River to the mountainous areas at the western edge of the project area. Thus, in a relatively small geographic area (i.e., the project area), most of the park’s major

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ecological communities are represented. Given this diversity of habitat, a wide variety of wildlife species inhabit the project area and depend on this unique ecological system. Furthermore, this natural constriction between the Snake River and the Teton Range functions as an important wildlife corridor within the broader park ecosystem, particularly for north-south movement along and above the Snake River floodplain. Prominent wildlife species within the corridor include grizzly and black bears, wolves, elk, moose, beavers, and a wide variety of migratory birds (Cain, pers. comm. 2014).” (DEIS:176 parentheses in original)

The top priority for management of this special corridor within the national park

must be to protect significant park resources and values. Designation as a national park confers responsibility to ensure the highest level of natural and cultural resource protection, and the management plan and actions must meet that responsibility. In addition to providing direct access to the park’s front country and to backcountry wilderness, the Moose-Wilson Corridor also gives visitors the opportunity to safely and slowly experience distinctive scenery through varied landscapes with unparalleled wildlife viewing opportunities. These values must be preserved under future management. It is not the purpose of the Moose-Wilson Road through the Corridor to provide visitor access to non-park destinations or to provide by-pass or commuter routes through the park. Grand Teton National Park is a national park belonging to all Americans, not a county or state park, and the roads in the Corridor are Park roads, not state highways. It is not the responsibility of the Park Service to provide transportation corridors through the Moose-Wilson Corridor to non-park destinations.

“Currently, there is high demand for and high levels of use in the corridor during peak summer months. The levels and patterns of visitation are causing some negative impacts and influencing the ability of the National Park Service to achieve desired conditions.” (DEIS:636) According to National Park Service law and policy, a national park is required to

provide access only for those uses that are compatible with and appropriate to resource preservation. National Park Service Management Policy 1.4.7.1 states that, “Park managers must not allow uses that would cause unacceptable impacts; they must evaluate existing or proposed uses and determine whether the associated impacts on park resources and values are acceptable.” Adding a separate bike pathway in the Moose-Wilson Corridor under Alternative D would negatively impact wildlife, scenic, historic, and other natural resource values of the area, as would increasing the width of existing roads and increasing traffic and human uses. If actions will cause deterioration of the National Park’s natural values, the Park Superintendent cannot allow them, nor can the Regional Director approve such actions.

Because the Moose-Wilson Corridor “sits amidst the large, diverse, and thriving ecosystem of the Greater Yellowstone Area. . . . one of the largest intact temperate zone ecosystems on earth,” (DEIS:175) it has significance far beyond the project area. The protection of the Moose-Wilson Corridor must be considered not only for the local values

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within the Corridor area, but for “its contribution to the regional Greater Yellowstone Area ecosystem.” (DEIS:175-176)

Additionally,

““Congress has charged the National Park Service with managing the lands under its stewardship “in such a manner and by such means as will leave them unimpaired for the enjoyment of future generations” (NPS Organic Act, USC 100101 (b) et seq.)” (DEIS:111) The Organic Act also directs the Park Service to “conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” (DEIS:13)

“Guidance from the Council on Environmental Quality defines the environmentally preferable alternative as the alternative that causes the least damage to the biological and physical environment; it also means the alternative that best protects, preserves, and enhances historical, cultural, and natural resources. . . . . The National Park Service has identified alternative C as the environmentally preferable alternative.” (DEIS:141) For these reasons, and others described throughout our comments, the Sierra

Club agrees that Alternative C, the Environmentally Preferred and the Park Service Preferred Alternative, (with some recommendations described herein), is the best plan to protect park resources and enhance visitor experiences as described in the DEIS:

“When looked at collectively across all resources, alternative C overall

would best protect the corridor’s natural and cultural resources by limiting new development and disturbances in the corridor, reducing the existing development footprint, providing some restoration of natural hydrological processes, and carefully managing traffic levels.” (DEIS:141)

“ (Alternative C) would substantially reduce negative impacts on natural

and cultural resources in several ways. The sequenced traffic management system would limit the potential increase in traffic and visitor use volumes that would likely otherwise occur, reducing potential impacts on soils, vegetation, wetlands, and wildlife, including grizzly bears and other listed species. Reducing traffic volume and congestion would also preserve the rustic and rural character of the historic road and its cultural landscape. The reduction in traffic speeds would reduce the potential for wildlife-vehicle collisions. Paving the unpaved portion of Moose-Wilson Road would eliminate impacts from dust and magnesium chloride applications on roadside vegetation. Realigning the northernmost segment of Moose-Wilson Road would reduce habitat fragmentation and create a more intact wildlife corridor near Moose. Reconstruction of parts of the road alignment south of the Sawmill Ponds to Death Canyon Road would improve drainage and the

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hydrology of this area and improve conditions of the large wetland complex downstream from the road. Installing officially designated roadside turnouts and design solutions to reduce off-road parking would reduce roadside soil, vegetation, and cultural resource impacts, and may lessen wildlife impacts.” (Id.)

It is especially noteworthy and dispositive to us that, under Alternative C, by not

relocating the portion of the Moose-Wilson Road east from the wetlands, “alternative C would avoid significant adverse impacts on major archeological resources in the Moose-Wilson corridor.” (DEIS:141) Under Alternatives B and D, constructing a new road to the east and multiuse pathway (Alt D) would irreparably obliterate critically important archeological sites. Sierra Club feels that the Park Service must treat those areas as important examples of continuous uses of these lands in Grand Teton and the Greater Yellowstone Area by cultures that span millennia. “The long span of American Indian presence in the corridor is reflected in the archeological record, tribal oral histories, and the enduring cultural connections retained by tribes associated with the park.” (DEIS:9) Indeed, tribal representatives with a deep spiritual connection visited these very locations with Park staff recently. The cultures and their people are still here and Park Service and other visitors to the Moose-Wilson Corridor must respect and protect these sites by keeping the road where it is. 2. Current Impacts from Existing Use Must be Acknowledged

Besides the impacts to natural and cultural resources, “The approximately 400,000 visitors that come to the corridor annually for these experiences would potentially be affected by changes to management of the corridor.” (DEIS:21) Alternative C is the Alternative “that best protects, preserves, and enhances historical, cultural, and natural resources.” Subsequently, Alternative C will be the best “stewardship in such a manner and by such means as will leave them unimpaired for the enjoyment of future generations.”

“The Moose-Wilson corridor lies in an area where high-quality habitats associated with the Snake River riparian corridor and high, productive habitats at the base of the Teton Range converge. As a result, wildlife is abundant, and human use in the corridor impacts distribution and behavior of many species. Visitor interactions with moose and black and grizzly bears occur most often. These interactions can result in disturbances to wildlife, especially sensitive species, disrupting activities such as foraging and breeding. In addition, animals may learn to ignore people (become habituated) or seek food from them (food conditioned), increasing the potential for physical interactions that cause injury to people and wildlife. “ (DEIS:98 parentheses included in original) The Park Service has documented harmful impacts and potential risks to natural

resources in the Moose-Wilson Corridor due to ongoing human uses. While Alternative C is the best Alternative, it remains for the implementation of Alternative C to ameliorate

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and reverse known harmful trends and better protect the natural and cultural resources in this part of Grand Teton Park.

“The main goal of the planning effort is to preserve the resources and values of the corridor. By managing the number of people in the corridor at one time, park managers can ensure the resources are protected and that visitors have space to enjoy their drive, view wildlife, and park at key destinations.” (Moose-Wilson Corridor Draft Visitor Capacity Determination-Handout:1)

Habitat and wildlife in the Moose-Wilson Corridor “are affected by a variety of

past and ongoing human activities . . . “(DEIS:187)

“(M)any of these disturbances result in at least some level of habitat loss and/or fragmentation. Some wildlife species are more sensitive to human disturbances than others. . . . (I)f the disturbance occurs during a critical migration period or during a sensitive nesting/breeding period, the same disturbance could have substantial negative effects on the species (Cain, pers. comm., 2014).” (DEIS:188) “The spatial and temporal nature of this visitation and use compounds the wildlife impacts. . . . Human activity can result in a wide range of disturbances to wildlife, including the alteration of daily or seasonal wildlife movement patterns, the disruption of foraging and hunting activities or timing, and the loss or degradation of important breeding or nesting grounds.” (Id.)

Improved stewardship is required in the Moose-Wilson Corridor because beyond

the concentration of human uses on or along the roadways in the Corridor, “some dispersed recreation also contributes to wildlife disturbance and impediments to habitat accessibility and connectivity. “ (DEIS:188) “(T)he negative effects of visitor use on wildlife and wildlife habitat . . . have the potential to worsen in the future if impact mitigation and visitor use management isn’t effectively implemented. . . . (NPS) staff have documented a trend of increasing levels of vehicular traffic on Moose-Wilson Road and side roads. All of these trends have the potential to compound and increase the already-documented wildlife disturbances and habitat fragmentation.” (DEIS:189)

While Alternative C will improve stewardship by the Park Service in the Corridor, it not only allows current levels of visitor uses but also allows for an increase in levels at non-peak use times. “(A) final capacity of 550 people at one time (PAOT) is determined (for the entire Moose-Wilson corridor). This capacity supports current use levels within the corridor while also protecting the visitor experiences and resources with it.” (DEIS:103) Sierra Club is concerned about potential impacts on wildlife resulting from an allowed increase in non-peak visitor use from current levels (see our recommendations to improve Alternative C in these comments), particularly during shoulder seasons when less people in the Corridor may make it more conducive to wildlife movement. Additionally, and this is critically important, “Visitor numbers would also need to be monitored to determine if use levels are approaching or exceeding the visitor use capacity for the corridor.” (DEIS:132) “Traffic metering devices would be installed at both ends of Moose-Wilson Road to monitor the number of vehicles in the

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corridor at a given time.” (DEIS:139) The timed sequencing techniques in Alternative C for vehicles entering into the Corridor will be key to monitoring and managing vehicle numbers. Additionally, the Park Service must continuously monitor conditions and trends of natural and cultural resources to determine the impacts from the implementation of the Corridor Comprehensive Plan. See more on the importance and need for monitoring below. 3. The Park Service Must Protect and Respect Important Archeological Sites

The Park Service must not only protect sites, but must implement plans so that no new desecration of sites is allowed.

“Only a small portion (approximately 8%) of the overall Moose-Wilson corridor has been surveyed for archeological resources.” (DEIS:241 parentheses in original) Among the Action Alternatives in the DEIS, Alternative C is clearly the best Alternative that protects archeological sites, particularly those along the bench south of Sawmill Ponds Overlook. “Three of the prehistoric sites are recommended eligible for the National Register of Historic Places, consisting of a large base camp, and two lithic scatters.” (Id.) “This site encompasses 12 acres and contains at least 11 partial stone circles. These circles, or tipi rings, identify the site as a habitation area. . . . Diagnostic projectile points from the site date to the Late Archaic period and indicate the site may be 1,450 to 2,888 years old. . . . The site is one of three large base camps in the Jackson Hole area and substantially contributes to understanding prehistoric, protohistoric, and historic occupation of the valley.” (Id.)

“An extensive previously unrecorded site in the vicinity of the Laurance S. Rockefeller Preserve (no site number at present) was identified and recorded consisting of 380 lithic artifacts that included nondiagnostic/irregular tools and tool fragments. The high percentage of primary flakes from obsidian cobbles suggests the site was long used as a place to initially reduce the size of material quarried from nearby obsidian source locations (NPS, Whitman Moore, October 2014 survey summary).” (DEIS:242 parentheses in original)

Numerous American Indian tribes valued, and continue to value, this area of

Grand Teton Park because over the generations tribal members “often passed through the area following stream and river corridors, or by way of other traditional access routes for hunting and foraging, migration, religious and ceremonial purposes, and other cultural activities.” (DEIS:242) “A recent report entitled “An Assessment of American Indian Occupation and Uses of the Cultural and Natural Resources of Grand Teton National Park and the National Elk Refuge” (Walker Research Group, Ltd. 2007) . . . notes that tribes view the entire region and its resources holistically, with geographic and other features contributing to their spiritual, economic, and material cultures.” (DEIS:243)

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“The enduring cultural importance of one of these sites was also expressed (during site visits with tribal members) because the large number of stone circles strongly supports the repeated use of the site as an ideal winter camp location. As expressed by a tribal representative, “This place tells us how our ancestors lived. We need to respect this place. It tells us what they had to deal with in order for us to be here . . . I would be saddened if this were destroyed.” . . . Tribal representatives emphasized the paramount need to protect cultural sites, and disturbance and loss of sites was seen as an erosion of tribal cultural identities and heritage (Tribal Consultation Meetings, Summary of Findings, October 5-7, 2014).” (DEIS:244 first parentheses added, second in original) Under Alternative C “Retention of the Sawmill Ponds section of Moose-Wilson

Road would provide the greatest protection of archeological site 48TE498. Parking/road design measures would also be implemented to avoid or minimize disturbance to the site in the vicinity of the LSR Preserve and site 48TE1197 along White Grass and Death Canyon Roads. The integrity and important archeological information retained by these sites regarding prehistoric occupation of the area would be preserved in situ. . . . Outside of the no-action alternative, alternative C would best protect archeological resources because it does not propose road realignments or substantial new construction that could impact known sites.” (DEIS:500)

It is clear in the reading of the Moose-Wilson Corridor Draft Comprehensive Management Plan and Environmental Impact Statement that Alternative C best protects and respects these archeological sites and Alternatives B and D would destroy them.

Under Alternative D, “Significant and irreversible adverse impacts on

archeological site 48TE498 would result from relocation of the road segment near Sawmill Ponds. . . . (T)he rerouted road would cross directly through the archeological site resulting in the total loss of the site as a consequence of grading and construction activities.” (DEIS:500) “(T)he multiuse pathway would also cross the site. . . The combined impacts of these actions would result in total loss of the site. The pathway would also cross the length of the site in the vicinity of the LSR Preserve with an estimated 4,425 yd2 of disturbance to that extensive site. . . . (Under Alternative D) Proposed project actions would cause significant damage and total loss of the sites and the exceptional information potential they retain in buried stratigraphic contexts regarding prehistoric occupation and use along this area of the park. (In addition, under Alternative D) Construction of a spur road connecting the Death Canyon Trailhead and White Grass and Death Canyon Roads would also result in significant disturbance to archeological site 48TE1197 because of ground disturbance associated with road construction activities.” (DEIS:501 emphasis added) Alternative B would have similar but slightly less devastating impacts to archeological sites as Alternative D because no multiuse pathway is proposed under Alternative B. (DEIS:498-499)

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4. The Park Service Must Respect and Protect Ethnographic Resources

“Ethnographic resources are defined by the National Park Service in Director’s Order 28 as a “site, structure, object, landscape, or natural resource feature assigned traditional legendary, religious, subsistence, or other significance in the cultural system of a group traditionally associated with it.” Ethnographic resources typically hold significance for traditionally associated groups whose sense of purpose, existence as a community, and identity as an ethnically distinctive people are closely linked to particular resources and places.” (DEIS:242)

See the list of twenty-four tribes at DEIS:242-243 for the many tribes

“traditionally associated” with lands now under the management of Grand Teton National Park including the Moose-Wilson corridor. “American Indians have occupied the Jackson Hole area for thousands of years, and places and resources within Grand Teton National Park continue to hold both traditional and contemporary significance for many tribal groups. American Indians often passed through the area following stream and river corridors, or by way of other traditional access routes for hunting and foraging, migration, religious and ceremonial purposes, and other cultural activities. Today, numerous American Indian tribes retain traditional associations with what is now park lands including the Moose-Wilson corridor. “ (Id.) Sierra Club recognizes that the ethnographic resources in the Moose-Wilson Corridor that would be destroyed by road and pathway construction are unique and irreplaceable, and of the highest value.

Therefore, we stipulate that it is clear that Alterative C would best respect and

protect ethnographic resources in the Moose-Wilson Corridor. We agree with the following:

“Outside of the no-action alternative, alternative C would result in the greatest degree of protection for ethnographic resources by retaining existing conditions to a large extent and retaining existing road alignments.” (DEIS:508) “Compared to the other alternatives, alternative B would result in substantial disturbance and loss of important ethnographic resources, primarily as a result of ground-disturbing road realignment and development actions.” (DEIS:506) “Compared to the other alternatives, alternative D would result in the greatest degree of disturbance and loss of ethnographic resources by the combined impacts of ground disturbing road realignment and multiuse pathway construction.” (DEIS:511)

5. The Park Service Must Protect Additional Cultural Resources

In addition to the previously identified prehistoric cultural resources in the vicinity of the Moose-Wilson road corridor, it is important to note that prior NPS cultural

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studies have recognized that the road corridor itself is eligible for the National Register of Historic Places (NRHP) under NRHP Criteria “A” and “C.” The road is significant both as an historic travel corridor and as an example of early twentieth century road design and alignment. The corridor vicinity also includes locations with NRHP-eligible architectural resources, including the White Grass Ranger Station and former White Grass Dude Ranch. The NPS is required to consider the significant historic values of all these resources as part of this planning process.

The NPS cultural evaluation of the Moose-Wilson road reveals that the resource still retains a substantial level of historic integrity, although modifications to the road corridor in recent years have diminished several aspects of that integrity. Among these changes are the partial paving of the road, bridge replacement, and construction of the Granite entrance station. It is therefore especially important to carefully consider the possible further impacts to the road’s historic integrity when evaluating potential changes to the roadway corridor, since further integrity losses could possibly render the road ineligible for the NRHP.

All of the alternatives described in the draft EIS will impact aspects of the road’s integrity to varying degrees, but the impacts caused by NPS Preferred Alternative C are less than those associated with other alternatives, and the Sierra Club applauds the selection of an alternative with relatively minimal historic impacts. In particular, we would be concerned with the addition of a Multiuse Pathway to the corridor, as proposed in Alternative D. In addition to the impacts outlined elsewhere in this document, the addition of the Multiuse Pathway would significantly diminish the historic integrity of the road corridor, impacting the corridor’s integrity of “setting” and “feeling,” as defined by the NPS.

In designing specific improvements and alterations to the historic road corridor, the Sierra Club strongly encourages the NPS to make design decisions that will preserve the historic integrity of the roadway corridor to the greatest extent possible, retaining the minimalist, rural nature of the historic roadway design. Increases in roadway width, the construction of large parking areas or developed turnouts, or other changes intended to increase the road’s carrying capacity will all impact the road’s historic integrity and potential National Register eligibility. This is a case where limiting and sensitively designing project components will benefit both natural and cultural resources, making an especially strong case for the implementation of minimally intrusive designs.

The Sierra Club is also largely supportive of the Alternative C proposals for the historic travel routes to the White Grass Ranger Station and Dude Ranch. In particular, limiting vehicular travel to these NRHP sites and removing parking from the vicinity of the ranger station will help minimize impacts to the resources and will preserve the feel of the historic cultural landscape.

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6. Managing Cycling & Protecting Wildlife in the Corridor

Sierra Club supports appropriate cycling as one of the recreational uses in Grand Teton National Park; however, cycling must be managed to ensure the safety of cyclists and wildlife, and must be consistent with the protection of the natural and cultural resources. Cyclists must also accept responsibility to know the conditions of and appropriate behavior on their routes, and whether there are other cycling routes and experiences that would better meet their preferences. There are many options for cyclists in and near Grand Teton National Park.

A very practical context in which to consider the cycling opportunities in the

Moose-Wilson Corridor is in the context of available cycling opportunities in other areas of Grand Teton National Park and nearby. Currently, there are many miles of separated pathways for cyclists to choose from during the non-snow cycling seasons (DEIS:304), as well as many miles of shared use paved and unpaved roadways to cycle on safely. There is also the unique opportunity for cyclists to cycle on the inner Park road from Bradley-Taggart parking to Signal Mountain in the spring when it is cleared of snow, but not open to automobile traffic. Under Alternative C, the Moose-Wilson Road will be yet another choice for cyclists to safely share a road where the speed limit is the lowest of any paved road in the Park. As also noted by an expert report submitted to the Park Service:

“Since 2012, (Grand Teton National Park) has had about 14.2 miles of multi-use pathway available for walking, rollerblading, and biking. The first 7.7 miles of multi-use pathway between Moose Junction and Jenny Lake Visitor Centre along the Teton Park Road was opened in 2009 (Phase 1). A second 6.5 miles of pathway from Moose Junction to the Gros Venture (sic) River opened in spring 2012 (Phase 2). This segment connects to a Jackson Hole Community Pathway that extends south from the Gros Venture (sic) River to the town of Jackson, Wyoming. The Jackson Hole Community Pathway system also has a route along WY 390, which extends from WY 22 north to the GRTE boundary at Granite Canyon entrance station on the southern border of the (Moose-Wilson Corridor).” (MacHutchon 2014:40)

National Park Service policy prevents construction of bicycle routes that

adversely affect important park values:

“NPS Management Policies 2006 addresses the development and designation of bicycle trails in section 9.2.2.4. It states that “the designation of bicycle routes is allowed in developed areas and in special use zones based on a written determination that such use is (1) consistent with the protection of a park’s natural, cultural, scenic, and esthetic values; (2) consistent with safety considerations; (3) consistent with management objectives; and (4) will not disturb wildlife or other park resources.” (DEIS:16)

The most harmful proposed alternative to accommodate cycling in the Moose-

Wilson Corridor, to both people and wildlife, is the construction of a multiuse pathway as

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described in Alternative D. Sierra Club strongly opposes a separated multiuse pathway. As noted in the DEIS, “The proposed multiuse pathway under alternative D would cause a significant increase in habitat fragmentation and wildlife disturbance. “ (DEIS:372) “The substantial widening of the Moose-Wilson Road/pathway disturbance corridor would have notable adverse effects on wildlife trying to use habitat along this corridor.” (DEIS:373) “For many wildlife species, including bears, the farther the pathway is offset from the roadway, the greater the overall width of human effect on habitat availability would be (MacHutchon 2014). In addition, the pathway’s alignment around the LSR Preserve would result in two separated disturbance corridors for the length around the Preserve, with the corridors being separated by roughly .5 mile.” This would have “even greater adverse effects on wildlife movement, behavior, and habitat connectivity,” than other segments. (Id.)

Under Alternative D, with the realignment of the Moose-Wilson Road and multi-

use pathway, there would be “increased numbers of human-wildlife interactions (e.g., moose, black bear, grizzly bear, elk) . . . More than 20 acres of existing habitat would be removed over the length of the pathway . . (and) the likelihood of humans startling wildlife as they traversed the pathway is high. This would cause increased stressors on wildlife and could result in defensive wildlife reactions to humans. “ (DEIS:373)

Additionally, construction of pathways can bring unintended consequences in fostering increased off-road and off-trail use:

"(T)he overall increase in non-motorized travelers since the pathway opened (in Grand Teton Park) could potentially increase interactions and possibly conflicts between wildlife and park visitors. This may be particularly true considering the three-fold increase in off-road and off-trail travel in the (pathway construction area) since pathway construction. Previous research demonstrates ungulates are more likely to respond to off-road and off-path activities than the more frequent but predictable activities that occur on linear infrastructure (MacArthur et al. 1979, Cassirer et al. 1992, Knight and Cole 1995, Miller et al. 2001, Papouchis et al. 2001, Borkowski et al. 2006). " (Hardy 2011:40, parentheses added)

In a study of the human use of a 7.7-mile segment of paved multi-use pathway in Grand Teton National Park, researchers found that, "The construction of Phase I Pathway has increased non-motorized travel nearly ten-fold." (McGowen & Gleason 2012:2)

7. Impacts on Grizzly and Black Bears

Sierra Club is very concerned about the impacts of existing levels of human use in the Moose Wilson Corridor on grizzly and black bears, and we are opposed to any increase that would exacerbate impacts on bears. As noted in the MacHutchon study,

“….bears in the MWC are already contending with a high level of human traffic and recreation activity that, for some bears, is probably limiting the availability of seasonally important foods.” (MacHutchon 2014:iv)

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We note the following from the DEIS:

“The Endangered Species Act of 1973, as amended, requires that federal agencies

consult with the US Fish and Wildlife Service before taking any action that could jeopardize the continued existence of any federally listed threatened or endangered species. As a result, the National Park Service must consider potential effects that any proposed action may have on these species. “ (DEIS:189) The grizzly bear is listed as Threatened under the ESA; Canada lynx is also listed as threatened; gray wolf is Nonessential experimental (Treated as Threatened in NPS units). (Id.:190) “Grand Teton National Park, part of the Greater Yellowstone Ecosystem, is one of the areas grizzly bears still currently inhabit.” (Id.) “Grizzly bears require large home ranges (50 to 300 square miles for females; 200 to 500 square miles or more for males), encompassing diverse forest interspersed with moist meadows and grasslands in or near mountains.” (Id.) “Since 2007, grizzly bears have been regularly observed in the project area throughout the nondenning period. At least one grizzly bear denned in the corridor in the winter of 2014-2015. . . . For several weeks in the fall when several types of ephemeral berries are available, grizzly bear may be present on an almost daily basis along portions of the road. . . Given the presence of an important seasonal food source for bears, there is a high likelihood of occurrence in the project area, especially in the fall. . . . The greatest threat to grizzly bears is human-caused mortality. More than 80% of the grizzly bear mortalities in the Greater Yellowstone Ecosystem result from human causes . . . “ (Id.:192) “Management of bears along Moose-Wilson Road is particularly challenging due to limited sight distances (due to the narrow winding road, uneven terrain, and roadside vegetation) and the roadside food sources (berries). All of these conditions make it difficult to safely manage grizzly bears and visitors along the road (NPS 2012).” (Id.:194) “A separate biological assessment is being prepared that analyzes the effects of the preferred alternative on the grizzly bear, Canada lynx, gray wolf, and greater sage-grouse in accordance with the Endangered Species Act. The biological assessment will be submitted to the US Fish and Wildlife Service for their concurrence and will be included in an appendix in the final environmental impact statement.” (DEIS:627-628)

As noted above, we support the Park Service’s Preferred Alternative, which

precludes a separated multiuse pathway. Numerous studies warn of adverse effects of such pathways on both bears and people, primarily from surprise encounters. We are particularly concerned about impacts on females, “the cohort most likely to be involved in an aggressive grizzly bear-cyclist encounter,” (MacHutchon 2014:39) and female bears consequently being killed. In the 2006 GTNP Transportation Plan FEIS several authorities on grizzly bears expressed concerns about increasing conflicts between people and grizzlies in regard to pathways. Brian T. Kelly, with the US Fish and Wildlife Service, expressed concern that pathways through grizzly habitat,

"will encourage unpredictable encounters and increase the likelihood for grizzly/human conflicts rather than minimize them. . . . These potential impacts

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are not only negative to grizzlies and human health and safety but run counter to the Parks' stated management objectives." (Letter 129651 at NPS 2006: 323)

In the 2006 GTNP Transportation Plan FEIS, the National Park Service explains:

"Indirect impacts associated with construction and use of the multi-use pathways inside and outside of the roadway corridor by more pedestrians and bicyclists would include human-caused displacement of bears from adjacent areas, potential habituation to humans (Herrero 1985), and possibly other behavior modifications. . . . . The creation of non-motorized corridors (i.e., multi-use pathways) is expected to result in an increase in non-motorized use of these areas. Bear-human encounters in these areas would increase because of increased human use and because of the added surprise factor that quiet, non-motorized use represents. . . This is particularly true where roads and pathways traverse habitats where terrain and/or vegetation limit sight distances, or where noise from streams can cover noise of approaching humans. Serious human injuries from such encounters are likely to occur . . . . " (NPS 2006: 210)

"Adding multi-use pathways in this (Moose-Wilson Road) area, along with varied terrain, heavy cover, and several noisy stream crossings, would escalate the probability of human-grizzly bear encounters and associated human injuries." (Id.: 211)

Chris Servheen , Grizzly Bear Recovery Coordinator for the US Fish and Wildlife Service, also raised concerns in the Transportation Plan FEIS,

"about the Moose-Wilson road corridor, in the SW corner of the park, where excellent bear habitat exists, black bears occur at high density, but at this time grizzly bears are mostly absent or at low density. A separated pathway there will have impacts on black bears, moose, and other wildlife, and will eventually involve grizzly impacts in the near future as bears continue to colonize in the south end of the park." (Letter 129648 at NPS 2006:322)

Additionally, a multi-use pathway would destroy important bear habitat in the corridor:

“…like roads, the physical surface of pathways results in direct loss of habitat. Human use of the pathway can reduce effective habitat near the pathway because of bear displacement. Bears could change their behavior around a pathway, such as becoming more night active. “ (MacHutchon 2014:40)

In another study on the impacts of Phase 1 of the 7.7 mile multiuse pathway on black bears, researchers “found the presence of the pathway resulted in direct loss of habitat from the pathway surface, new human activities in the corridor, and a wider zone of human use than just the presence of the road.” (Costello et al. 2011)

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8. Alternative C Best Ensures Cyclist and Bear/Wildlife Safety

In contrast to all other Alternatives, Alternative C allows cycling in the manner which best protects users and natural resources. “Alternative C would not construct a separate multiuse pathway. The existing Moose-Wilson Road would be designated as shared use,” (DEIS:139), thereby greatly diminishing the likelihood of a surprise encounter between cyclists and wildlife, compared to a separated multiuse pathway. Additionally under Alternative C, the unpaved section of the Moose-Wilson Road will be paved “to improve biking safety and enhance visitor experience,” improved signs will “safely guide bicyclists through the corridor,” and, the speed limit for all vehicles, autos and bicycles, will be reduced along the entire roadway, “to improve bicyclist safety.” (DEIS:153) Improved turnouts and parking lot capacities for autos, “safety edges” along each side of the paved road, and vegetation setbacks to improve visibility would all benefit cyclists by managing autos and shared uses of the roadway much better and safer than current conditions. (DEIS:559 and 560). Cycling would also be allowed on the Moose-Wilson Road “during seasonal periods when the road is closed to motor vehicles . . . when (the road) is free of snow and ice.”

Additionally, the “sequenced entry system” for autos managed at both the north

and south entry kiosks would also improve the cycling experience on the Moose-Wilson Road. “By managing use levels over time through a sequenced entry system, visitors who enter the corridor would have the opportunity to experience the corridor in an uncongested and relaxed manner compared to average current peak levels.” (DEIS:561) The safety of the cycling public is a concern for all who visit the Park and must be a significant concern of the National Park Service. Sierra Club shares that concern. Alternative C, with the shared use road, ensures that cyclists and wildlife, under careful management of cycling times and locations, can coexist in the Moose-Wilson Corridor. Cyclists must be educated on appropriate behavior in wildlife habitat, must accept responsibility for their behavior and safety, must be aware of conditions and appropriate behavior in the Moose-Wilson Corridor, and must be aware of alternative cycling locations that may better meet their preferences. The Park Service must continuously monitor the shared use road and manage visitors during times when people and wildlife are in the same areas. 9. Additional Measures to Protect Bears and other Wildlife

Sierra Club particularly supports the following elements of Alternative C that will help protect wildlife and wildlife habitat:

1) Realignment of the northernmost .6-mile section of Moose-Wilson Road 2) Reduced speed limit and limiting the number of vehicles entering the corridor

during peak use periods through timed sequencing

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3) Relocation of the Death Canyon Trailhead and conversion of the unpaved portion of the access road to a trail.

4) Restoration of more natural hydrological patterns and wetland connectivity in the section of Moose Wilson Road between the Sawmill Ponds Overlook and Death Canyon Road junction.

5) Closing one equestrian parking area.

Alternative C does not include realignment of Moose Wilson Road between the Sawmill Ponds Overlook and the Death Canyon Road junction, which, as the DEIS points out, could in some ways be beneficial to wildlife, and a measure for which the Sierra Club would normally advocate. However, we understand the importance of the Native American sites in the area to which the road would be relocated, and for that reason support the Preferred Alternative C, but we urge the Park Service to take all possible steps to further protect wildlife in this critical area within the existing road alignment.

As indicated above, we also recommend that the Park Service implement the following additions/modifications to Alternative C in order to better protect wildlife and other natural resources:

1. The Park Service should limit traffic to levels that will not adversely affect wildlife, including considering completely closing the road, during early morning and dusk time periods during peak use seasons when the timed sequencing techniques are in operation. As noted in the DEIS, “it is possible that some degree of a morning and evening pulse of traffic could occur…to get into the corridor before the time sequencing system activates for the day. If this occurs, it would have some adverse effects on the behavior of crepuscular wildlife along Moose-Wilson Road in mornings and late afternoons early evenings because crepuscular species are much more active during these periods. Historically, crepuscular species have benefited from lower traffic volumes in the corridor during the early morning and early evening hours…if this traffic phenomenon occurs, several species (bears, moose deer) may be forced to rely on lower quality foraging habitat/areas.” (DEIS 361)

2. Increase the length of the unplowed section of Moose Wilson Road as

outlined under Alternative D (Granite Canyon Trailhead to Sawmill Ponds Overlook). Winter in Grand Teton is a harsh time for some wildlife and elimination of any potential stressors would help to protect wildlife. As noted in the DEIS, “This change would reduce impacts on wintering wildlife behavior from vehicle traffic, visitor use, and park operations…this reduction in human disturbances (e.g. noise, human presence) in the backcountry would have beneficial effects on wildlife and habitat. (DEIS: 375)

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3. Cap use during non-peak periods at current levels (rather than allowing increased capacity of 550), to avoid any additional impacts on wildlife from increased human use of the corridor.

4. Consider creating fewer turnouts in the section of Moose Wilson Road

between the Sawmill Ponds Overlook and Death Canyon Road junction. Currently, four turnouts are proposed in this wildlife-rich section under the Preferred Alternative. Although we understand and support the desire to reduce impacts from people parking in undesignated areas, we are concerned about more people having closer encounters with wildlife than they otherwise would. As noted in the DEIS, “…by providing turnouts for up to 120 vehicles, visitors driving through the corridor may actually be encouraged to stop along the road if they see wildlife when otherwise they would continue driving at slow speeds…this possible increase in vehicle stopping (and/or visitors leaving their cars) due to designated turnouts could have an adverse effect on wildlife behavior….and wandering off-road could be expected.” (DEIS: 363)

5. Whenever vehicles enter the Moose-Wilson Corridor carrying appreciably

more than the “people per vehicle average of 2.7” (DEIS:639), the Park Service should account for that additional number of people in the corridor and debit a corresponding number of autos accordingly until that vehicle exits.

6. The Park Service should maintain the curvilinear characteristics of the

Moose-Wilson Road which encourage slow speeds, and consider installing rumble strips or speed bumps to keep traffic speeds at or below 20 miles per hour.

7. During peak use times, when some autos may be queuing up, waiting to

enter the Moose-Wilson Road from either the south or north entrances, drivers should be required to shut off their engines and not idle in order not to contribute to pollution. The same for autos within the Corridor, safely parked in turnouts or parking lots off the road for viewing opportunities.

8. The Park Service should not allow motorcycles on Moose-Wilson road

that are so noisy as to disrupt the natural soundscapes and visitor experiences.

Given that “the surrounding topography and vegetation between Death Canyon Road and Sawmill Ponds Overlook makes achieving the parkwide standard of visitors being 100 yards away from bears and wolves difficult to maintain” and that “if visitors see wildlife from the road in this wetland habitat area, they are already likely less than 100 yards away,” (DEIS: 346) we are very concerned that additional turnouts will

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negatively impact wildlife behavior and cause unsafe situations for both wildlife and people. In any case, it is imperative that the Park Service does indeed implement “increased use of park staff and volunteers to assist in maintaining parking management during high wildlife activity periods” as promised in the Preferred Alternative C, to reduce wildlife behavior disturbances from human activities .

We commend the Park Service for closing the road when bears are present in the Corridor, and urge the Park Service to continue to implement and enforce closures in order to give bears the highest level of protection and space, particularly during fall when bears are in hyperphagia. Research has shown that the most effective protocol to ensure the safety of wildlife and people is to close the Moose-Wilson road when bears are using the habitat on and near the road.

“In the absence of appropriate behavior and action, however, interaction with bears can negatively affect humans by causing injury or property damage. Humans also can negatively affect bears by displacing them from important habitat, changing their activity patterns, changing their habitats, or when conflicts occur, leading to the destruction or relocation of bears. (MacHutchon and Wellwood 2002.)” (MacHutchon 2014:19)

“In recent years, (Grand Teton National Park), like Yellowstone National Park to the north (Gunther et al. 1999, Haroldson and Gunther 2013), have put less emphasis on direct management of roadside bears and more emphasis on managing people at bear jams. When a bear-jams (sic) is reported or detected, Park Rangers, or, since 2007, Wildlife Brigade staff are dispatched to monitor visitor behavior and prevent visitors from feeding bears or approaching them too closely (Wilmot and Cain 2012). They also have used no stopping zones and temporary closures to reduce the need to haze, capture, move, or destroy bears that frequent roadside corridors. These management approaches have made human behavior more predictable to bears, prevented bear-inflicted human injuries at bear-jams, and largely prevented people from feeding bears (Haroldson and Gunther 2013).” (Id.:28-29) “(M)anagement of people rather than direct management of bears likely has increased the overall amount of habitat in GRTE available for use by bears and reduced the number of management mortalities of bears.” (Id.:29)

In contrast to Alternative C, under Alternative B and D, moving the Moose-

Wilson Road east (and under Alt D, a multiuse pathway), “would result in further habitat quality degradation, loss, and fragmentation in the newly developed road corridor through the sagebrush flats. In addition, wildlife behavior disturbances would result from visitor activity on and off designated trails near the wildlife viewing areas.” (DEIS:376)

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“(T)he most notable adverse effects of alternative D on wildlife habitat and behavior would be the significant net increases in ecological disturbances, habitat loss, and fragmentation in the corridor by introducing a second primary human use corridor through the length of the project area- the multiuse pathway.” (DEIS:379)

10. Protection of Wetlands and Hydrologic Functions

The Moose-Wilson Corridor, while modest in size at approximately 10,300 acres, has abundant surface water features. Fed by high elevation snowmelt, the Corridor boasts ponds and lakes, streams flowing into the Snake River, and wetlands and springs throughout. Of particular concern among the waters are wetlands.

“The interconnected wetlands and beaver ponds in the Sawmill Ponds area is the most notable wetland complex in the project area. Given the large size and diversity of this wetland complex, and its proximity to Moose-Wilson Road, these wetlands attract a large number and wide variety of wildlife as well as a large volume of park visitors (for wildlife viewing). . . . A notable characteristic of many wetlands in the project area is their dynamic nature due to the effect of beaver activity. “ (DEIS:199)

“Wetlands play a vital role in ecological systems and hydrological processes. These natural systems and processes associated with wetlands provide a variety of environmental maintenance functions on local, regional, and global scales. Disruption or removal of wetland functions can alter these broader processes and ultimately inhibit many of these ecological and hydrological values.” (DEIS:199)

“In terms of social or human values, wetlands also provide benefits such as aesthetic open space and places for recreational activities such as birding, wildlife viewing, photography, and nature appreciation. The wetlands along the Moose-Wilson corridor provide a high level of these social values given their proximity to a popular park visitation area.” (DEIS:200)

The Executive Order 11990, “Wetlands Protection” requires the National Park

Service to, “(1) exhibit leadership and act to minimize the destruction, loss, or degradation of wetlands; (2) protect and improve wetlands and their natural and beneficial values; and (3) refrain from direct or indirect assistance of new construction projects in wetlands unless there are no feasible alternatives to such construction and the proposed action includes all feasible measures to minimize damage to wetlands.” (DEIS:14)

It is unfortunate that the Moose-Wilson Road impacts important wildlife habitat in this area.

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“(T)he (Moose-Wilson) road fragments some . . . habitats and human use of the road has notable effects on wildlife behavior.” (DEIS:178) “(T)he road corridor passes, and effectively constrains, the relatively large acreage of beaver-created wetlands on the east side of the road. Moose, waterfowl, migratory birds, amphibians are common in this area. The narrow, winding road fragments this valuable wetland habitat from the adjacent steep hillsides covered with fruit-bearing trees and shrubs on the west side of the road (an area where black bears and grizzly bears commonly forage in summer and fall). The road also limits beaver activity in this area, as beaver pond water levels are currently managed by park staff to minimize road flooding. This segment of the road corridor provides quality habitat for black bear, grizzly bear, moose, elk, beaver, and owls, and possesses some of the most diverse wildlife habitat in the entire corridor.” (DEIS:178-179 parentheses in original)

However, given the geographical constraints of the Corridor, and the existence of

important archeological sites east of the current roadway, there are no “feasible alternatives” to leaving the Moose-Wilson Road in its current location. As the DEIS explains (and with which our comments concur as described in the Archeological and Ethnographic Resources sections above), moving the road to the east under Alternatives B and D would destroy American Indian sites which by the NPS Organic Act (DEIS:13), and by Executive Orders, the Park Service is directed to protect (Executive Orders 11593 and 13007, DEIS:14-15). Therefore, Alternative C is the most feasible alternative and must include “all feasible measures to minimize damage to wetlands.” (Executive Order 11990, DEIS:15)

Leaving the road alongside the wetlands without significant engineering improvements, as described in Alternative A, No Action, is not feasible either. Under Alternative A:

“(T)o protect against road flooding and erosion along Moose-Wilson Road, park staff have to artificially manipulate water levels on beaver ponds adjacent to the road. Aside from direct effects on individual beavers, this type of maintenance also modifies local hydrology that can have secondary effects on downstream wetland habitat. And the presence of park staff (performing operations and other management activities) in the project area can cause direct disturbances on wildlife and wildlife habitat.” (DEIS:189 parentheses in original) “Because wetlands are protected by various laws, the boundary of the protected wetland is important to determine before any development or construction is approved by various governmental agencies.” (DEIS:200)

While Sierra Club remains concerned that leaving the Moose-Wilson Road in its

current alignment from Sawmill Ponds Overlook to Death Canyon Road junction under Alternative C will continue to “adversely alter the Ecological Communities and Wildlife fundamental resource and value,” in this area (DEIS:369), reconstruction of the road, “to

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improve hydrological connectivity, (and) improve wetland habitat,” would actually result in important ecological benefits. (Id.)

“(T)he reconstruction of the road segment to improve hydrological

connectivity between Death Canyon Road and Sawmill Ponds Overlook would still have appreciable long-term beneficial effects on wetland areas 1, 4, and 5 and some of their ecological functions.” (DEIS:415) “Collectively, across all beneficial and adverse effects, alternative C would offer an appreciable improvement to wetland conditions relative to alternative A. . . . Although the most notable adverse effects to wetlands under alternative C would continue to be considerable in the area between Sawmill Ponds Overlook and Death Canyon Road, given the relatively localized nature of these effects, these adverse impacts on wetlands would not likely be significant.” (DEIS:420)

Therefore, the Park Service must use all feasible measures to mitigate the adverse

effects to hydrologic functions, wetlands, and associated biota, plants and animals, vertebrates and invertebrates, when reengineering the road along it’s present alignment in the wetlands between Sawmill Ponds overlook and Death Canyon turnoff.

The Park Service also must, at the earliest opportunity, “Conduct a wetland survey by qualified NPS staff or certified wetland specialists to certify wetlands within the Moose-Wilson corridor and to accurately identify locations of wetlands and open water habitat.” (DEIS:117) “(I)t must also be noted that wetland areas in the project area are in constant flux and evolution. This is particularly prevalent in the project area due to the additional dynamic variable of beaver activity, which has the potential to alter surface flows frequently and substantially.” (Id.:200)

This area of the Moose-Wilson Road and its proximal habitats will need to be

monitored and stewarded in the most careful and diligent manner by the Park Service in order not to further harm and to actually improve wildlife habitat, wildlife use, and visitor experiences. Managing auto traffic volume, speed, and flow, managing cyclists, educating visitors, and continuous interaction with visitors to achieve compatible human behavior in wildlife habitat, and minimizing the effects of the roadway on hydrologic function in this area will all be critically important for the duration of the Comprehensive Management Plan and beyond. 11. Climate Change and Hydrology

The National Park Service acknowledges that NPS-managed landscapes in the U.S. Northern Rockies are experiencing and are vulnerable to climate change. “The effects of climate change have already been documented in the Greater Yellowstone Ecosystem region (Gonzalez 2012; Chang and Hansen 2014).” (DEIS:171) “Climate change has a high potential to adversely affect future conditions of the Greater

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Yellowstone Ecosystem, including the Moose-Wilson corridor of Grand Teton National Park.” (DEIS:129)

Some additional indicators that climate change will affect future conditions in the

Moose-Wilson Corridor are:

“Analysis of snow course and tree ring data from sites across the Rocky Mountains, including in the Greater Yellowstone Ecosystem, have detected snowpack melting in the 20th century greater than any time since AD 1200 and attributed the melting to climate change. “ (DEIS:172) “The ratio of snow to rain has decreased and spring flows are starting earlier- attributed to a documented shift in spring warmth (10 days early for the Yellowstone region during the second half of the 20th century).” (Id.) “Changes in climate have favored insect outbreaks resulting in increased mortality in conifer forests.” (Id.) “The Greater Yellowstone Ecosystem is projected to be largely snow-free on April 1 by 2075 under the highest emission scenario as a result of warming temperatures and a declining snow water equivalent.” (Id.) “The aridity of the region is projected to increase between 7% and 18% by 2100. While mean annual precipitation is projected to rise, these increases will not be adequate to offset increases in potential evapotranspiration that will result from increases in temperature; therefore, aridity is projected to increased (sic).” (Id.)

“(W)ith warming temperatures, the length of the growing season for the Greater Yellowstone Ecosystem would be expected to increase. Increased spring and summer temperatures and an earlier spring melt have been associated with higher large-wildfire frequency, longer wildfire durations, and longer wildfire seasons (Westerling et al. 2006), potentially resulting in major changes to vegetation.” (DEIS:172-173) “(S)ome species of plants and animals are less resilient to changes in climate conditions.” (DEIS:173) “(In a warmer, drier climate) sedges, rushes, and other mesic plants may lose habitat, as well as amphibians and birds that rely on this habitat (Ashton 2010; NPS 2013).” (DEIS:173 first parentheses added) “Climate change is also expected to affect wildlife in the area. . . . Climate change is predicted to cause birds to shift their range, migratory patterns, and timing, and interfere with reproduction. The current trend of grizzly bear males to den later would continue. Impacts on amphibians could include earlier breeding, resulting in more frequent exposure to killing frosts and a longer larval period because water temperatures warm more slowly in early spring, leading to higher larval mortality.” (Id.)

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Furthermore,

“Temperature increases are more pronounced during the cool season (Hamlet and Lettenmaier 2007). In the Northern U.S. Rocky Mountains, annual rates of increase are roughly 2-3 times that of the global average (Vose et al. 2005; Bonfils et al. 2008; Pederson et al. 2010; Hall and Fagre 2003) . . . a major portion (of the warming temperatures) is attributable to human-influenced changes in greenhouse gas and aerosol concentrations.” (NPS, Oct 2010b:31-32, parentheses added) “For much of the interior western United States, the multi-model average projects an annual mean warming of about 2 degrees C (4degrees F . . . ) by 2015.” (Id.:47) “Temperatures for the CR-GYA (Central U.S. Rockies and the Greater Yellowstone Area) increased 1-2degrees C (2-4degrees F) during the last century, with the greatest increases occurring in the second half of the 20th century (Vose et al. 2005; Bonfils et al. 2008; Mote 2006, 2003). . . . . Increasing winter and spring temperatures have resulted in reduced snowpack, earlier spring snowmelt and peak flows, and, in some cases, lower summer flows for major basins (Mote 2006; McCabe and Clark 2005; Stewart et al. 2004; Hidalgo et al. 2008).” (Id.:38)

While admittedly, “the long-range and cascading effects of climate change are just beginning to be understood.” (NPS 2010a:5, emphasis in original) the National Park Service has determined that units in the Northern Rockies are particularly vulnerable to a warming climate. Models and empirical measurements indicate significant changes and impacts to the bioregion that includes Grand Teton National Park. “Glaciers have been receding since the 1850’s,” in Grand Teton Park. . . . Due to their sensitivity to precipitation and temperature, the glaciers are important indicators of regional climate change (Granshaw and Fountain, 2006).” (Tootle et al. 2010:1) The three glaciers studied in Grand Teton (Teton, Middle Teton and Teepe) experienced, “a decrease of 25%” from 1967-2006. (Id.:abstract) Despite short periods of growth, “six glaciers in the Teton Range, Wyoming, decreased in ice area from 1956 – 2010.” (Reynolds 2011:Abstract ix)

With warmer summer temperatures, “The mean annual runoff is projected to increase, with pronounced increases in the spring runoff, more extreme spring peak runoff volumes, and decreases in the summer.” (DEIS:172) During the implementation of Alternative C, the Park Service must take into account the anticipated runoff regime in the engineering and construction of the Moose-Wilson Road and Death Canyon-White Grass Ranch Road. Bridges, culverts and borrow ditches must be designed and built so as not to impede hydrologic function. Since there is no feasible alternative to keeping the Moose-Wilson Road in its current alignment from Sawmill Ponds Overlook south, and since the road has had adverse impacts to waterways, the Park Service must mitigate the impacts of the road, and must restore and protect unimpeded surface and subsurface water flows as best as possible.

“(Under Alternative C) the most notable beneficial effects on hydrology would relate to the reconstruction of Moose-Wilson Road between Sawmill Ponds Overlook and Death Canyon Road to improve drainage conditions and restore

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some aspects of hydrological connectivity between Reserve Creek and Stewart Draw drainages and the downstream wetlands. This action would also benefit the wetland hydrology downstream (to the east) of the road alignment.” (DEIS:439 first parentheses added, second parentheses in original)

While not everything is known about the effects of a warming climate on natural

ecosystems and cultural resources in Grand Teton Park, “(A) management approach that enhances the protection and resilience of climate-sensitive resources is becoming increasingly important.” (DEIS:129) As stated in the DEIS, the NPS must, “Restore key ecosystem features and processes and protect cultural resources to increase their resilience to climate change.” (DEIS:130)

Sierra Club supports the Park Service’s commitment to, “Reduce or mitigate greenhouse gas emissions associated with park operations and visitor use such as [implementing] alternative transportation options (e.g., shuttles and low-emission vehicles for the park’s fleet) and biofuels and other renewable energy sources for visitor center and administrative buildings.” (DEIS:131 brackets added)

Very importantly, the Park Service can also, “Use the fragile environments of the Moose-Wilson corridor as an opportunity to educate visitors about the effects of climate change on the resources they are enjoying. (And) inspire visitors to take action through leadership and education.” (Id. parentheses added) The Park Service commits to, “Manage the facilities and infrastructure . . . . within the Moose-Wilson corridor in a way that prepares for and adapts to the effects of climate change.” (Id.) The Sierra Club supports these and other actions described in the DEIS to address the impacts of climate change. 12. Wilderness character

For nearly 125 years, Sierra Club has advocated for the protection and enhancement of wilderness on America’s public lands. Our members and supporters want the Park Service to protect and enhance lands with wilderness qualities now and for future generations.

We agree that:

“The Moose-Wilson corridor contains areas of potential wilderness and borders recommended wilderness. Preserving the acoustic environment and the natural soundscapes of such areas are critical to effective wilderness management and can have important effects on wilderness character. Natural soundscapes and the absence of anthropogenic noise are crucial components of the wilderness qualities of solitude, naturalness, and undeveloped character. Noise, often from distant roads, park operations and maintenance activities, or aircraft overflights is one of the most common and pervasive human influence on the primeval character of wilderness. “ (DEIS:257)

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While acoustic values and solitude are very important wilderness characteristics

that the Park Service must protect and enhance, there are others equally important.

“Addressing impacts on wilderness requires a clear understanding of the five qualities of wilderness character for these qualities to be protected in accordance with the mandate of the Wilderness Act. These qualities include: (1) untrammeled, (2) natural, (3) undeveloped, (4) solitude or primitive and unconfined recreation, and (5) other features and values- which together are referred to as wilderness character.” (DEIS:537)

Sierra Club agrees that Alternative C, with the “implementation of timed

sequencing strategy during peak use periods” and the “limit on the number of people/vehicles at one time in the corridor” (DEIS:539) is the best Alternative to protect wilderness values.

In contrast with Alternative D which would inflict “adverse impacts on wilderness character” (DEIS:541). “Overall there may be a small number of benefits to wilderness as a result of potential decreased use in the recommended and potential wilderness areas under alternative C. . . . Overall, alternative C would contribute a small beneficial increment to the impacts on wilderness character in the corridor. There would not be significant adverse impacts caused by actions under alternative C.” (Id.:540)

As indicated elsewhere in these comments, Sierra Club encourages the Park

Service to explore speed-reducing mechanisms such as speed bumps and/or rumble strips in pavement on Moose-Wilson Road. The Park Service should determine what level of noise rumble strips might generate and if that noise adversely affects natural values, wilderness character, and visitor experiences.

The Park Service should also prevent extremely noisy motorcycles from

disturbing natural soundscapes, wilderness character, and visitor experiences in the Moose-Wilson Corridor. 13. Traffic and Transit

As noted earlier in these comments, “Currently, there is high demand for and high levels of use in the corridor during peak summer months. The levels and patterns of visitation are causing some negative impacts and influencing the ability of the National Park Service to achieve desired conditions.” (DEIS:636)

The primary reason for the negative impacts is human use enabled by unregulated auto traffic.

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“The corridor is primarily reached via personal vehicles. The experience of driving in the corridor is a sought after visitor experience and consistent with desired conditions of the corridor. “ (Id.:636)

While cycling and hiking are excellent options to enjoy the Moose-Wilson

Corridor, auto traffic will continue to affect natural resources and visitor experiences as long as there is a road on which to drive.

“(U)nder all the action alternatives, existing traffic levels would be maintained, or possibly reduced from current levels(.)” (DEIS:26) However, “Potential increased visitation in the long term in the corridor is anticipated under alternative C in the off-peak times (e.g., morning) and shoulder months compared to existing conditions because visitors would avoid congested peak times when they would have to wait to travel the corridor.” (DEIS:594) “Proposed road improvements, including paving the unpaved road segment, correcting drainage issues, vegetation setbacks, and adding turnouts, would reduce congestion and visitor conflict by improving traffic flow and increasing visibility for drivers. Increased use of park staff and volunteers would also help improve traffic flow around wildlife jams by controlling and directing traffic and increasing visitor education on appropriate behavior around wildlife.” (DEIS:561)

It is unrealistic to expect cycling to reduce auto traffic anywhere in Grand Teton

Park, including the Moose-Wilson Corridor. In a study of a phase of multi-use pathways in Grand Teton Park, “automobile traffic did not change over the duration of the (four year) study (Sawyer et al. 2011).” (Hardy 2011:40 parentheses added)

Alternative motor vehicle transit can be considered as an alternative to all or some vehicle use. Park staff, volunteers and the visiting public can be encouraged to use shuttle transit overseen by the Park Service. Transit should be by small vans appropriate for the narrow Moose-Wilson Road. However, if shuttle transit is implemented, such a program must not facilitate levels of use that would harm natural or cultural resources and visitor experiences.

“(I)n the future alternative transportation systems could be implemented as part of this plan. To protect resources and meet desired conditions, the number of people using these sites would need to remain the same, regardless of how visitors reach those destinations. If a shuttle or other system were to be implemented, increased numbers of visitors could be brought into this area, likely resulting in unintentional consequences to resources and visitor experiences. By establishing a visitor capacity related to visitation levels, a shuttle or other system could be managed around that number, therefore maintaining desired conditions and avoiding to resources.” (DEIS:636)

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The Park Service must not allow environmental and experiential conditions to degrade in the Moose-Wilson corridor, even under the auspices of public transit replacing personal vehicles regardless of how well intended. In fact the Park Service’s duty is to restore degraded areas and park values and protect and enhance visitor experience. Future transit discussions should be based on Park purposes, and consider connecting to a broader Park-wide system that benefits the Park and its resources. If adaptive management is ever implemented and shuttle transit is offered as an alternative to personal vehicles partly or entirely in the Moose-Wilson Corridor, the Park Service must monitor conditions and consider the combined impacts of all visitors using the corridor area, and ensure the protection of park resources and visitor experiences.

Under the traffic management in Alternative C, some potential visitors may choose to drive through the town of Jackson during peak times rather than wait in a queue. However, the economic and traffic effects in Jackson would be negligible. “Any small increases in visitor spending that could occur in the town of Jackson would not be measurable. Traffic management (in the Moose-Wilson Corridor) . . . would provide negligible impacts on the regional economy.” (Id.:595 parentheses added)

Overall, under Alternative C, the vehicle time sequencing system, reduced speed limit, occasional road closures, sufficient parking and pullover spaces would “result() in considerable long-term, beneficial effects” to habitat and wildlife. (DEIS:360-361) Additionally, when black or grizzly bears use habitat on or near the Moose-Wilson Road, the Park Service must close the road to ensure the safety of both bears and people.

Also, “The prohibition of (taxis) would reduce the number of vehicles on the road

and the number of through-trips, even during nonpeak visitation periods. This would improve traffic flow and would eliminate the potential for conflict between these users and visitors who often seek exploration, sightseeing, and recreation in the corridor.” (DEIS:578)

For the taxi-using public to or from Teton Village, “(a)lternative C would prohibit nonpark-dependent commercial and taxi use on the road, possibly causing higher travel times and less convenience for those using this route to access the airport. . . . (T)ravel distance would increase for travel to the airport from Teton Village by approximately 8.3 miles. However, because of slower travel speeds along the Moose-Wilson corridor, traveling to the airport via the town of Jackson (without congestion and delays under either route) is one minute shorter in travel time than travel via the Moose-Wilson corridor.” (DEIS:597 longer parentheses in original) Therefore, this impact of prohibiting taxis is negligible.

It is critically important for the Park Service to follow through on mitigation. “Impacts were assessed assuming that mitigation measures would be implemented as part of the alternative management actions to minimize or avoid impacts. If the mitigation measures described in chapter 2 were not applied, the potential for adverse resource impacts and the magnitude of those impacts would increase.” (DEIS:570) This emphasizes the importance of implementing all the mitigation measures such as reduction

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in speed limits, sequencing vehicle entry access to the corridor during peak use periods, sufficient parking and pullover spaces, and improved sight distances, periodic road closures, and many other mitigation measures in order to achieve the necessary levels of safety and resource protection. The Park Service should maintain the curvilinear characteristics of the Moose-Wilson Road which encourage slow speeds, and consider installing rumble strips or speed bumps to keep traffic speeds at or below 20 miles per hour.

During peak use times, when some autos may be queuing up, waiting to enter the

Moose-Wilson Road from either the south or north entrances, drivers should be required to shut off their engines and not idle in order not to contribute to pollutants. The same should apply for autos within the Corridor, when they are safely parked in turnouts or parking lots off the road for viewing opportunities: No idling.

We agree with the Park Service that conditions under Alternative C will improve

conditions for cyclists. For examples: “Cyclists would continue to share the road with vehicles (in Alternative C), but certain enhancements would also improve conditions for those users. The unpaved section of the road would be paved in (Alternative C), which would provide an improved road surface for motor vehicles and bicycles and increase navigability. Paving would generally allow for faster speeds, but the physical design characteristics (e.g., curvilinear road alignment and obstructed sight lines) would still discourage speeding in this alternative. In addition to design limitations, this alternative also includes an overall reduction in the speed limit to 20 mph.” (DEIS:578 first two parentheses added, last parentheses in original)

See the section Managing Cycling & Protecting Wildlife in the Corridor

above for more about cycling safety. 14. Visitor Use, Experience, and Capacity

Given that it is the Park Service’s duty to manage the natural, scenic, and cultural resources in Grand Teton Park “in such manner and by such means as will leave them unimpaired for the enjoyment of future generations” (NPS Organic Act, USC 100101(b) et seq.), the Comprehensive Management Plan must describe specific actions that the Park Service will take to implement its duties. Managing visitor numbers and uses is a critically important element of the Plan.

“The main goal of the planning effort is to preserve the resources and values of the corridor. By managing the number of people in the corridor at one time, park managers can ensure the resources are protected and that visitors have space to enjoy their drive, view wildlife, and park at key destinations.” (Moose-Wilson Corridor Draft Visitor Capacity Determination-Handout (MWCDVCD-H hereafter):1)

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There are indications that better management of visitor numbers and uses are

needed to protect natural and cultural resources.

“Currently, there is high demand for and high levels of use in the corridor during peak summer months. The levels and patterns of visitation are causing some negative impacts and influencing the ability of the National Park Service to achieve desired conditions.” (DEIS:636)

Current uses in the Corridor, at current levels, “would continue to result in

negative impacts on resource conditions and visitor experience (,) . . . potential management strategies such as designated pullouts and improved parking areas, paving the unpaved road segment, and reducing the speed limit were identified to address these impacts and better accommodate current use (levels).” Implementing management strategies to mitigate impacts is critical to maintaining desired use levels and achieving desired conditions. (MWCDVCD-H:2) The public, now and in the future, will be best served if the Park Service utilizes the “precautionary principle” and manages uses in the Moose-Wilson Corridor short of levels that impair or degrade resources and short of levels that diminish the quality of visitor experiences.

“Alternative C emphasizes the important conservation stories within the corridor

and public use of the corridor is balanced with preservation. Management actions within the alternative aim to provide high-quality visitor opportunities while maintaining a high integrity of natural and cultural resources. ” (DEIS:553)

Regarding human use capacity specifically at LSR Preserve: “current levels of use are acceptable; however, those levels are still of concern as an increase could easily push them to an unacceptable range.” (DEIS:641) Under the preferred Alternative C, “the proposed visitor capacity for the corridor would maintain visitation at current levels seen during peak visitation.” (MWCDVCD-H:3)

“The total visitor capacity for the Moose-Wilson corridor has been determined to be 550 people at one time. . . . Where vehicles are specifically managed, the capacity results in approximately 200 vehicles.” (DEIS:644) As stated in these comments above, Sierra Club recommends that the Park

Service should limit traffic to levels that will not adversely affect wildlife, including considering completely closing the road, during early morning and dusk time periods during peak use seasons when the timed sequencing techniques are in operation.

Under the 200 maximum allowed vehicles at a time in the Corridor, “a wait (at the south or north queuing area) would occur on 20 to 25 days of the season. These short waits would only occur during the middle of the day, from roughly 11:00 a.m. to 4:00p.m. The queuing lanes would be designed to accommodate all waiting vehicles within the park.” (MWCDVCD-H:3 parentheses added) Wait time for vehicles wanting

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to drive the Corridor road would be approximately 10-11 minutes “on the busiest day of the summer” in year 2020. (Id.)

Sierra Club stipulates that the wait time is very reasonable in light of the

following benefits for visitor experiences:

“(O)verall, the actions proposed (in Alternative C) would result in substantial beneficial impacts on visitor use and experience. This alternative would increase the types of opportunities available for visitors within the corridor while maintaining current average peak visitation levels. The proposed actions that would have the largest beneficial impacts on visitor use and experience are the proposed sequenced entry system and road improvements. . . . By managing use levels over time through a sequenced entry system, visitors who enter the corridor would have the opportunity to experience the corridor in an uncongested and relaxed manner compared to average current peak levels. . . . Over the long term, a sequenced entry system would result in substantial benefit to visitor use and experience by keeping crowding and congestion relatively stable within the corridor.” (DEIS:561 brackets added)

Alternative C is also the best alternative to ensure that the Key aspects of Monitoring

Guidelines for Visitor Experience in an Outstanding Natural Environment are met:

• “Visitors may immerse themselves in the spectacular natural setting of the Teton Range.

• Visitors have extraordinary opportunities to observe wildlife, experience solitude, explore wilderness, appreciate dark night skies, and listen to natural quiet.

• Visitors can experience a multitude of recreational opportunities, including bicycling, winter use, and equestrian activities.

• Visitors to the Moose-Wilson corridor can become intimately involved in one of the most scenic and rustic road corridors found in any national park.” (DEIS:128)

Sierra Club recommends that during peak use times, whenever vehicles

enter the Moose-Wilson Corridor carrying appreciably more than the “people per vehicle average of 2.7” (DEIS:639), the Park Service should account for that additional number of people in the corridor and debit a corresponding number of average capacity autos accordingly until that vehicle exits. This monitoring and accountability will help ensure high quality experiences for all visitors in the Corridor.

15. Mitigation

As stated previously, the National Park Service must manage Grand Teton National Park and the Moose-Wilson Corridor to a high standard of protection.

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“Congress has charged the National Park Service with managing the lands under its stewardship “in such manner and by such means as will leave them unimpaired for the enjoyment of future generations” (NPS Organic Act, USC 100101(b) et seq.: DEIS:111). “As part of the environmental review, the National Park Service would avoid, minimize, and mitigate adverse impacts. The National Park Service could consider implementing a compliance monitoring program that would apply these mitigation measures and also include reporting protocols.” (DEIS:111-112)

In order to ensure such a high level of protection, the park Service must

continuously monitor the conditions of natural and cultural resources and values in the Moose-Wilson Corridor and implement corrective actions and mitigations “to ensure their conditions are not being degraded.” (DEIS:123) See more in section Compliance, Monitoring and Enforcement in these comments. It is undeniable that in order for natural and cultural conditions to remain “unimpaired”, “mitigation measures to avoid or minimize potential adverse impacts from implementation of the plan” (DEIS:83 emphasis added) are necessary for the Park Service to fulfill their Organic Act.

The Park Service must bring to bear sufficient agency resources to accomplish the requisite levels of monitoring, mitigation and enforcement.

“All available and emerging management techniques would be used to reduce undesirable human-wildlife encounters, particularly during wildlife high-use periods (September through October). This may include the need for additional temporary road closures and increased use of the park’s Wildlife Brigade staffing.” (DEIS:152 parentheses included in original)

Mitigation measures must be part of the decision and openly presented to the

public and interested stakeholders. “If the mitigation measures described in chapter 2 were not applied, the potential for adverse impacts and the magnitude of those impacts would increase. Therefore, the mitigation measures would be incorporated into the record of decision for the selected alternative.” (DEIS:542)

As described elsewhere, some of the most important mitigations will be to ensure

reasonable safety for users and wildlife on and along the Moose-Wilson Road.

“(C)ertain strategies presented would minimize the potential for user conflicts.” (DEIS:579) “Restricting taxis and nonpark-dependent commercial traffic, as well as other through-traffic during peak periods in this alternative would decrease the number of vehicles on the road and reduce the potential for vehicle-bicycle conflicts. This would also be supported through formalized turnouts and improved parking, which would accommodate stopped vehicles and allow more room for cyclists and other vehicles to safely navigate the roadway near the

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shoulder where cars are frequently inappropriately parked during wildlife jams. (Alternative C) would also incorporate a “safety edge” along the road shoulder, which would slightly reduce the potential for injury or property damage due to run-off-road bicycle incidents. (Alternative C) includes paving the unpaved segment of Moose-Wilson Road. This would provide an improved road surface for motor vehicles and bicycles and would increase navigability for both of these user groups. . . . This (road) segment would still maintain its curvilinear road alignment and sight lines would still be obstructed by vegetation- characteristics that both serve to physically limit speeds. . . . Potential for vehicle and bicycle conflict may also continue, but the use of timed sequencing to control traffic near current levels would ensure that this potential for conflict does not become a larger issue. The reduction in speed in (Alternative C) could also serve to reduce safety-related issues and improve public perception of safety.” (Id.: parentheses added)

In particular, Sierra Club feels that it will be critically important for the Park

Service to enforce the speed limit. The presence of Park Service law enforcement vehicles, Park staff, volunteers, speed limit signs, and informational materials will serve to mitigate potential impacts to people and wildlife from unsafe speeds. 16. Do not groom unplowed section of the Moose-Wilson Road

No place in the Moose-Wilson Corridor should be mechanically groomed for winter recreation including the unplowed section of the Moose-Wilson Road between Death Canyon Road Junction (or, per our recommendation, Sawmill Ponds Overlook) and the Granite parking lot. Nor should any new uses such as oversnow use of fat tire bikes or snowmachines be allowed in the Corridor. We recognize that the Park Service will allow wintertime cycling on the Moose-Wilson Road during such times as it is free of snow or ice. 17. Environmental Equity

“The principal of equity acknowledges that there are historically underserved and underrepresented populations and that fairness regarding these unbalanced conditions is needed to assist equality in the provision of effective opportunities to all groups.” (Sierra Club 2015)

Fourteen percent (14%) of Teton County residents are Hispanic. (DEIS:312) In

addition to locally and regionally diverse demographics which include long term and short term residents, the four million visitors to Grand Teton National Park each year consist of diverse ethnicities, backgrounds, and economic strata. In order to recognize the demographics of the regional community, and to acknowledge the demographics of the visiting public, the Park Service must effectively reach out to, welcome, and include diverse visitors to the Park, and to the Moose-Wilson Corridor. “Inclusion (is) the act of

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creating environments in which any individual or group can be and feel welcomed, respected, supported, and valued to fully participate.” (Sierra Club 2015) As leaders in incorporating and celebrating diversity in our advocacy, Sierra Club supports the Park Service’s efforts to seek solutions to any challenges and assist visitors with having a safe, educational, and enjoyable experience in the Moose-Wilson Corridor and throughout Grand Teton National Park. 18. Compliance, Monitoring, and Enforcement

The National Park Service must “Implement compliance monitoring to ensure that the project remains within the parameters of NEPA (National Environmental Policy Act), and NHPA (National Historic Preservation Act) compliance documents.” (DEIS:112)

In addition, the Park Service must consistently monitor conditions within the

Corridor to ensure that the safety of wildlife and humans is protected and there are no significant harmful impacts to the natural and cultural resources of this National Park from the implementation of the Comprehensive Management Plan.

“The National Park Service would conduct regularly scheduled monitoring of key human use areas (e.g., road corridor, trails, turnoffs) to determine if visitation is affecting ecological communities, native vegetation, and wildlife. Populations of various wildlife “indicator” species would be monitored to assess possible effects of visitor use. Wildlife observations, human-wildlife interactions, wildlife jams, traffic incidents, and vegetation disturbance would be documented. Monitoring results would indicate if actions need to be taken to reduce or eliminate the impacts.” (DEIS:125)

Other important Monitoring Guidelines are listed in the DEIS “for park managers

to use to periodically check on the status of the fundamental resources and values to ensue their conditions are not being degraded.” (DEIS:123) Those categories are: Scenery, Geologic Processes, Ecological Communities and Wildlife (part of which is quoted above), Aquatic Resources, Cultural History and Resources, Natural Soundscapes and Acoustic Resources, and Visitor Experience in an Outstanding Natural Environment. (DEIS:123-129) In order for the varied resources to be protected given the current and anticipated levels of human uses in the Moose-Wilson Corridor, the Park Service must follow through on their commitment to monitor the trends and conditions of these treasured resources and promptly implement corrective actions if needed.

One of the most visible, continuous, and basic actions the Park Service must

implement is to enforce the reduced speed limit on the Moose-Wilson Road, 20 miles per hour. (DEIS:579) The safety of people and wildlife depends on this.

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19. Conclusion

In this 21st Century, as the world’s human population climbs steadily towards 8 billion and beyond, among the rarest and most cherished natural resources will be clean, cold, abundant, natural flowing waters; free-ranging, healthy, native biodiversity; public lands managed as wilderness; and opportunities for people to experience intact, large, natural landscapes. The Moose-Wilson Corridor in Grand Teton National Park has all of these resources. Sierra Club supports the Park Service’s efforts to manage these lands and resources so as to pass them on “unimpaired for the enjoyment of future generations.”

We offer our comments on behalf of Sierra Club’s 2.4 million members and

supporters who value Grand Teton National Park including the Moose-Wilson Corridor. Please keep us apprised of any developments in this and connected issues. Sincerely, Lloyd Dorsey Conservation Director Sierra Club Wyoming Chapter Box 12047 Jackson, WY 83002 307-690-1967 lloyd.dorsey@sierraclub.org www.sierraclub.org/wyoming Bonnie Rice Greater Yellowstone/Northern Rockies Senior Campaign Representative Sierra Club PO Box 1290 424 E. Main St., Ste 203C Bozeman, MT 59771 406-582-8365 ext1 bonnie.rice@sierraclub.org www.sierraclub.org

References: Costello, C.M., S.L. Cain, R.M., Nielson, C. Servheen, C.C. Schwartz. 2011. Impacts of a Multi-Use pathway on American Black Bears in Grand Teton National Park, Wyoming. Moose, WY. Hardy, A.R.. 2011. Ungulate Responses to Multi-Use Pathway Construction and Use in Grand Teton National Park, Wyoming. Final Report Prepared for the National Park Service, Grand Teton National Park. Moose, WY.

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MacHutchon, A. Grant. 2014. Human-Bear Interaction Risk Assessment for the July 2014 Moose-Wilson Corridor Management Plan Alternatives. Prepared for Grand Teton National Park. Moose, WY. National Park Service. 2006. Grand Teton National Park Transportation Plan Final Environmental Impact Statement (NPS 2006 in these comments). September 2006. Moose, WY. National Park Service. 2010a. National Park Service Climate Change Response Strategy. Climate Change Response Program. Fort Collins, Colorado. September 2010.

National Park Service. 2010b. Climate and Terrestrial Ecosystem Change in the U.S. Rocky Mountains and Upper Columbia Basin: Historical and Future Perspectives for Natural Resource Management. Natural Resource Program Center, Fort Collins, Colorado. October 2010.

National Park Service. 2015. Moose-Wilson Corridor Draft Comprehensive Management Plan/Environmental Impact Statement (DEIS in these comments). Moose, WY. National Park Service. Unknown year. Moose-Wilson Corridor Draft Visitor Capacity Determination-Handout (MWCDVCD-H herein). Grand Teton National Park. Moose, WY. Reynolds, H.A. 2011. Recent Glacier Fluctuations in Grand Teton National Park, Wyoming. Masters thesis. Department of Geosciences, Idaho State University. Pocatello, ID.

Sierra Club 2015. Diversity, Equity and Inclusion: Sierra Club History, Context and Current Initiatives. 2015. Power Point. San Francisco, CA. Tootle, G. G. Kerr, J. Edmunds. 2010. "Glacial Change in Grand Teton National Park." Submitted to National Park Service May 2010. Moose, WY.