McCAULEY MEADOWS Should be Wilderness NOT New Stables

yose_planning@nps.gov
Fax 209 379 1294

David A. Mihalic, Superintendent
Yosemite National Park
P.O. Box 577
Yosemite, CA 95389

RE: Wilderness Suitability McCauley Meadows ("McCauley Ranch Addition") and Crocker Ridge Comments submitted by Friends of Yosemite Valley
These comments supersede the FoYV comments submitted on July 10, 2002

Dear Superintendent Mihalic:

McCauley Meadows ("McCauley Ranch Addition") and Crocker Ridge were both purchased for and made part of Yosemite National Park (YNP) as a part of the 1984 Wilderness Bill. That bill requires the McCauley Ranch Addition to undergo a wilderness suitability study; not, as the National Park Service has incorrectly asked the public to comment on, whether or not to do a wilderness suitability study. The National Park Service should conduct and prepare, with public participation and adequate prior noticing, an objective, full and complete study for both of these areas to determine possible designation as wilderness by Congress.

While each of these areas is less than 5,000 acres, they are of sufficient size, remote location, and surrounded by additional wildlands to enable its preservation and use in an unimpaired condition. Congress has designated many other areas as wilderness that have limited intrusions or developments, such as roads and are less than 5,000 acres in size. Although a powerline and road exist within a portion of the area, these do not preclude wilderness designation and should not deter the NPS from conducting a full wilderness suitability study. As the Wilderness Act recognizes, with "the increasing population, accompanied by expanding settlement and growing mechanization," it is more important than ever to protect areas which are worthy of wilderness designation as is the McCauley Meadows area.

Ecologically Unique
The McCauley Meadows area is a rare habitat type for its elevation and unique ecologically. It is the only low-elevation south-facing Yosemite Park meadow in the entire Merced watershed. it is a unique ecological zone. A black oak and ponderosa pine forest border its uphill (mostly eastern) side. Crane Creek flows across the bottom of the sloping basin, dividing a low-lying meadow at the south end from the larger sloping meadow to the north. A chaparral ecosystem begins on the west and south sides which is continuous, descending down to the Merced River in its El Portal reach. In the middle is a riparian corridor with a mixed fire history mosaic. This incredible convergence of ecotones should put this area on the top five to ten list of biologically diverse places in the Park, certainly deserving of special protection.

Birds
This area is one of the hottest birding spots in the Park. It contains an unusual overlap of California and spotted towhee; steller and scrub jay; mountain and California quail; nuttall's and black-backed woodpeckers; band-tailed pigeon and mourning dove; warbling, solitary and Hutton's vireos. The SNEP (Sierra Nevada Ecosystems Project) report lists olive-sided flycatcher as a species that is threatened/declining in the Sierra, yet this McCauley area hosts them -- for now. For years, McCauley's has been a hot-spot on the annual Christmas Bird Count, producing a spike of species diversity unique to the area.

Other interesting birds seen at McCauley's are: Woodpeckers -- Lewis, acorn, hairy, white-headed, nuttall's black-backed, red-breasted sapsucker, flicker. Wrens -- house, winter, Bewick's. Flycatchers -- ash-throated, olive-sided, black and say's phoebes. Others -- Lucille bunting, a variety of raptors including the golden eagle, pygmy owl, California thrasher, wrentit.

This area is suitable winter habitat for the endangered great gray owl. Although it appears that no willow flycatcher is known here, it could/should be here and is suitable breeding habitat for the severely threatened willow flycatcher. Their absence could be due to some degradation of the meadow by stock (discussed herein).

Brown-headed Cowbirds are present at McCauley's' during breeding season. These are a serious threat to the health of other breeding songbird populations. The presence of stock brings and encourages these birds. More stock will bring more cowbirds and more loss of native avifauna. Not only should more stock not be brought in, but the present seasonal use should be and can easily be eliminated, protecting and enhancing bird species' populations and species' biodiversity as well as wilderness designation suitability.

Other wildlife at McCauley's include: mountain lion, black bear, bobcat, mule deer, gray fox, coyote, pacific tree frog, California salamander, western rattlesnake, various voles, mice, etc . These species use the wet meadows, stream corridor, bunch-grass meadow, forest areas, and chaparral.There is an isolated population of cottontail rabbits just south over the ridge from McCauley's which could be adversely affected by building stables or conversely protected by wilderness designation.

Water quality:
Impacts to Crane Creek water quality could be substantial by building a stable and developing the area: more topsoil erosion, manure deposition, nitrate loading, all on a Yosemite Park watercourse that is otherwise in good condition, a major tributary of the Merced Wild and Scenic River, upstream of a popular El Portal swimming hole. Here, the NPS might be the major negative impact on the Merced River fishery. Conversely this area could be protected and enhanced through appropriate designation as wilderness.

Recreation:
This area has outstanding opportunities for solitude or a primitive and unconfined type of recreation and is used as such currently. It receives less visitation than many other portions of the Yosemite wilderness. Many people, including members of Friends of Yosemite Valley, visit this area as a quiet contemplative opportunity; to bird-watch, to view the beautiful scenery, including spectacular views of the Merced River Canon -- unintruded by human structures or contrivances -- listen to Crane Creek, to take photographs, draw and paint, hike and observe wildlife, identify plants, and attempt to get in touch with the pre-history Native people's experience of the area.

The area contains the record of a rich Native American/Miwuk/Piute pre-history and of the former McCauley Ranch. This is an area especially valuable for bird watching in the Park ,which has few areas at this elevation without the noise and habitat fragmentation due to development, and is used as such.

Solution to stables location:
The McCauley Meadows area has numerous special and unique attributes that should qualify the area for wilderness designation. However, the Friends of Yosemite Valley remains concerned that the National Park Service has a predisposition to develop this sensitive, predominantly undisturbed area. All four alternatives of the final Yosemite Valley Plan, rushed to completion and approved by the National Park Service in December 2000, improperly and detrimentally propose to develop and consequently degrade this sensitive meadows area.

The Yosemite Valley Plan calls for potential relocation of the Yosemite Valley stables to this area. The inception of this idea seems to stem from one YNP stable employee who thought it would be a good idea. As has been happening with so many YNP plans, an idea, which should be considered and then rejected, instead takes on a bureaucratic life of its own, becomes a plan which becomes a development, and causes further and/or new disturbances and degradations to the ecosystems and the biodiversity of the Park and surrounding areas.

The best option appears to be to leave the stables where they are in Yosemite Valley in the already disturbed area, rather than creating new and/or more negative impacts elsewhere. Moving the stables to McCauley would constitute new building(s), more trucking trips to and from Yosemite Valley with its attendant additional air pollution, upkeep and probably widening of the existing low use road -- mainly used by NPS to bring some horse stock there in the summer. That use can and should be eliminated. As the Yosemite Valley Plan calls for discontinuing the commercial concession rides in Yosemite Valley, that will cut down on the amount of stock needing to be stabled and fed. Reducing concessionaire stock traffic and the questionable High Sierra Camp stock use in wilderness areas would further reduce the need for stables or at least for the current size and amount of stock. This current use significantly degrades the High Sierra Camp areas which are located in Yosemite wilderness and are designated as potential wilderness additions. Those areas are being degraded from stock urine and feces runoff into the Merced River and its tributaries, trampling of trails, and stock feces' droppings bringing invasive non-native seeds.

Without stock use for the Yosemite Valley commercial concession rides, Merced Lake and other High Sierra Camps, the NPS would have little or no need for stock in Yosemite Valley, other than an occasional resupply of backcountry trail crews. Such occasional resupply operations could be conducted using stock staged in the existing Yosemite Valley stable area. That area could be greatly reduced in size or moved outside the Park entirely (as per the previous discussion). Elimination of the stable area from Yosemite Valley will not restore the area, as it is slated to be used for additional administrative purposes.

The McCauley Meadows area today is grazed only part-time, is not developed, and contains wilderness qualities important to be protected. A district-wide administration and stable area would severely impact and degrade the opportunity for solitude and bird-watching, and degrade the meadows, the biodiversity, ecosystems, flora, fauna and water quality. Conversely, the area could and should be protected and used as a wilderness area.

Inadequate public notice and information
The Friends of Yosemite Valley is concerned that the public has neither had adequate opportunity to know about this public comment period, nor about the special attributes of these areas. Indeed, few people knew about the NPS Open Houses and fewer were able to attend. The double-sided sheet on the "McCauley Ranch/Crocker Ridge Wilderness suitability Assessments," which was handed out at the recent NPS Open Houses and only recently posted on the NPS planning web site, did not give even those trying to actively follow and keep up with the many, simultaneous plans and comment periods, time to find out, research the issue and/or view the site and put together comments for the July 31, 2002 deadline (at least extended from the previous July 10th deadline, which had only given FoYV two days notice). In addition, neither the sheet nor the web site offers the public insight into any of the important wilderness attributes of the areas, which obviously exist since Congress included the areas in the 1984 Wilderness Bill. Instead, the sheets appear weighted towards a conclusion that a wilderness suitability study is not needed.

Wilderness Suitability Study
Given the description of the areas above and other wilderness attributes of the areas, the Friends of Yosemite Valley asks that the NPS conduct a full Wilderness Suitability Study for the McCauley Meadows (185 acres) and the Crocker Ridge (253 acres) areas.

EIS
If the National Park Service does not undertake a full Wilderness Suitability Study for the McCauley Meadows area, a full and adequate EIS (Environmental Impact Statement), including adequate baseline studies and surveys of the flora, fauna, water quality, hydrology, visitor experience, and Native American cultural and archeological attributes will never-the-less need to be prepared before any ground breaking occurs.

Thank you,

Joyce M Eden, Co-Director, Friends of Yosemite Valley
10213 Lockwood Dr.
Cupertino, CA 95014

cc: Senator Barbara Boxer
Senator Diane Feinstein

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