Crane Flat Campus Comments -- Great Gray Owl Threatened

Re: Environmental Education Campus Development Center -- Crane Flat
Friends of Yosemite Valley Scoping Comments

Superintendent:

A. INTRODUCTION

One of the main purposes of Yosemite National Park is to pass this Park on as a protected public legacy to future generations. In order to do so, the present generation of children need to be educated to preserve and protect Yosemite and to understand it as a precious national treasure which has been preserved for them and which they need to preserve for the next generation. The children need to understand and respect Yosemite's special natural/ecological values, Native American past and present cultural values, and historic attributes.

A program which intends to implement this is the Yosemite Institute, which has been educating children in Yosemite since 1971. However, it now appears that YI is intending to expand its program in size, to include adults, and to rent out its facilities to other groups and entities as well.

The Yosemite Institute (YI) educates thousands of school-aged students during the school year in week-long programs. Before the high water of January 1997, the Yosemite Institute students were housed for a few days at the Crane Flat Environmental Education Campus and the other days in Yosemite Valley at the cabins with and cabins without baths in the Yosemite Lodge Area. Those cabins were in the flood-plain and were soaked by the high water. Although most of the cabins probably only needed drying out, and some or most replacement of drywall, the National Park Service in its haste to build new, upscale lodging, declared the cabins a flood loss and tore them down -- thus removing the Yosemite Institute student housing in Yosemite Valley. Since then, the students have been housed at increasing expense at Curry Village and sometimes in Yosemite Lodge motel units. This makes YI dependent on the Concessionaire's (Delaware North) inflating lodging costs abetted by National Park Service (NPS) agreements to the rate rises.

The NPS and YI solution at this time appears to be to tear down the existing facilities at Crane Flat, increase the number of students accommodated at Crane Flat (from 76 students and 3 staff using 20,000 sq ft to 200-300 students and 6-8 staff using 45,000 sq ft), and upgrade and expand the Crane Flat facilities and campus. Currently YI houses students at Crane Flat and in Yosemite Valley at the same time, so the current number of students in Yosemite each week is probably around 150.

Many members of Friends of Yosemite Valley (FoYV) have children who participated in and benefited from the Yosemite Institute's environmental education program. Many members of FoYV developed their deep feeling for, connection to Yosemite, and desire to protect the natural and cultural values of Yosemite from participation in outdoor education programs in Yosemite when they, themselves, were children. While we value and support environmental education for children in Yosemite, there are many fatal flaws in the NPS/YI proposal for the expansion of the YI program, as follows (these comments are not intended to be all-inclusive):

B. GENERAL ISSUES

Firstly, it must be questioned whether it is appropriate to have a private entity, rather than a public entity, providing environmental education and interpretation at a monetary cost to children in a public land. It is a shame that the US Congress and the NPS continues to cut the NPS Ranger interpretive program (of natural and cultural Park values NOT interpretation of Park development plans). If there is no "Ranger Rick" present, but instead increasing amounts of commercial "opportunities", amenities having nothing to do with Park values, costs, and fees, what does the US Congress, the National Park Service and the public think public lands are for and how are they valued? We believe there is a huge difference between public lands and values, and private lands and values and that this difference must be preserved.

The proposal to increase the facility and numbers of students at the Crane Flat Center greatly increases the human impact on the sensitive environment at Crane Flat: One-and-one half to two times the numbers of students, teachers, housing accommodations needed, support accommodations such as meals/dining room/cooks, and impacts to the environment. The increase would concentrate and increase the overnight and morning impacts at the Crane Flat area, instead of partly using already developed areas in Yosemite Valley.

Plans for greenbuilding, while laudable (and should be the standard), do not mitigate for an expanded footprint or for expansion in numbers of students.

In other areas of the Park, often visitors and others remark that some of the existing YI groups of children are noisy and disturbing. It appears some schools do a lot more preparation for the YI experience than others and are more selective based on behavior and grades than other schools. Others are concerned about their footprint impact in trampling plants and soils. An increase in numbers of students will only increase these impacts (This goes also to the carrying capacity issue in B., 2) below.) Adding more traffic and buses to the Crane Flat area will increase traffic congestion and create more dangerous driving conditions as traffic moves to and from the Tioga Road to Yosemite Valley.

1) NO INCREASE IN CAPACITY OR FOOTPRINT AT CRANE FLAT OR IN OR AROUND YOSEMITE:
While the Yosemite Institute (YI) provides a valuable environmental education for children, it should not increase in size either in or around Yosemite. It already negatively affects the Yosemite environment and other visitors' quiet experience. This is due to the concentration of the children on the trails and other spots in Yosemite. If YI wants to increase capacity to educate children regarding the environment, a campus in Martinez could be considered linking to the John Muir House and his environmental values, experiences, and writings. This would also provide access to lower and middle income and other communities not well served by environmental education.

2) YOSEMITE VALLEY PLAN'S (YVP) FAILURE TO ADOPT CARRYING CAPACITY:
The Yosemite Institute expansion proposal is another example of the failure of the Yosemite Valley Plan to adopt carrying capacity numbers for the protection of the natural environment, and instead to accommodate an ever increasing growth in visitorship, not only supported by the managers and administrators of the National Park Service (NPS), but actively promoted by NPS (see attachment). The YVP throws out the Carrying Capacity numbers instituted in the 1980 General Management Plan (GMP) and leaves it wide open.

3) YOSEMITE VALLEY PLAN AND THE ENVIRONMENTAL EDUCATION CAMPUS DEVELOPMENT CENTER EXPANSION ALTERNATIVE WILL DEGRADE THE NATURAL VALUES OF YOSEMITE:
Any alternative in the draft Environmental Education Campus Development Center which allows for an increase in the size of the Crane Flat Campus -- by numbers and/or by footprint will demonstrate the failure of the Yosemite Valley Plan to protect the health of the ecosystems and hydrology of Yosemite National Park and the health, survivability, ability to reproduce, and future sustainability of the flora and fauna which depend on them.

It must also be remembered that the wilderness boundary is nearby and must be respected and the wilderness values protected.

C. SPECIES (This is not intended to be all-inclusive)

1) GREAT GRAY OWLS WILL BE FURTHER IMPACTED BY ANY EXPANSION IN NUMBERS AND/OR FOOTPRINT AT THE CRANE FLAT CAMPUS:
The Great Gray Owl (Strix nebulosa) is very rare south of Canada, is listed as an Endangered California species, and is easily disturbed -- disrupting its foraging, nesting, and other processes. There are only around 75 owls in the entire state of CA. "Entire California population of this species is restricted to the Yosemite region,..." "Research suggests that human disturbance, could affect foraging success of this species, which may explain its absence from the [Yosemite] Valley." (YVP, K-25) They probably exist at all due to the existence of the Park, yet the Park proposes to impact and probably cause the demise of some or many of them -- and their ability to reproduce -- through this expansion at Crane Flat. Some or many of them use and probably depend on the Crane Flat area.

How ironic would it be for a children's environmental education organization to be the cause of the degradation of Yosemite's natural values, the death of Great Gray Owls, and elimination of the owls' future generations.

2) "FISHERS [Pacific fisher, Martes pennanti pacifica] HAVE BEEN SEEN WITHIN THE LAST 10 YEARS NEAR HENNESS RIDGE AND CRANE FLAT." (All caps added, YVP K-27) In fact in the last year, a Fisher was unexpectedly seen near the Crane Flat Campus. They are a Federal and California Species of Concern. All the more reason not to increase impacts at Crane Flat and potentially impact this unexpected good indication of their presence. Densities in the central Sierra Nevada where Yosemite is located are very low. (YVP K-27)

3) BATS AND OTHER SPECIES
Yosemite is habitat for many federal and state listed bat species. We can well imagine that the Crane Flat area is habitat for many of these species containing meadow and woodland interfaces. The historic buildings that NPS and YI propose to tear down undoubtedly provide roosting sites for many bats. Even if the buildings are torn down outside of roosting time frames, can NPS ensure that the bats will find suitable new sites in the same approximate areas? There are probably other sensitive species that also depend on the habitat and attributes of the Crane Flat area which would be negatively affected by this proposal.

4) THE PROXIMATE LOCATION OF THE CRANE FLAT CAMPUS TO THE TUOLUMNE GIANT SEQUOIA GROVE INDICATES INCREASED IMPACTS FROM INCREASING OR DOUBLING THE STUDENT POPULATION AT CRANE FLAT.

D. HYDROLOGY, MEADOWS, WETLANDS

Impact on nearby meadows and hydrology. One-and-one-half to two times the number of students will negatively impact the wetlands in the Crane Flat area. And where will YI get increased water to support a campus increase? The Crane Flat campus currently uses a well in the meadow, already an iffy situation.

E. UNDISCLOSED, UNCLEAR, NONCOMPLIANT >

1) WHAT DOES NPS MEAN BY ITS STATEMENT on the planning web site, "This center (the NPS's Environmental Education Campus) will serve the unmet current and future needs of all park partners focused on education and interpretation?" There is no definition of either education or interpretation. Since NPS has been using those two terms to "educate" the public and "interpret" for the public their development plans, and since this statement talks about "future needs" of "all park partners" focused on these, what are the implications of this? Accommodation of more visitors, more students, more unspecified interpretation, more facilities, more impacts to the natural values, and to Native American past and present cultural values? This is very troubling and potentially very negatively impactful.

In addition, the brief, nondescriptive paragraph in the YVP does not disclose that this will be an expansion in numbers served and in footprint. It merely mentions that, "[a]moung the expanded facilities would be a science lab..." It does not disclose the many cumulative impacts at all and, e.g., does not mention the Great Gray Owl.

It does mention in addition to YI groups and park partner interpretive and educational programs (presumably additional partners and programs) "training programs, research and field seminars." These types of programs while they sound all well and good, are in addition to YI programs. What good does it do to study and interpret such values when in order to do this, those very values are put at risk and destroyed? For example the program might teach or interpret, "This was an area that used to support Great Gray Owls, but the development of these structures and the implementation of this program in 2004 served to disturb or destroy the environment which used to support them. They are no longer here."

2) MEETINGS, SEMINARS, CONFERENCES, COLLOQUIUMS: An additional wrinkle to this development is the ongoing and presumably future increase in accommodation of meetings and seminars of other groups. In the past, groups other than YI have inappropriately held meetings or conferences at Crane Flat. We believe that it is appropriate for a children's educational group such as YI to educate the children about Yosemite on-site, as its value is as a hands-on, site-based experience; however, groups whether their subject is Yosemite or not, should not be meeting in Yosemite to discuss Yosemite or its values, and therefore unnecessarily negatively impact Yosemite by being there. Those groups should more appropriately meet in cities where meeting facilities abound for such purposes.

Enticement of additional visitors and groups by holding meetings, seminars, conferences, and/or colloquiums at YI facilities in or around Yosemite especially during the off-season, non-summer months would bump-up visitation (to be clear, we believe this is inappropriate in any season). The concessionaire, Delaware North, would then further profit from the (publicly built) lodging to accommodate the participants, while the Yosemite animals and ecosystems would be further impacted. The late fall/winter/early spring is when the Valley rejuvenates so that sensitive resources can survive the busy summer (or have a better chance); to increase impacts during the shoulder seasons/off-season would be disastrous to Yosemite's ecology.i

3) ALTERNATIVES -- are these merely to make a show of satisfying the National Environmental Policy Act (NEPA), has a predetermination already been made to keep the campus at Crane Flat and expand it -- as on the schematic on the board at one of the NPS open Houses at the East Auditorium, Yosemite Valley Visitor Center. This layout showed an alarming increase both in footprint and amount of accommodations, which would greatly increase the negative impacts discussed in Section C., 1), 2), 3), 4) and Section D. above.

SOME POTENTIAL ALTERNATE SOLUTIONS
None of this should be accomplished by new development in Yosemite National Park.

a. There should be no expansion at Crane Flat or development of a new campus anywhere in Yosemite.

b. If YI wants to expand, a campus in Martinez could be of benefit (see Section B., 1) above).

c. Turn over a Yosemite Lodge motel unit for YI use. Rent from NPS NOT concessionaire: 16 motel rooms turned into dorm rooms by replacement of beds with 4 bunk beds (1 up, 1 down) 16 x 8 = 128 pillows. This would not require any new building construction. Shouldn't the children have the opportunity to have an environmental educational experience in Yosemite Valley? Or will it merely be the élite visitors who can pay the increasingly upscale prices for the existing and the proposed new resort-type developments for the concessionaire (at Yosemite Lodge), to be bulldozed and built with public funds?

d. Evergreen Lodge is an existing facility just outside Yosemite National Park with a similar configuration to the exiting Crane Flat Campus, but in good condition. It was recently for sale and might still be a possibility.

e. Neither Foresta nor Wawona should be considered as appropriate sites. These areas are in the Park and should not be further developed and impacted. The 1980 General Management Plan (GMP) intends Foresta to be restored, not developed. It should not be used for student or additional employee housing for the same reasons as at Crane Flat. Foresta is also Great Gray Owl territory. In the 90's many members of FoYV fought NPS proposed employee housing development in Foresta which would have greatly impacted the Great Gray Owls -- let's not threaten the owls again.

4) PIECEMEAL PLANNING "The Yosemite Institute's Crane Flat facility is not considered in the Yosemite Valley Plan." (YVP III-304)

5) MONETARY INCENTIVES Does NPS get a kick-back from YI expansion (i.e., do additional revenue opportunities for YI also mean increased revenue sharing with the NPS?) from YI additional outside rentals? Does NPS have a monetary incentive for YI and/or Crane Flat Campus expansion?

6) THIS PROJECT IS BARELY DISCLOSED IN THE YOSEMITE VALLEY PLAN, yet it will create significant cumulative impacts -- none of which were disclosed in the YVP.

7) NOWHERE IN THE YOSEMITE PARK PLANNING SHEETS ON THE NPS WEB SITE, NOR IN THE YVP DOES IT DISCLOSE THAT THIS PROPOSAL WOULD BE A SIGNIFICANT AMENDMENT TO THE PARK'S GENERAL MANAGEMENT PLAN.

8) The YVP should be based on a protective Merced River Plan. After the YVP is in compliance with a protective Merced River Plan, A FULL EIS SHOULD BE COMPLETED FOR THIS PLAN.

Thank you,

Joyce M Eden, Friends of Yosemite Valley
Scott Silver, Wild Wilderness

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