Wawona: Proposed Public Land Exchange

Fax: (209) 742-5024

Superintendent Mike Tollefson
Yosemite National Park
Yosemite, CA

Fax 209 379 1294

Re: Friends of Yosemite Valley (FoYV) Comments on Draft EIR for Camp Wawona Redevelopment Project and Proposed Land Exchange (DEIR)

There is no project alternative in this document that is acceptable. There is no valid reason to exchange the proposed National Park Service land parcel with that of the proposed Seventh Day Adventist (SDA) land parcel or any SDA parcel.

The National Park Service land is an intact oak woodland; whereas the SDA parcel has been trampled and degraded over many years. The NPS land is closer to the Merced Wild and Scenic River, the SDA land is significantly further from the River and would entail creating more development near the River and would entail the degradation of outstandingly remarkable values of the Merced River.

"The project applicant proposes moving many Camp Wawona facilities and activities from a parcel uphill and away from Forest Drive and the river, to a parcel directly south of Forest Drive, closer to the river. This would bring camp visitors closer to the sensitive floodplain of the South Fork Merced River. " (DEIR page 5.4-11)

"As shown in Figure 6.1, Camp Wawona is situated within the boundaries of the Merced Wild and Scenic River’s South Fork, specifically within river Segment 7 (Wawona)." (DEIR page 6-4)

"The proposed action would result in grading of portions of currently undeveloped land, and the construction of camp facilities and buildings on the National Park Service lands proposed for exchange. These activities would result in the removal and/or damage of native conifers and hardwoods, including black oak, within Sierra mixed coniferous forest. The indirect loss of trees and habitat resulting from soil compaction and nearby human disturbance is also anticipated to occur under the proposed action. The integrity of the Sierra mixed coniferous forest may also decline as a result of weed infestation. Weeds are likely to colonize areas following disturbance such as that anticipated with the proposed Camp redevelopment. Although this habitat is not considered a sensitive natural community, it contains black oaks, which along with oak woodland habitat, are considered sensitive and constitute a valued resource by National Park Service." (DEIR page 5.4-7)

The idea that there would be better protection of the wilderness boundary through this land exchange, does not hold water. We highly doubt if few or any SDA Camp participants wander into the wilderness area, as this portion of the SDA camp is not used for overnight camping or lodging; but rather for specific planned activities at specific times. This area is a the top of a steep hill. Participants probably leave the area when their planned activity is over to participate in the next activity or to return to their campground or lodging below. Contrarily, if the NPS in the future were to put a campground in this area in the future (which we have heard talk of), campground residents would undoubtedly wander and hike into the wilderness area, thus create new and potentially significant impacts.

Furthermore, the Draft EIR claims National Park Service (NPS) authority to do the proposed land exchange from 16 USC Section 51. However all the exchange alternatives would create a net gain in private land in the Park.

The NPS proposes to exchange 18 acres of land within the Merced River corridor for 15.36 acres of private inholding land also within the corridor. (DEIR page 6-4)

The idea of this land exchange is yet another ill conceived idea regarding Yosemite National Park that should have been considered, and then duly and appropriately rejected. But, apparently through bureaucratic arteriosclerosis it remained on the table. It should not become a project.

FoYV does not agree with increased and intensified use of the SDA land either in its proposed new boundaries or in its current boundaries. This new proposed development would not serve the public. This proposal to increase private development in a national park inholding is not appropriate for the public good, and should remain at status quo at the least. We are not disagreeing with some needed repairs and limited replacement of some existing facilities in situ for maintenance purposes.

The consideration of this land exchange project has been a waste of federal tax payers dollars, of Mariposa County tax revenues, and of SDA funds -- presuming SDA paid their consultant for investigating SDA plans based on the NPS land exchange. Is it the case that the SDA consultant has benefited monetarily from this proposal, whereas US taxpayers and Mariposa County taxpayers have had to pay out their money towards this inappropriate land exchange proposal? We ask you not to waste any more public money or agencys' time on this proposed and inappropriate land exchange. We ask that this land exchange not go forward, and that the NPS land be preserved as public land for present and future generations.

Thank you, Joyce M Eden, on behalf of Friends of Yosemite Valley

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