FoYV Scoping Comments for Revised Merced River Plan

Friends of Yosemite Valley
Cupertino, CA; Yosemite, CA
yojo@batnet.com

MERG (Mariposans for Environmentally Responsible Growth)
Mariposa, CA

Superintendent Tollefson
Yosemite National Park
PO Box 577
Yosemite, CA 95389
FAX 209 379 1294

RE: FoYV/MERG Scoping Comments on Merced River Plan/SEIS

Superintendent Tollefson:

As a result of FoYV/MERGS' 4 year work to get a truly protective Comprehensive Management Plan (CMP) for the Merced Wild and Scenic River as required by the Wild and Scenic Rivers Act, the court ordered the Merced River Plan to be redone or revised. Thus the National Park Service has opened the Merced River Plan for revision; projects in the Yosemite Valley Plan, which tier from the illegal and unprotective River Plan, need to be revisited based on a valid CMP for the Merced River.

1) PRIORITY OF WSRA: A river is designated Wild and Scenic based on specific outstanding values which are known as the "outstandingly remarkable values" (ORVs) of the River. The Wild and Scenic Rivers Act (WSRA) requires protection and enhancement of these identified values of the River for which it was designated Wild and Scenic. It does NOT allow for uses which degrade the ORVs.

The Act places primary emphasis on protecting the river's esthetic, scenic, historic, archaeologic, and scientific features.

2) BASE RIVER PLAN ON ORVs: The Merced River Plan must be BASED on protecting and enhancing the Outstandingly Remarkable Values (ORVs) of the Merced River. The Merced is a designated Wild and Scenic River. The Wild and Scenic Rivers Act (WSRA) mandates that the Rivers Values not only be PROTECTED, but also ENHANCED! If this plan once again fails to truly protect the River's values, the plan will again be a failure.

Start the planning process with identifying where each ORVs occurs (eg not merely where an animal nests, but its range and the plants, other animals, river processes, and so on upon which it relies and with which it interacts), what it is affected by (eg River backwaters, tributaries, other animals, plants, noise, proximity to lodging, night-lights), what it effects, and so on, and build the plan from that essential picture and platform.

FoYV has suggested to the River Plan planning team that they put a large sign up over the table at which they meet stating, "IT'S THE ORVs".

3) SCOPE OF SCOPING AND INTERRELATIONSHIP OF USER CAPACITY TO "ZONING" AND OTHER MANAGEMENT ELEMENTS: NPS is improperly attempting to limit the scope of scoping comments by stating in their scoping period announcements that they will not revisit River Plan management elements other than user capacity and El Portal District boundaries.

* The National Park Service's (NPS) determination on user capacity and boundaries in El Portal cannot be made in isolation and then simply inserted into the old Merced River Plan. Rather, decisions about capacity and boundaries must be integrated into a new or revised CMP and considered in combination with other management elements, which may need to be revised, or revisited to meet the Park Service's duty to protect and enhance ORVs. For example, the amount of use an area can sustain is linked to how the resource is to be used.

* The Appeals Court ruled, "While we remanded to 'the district court to enter an appropriate order requiring the [National Park Service] to remedy these deficiencies [user capacity and El Portal area boundaries] in the CMP [Merced River Plan] in a timely manner,' id. At 803, we did not 'otherwise uphold the [CMP].' "

* Scoping is supposed to be taking a fresh look . We invite NPS to join together with the concerned public to use this opportunity to cut through the veil of bureaucracy and NPS management's current view of visitors as "customers," and instead forge this plan around real protection for the Merced River's Values. Rather than continuing to be driven by predetermined Yosemite Valley Plan development projects and inappropriate goals -- such as bringing the amenities and experiences of suburbia and resorts to Yosemite and the visitor experience, focus on the purpose of the Wild and Scenic River Act to truly protect Yosemite's Merced River.

* Rethinking the River Protection Overlay; the invalid plan's "zoning program;" and the Section 7 determination process, as presented in the old Merced River Plan, is critical to upholding a protective user capacity. Other management methods than the two former, would be more appropriate and protective.

* The so-called "River Protection Overlay" does not protect the River despite its Orwellian name. It allows for roads, building, maintenance and storage areas (such as in Wawona at the South Fork of the Merced) under the rubric of Administrative uses. We need to remind the NPS that the full quarter mile of the River Wild and Scenic corridor is supposed to be protected. We need to remind the NPS that the ORVs outside the WSR corridor, as stated also by NPS in legal briefs, also need to be protected.

* The "Zoning" management tool needs to be thrown out. It is not based on the River's ORVs and it is not protective of the ORVs. If the revised River Plan still contains the zoning management element, it will not be based on the ORVs and the plan will once again not be a protective plan. The Merced River, and its ORVs, is a national treasure, not a grid on a planning use map for a city.

* The Merced River Plan should not be used (again) as a tool to allow development plans.

* The 500 pound gorilla --- the Yosemite Valley Plan. The head of the MRP revision planning team indicated that as part of preparation for the revision of the MRP, the planning team re-read the Yosemite Valley Plan and consider it in the planning process. When a member of FoYV questioned this, it was indicated that this did not seem to be a problem. We feel it is a major problem to producing a protective River Plan. The ORVs need to come first. They need to be what forms the River Plan. The Yosemite Valley Plan and its myriad of development projects, lurking on the sidelines, should not be determining what happens in the MRP. The short term goals of previous and current administrators of Yosemite National Park to get the Yosemite Valley Plan implemented need to be set aside by the Merced River Planning Team. We trust that in your hearts and in the heart of the current Superintendent you all want to truly protect the Merced River. You can turn your back on the 500 pound gorilla, you all have the strength to do so. We are confident that you want to leave a real legacy to your children and grandchildren, that you know that public relations rhetoric is not a valued and true legacy for future generations. You will be backed up by us, by the American public who truly wants its treasure protected, by the legacy of John Muir and David Brower -- the legacy to work to truly protect and preserve. The Planning Team needs to and can rise above this pressure and do its real job -- to protect and enhance the ORVs of the Merced River.

* Determination of user capacity must be built around specific defined conditions of each of the River's values as a baseline beyond which no value can be allowed to be degraded, and must be protected and enhanced. The River plan should show specifically for each river value how, where, and by what means each value (ORV) will be protected and enhanced.

* We, the public, need to know, and have the right to know, about the condition of each River value so, as a concerned members of the public, we can take an active role in monitoring and protecting these public values. This should be in and a part of the revised MRP.

4) EQUITY, CAMPING, "RESTORATION" : In 1997, the National Park Service closed the Rivers and other campgrounds. This removed 40% of the camping in Yosemite Valley. At the same, NPS began planning a $441,000,000 construction/pavement/development project which came to be called the Yosemite Valley Plan and included new motel buildings for Yosemite Valley. Meanwhile since 1997 more lodging has continued to be built in the Yosemite gateway communities. With this increase in nearby lodging, there is no valid reason to build new upscale lodging units in Yosemite Valley -- but that is what NPS intends, and at taxpayer expense -- in essence and reality subsidizing the private for-profit monopoly Yosemite concession with our money. (Although in the YVP, NPS defines certain lodging units they intend to build as "economy" and others as, "rustic" those descriptions do not realistically reflect that they will be higher-end, whatever their configuration, and their cost will be out of range of the average family.)

The NPS claims that is it going to "restore" the areas where it removed the campgrounds in 1997. It is not clear what the NPS plan will actually be (which should not be on the table now in any case and was not allowed to go forward by the Court until a revised valid River Plan is finished). The restoration they claim is in an area, in the invalid River Plan, designated as a high-use area they zone as "Day-Use". What is sure is that the public never had the opportunity to comment on this removal of 40% of the camping in Yosemite Valley. The revised River Plan should have an alternative that restores these 40% of camping spots removed, but not in new areas. Moving impacts into new areas is not protecting ORVs or the ecosystem. Perhaps it is some of the Lodge buildings that should be removed. Camping could be considered to be put there for example.

So this claimed "restoration" would be on the back of Yosemite Valley campers, while unnecessary upscale resort hotels are built in Yosemite Valley. This former camping area is the main "restoration" (6% of the $441,000.00 plan) part of the Yosemite Valley Plan. Almost all of the rest of the Yosemite Valley Plan (see the YVP) is for development, construction, concession amenities, employee housing to house the additional employees needed to support this additional infrastructure and level of services (changing motel room sheets, ice cream parlors, etc). And the Valley Plan makes clear (although the NPS press releases and public materials give the opposite impression) that the $441,000,000 plan will bring more miles of asphalt both in Yosemite Valley and in the rest of Yosemite Park. Pretty sad. However, if the River plan is a truly protective plan, this would not happen under it. This is the litmus test of the revised River Plan that NPS will put out.

Camping in Yosemite Valley directly connects visitors with the natural values for which Yosemite was saved. An upscale resort style hotel can be built anywhere and is not an appropriate use of a national treasure. Camping allows lower income and other families to enjoy Yosemite's spectacular natural values on their own terms. It allows families to bring in their own supplies, their food, their bicycles, their rafts, their children's strollers, etc. They are not dependent on the concessionaire.

The average family is being more and more shut out of Yosemite as Yosemite becomes more and more of a resort/Disney style destination. This is how not only the concessionaire, but also the NPS markets Yosemite. This is not equitable. Camping is also an important opportunity for social interaction in Yosemite which builds democracy. Lodging separates people both physically from social interactions and stratifies them economically.

5) THE MARKETING OF YOSEMITE AND USER CAPACITY: While the National park Service has eliminated any user capacity numbers for Yosemite, it markets Yosemite as a part of quickie all-in-one-day tour packages -- actively enticing more people to tour and impact the Park's natural values. The Park Service then claims that it has to accommodate these tourists with ever increasing amounts of, and increasingly upscaled types of accommodations.

Usually people on such tour packages spend a mere few hours in Yosemite, while leaving many dollars in the concessionaires pockets and a large impact on Yosemite's resources. Rather than taking home a priceless in-depth experience of Yosemite's natural values, they rush from spot to spot to take quick photos, purchase souvenirs, and eat. Rather than Yosemite leaving a lasting impact on them, their impact leaves a lasting impression on Yosemite.

See for example the National Park Service Press Release: "Yosemite National Park Employees Attend Travel Expo [in China] to Promote Tourism to National Parks"
http://www.yosemitevalley.org/HTML/Articles/2002_07_01.html (Attachment #2)

Now that the Court has ordered NPS to adequately address user capacities, how will this mesh with the concession and the NPS marketing of Yosemite? The Yosemite Valley Plan says it will accommodate the tourists as they come by building ever increasing outlying parking lots, bus systems, and a 22 bay urban style bus depot in Yosemite Valley with buses arriving in peak season every 1.4 minutes (see YVP -- yes, it's in there).

Look at the Lower Yosemite Fall project (if you can stand it). It controls tourist pedestrian traffic through a maze of split rail fencing and obtrusive stone walls. Do not deal with impacts by putting up more fences, instead the concessionaire and the National Park Service should stop marketing Yosemite as part of intensive tour packages and stop working to grow the numbers of tourists (dollars). Is this the kind of Yosemite experience you want? Separated from nature? Directed around by fencing?

Most people stay on the trails. The occasional family group or group of friends that ventures off a trail, does not degrade the values, but the NPS degrades the values through their massive construction/destruction projects. The El Portal Road widening, the unnatural grading throughout the 56 acres braided alluvial braided stream area from the ongoing Lower Fall project with the overbuilt bridges with 20' footings (inappropriate according to the NPS hydrologist in the Freedom of Information Request info we have) which will prevent natural processes (degrading the hydrologic ORV), the overbuilt bus stop in one of the most scenic areas in the world (degrading the scenic ORV), the overbuilt bathroom edifice built on top of archeologic sites (degrading the archeologic ORV) and a monument to disrespect, and on and on.

6) VALLEY PLAN PROJECTS already have been planned by the NPS based on a River Plan determined by the court to be invalid. Those projects include a myriad of interrelated plans and projects in the Yosemite Valley Plan. These plans and projects and the Yosemite Valley Plan, including plans and projects throughout the Wild and Scenic River corridor, need to be revisited and based on a valid/protective revised CMP/SEIS.

For Example:

* Curry Employee Dorms and Rockfall Danger: Construction for sleeping quarters for these "lower level" employees is scheduled to begin soon. However, less than a year ago and a mere 300' from this construction area, a dangerous rockfall occurred in which rocks and boulders fell through roofs and damaged 10 inhabited duplex cabins at Curry Village, in which at least one person was almost hit. (Documented in an NPS categorical exclusion for repairs. See Attachment #2.) Perhaps the NPS planners and administrators who signed off on this plan should sleep on the top floor of these dorms? At minimum and certainly before any construction and any more planning resources are put into this project, the Valley Wall above this area needs to be thoroughly studied for rockfall potential; and the 27 planned employee dormitory buildings' area be studied for potential bounce zone.

An NPS official told a FoYV representative at one of the recent scoping meetings that NPS was surprised by the ricochet effect that took place in the Dec. '03 rockfall referred to in the previous paragraph. Does NPS really intend to let employees' be potentially surprised by this ricochet effect when they are sleeping?

* Before any more development is planned or construction commenced in Yosemite Valley, a rockfall/bounce zone/ blow down map of at least the Eastern portion of Yosemite Valley needs to be completed and incorporated into the River Plan for the public to see. Perhaps the construction of the amphitheater at Glacier Point with its attendant dynamite blasting has loosened the Valley Wall in that area? Perhaps the leach field and sewage leakage problems at the Glacier Point bathrooms have loosened the Valley Wall in that area? A geologist proposed to the National Park Service to put blue dye into the Glacier Point toilets to see where the sewage water was flowing, the NPS refused to let him do that study.

* The Curry Employee Dorm project area is also an important area which climbers use for bouldering, the "Root Canal" boulder is in that area. Yet NPS will destroy that opportunity if the Employee Dorms are built there. That area was undisturbed until NPS did a preemptive logging, well before any construction was scheduled to begin. The April '04 court injunction stopping tree cutting was too late for many of the trees logged to make way for the dorm construction.

* The Yosemite Lodge Plan calls for new lodges in the River Corridor and plans to bulldoze and cut a new road adjacent to the River, rather than use the existing road which is away from the River. This project would degrade and destroy River ORVs. For example, it is now an easily accessible opportunity to enjoy a quiet walk along the river enjoying grazing deer and squawking Stellar's Jays, to contemplate the River's oxbow and meander and enjoy the water plants in the River's special backwater in that area as well as wonderful solemn views of Sentinel Peak. A road with buses driving through it would destroy that area and that experience. If this project, as one Yosemite Valley Plan project example, which will be destructive of many ORVs, were to be able to move forward under a revised River Plan, that will demonstrate that the revised River Plan is not be a protective plan, that River Plan will not conform with the goals and mandates of the WSRA to protect and enhance ORVs. That would be a sad outcome of this new round of planning processes.

* The closures of the Upper and Lower Rivers and Group Campgrounds by NPS in 1997 was never put out for public comment. This area was subsequently "zoned" for "Day Use" in the invalid River Plan; thereby eliminating 40% of the camping in Yosemite Valley. NPS now improperly argues that it is already "zoned" for "Day Use". As a part of the Draft CMP/SEIS, the public should at last have the opportunity to consider and comment on the use of this area in at least one valid alternative.

* Curry Village and East Yosemite Valley Campgrounds Improvement Project calls for more upscale lodging requiring more infrastructure and more employees (an additional 405 Park-wide). Who, in turn, require more infrastructure -- all this when more and more lodging since 1997, and almost each year since, has already been and is being built in the gateway communities outside the Park -- violating Park Service Management Policies. (In this past year, eg, many additional lodging units were built right outside the Yosemite Park boundary at the Yosemite View Lodge) The Plan calls for destroying undisturbed areas to replace a minute number of the more than 300 camping spaces closed by NPS in 1997. Instead of building new expensive resort-style hotel lodging in the Park (more profits for the concessionaire), relocate the 40% of Yosemite Valley campgrounds closed by NPS in 1997, into those "lodging" areas, changing them into camping areas. (Protective of the ORVs of the Merced and beneficial to public values and our right to experience the natural values of the River.)

"The Councils choice of alternative is Alternative I (No Action Alternative). Alternatives 2 and 3 of this project will have significant impacts to the cultural resources in the east valley area. The archeological sites, gathering sites and the village sites in this area will be disturbed forever. The Councils position on all major projects is no action." (Tribal Association, Mariposa, CA - #41) pp. E.2-12, E.2-13, Curry Village and East Yosemite Valley Campgrounds Improvement Project.

* "The Utility Improvement Plan will be the most destructive Project in Yosemite since the 1997 High Water Flood and it is the responsibility of all who love Yosemite to minimize the ground disturbance and rethink where the utilities should be placed without disturbing virgin soil and riparian zones." (Tribal Organization, Mariposa, CA, Comment #7-3) p. E2-14, East Yosemite Valley Utilities Improvement Plan Environmental Assessment. Will the NPS finally listen to this wisdom?

* The El Portal Area Wild and Scenic River Corridor is more important biologically than understood years ago. In addition, some River values still remain in El Portal which have been degraded or lost elsewhere along the River. These need to be protected, and many still need to be identified. eg, there is National Park land that is probably a pristine riverine area on the boarder of the Yosemite View Lodge, it is certainly currently undisturbed and contains a wetland area (we explored the area). (This area was shockingly almost traded off by the National Park Service in the last few years. Who knows what wildlife use this area?)

* The El Portal Road Segment from Pohono Bridge to the 120/140 Highway split, (known also as, "Segment D"), saved from being destructively widened in 1999 by the Court. The River Plan must protect this area's ORVs. The only way to do that is to NOT WIDEN THE ROAD. The geologic and scientific ORV in which the "U" shaped Yosemite Valley turns into the "V" shaped Yosemite Gorge is the area with the granite wall which forms this ORV. If the road were to be widened, either that ORV would be degraded or destroyed, or the road would illegally and destructively encroach into the Merced River, and also destroy rare old Canyon Live Oaks growing along the River side of the Road. Either way, widening the road would not be protective, and in fact would be destructive.

* The Merced River Plan should not be used again as a tool to allow development plans.

7) AMEND CONCESSION SERVICES PLAN: The Concession Services Plan (CSP) was put into place 5 years after the Merced was designated a Wild and Scenic River. However, at that time, 1992, there was no valid legally mandated Comprehensive Plan for the Merced River. Therefore, the Concession Service Plan, along with the General Management Plan which it amended, needs to be changed to specifically ensure protection and enhancement of the ORVs of the Merced River.

In addition, the CSP will be up for renewal and change in 2007. The River Plan is a 20 year plan. NPS should not lock in the current concession plan with its myriad of concession opportunities and amenities in this River Plan. That would be an unbelievably huge mistake. However, that is precisely what the zoning in the illegal plan does. This needs to be changed.

For Example:

* The number of hotel units and concession eating areas may need to be reduced.

* The Merced High Sierra Camp, which is in designated wilderness, may need to be replaced with a lower impact campground due to various impacts such as the ongoing serious bacterial water contamination in the Merced River (see nps document) from horse and stock feces.

* The concessionaire rafting (as opposed to families/individuals bringing their own raft) may need to be discontinued due to the high impact of multiple rafts entering the river at the same point and the impact of concession diesel trucks picking up the rafts in places that would otherwise be a quiet experience, such as Sentinel Beach.

8) A FULL RANGE OF ALTERNATIVES must be presented to the public which REVISE the River Plan IN COMPLIANCE WITH THE ORDER FROM THE COURT to PROTECT AND ENHANCE THE MERCED RIVER'S OUTSTANDINGLY REMARKABLE VALUES with user capacity based on that mandated protection and with the boundaries of the El Portal Administrative District drawn to protect ORVs not merely drawn proforma, or drawn to allow predetermined developments, such as "Abbieville". We ask that these all be viable protective alternatives so the public has the opportunity to consider various valid options.

9) ALL SCOPING COMMENTS SHOULD BE AVAILABLE TO THE PUBLIC by OCT 10, 04. Put out a CD containing all the public scoping comments as written (not excerpts) so the public can know what others are concerned about and what ideas people put forward. We want this to be a public dialogue not a one-way street. Post the availability of this CD on the NPS Yosemite Planning web site.

10) ACCOUNTABILITY -- OR LACK THEREOF: So where is the accountability for the numerous plans deemed illegal in the courts? Where is the accountability for the excessive use of resources for all the over planning and over constructing that has been done and is being planned to be done in Yosemite? Where is the accountability for the close to $100,000,000 spent by NPS since 1997 (or what is the figure?, the public would like to know how much and exactly where it was spent?) The next time NPS builds yet another building in Yosemite, it could be built by using those truck loads of trees logged by NPS in Yosemite and by and stacking the tons of planning documents generated since 1997 for the walls and structure, we would not even want to try to list those documents.

What is the purpose of having NPS officials sign off on the Record of Decisions of planning documents? We assumed it was an attempt to hold someone accountable. But we have seen no one held accountable. The more illegal and overbuild/overblown plans and projects, the higher in rank NPS planners, managers, and administrators seem to rise.

It is a serious concern that the same head of planning for the River Plan that was not protective and was declared illegal in the court, is now the head of the planning for the revised plan. A fresh look at the planning process and the management tools is needed to create a protective plan with management tools that are not made to implement Yosemite Valley Plan projects, but are made to focus on Merced River ORVs and their protection. Will that happen?

11). General Categories of the Outstandingly Remarkable Values of the Merced River in Yosemite -- 81 miles including the Main Stem which runs from the high Sierra though Yosemite Valley, down the Merced River Gorge, and through the El Portal Administrative District; and the South Fork which runs from the high Sierra in Yosemite, and out through Wawona.

The ORVs: biologic, scenic, geologic, scientific, cultural/archeologic, recreation, hydrologic processes. The National Park Service has stated that by being more general in their descriptions of the ORVs they can better protect the ORVs. On the contrary, in the River Plan, NPS needs to be transparent and specific in their description and discussion of the ORVs, their locations, interactions with other animals, plants, processes, etc. The public should understand the specifics of the ORVs in order to be able to help watch and follow and participate in working towards and monitoring their protection and enhancement (Except of course archeologic sites. Although, it is the NPS itself that is creating vast amounts of disturbance and degradation of archeologic sites through their construction projects).

Cultural ORVs are properly those such as current ongoing Native American Gathering areas based on traditional indigenous Native American values; not every recreational activity developed in Yosemite since its inception as a National Park, nor all structures or amenities developed for visitor recreation over time.

The current data and surveys of ORVs should be a part of the River Plan, and as data is collected, it should be put up on the NPS web site. The public that loves Yosemite and appreciates the Park's special values, can be the eyes and ears that are most helpful in the Park's and ORVs' monitoring and protection. The many knowledgeable members of the public will watch and make known if an ORV is not being protected. Wouldn't the NPS want this help?

12) AUTHENTIC/HISTORIC versus FAKE and DISNEYLAND style simulated "historic". One of the most important historic structures in Yosemite to some members of FoYV, was the historic rock wall which was built as a double public good: 1. for society to contribute to out-of-work people in the depression by employing them through the CCC to build the rock wall along the El Portal Road in Yosemite, and 2. for those workers to contribute to society by building a rock wall which would make traveling the El Portal Road safer for visitors and built in the way of master stone masons. The NPS bashed this important historic wall to simtherines .................. and almost completely destroyed this important and irreplaceable ORV, leaving merely a small, remnant to make us morn its loss even more.

13) VERP: "VERP does not address capacity. It is legally and conceptually insufficient. It is a smoke screen for dealing with user capacity." Glenn Haas, user capacity expert, Sept. 9, 2004, asked us to include this quote from him in the FoYV/MERG comments. This pretty much says it about VERP (as we refer to it, "Very Elusive Resource Protection.").

14) CUMULATIVE IMPACTS: There have been multiple cumulative impacts on ORVs from multiple recent Yosemite National Park projects and planned additional projects with additional cumulative impacts. For example, cumulative impacts from the El Portal Rd widening project which violated the WSRA in multiple ways including putting rip rap into the Merced River, bashing down bat roosting trees, destroying habitat for multiple creatures, destruction of most of the threatened Tompkins Sedge along the 4 mile project area, opening multiple disturbed areas for the invasive yellow star thistle to have a corridor to invade Yosemite Valley, etc.

Since hardly any impact from any project that NPS has designed and signed off on for Yosemite has any impacts determined other than, "No Significant Impact"; How many, "No Significant Impacts" make up a cumulative impact? We ask NPS to answer this question specifically for all and every part of the revised CMP, how each management elements relates to this, and how specifically user capacity relates to this issue and to each and all specific ORVs in every River segment and area. We ask NPS to answer this question specifically for all and every part of each plan and project in the Yosemite Valley Plan which is reliant upon or tiered to the Merced River Plan.

Thank you,

Joyce M Eden, for Friends of Yosemite Valley
Shirley Schmelzer, Vice-Chair MERG
Martin Litton

Attachments mailed to PO Box 577 on Sept. 10, 2004, to be included as a part of our scoping comments:

1) Rockfall Categorical Exclusion,
p. 1-6, http://www.nps.gov/yose/planning/documents/catex/2004/2004_052.pdf

2) Yosemite National Park News Release, July 1, 2002,
"Yosemite National Park Employees Attend Travel Expo to Promote Tourism to National Parks

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