Read DCC’s updated Vehicle Management Plan comments
We recently completed another round of comments on the Draft Denali Vehicle Management Plan, after continued discussion with members, constituents and the National Park Service. Our comments provide greater detail on our concerns about the plan, and suggestions for improvements. We remain very skeptical about the capacity of either action alternative to fully protect park resources, and we continue to argue for a firm vehicle capacity number. Please read our latest comments below. And remember, comment deadline is October 31st. Look for more comment suggestions in the next 10 days.
DCC News – VMP comments 10-15-11-web
For more information, see the resources on our page for the Denali Vehicle Management Plan.
To comment on the plan, visit the NPS PEPC website.
I submitted the following comments on the Vehicle Management Plan to Park Service:
I have visited Denali National Park every summer since 1971. I did my Master’s thesis study in the Park, spending two summers based in Teklanika Campground and riding the shuttle busses nearly every day. Later, in my capacity as a biologist with the Alaska Department of Fish and Game, I consulted with Park biologists on various wildlife research projects. I was an outside reviewer for Dall sheep studies in the 1990s. I reviewed and advised Park Service on its wolf and caribou research and management programs. I have provided naturalist training to
Concessionaire, Park Service, and Camp Denali employees. I have guided private nature excursions to all four Kantishna area lodges. I have held a Professional Photography permit for the past eleven years. I have frequently stayed at Teklanika and other campgrounds and have often ridden the Park transit busses. I have frequently gotten on and off transit busses and have hiked throughout much of the Park from the Nenana River to Wonder Lake. I believe I am well-qualified to comment on the Vehicle Management Proposals.
I strongly support Alternative A—the No Action Alternative. Recent traffic levels on the Denali Park Road have been well below the current limit of 10,512 vehicle trips per season. Also, visitor surveys conducted during the Road Capacity Study did not indicate any major problems. Responses to all questions ranged between “no problem” and “small problem.” No “big problems” were identified. Yet the action alternatives B and C go to great lengths to fix minor problems. Many of the proposed changes in Alternatives B and C would require very strict scheduling and adherence to time tables at various waypoints throughout the Park. This is not specifically stated in the planning documents made available to the public, but it is implied by some of the figures presented in the documents and by some vague statements about finding schedules that would achieve desired results. To my knowledge, no specific schedules were made available to the public. Such strict scheduling would likely result in reduced time at wildlife stops and a loss of flexibility for optimizing visitor enjoyment.
The vast majority of all passengers, including transit bus passengers, use the busses as a de facto tour of the Park. Very few, if any, passengers need to be at any specific destination at a certain time. The public would be better served by a system that run all busses as if they were tours with somewhat flexible schedules (and the option for some passengers to get on and off, if they so desire) rather than perpetuating the current fiction that transit busses primarily serve to get people from place to place according to a strict schedule. None of the proposed alternatives would accomplish that, but the No Action Alternative probably comes closest. In my experience, transit busses under the current system are seldom actually on schedule, but then the current system lacks the measurable and presumably enforceable parameters such as “sheep gap spacing,” viewshed limits, and limits on numbers of vehicles at a rest or wildlife stop that would mandate strict adherence to schedules.
Other than extending Natural History tours to Teklanika Rest Stop instead of Primrose Ridge, the tour options in alternatives B and C are hardly any different from the options available under the current system. Trying to combine various levels of interpretation and pricing on a single bus would be unworkable.
Under no circumstances should any of the following be adopted:
Sheep gap spacing—I did my Master’s Thesis study on Dall sheep in Denali Park. I was also a reviewer of the sheep studies conducted by Park biologists Jeff Keay and Judy Putera in the 1990s. Scheduled gaps in traffic to facilitate road crossings by sheep are based on the assumption that road traffic inhibits crossings between seasonal ranges. Data are inconclusive on this point. Recent findings during the Road Capacity Study indicated that sheep sightings along the road were more common during the early, low traffic, part of the summer and decreased later as traffic levels increased. It was pointed out that reduced sightings later in the season could also have been due to natural shifts in habitat use to higher elevation areas away from the road. The habitat shifting definitely occurs—that was the basic finding of my thesis research. There were also a total of three observations during the 1990s that suggested sheep cross the road more quickly (i.e., in about 10 minutes) when no vehicles were present. However, documents available to the public in conjunction with the Road Capacity proposals failed to mention that road crossings by GPS-collared sheep occurred primarily during midday and at higher traffic levels. Thus, relationship between vehicle traffic and sheep sightings seems spurious. In short, data do not support the assumption that road traffic actually has an adverse effect of sheep or that 10 minute gaps in traffic every hour will facilitate sheep crossings.
Viewshed limits—Why is this even a consideration? Implementing such limits would require very strict scheduling and/or some way for busses and other vehicles coming from two different directions to communicate and decide which vehicles can proceed through the area. What if there’s a wildlife viewing opportunity in the viewshed? Would some busses need to leave the wildlife sighting so some other bus wouldn’t have its viewshed spoiled? How would private vehicles or maintenance vehicles comply with the limits?
Vehicle limits at wildlife stops—Having too many vehicles at a wildlife stop was not identified as a “big problem” by visitors. The proposed limit of three vehicles was seldom exceeded. Which would be more preferable to the public—having to share a sighting with several other vehicles or having to wait somewhere out of sight until other vehicles move on. Spending more time watching the wildlife or having to move on prematurely so that another bus can take your place?
Night time road limits—Not supported by data. Increased wildlife sightings after “quiet nights” weren’t even close to statistically significant. Proposed limits seldom approached under current conditions.
Limitations on private vehicle travel to Teklanika Campground—Other than its gravel surface, the road from Savage River to Teklanika Campground is not fundamentally any narrower or more difficult to drive than the paved road to Savage. I see no reason to limit private vehicle traffic to the campground. Teklanika is highly popular with resident Alaskans and with other travelers with self-contained RVs, campers, or passenger vehicles who don’t want to lug all their gear on a Camper Bus. The campground has occasionally been closed to tent camping because of wildlife conflicts. Converting this campground to tents-only would be a huge mistake.
Hiker time for reboarding busses–Hiker wait time is supposed to be a surrogate for walk-in seat availability at the Park entrance. However, busses often fill 2 days in advance at the Park entrance. Getting a bus seat at the Park entrance during peak season without advance reservations is a particularly difficult problem and there may be no easy solution, but it is a totally separate problem from being able to get back on a bus further out in the Park. Hiker wait time is a problem because the shuttle busses in reality are de facto tour busses. During peak season busses leave the Park entrance with a few empty seats, but those seats fill up at Teklanika Campground. Nearly all passengers stay on the same bus when it returns from Eielson, or some remain at Eielson but their seats are reallocated to other passengers by the Eielson dispatcher. Either way, there are sometimes not enough empty seats to accommodate hikers who want to reboard a bus somewhere else along the road. The solution to hiker wait time during peak season is to add a small amount of capacity to the transit system and spread that capacity throughout the day and throughout the Park by having busses leave the Park entrance with more empty seats and maintaining some empty seats when departing Teklanika westbound and departing Eielson eastbound. In shoulder seasons, when morning busses tend to be full but later busses have many empty seats, the solution is to allocate more empty seats on the early busses and spread riders more evenly throughout the day—no need for additional capacity, just use existing capacity more efficiently. That could be accomplished under the present system.
Combining Film Permits and Professional Photography permits—Conditions for commercial film permits are very different from the conditions for Professional Photography permits. Film permits (there are similar requirements for other Parks) are designed for commercial shoots using models and props and/or large crews and for special productions (usually on contract) that may require extended shooting periods. Professional Photography permits accommodate professional wildlife and nature photographers with the understanding that public transit options are incompatible with serious nature photography. Professional Photographers must meet certain qualifications that would not necessarily be appropriate for commercial film photographers. Commercial film permits can require bonding and monitoring that would be unnecessary for Professional Photographers. Professional Photographers can qualify for up to 12 days assigned by lottery several months before the season starts. Film permittees may require more than 12 days or days at specific times that might not be available by lottery. The two programs serve different purposes and simply don’t mix. Recently Park Service has issued Film Permits to some individuals who should actually be in the Professional Photography program. That’s an administrative blunder, not an excuse for merging the two distinct programs.
Changes in the Professional Photography Program—All alternatives would continue the Professional Photography program at some level, so the basic justification for the program doesn’t seem to be in question. There is no compelling reason given for the reductions in number of permits or shortening of season dates in Alternatives B and C. Splitting permit allocations between the Savage to Toklat and Toklat to Wonder Lake areas would be completely unworkable. I brought this up at a public planning meeting in Fairbanks before the final Alternative proposals were developed and specifically asked where a photographer with a Toklat to Wonder Lake permit could spend the night. Superintendent Anderson responded that they could camp at Wonder Lake. I pointed out that Wonder Lake is a tent-only, no vehicle campground. No Park representatives at the meeting seemed to be aware of this. Superintendent Anderson then said photographers could camp at Teklanika, but he couldn’t say what they would be allowed to do along the road between Teklanika and Toklat. In spite of my bringing this issue to their attention, that option still occurs in alternative B, with no explanation of how it could be implemented. The Professional Photography should be left as it is.
Again, I strongly support Alternative A, the No Action Alternative.
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