A winter-use plan for Yellowstone National Park being promoted by park staff would "make a bad situation ... worse," according to the viewpoint of the Coalition of National Park Service Retirees.

“The NPS is proposing to make a bad situation at Yellowstone even worse," said Maureen Finnerty, chairperson of the Coalition's executive council. "Our members understand the real world consequences of motorized recreation in national parks. We are bewildered about this proposal after seven previous environmental reviews resulted in a major federal court decision ruling that NPS was not following its own legal and policy mandates in managing snowmobile use in the Park in the winter.”

The draft winter-use plan released earlier this summer proposes to redefine over-snow entries into the park under a system that stands to increase the number of over-snow vehicles into the park beyond the total that has been permitted in past winters.

It calls for the park to "manage oversnow vehicles by their overall impacts to air quality, soundscapes, wildlife, and visitors, rather than focusing solely on the number of snowmobiles and snowcoaches allowed in the park each day. The park would allow up to 110 'transportation events' a day, initially defined as either one snowcoach or, on average, a group of seven snowmobiles (maximum group size would be capped at 10). No more than 50 transportation events a day would be allocated for groups of snowmobiles."

At the high end, as many as 480 snowmobiles could be allowed in the park on a single day. Under the temporary winter-use plan regulations in use the past two winters, a maximum 318 snowmobiles and 78 snowcoaches a day were allowed into the park.

Claims by Yellowstone officials that their preferred plan will result in a cleaner, quieter park open to more visitors seem to be contradicted by data contained in documents upon which the plan is built. While Superintendent Dan Wenk has said the preferred alternative "makes the park quieter and cleaner, and allows some increases in visitation," data show that that desired alternative will result in substantially higher carbon monoxide levels. Benzene emissions also will increase in the near-term, as will levels of formaldehyde and acetaldehyde, according to numbers contained in the Draft Winter Use Plan Supplemental Environmental Impact Statement.

As for noise levels, the draft clearly states on page 262 in Chapter 4 that, "(A)ssuming the maximum allowed use levels, OSVs (over-snow vehicles) would be audible over 50 percent of the time in approximately 14.1 percent to 17.4 percent of the travel corridor area, compared to 9.7 percent of the travel corridor area under recent average conditions."

But Wade Vagias, the superintendent's management assistant who has been deeply involved in developing the winter-use plan, has said those numbers are at the very high end of the spectrum, and not what likely would be realized on a daily basis.

The Coalition is not sold on those claims, however. In a statement issued last week the group said the proposed plan could more than double the number of dirty and noisy snowmobiles currently operating in the park.

“Even while acknowledging that the current average of about 200 snowmobiles operating daily in Yellowstone now are dirtier and noisier than those that were operating in the Park five years ago, Superintendent Wenk, in a complicated scenario of ‘transportation events,’ proposes to allow up to 480 snowmobiles per day to enter the park for the next five years; levels not seen there for nearly a decade,” said Ms. Finnerty.

Deny Galvin, a Coalition member and former deputy director of the Park Service, said, “As the deputy director of the National Park Service 10 years ago when the snowmobile industry promised to produce cleaner and quieter machines, I can tell you that the trust has been broken. Instead of working to enhance the snowmobiles to make them quieter and cleaner, they’ve actually cut production of those that meet the existing environmental standards in the park. Why should the resources of Yellowstone continue to be degraded for the next five years under the assumption that the industry will change?”

The Coalition release also pointed out that the "NPS proposal asserts that air quality impacts in Yellowstone would be 'moderate' and air quality would improve relative to the 'National Ambient Air Quality Standards.' However, the Clean Air Act, under which Yellowstone is designated as a 'Class I Area' does not use NAAQS as its criteria – it says air quality will be 'the best possible' in Class I areas. NPS’s plan does not meet that standard."

The Coalition officials maintain that the park's preferred alternative "is more impacting on Yellowstone’s resources than any of the other three alternatives listed in the Draft Supplemental Environmental Impact Statement winter use plan that was released on June 29, 2012."

The plan is open to public comment until August 20, 2012.

The Coalition supports Alternative 3, which would allow current levels of motorized oversnow vehicles to operate until the 2017-2018 season, after which all snowcoaches would have to meet “best available technology requirements and could increase to 120 per day with a corresponding decrease in snowmobile numbers to zero during a 3-year phase-out period.

“Alternative 3 is the only proposal that meets the National Parks Service’s legal and policy mandates and is shown by scientific analysis and resource monitoring to reduce impacts on the park’s resources," said Ms. Finnerty. "Moreover, it is what 80 percent of the nearly one million members of the American public who have commented in previous environmental reviews have said about how they want Yellowstone to be managed in the winter.”

The Coalition counts more than 830 former Park Service employees as members.