Decaying Management In America’s National Park System-
Yellowstone Park is loved by millions of Americans and many more around the world. It is the original model for not just America’s National Park System, but for national parks in other countries. By “system,” it is meant the national parks are established and managed by a common vision and set of rules for the benefit of the entire nation.
As the PBS series says “The National Parks [are] America’s Best Idea.” The series is based on Dr. Alfred Runte’s book, National Parks: The American Experience. In 1959 Runte travelled with his mother and brother across the West, visited many Parks, but especially Yellowstone and Grand Teton, and became “a lover and defender of the national parks.”
His experience was hardly unique. As a boy, growing up in Rexburg, Idaho, I knew the routes and gave my father traffic directions in Yellowstone by the time I was five years old. My Aunt, who lived in Sugar City, Idaho, until she recently died at age 85 was a favorite of mine, but I remember her and my Uncle most joyfully when they went with us to the wonderland of geysers and bears.
I could write more about myself and how Yellowstone has motivated my life, but my experience is so widely shared. Dr. Brian Horejsi first went to Yellowstone in the 1960s and spent a night at Lamar and watched as helicopters herded “excess” elk into the pens for eventual removal /slaughter. He recalls that “at that time, I thought this can’t be wildlife management in a National Park”? Later though, with a degree in wildlife, he returned and returned to the Park. For the last 16 years, except for one year, he goes every year, usually for 2 or so weeks in the spring and the fall. He says, “It is a remarkable place, and the changes imposed by a more natural management agenda (flowing from Leopold report) have been a pleasure to watch (wolves, bear population improvement -not recovery yet- natural fire regime). These are some of his examples.
All of us know the Park has been endlessly threatened by interests both local and national. Even as I write the Montana legislature is expressing a kind of hatred toward the Park more typical of the 1890s. Not all threats are external, however. The Park Service itself makes accommodations to its internal politics, to that of the concessionaires, and, of course, to that of the towns at its entrances, including Gardiner, Montana, where boundary issues have been more or less contentious for more than a century.
In the following paper, Dr. Horejsi addresses these kinds of problems as they are currently happening at Gardiner, Mammoth Hot Springs, and the Park highway between them.
Following is the first publication of his paper on these issues and what they mean.
Crosshairs on Yellowstone: Decaying Management In Americas National Park System
By Brian L.Horejsi 2013
There are five sections in this paper:
1. For Whose benefit? Beware the Legacy Builders.
2. A Monster at Mammoth.
3. Cumulative Effects are Massing but impact analysis is AWOL.
4. Closed doors shield transactions worth hundreds of millions of dollars!
5. Invasion of the Trail Snatchers; Coming soon to Yellowstone?
6. Concluding Thoughts
1. FOR WHOSE BENEFIT? BEWARE THE LEGACY BUILDERS.
Gardiner, Montana, is a very, very lucky town. I say this because it counts as its neighbors – in fact it is buried in – public land. National forests block in the little town of well under a thousand permanent residents on two sides and what is often considered the crown jewel of North Americas public lands, Yellowstone National Park, blocks in the other two sides. That is as close to jurisdictional heaven on earth as one can get. But, not everyone see it this way. After all, this is America, an ecological and political landscape feeding off fast food corporations, box stores, and trinkets make in China, all of these fixations driven by commercialization, consumption and blind growth. Few places escape the intensity of this agenda, and yet, barring a transient influx of motorized visitors, Gardiner is one place that has managed to hold off the worst of Americas excess.
In Gardiner, Park street is named for a damn good reason. It also functions however, as the towns “main” street, being home to the greatest concentration of businesses in town, and it “handles’ virtually all the vehicles that enter and depart Yellowstone National Park via the historic Roosevelt Arch, which stands majestically at its west end. More importantly, however, Park Street separates a no longer quaint but still surprisingly low key Gardiner from Yellowstone National Park. The Park boundary, largely unmarked and unseen to visitors, runs the full length of this one-sided street; even the sidewalk is “squatting” on Park land. Standing on Park street a person can enjoy a fabulous, largely unadulterated view of the north entrance to Yellowstone, the exception being an in-obtrusive iron fence that confines parked vehicles to a strip along Park Street. For decades, the commercial district of Gardiner, as small as it is, has been borrowing this parking area, at no cost to local businesses or residents, to serve and increase visitor use of local businesses. A very sweet deal!
Just beyond the metal fence is a unique, dry, desert like habitat, found in limited supply in the park. It has borne the brunt of extended historical human and wildlife use but still routinely supports, for days at a time particularly in spring, fall and winter, elk, bison, mule deer, and members of the regions highly endangered pronghorn population. Looking over this landscape, you get the impression of days past, the days of famed naturalist and Yellowstone protection activist George Bird Grinnell, the Park’s first gamekeeper Harry Yount, and of course, Theodore Roosevelt. It’s a strange mix, one of stark contrast with today’s frantic world, represented by the thousands of vehicles that file into the park through this remnant historic landscape. This “old”, presently undeveloped space still manages to send a message to today’s perceptive visitors – beyond this largely invisible line, it says, starting right now, things are meant to be different, and in some ways they still are, just as they should be in a National Park. This initial look at Yellowstone can be a huge bonus to park visitors, as it is to local businesses, and people gather to enjoy, talk about, marvel at, and photograph what is for many their “first” Park landscape and wildlife experience. I have looked over it hundreds of times, and it still captivates me and whets my appetite for “more Yellowstone”.
I pass through this area daily during several periods each year. Last September, early evening, I was leaving Yellowstone on the east end of Park Street, virtually on the Park boundary, when I suddenly became aware of a very large snake on the warm pavement just ahead of me. I swerved into the oncoming lane to avoid it, pulled a U turn, literally jumped out, and there, to my amazement was a rattlesnake, about 36 inches long and thicker at mid body than my fore arm. I would have welcomed the opportunity to sit nearby and watch it, but vehicles were oncoming. I waved them around, then began to coax the snake off the road, back into that unique little piece of habitat that stands eerily close to the little town of Gardiner; a habitat that has “sat” there for roughly a century of nearby human use, and yet, because it was neither paved nor industrialized, it was able to “serve up” this rare beast.
Using my hat I waved the reluctant snake off the road, back into the Park. I suspect it was headed into town, attracted by the warm pavement, one of those ecological traps ecologists refer to, places that entice wildlife for various reasons,
none of which are beneficial to them – places that prove to shorten life spans and reduce reproduction. After the snake made its way back into the Park, not “safe” confines in the big picture sense, but still National Park habitat that was obviously able to ecologically contribute to the presence of this representative of an endangered species. Pretty significant, from a conservation point of view, and significant from my perspective as a conservation scientist.
Several days later, while engaged in another critical event (however insignificant it really is) – getting my morning coffee from Lynne in a Park Street establishment – I happened to learn that “big plans” were in the works for “redeveloping” Park street and the famous Roosevelt Arch. I was surprised, since I had been on the Yellowstone e-list for project announcements after providing comments on several other development schemes, and I’d not gotten notice of this particular one. I reacted as though I’d just seen surveyors stakes and flagging on one of my favorite trails! Basically, it was a punch in the gut!
I have thankfully enjoyed the view into Yellowstone from Park street immensely, and done so for 15 years, each time marveling at this essentially “wild” piece of land holding its own against a virtual tsunami of pressures from Gardiner, a very unfriendly Park County government, and the state of Montana. This little landscape has somehow survived, sandwiched between Park street and Yellowstone’s “old” entry kiosks a short way up the Gardiner river toward Mammoth. The original kiosk, historic in appearance, and in my view perfect for any National Park, acts to enhance the feeling that park management has been trying to keep the park as a Natural area, a throw back to the days of Roosevelt, a rejection of commercialization and modernization, an abandonment of the corporate notion that a park should be “developed”.
It is not clear what generated the Roosevelt Arch development scheme. The “push” likely was multipronged and Park Service “builders” and planners were no doubt a major part of the thrust. They were reinforced by pressures from businesses on Park street to provide more parking for consumerism, and at the same time, rid themselves of lines of slowly moving vehicles waiting to pass through the Roosevelt Arch, presumably of course, after the occupants had dropped some cash in town – in other words, ramp up the through-put. While we expect that in the business world, we do not, and should not, expect or tolerate it in National Parks. A third likely force was irritation with the public by concessioners employees who find themselves having to share what was historically “their” service road with the very people they make a living from.
But there is more to this. Park Service planners and management, like so many public servants in todays prolonged attack on agency budgets, are always on the hunt for dollars; “planning” in Yellowstone sadly is embodied, all too often, in building infrastructure and expanding internal use. The prospects that millions of dollars might be extracted from congress to empower public servants who want to push parking and development beyond the edge of Park Street further into Yellowstone, onto the unique habitat from whence “my” snake came, lures planners and management like a candy store lures kids.
Part of the scheme is to turn the Roosevelt Arch area into a stand-alone Roosevelt Park, a Coney Island of sorts, surrounding it with pavement and walk ways, and of course, feed more consumers onto Park Street, as though this were a National Park mandate. It is also intended to eliminate what has been a long standing occurrence of vehicles sorting themselves out, even though this local squeeze occurs only during part of the three peak months, as drivers work to enter the Park through the Arch. In doing so, the entry road is to be redirected and reconstructed and a further lane added, eating up evenmore of the “near desert” habitat I’ve referred to.
To cap off this scheme, the historical kiosks would be “eliminated” and that rare little piece of habitat behind the Roosevelt Arch would be invaded by a greatly expanded “modern” entry facility. 
There remains, however, “a whiff of the malodorous”  associated with this scheme. Sitting in the middle of this new development is the brand new building housing the Yellowstone Association, which makes a considerable amount of its funding from tourists that stop on their way into the Park. Almost too conveniently, the Association headquarters and sales areas are just yards from the Arch; they would be front and center in any parking and walking redevelopment of the Arch area. As self-proclaimed “friends” of the Park, it is not difficult to imagine sub surface collaboration with the Park Service about pushing this encroachment and expansion into the Park. As a major business in Gardiner, the Yellowstone Association stands to benefit more than any other establishment by concentrating people around its facility.
Picture how this fits together; in June 2011, a new Superintendent, Dan Wenk takes the wheel in Yellowstone. With formal training in landscape architecture, he comes to Yellowstone with credentials, highlighted on the NPS website announcing his appointment, of six years as director of Park Service “planning, design and construction services” with accolades for spending $60 million dollars on construction of facilities and structures in Mt. Rushmore National Park, including raising $30 million in private funding to enhance that construction.
Yellowstone thus finds itself under the day-to-day command of an architect, a specialist in design and construction. He has, as number two in charge, an engineer. I can only assume that these senior managers are both hardworking and decent people but the worry lingers that both see Yellowstone through the eyes of Washington politics and special interests, like concessioners and transportation interests, that lean very heavily on them. In todays world, more than ever in our history, the public is entitled to question where, and in whose interest, senior management effort is being channeled.
Both have been beholden to a (former) secretary of the Interior – Ken Salazar – who has been point man for the administrations “all of the above” strategy for growth and tax payer subsidized economic expansion, destructively focused on public lands. Salazar’s pro-development interference for example, appears to have instigated an ongoing revision of the ColoradoNational Monument management plan to consider growing demands for visitor/commercial use, including bike races, while admonishing  that they “need to be better neighbors”. There is little doubt Salazar’s background and training are questionable in context of oversight of any organization / agency in which conservation of landscapes is a priority; certainly no consolation to Americans who care about Yellowstone’s future!
People enter the architect and engineering professions to build and redesign “things”, including nature. They do not go to university, or spend a career, learning to NOT build things, yet no-growth, and in some cases, de-growth is precisely the management strategy National Parks must implement to ecologically (and economically) survive todays wound up world and all its predatory interests. In my view, the evidence indicates that “design and construction” are the very things National Parks can no longer afford, either from an ecological or social perspective.
There have always been opportunists lined up to exploit Yellowstone’s phenomenal landscape – imagine, for example, the great tragedy Americans would have suffered if a fellow by the name of Jay Cooke, known as a railroad “financier”, had succeeded in building his railroad through the Lamar valley  – and while they typically are, they have not always been, from “outside” the Park. My view is that we are seeing the descent of a new breed of management no longer tied to national standards, or bound by national tradition, history or commitment to optimize protection or recovery of landscape wide ecological viability in Parks on behalf of all Americans.
With this evolution of Yellowstone’s senior management team, and fueled by financial stimulus packages searching for places to “put shovels in the ground”, Yellowstone and National Park management are in retreat, backing away from the path necessary for maintaining and strengthening the ecological integrity of National Park ecosystems. I am not privy to insider relations with Yellowstone senior management, so I am relegated to reading the tea leaves, so to speak, or more appropriately, examining the evidence! Americans have to stand back, look down the trail both ways, and calculate whether a necessary change to repower conservation is imminent, or even possible. And I submit that what they see are not the criteria essential to managing the conservation legacy of Americas National Parks. To the contrary, Parks need people at the helm who aggressively resist intensified invasion of National Park ecosystems, people that are active in reaching out of the Park to ward off never-ending commercial and destructive designs, all of which consume and degrade ecological capacity in Parks.
The Park Services North Park Entrance FONSI (finding of no significant impact) statement, and the EA it rests on, is like so many others issued by government agencies intent on pushing their own agenda, far too specious. It points more to a self-serving process designed to brush aside public scrutiny than to problems or analysis that would be revealed by preparing a full Environmental Impact Statement. Further, it is a very classic, and far to common, example of a major structural breakdown in the EA process, wherein agencies like the National Park Service call their own shots on whether (and how) they should scrutinize their own activities with a legitimate environmental assessment. High-falutin declarations and self serving conclusions dominate the contents of the Arches FONSI; “this proposal is necessary”, and then, their own confirmation: the preferred alternative “best meets the purpose and need for the project”. Perhaps not so strangely, there is no evidence anywhere that the public drove this process.
A bone of contention for the public should be that Park management is degrading part of the Park because “improvements will have beneficial economic impacts on the community of Gardiner;” while there is no question that regional communities essentially “live off” the park, hand feeding local businesses is not, and should not be, the purpose of a National Park or changes to it. This agenda and “purpose” cannot be justified given even incremental impacts within and on Park resources. When the “build up” of impacts (cumulative effects) resulting from greater local human activity, substantial increases in park traffic volume, and as yet unrevealed plans to expand Mammoth are considered – and they have not been – with all the behavioral and ecological consequences for humans and wildlife, it takes narrowly focused Park Management to deny that this development scheme will impair park resources.
The North Entrance redevelopment agenda hangs its hat partly on a classic case of selective public engagement designed to ensure acceptance of a predetermined goal rather than a thorough analysis of impacts and full public participation. The “meet the public” schedule for the Roosevelt Arch plan amounted to one scoping open house and one open house about the environmental assessment, both in one community – Gardiner.
Building Park staff facilities over 5 times as large as those now in existence, as the proposed new entry gate facilities would be, may provide park employees with a new lunchroom, and that is part of the listed justification, but it is disingenuous to construe it as a benefit to the park. Part of the historical Gardiner entrance is today’s drive from the relatively primitive site of theRoosevelt Arch to the little Kiosks where you pay your entry dollars or have your pass checked. This unique site and experience will be destroyed by another government building plan and more infrastructure, an unnecessary impact particularly when construction is not for the benefit of the park, but for commercial, personnel, and quite possibly, personal reasons.
There are more reasonable and far less destructive (to Yellowstone National Park)alternatives to help sort out traffic issues at the North Entrance, and they protect and maintain the primitive nature of the park and existing entrance. As should be the case, these outside-the-Park alternatives shift the ecological and economic costs to the local business community, Park County and the state of Montana, who appear to so far have successfully parlayed this scheme into a “shift the costs onto Yellowstone and the Park Service, but keep economic benefits out side the park in Gardiner” scenario.
2. A MONSTER AT MAMMOTH
Mammoth Hot Springs, on a good driving day just 20 minutes south of Gardiner, is ofcourse home to the geothermal extravaganza from which it takes it name. It is also home to historical but still limited infrastructure built to allow humans to enjoy these exceptional natural features; there are roughly 678 “pillows” in Mammoth, and occupancy is very high in the May to September season. The town is also home to Park administration and staff living and working space, and to concessionaire staff accommodation. Almost 400 concession employees, plus Park staff, are concentrated here from May to October, fewer outside that period. What this creates, on any given day during peak season, is a mass of close to 1200 people essentially living and working in this National Park town. Add to this as many as 3500 people per day entering from the Gardiner entrance alone, and “congestion” is a seriously inadequate definition of the state of affairs.
Mammoth is also an amazing place from a human and wildlife interaction perspective, particularly in spring and fall, and I often sit and watch the goings on there, at timesalmost in disbelief. A male bison weighing well over half a ton, with a toss of his head and a stutter step, shooing off part of an ever growing contingent of Asian tourists as they naively crowd his space; Elk stepping between cars in a never ending flow of vehicles, “freezing” traffic, pooping on the sidewalks, resting in the shade of the post office; a large male elk in full rutting regalia, taking out the grill on a jeep whose driver treated the animal with contempt, as an ever growing number of drivers do, all of these mobilizing a sometimes frantic Ranger (or 2 or 3) and /or commanding the attention of volunteers and concession staff trying to give them space and protect people from, well, themselves! Truly amazing!
As entertaining as this is on the surface, there is also a very dark side to Mammoth. This historical site is threatening to burst its human and ecological seams and push this complex into an unmanageable and severely degraded human and environmental state. Along with Park Service and concession staff, thousands of humans clog the area daily from May to October. To put it nicely, the place is ecologically and socially maxed out!
While there still persists in the immediate area a local sub population of elk, bison, mule deer, and even the occasional grizzly bear preying on an elk calf in spring, what most visitors do not understand is the animals they can virtually reach out and touch number but a tiny minority of the parks population; they are the super tolerant, the habituated. To the untrained eye they look, and mostly behave, as though they are “tame”, yet they are behavioral chameleons, not to be mistaken for the vast majority of the remainder of the Parks wildlife! And not even to be mistaken for themselves at other times of the year, and in other parts of the Park, where circumstances demand they revert to more normal behavior if they expect to survive. Further, they are at Mammoth largely because they are drawn there by artificial circumstances, lured by manicured lawns and the readily accessible nutritious green grass that make these artificial habitats stand out in a sea of relatively dry native sagebrush and grasses. And strange as it may seem, some are there because they seek adegree of security from natural threats that are fended off by swarms of humans.
This highly artificial situation present tens of thousands of Americans and foreign visitors with a completely erroneous, misleading, inaccurate, and it could be argued, dishonest view and understanding of the relationship between wildlife and industrial development. There is no doubt most visitors are entertained, even thrilled, by the bison and elk they see up close in May-June and September-October. But many take away, from their brief, largely uninformedexperience at Mammoth, a jaded message of what bison and elk are and how they relate not only to the vast majority of animals in the Park, but also to the industrialized habitats that now constitute the vast majority of America, including the Mammoth hotel complex. They watch, with a hundred other humans, as elk “nonchalantly” breed outside the visitors center, and they burn up video cards filming bison on the lawn just yards from the dining room. To many of these visitors, without even a local let alone a regional perspective, what they “know” of wildlife comes from their experiences at Mammoth. Elk and bison monitors, volunteers and concessioner employees trying to keep some physical and behavioral order between humans and wildlife, do try to inform some visitors, but the contact is fragmented and reaches a relative few. And it is notablethat the Park Service does not run a full time, intensive interpretive program in spring and fall even though it has a “captive” audience. We can label this as a huge opportunity lost, or we can term it a major failure!
It is, and should be, a given that Parks are meant to be different – so far Yellowstone doesn’t, for example, allow hunting, oil and gas drilling, logging or wheeled vehicles on trails, whether they be motorized quads or mountain bikes. Protecting landscapes from these industrial and mechanical threats is what most Americans believe Parks are meant to do. A consequence of this century long purpose and design is that visitors have wildlife and social experience opportunities (amongst a range of other natural landscape opportunities) in Yellowstone that are increasingly rare. But historical, traditional and legal intentions can easily get blurred by management manipulation.
What message do visitors take home from their Yellowstone experience: a new-found or reinforced respect and value for wildlife, and even more so, how many translate that into pro-park activism and involvement, even if just in the form of a letter or phone call to their congress person or the Park Superintendent? Obviously, if even some do, that would be a strong upside.
If Yellowstone management succeeds in making Mammoth a Monster by driving up both visitor and employees housing numbers, as is now in an advanced proposal stage, the Mammoth wildlife experience can readily turn ugly. It now rests on a threshold beyond which it will degenerate quickly into the abusive practices of heavyhanded wildlife control and selective killing perpetrated by Park Staff, precisely like that which characterizes, for example, the blatant domination of commercialism over visitor wildlife interaction in Banff National Park in Alberta, or even the anti bison agenda of special interests, acting in close collaboration with the Park Service, on Yellowstone’s boundary in Montana and Idaho. Mammoth appears today to be teetering on the artificial, often management-concocted, fine line between too many people and too many elk wherein the same number of elk now at Mammoth, continuing the same behavior, can easily derail into “too many elk” as human numbers escalate and human – elk interaction becomes a management liability.
I don’t know if Americans will prevent this deterioration at Mammoth or not, but there is no question that what is being proposed for Mammoth would herald a defeat for the conservation ethic and standards that have taken over a century to establish themselves in Yellowstone.
3. CUMULATIVE EFFECTS ARE MASSING BUT IMPACT ANALYSIS IS AWOL
This section could have been left for the end of this paper and included the imminent threat of off-pavement mountain biking but it is important to focus now on the core area surrounding Mammoth and stretching through the Gallatin Canyon to the Roosevelt entry arch. Even amongst the many wonders of Yellowstone this local ecosystem stands as one of the most unique in the Park and I consider it already stretched to the absolute limits of it ecologica lelasticity. Humans and their vehicles concentrate around the Roosevelt Arch and entry kiosks, they clog the Gallatin canyon microhabitat where they literally battle the northern range bighorn population for space and survival, and they are at or beyond threshold numbers at Mammoth. In other words, they have reached or exceeded the ecological limits of acceptable change. Yet the Park Service is surreptitiously locking into development plans, each carefully isolated from the other, significant expanded human congestion and impact in this unique corridor. It is an inexcusable example of the tyranny of small decisions. 
While never openly expressed in the Park Service plans to eliminate traffic back up at the entry kiosks, the quantitative easing effect of wait time at the kiosks will be reduced or at least temporarily eliminated, essentially forcing in time and space, hundreds more people and vehicles per day through the Gardiner entrance (Roosevelt Arch). This will substantially intensify vehicle traffic (congestion) and amplify the buzz of human presence in the canyon. If the Park Service keeps retreating in the face of unmanageable numbers of people and vehicles by manipulating facilities and force feeding impacts into this ecosystem, the consequences forbighorns, elk, air quality, and pressure on day to day demands for management of people and vehicles, all of which are negative, will only escalate and have no hope of ever being contained.
As just one example of direct impact two bighorn rams were killed by vehicles in the canyon in one week this past year and the barrier effect of a virtually continuous “vehicle chain” routinely modifies sheep movements and activity. The forced proximity of wildlife and people cannot be considered beneficial to either wildlife or the Park. Indirect effects like displacement and stress arising from extreme levels of human use are intense but generally overlooked disadvantages for animals, like bighorns , that are ecologically “locked in” to using the area and those, like elk, that try to make use of it for its seasonal resources.
At the south end of this unusual landscape is the townsite of Mammoth. Expanded accommodations at Mammoth will attract and hold more people and vehicles, contributing to both human and wildlife contact – separation problems, deteriorating habitat and security effectiveness, and they will force vehicles and people into the south end of the Gardiner Canyon corridor. It’s a bit like stuffing a sausage casing from both ends, all while ignoring that its happening! No analysis of this burgeoning impact can be found anywhere in Park documents – simply vanished into the convoluted air of managerial priorities.
But a probable and foreboding reason for instigating user and political friction focused on the Mammoth – Gardiner road is the long standing senior management desire to upgrade and re-align the highway now in the Gardiner canyon. This historic drive has, I suspect, long irritated senior management, particularly highway operations, and they have, decades ago, proposed realignment parallel to but on the “benches” above the canyon. Re-alignment to the east (McMinn Bench) would be catastrophic, and any upgrade facilitating faster travel and more vehicles would be destructive. While the earlier proposal was shelved, it is likely sitting close to the renew basket on the planning desk. And what better way to resurrect such a scheme than to contrive demand by building congestion into the Mammoth and Gardiner ends of the corridor?
It is not known whether the concession contract and its environmental consequences – for example demands for expanded visitor and staff infrastructure at Mammoth – has ever been the subject of an Environmental Impact Statement. Once the contract process is closed to bid submission, as is now the case, a shroud of secrecy is imposed on the deliberative – analysis process, again shutting out the public.
Others are more versed in NEPA  than I, but my understanding is that cumulative effects analysis of agency proposals and actions are an obligation under that legislation. NEPA calls for “meaningful” cumulative effects analysis of projects that overlap in time and space; there is no question that the Park Service push on development in the Gardner Canyon corridor qualifies in both respects. Just the concession contract in itself projects a 20 year impact and essentially permanent changes proposed in it could extend impacts well beyond that time even if the Park Service were not in the practice of manipulating the visitor and ecological landscapes as in, for example, changing winter use, introducing new uses/users, and hand cuffing itself with contractual commitments.
The present impacts of existing development and activities in this corridor aresignificant and they are, and will continue to have a cause and effect relationship with Park Service proposals now either on the books or about to be locked in by secret negotiations.
None of these possibilities, or probabilities, has been exposed to Impact Assessment analysis. It is difficult not to see this glaring omission as deliberate. This alarming state of affairs can only be remedied by:
1) delaying concession contract finalization,
2) full public exposure and analysis of Park Service concession ambitions, including financial considerations,
3) delayed implementation of Roosevelt Arch / entry gate proposals and re-examination of the related Park Service agenda, and
4) eventual full exposure of the combined proposed agency actions to a thorough and publicly vetted Environmental Impact Statement.
4. CLOSED DOORS SHIELD TRANSACTIONS WORTH HUNDREDS OF MILLIONS OF DOLLARS.
As is true of the dynamics of wildlife at Mammoth, very few people understand the mechanics or politics of Park Service and Concessionier management of visitor facilities at Mammoth. In spite of some effort I can’t claim to be one of them. But what we do know should cause Americans to pay much greater attention, starting immediately.
There is a direct link between the ecological and conservation consequences of a Monster at Mammoth and the ties that bind the Park Service to the corporations that operate that manage concessions in the Park. Virtually all things in this essay are ultimately tied to this largely secretive alliance.
The National Park Service owns the hotels, dormitories, service stations, gift shops, even pubs, in a place like Mammoth. As I have suggested, it is likely that they have a very comfortable, almost day to day relationship with the concessionaires who “use” those public facilities, a relationship guided by contracts ironed out between the concessionaire(s) and the Park Service in an anonymous process almost entirely beyond the checks and balances of public scrutiny. If the absence of public and media attention are any measure, these agreements and this working relationship, appear to have settled in comfortably over the span of decades. If more and more Park “entries” – leading to more rooms and RV space rentals – in short growth and commercialism – become a management priority, and they surely are a concessionaire priority, what we see bubbling just beneath the surface in Yellowstone National Park, like a mud pot in the Norris basin, could easily foretell an irruption of commercial and ecological change. What the public doesn’t know, amongst other workings in the Park – Concessionaire world, is to what extent the Park, and Americans, benefit from these agreements?
The Park Service, according to Director Jon Jarvis, has experienced a five percent decline in day to day operations funding over the last three years (2009 – 2012) and further reductions are expected. This situation aggravates a 13% decline in annual appropriations – nearly $400 million lost – in the last 10 years.[12[ The impetus for each Park to raise more money, and keep the in-service wheels of “business as usual” churning, even as they suffer staffing losses and close or restrict access to public facilities, is clearly there. In this respect Americas politicians have thrown National Parks to the wolves, so to speak, forcing them, by incremental attrition, to fight for their own survival. That’s why the following adds up to frightening news!
In late 2013 the agreement between the Park Service and the concessionaire now operating the Mammoth hotel complex (privately owned Xanterra Holding Corporation) will be up for renewal (negotiations are intended to finalize in March, with the contract term to start in fall). This is a big, big deal!
Two major issues are at stake; first is a brewing proposal to significantly expand accommodation at Mammoth, and second, what rate of return – how many millions of dollars – will Xanterra, assuming they continue as manager of Mammoth services, pay to the American people via the Park Service. Obviously the two issues, as I have attempted to stress, are intimately linked, and each could change the face of Yellowstone.
First, lets look at the quiet development of the proposal to dramatically increase the size of the townsite at Mammoth Hot Springs. At present, there are a number of large dormitories that house about 383 Xanterra employees, the people that work in the dining room, behind the desk in the hotel, the gift shops, and thosethat do house cleaning in the Mammoth Hotel. These dorms, very recently renovated, have been there for decades. But smoldering in the background is an explosive expansion of visitor accommodations, which are presently confined to the Mammoth Hotel and cabins. The Park Service, no doubt complicit with Xanterra, is proposing to convert the Dormitories to visitor accommodation,that is “beds” that Xanterra can rent. Expansion of accommodation and housing in winter  seems to be of particular focus, but once that happens, rooms do not suddenly “close” for summer. It would be a dramatic increase to add even 250 paying persons daily to the Mammoth landscape, a place, as I’ve pointed out above, already on the verge of imploding. But this is only part of the threat.
How many employees will be displaced by dormitory conversion is unknown, but where then do these displaced employees reside? One option is to force the employees to live in Gardiner, where accommodations are already maxed out in peak season. The latter is a problem for Gardiner, but the problem for Yellowstone is even greater. Xanterra already has about 71 employees living in its Gardiner complex, and any additional people getting to and from work at Mammoth would impose a sharp increase in traffic on the highway connecting Gardiner to Mammoth. This highway (Hwy 89), twisting its way through the unique Gardiner River canyon, is already well “over threshold” at peak season, and management is already taxed as it tries to “maintain order” with an extended but entirely justified 25 mph speed zone.
Option two is to build new dormitories and grossly expand the footprint of Mammoth infrastructure. This would be the most significant expansion of infrastructure in Yellowstone in many decades, and along with parking space, would physically destroy already limited wildlife habitat at the Mammoth complex.
Complicating this already ominous proposal is the demand for additional services that 200 to 400 more visitors per day require – more meals, more sewage, more trinkets,more parking. It will not be just an additional 400 users imposed on Mammoth, but a ratcheting up of staff to serve those visitors.
A brief reference has been made to the financial difficulties facing Yellowstone. What is unknown to the American people – and I have yet to extract the numbers – is the return the concessionaires pay back to the American people for the privilege of: a) using public / Government (Park Service) infrastructure, b) for the privilege of doing business in one of North Americas premier landscapes, and c) having a captive clientele of over three million visitors annually. You couldn’t wipe the grin off the face of most businesses if they had that opportunity, and it may be that those operating in Yellowstone are grinning all the way to the bank. There lingers, however, a suspicion that, for example Xanterra (and other concessionaires), after decades of control, looks upon using Yellowstone as an entitlement granted by contract with the Park Service. What the Park Service may concede in such a long-standing relationship is unknown!
Part of the deal with concessionaires requires them to maintain the public buildings they use to conduct their business. They are contracted to keep in working order, and occasionally renew, structures, as has been the case in recent years at Mammoth with the Dining Room and the previously mentioned dormitories. That should be a no-brainer. But what becomes of the millions of dollars beyond maintenance / renewal that visitors pay for services provided by this infrastructure?
The history of public lands management regarding financial returns to American taxpayers has not been an illustrious one; below cost timber sales, grazing a cow for a month for barely more than the price of a loaf of bread, a prehistoric mining law, and massive royalty exemptions for the oil and gas industry. These kinds of shoddy practices may not be in place in National Parks like Yellowstone, but the point is, the public doesn’t know that.
Concessionaires typically pay to the Park Service, a “franchise fee” determined by a financial analysis of the probable value of their contract to the concessionaire. They pay this fee based on gross receipts of their operations. In addition, they reserve a percentage of annual gross receipts for “component renewal projects” – the repairs and replacement I mentioned above. In the case of Xanterra (operators of Mammoth Hotel) this renewal reserve is presently 11.5% of gross receipts and comes with a requirement to, for example, complete a $5.3M capital improvement at Canyon Village.
I found it striking that the franchise fee paid by concessionaires in Yellowstone is, for example, 2.5% for Xanterra, and between zero (no fee) and 2% for other concessionaires. Most people would be pleased, I think, if they were obliged to keep their house in repair and then pay not more than 2.5% tax. The reality is that gross receipts of concessionier corporations are unknown – some are privately held companies and this information is treated as proprietary – and the value of the fee returned to the Park Service is unknown. In addition, the financial analysis that “sets” the franchise fee is critical in terms of eventual return to the taxpayer, and I have yet to determine who audits the concessionaires books.Americans can, at this point, only hope that the National Park Service is doing diligence in this respect. History has shown that “hope” tends to lead to slim pickins!
The concession business in National Parks is, in my view, Americas business; it should not be secreted behind the iron wall of private contractors or shielded internal to the Park Service. On the contrary, it must be subject to total disclosure and intense public scrutiny; but at this point, that is not the case.
I would like to trust that the American people can connect the dots between the Park Services financial squeeze and undetermined income from franchise fees from concessioniers. Money generated in the Park, by Park resources (clear air, water, beautiful landscapes, quiet, wildlife, ecological spectacle, escape from industrialism and technological overload, as examples) may well be escaping the Park, the Park Service, and by extension, Americans. At the same time as financial stress threatens Yellowstone, Americans have made it clear that ecological protection must be a major role for National Parks.
The major contract for concessions in the Park is due to be renewed in November 2013 (decision about March 2013). Projections are that its value is at least $2 billion over a proposed 20 year life. This is an inordinately long term,
given that other Parks are operating on or negotiating ten-year agreements, and points once again to deteriorating National standards and processes. Considering the propensity of public servants to grossly discount the future (particularly negative or destructive environmental, economic and regulatory impacts) the consequences of a cozy,unscrutinized agreement in years 10 to 20 could be monumental. According to a superficial Park Service public release, about 19% ($390 million at the high end of estimates) of projected contract value will be fed back into Yellowstone for repairs and maintenance of infrastructure, leaving $1.6 billion (81%) in the hands of the private contractor. Obviously that provides for operating costs – wages, fuel, and cost of products used and sold, for example. These numbers, and profit, may be buried in documents not readily available to the public but I suspect several hundred million dollars shake through as profit. The American public needs to see these numbers and be informed by asharp penciled, public interest analysis independent of the Park Service. Two (2) or 3 million dollars annually, or thinking on a greater plane as in nonprofit management, $20 million annually, would be decisive in managing and protecting this gem in Americas National Parks crown!
Yet the existing level of ecological integrity and ecosystem viability in National Parks cannot be maintained when, on one hand, they are confronted with (and even promote) growing infrastructure and visitation while, on the other hand, management resistance to human overuse and abuse is impaired by lack of personnel and resources to let them do the job. In a functional sense that means commercialism and inappropriate recreation expansion, both of which inherently degrade ecological viability, should be capped or even reined in. The focus on franchise fees, then, is not to expand commercialism and conflicting and damaging activities, but making it clear that the Park Service should get afair share (or quite possibly all) of income generated by existing visitor economic activity. A revised share agreement with concessionaires may be the order of the day or alternatively, the option of converting concession management to a public non profit service, operated either by the Park Service or some other non profit organization, should be on the table, in which case all proceeds generated in the Park would remain in the Park for conservation, interpretation and education, and protection services.
5. INVASION OF THE TRAIL SNATCHERS; COMING SOON TO YELLOWSTONE?
For Americans that seriously watch events in the countries National Parks, it comes as a disturbing surprise to see senior management of any National Park deliberately introduce and promote, in these rare and irreplaceable spaces, an activity like off pavement mountain biking; mtn biking is based on machines and dependent on vehicles, and it is an activity in which the off pavement culture is knowingly inbred with a disproportionate level of cheating and lawlessness . The move is in stunning conflict with reality; it comes as National Parks advance rapidly toward ecological isolation and are increasingly ecologically fragile – and each day they become more valuable to Americans and the Nation for their natural ecosystems and contributions to social and democratic cohesion.
This surreptitious campaign to alter the very nature of National Parks is not happening by accident. It is a calculated effort to capitulate to aggressive national and commercial interest lobby groups like the International Mountain Biking Association, gear manufacturers and dealers, and vocal extremists inlocal communities.
This stealth initiative (see the Federal Register, 06 July 2012, a rule by the National Park Service, Vehicles and Traffic Safety, bicycles) has only recently reared its ugly head. It now threatens to deliver a destructive and irreversible blow to the national role that National Parks have historically played, and not incidentally, were established to play. National Parks have united Americans from coast to coast, faithfully serving hundreds of millions of citizens, and they have successfully done so by being stable refuges from mechanization, commercial development and industrialization. Based on this deviant National Park Service Rule, a century of successfully serving people from across the nation is apparently no longer a high priority – no longer a management standard. Satisfying millions of visitors expecting equal and unimpaired access to most park natural areas, all while serving the dual role as home to relatively intact and protected ecosystems, is now under severe and intense attack from commercial and mechanized interests. And sadly, Parks management has become a significant contributor to the threat. To suggest that this is a serious betrayal of the will of the American people, crafted over a century of conservation involvement, is a gross understatement.
The cultural change in National Parks management that has been underway for over three decades, has been, to Parks watchers and conservationists, palpable. You can feel it! The swing has been from old time senior management, people dedicated to protection and commercial restraint, to the new breed of promoters and collaborators, people whose swagger comes from incorporating local commercial business interests into Park Management. Gone, or going, are people that see Parks as National assets, not just as symbols, but as real and tangible landscapes divorced from the growth and consumption agenda of other federal and state lands, lands where decisions and management are based at least partly on scientific ecological integrity, lands where national democratic citizen involvement directs decisions, lands where the protection and conservation agenda are to be aggressively defended.
The July 2011 Park Service rule strikes not only at National Park ecosystems, but equally as dangerously, it attacks the century long conservation and protection vision and philosophical foundation of National Parks. The rule is being justified by senior Park Service management spouting the same tired proclamations that have led over decades to Americas long and growing list of endangered species, the critical state of biodiversity across the continent, and the degraded state of public lands “managed” for industrialism and motorized/vehicle use (National forests and Bureau of Land Management holdings). There have always been commercial and extreme activity interests pounding at the doors of National Parks, whether they be mining, grazing, or hotelier interests. But the newest breed, equally as dangerous, are mountain biker dealers and manufacturers and their anointed spokes persons. National Park management has cowered before these latest pressures who sense weakness andincapacity to regulate; senior Park Service Management has assuaged its failures to protect National Parks with cries that compromise is necessary!
Compromise, however, no longer has a place in the conservation and protection of critical lands like National Forests or Wildlife Refuges. Compromise is the function of giving away something each time pressure or demand occurs. It works well for commercial and corporate interests – to use an example, a special interest Group demands a piece – a few acres or just a “few” trails – of the $100 dollars the public has in its hand. Five years later another Group wants the same thing, or the first wants even more. After decades of compromise, the public now holds $13.47. Some might consider that a benefit; after all, “we” could have nothing! I don’t see it that way. Nor do living ecosystems function that way.
The National Park Service, with its recent decision to grant local autonomy to Park Superintendents, essentially allowing National Parks to scatter in every direction, has arbitrarily decided local politics and pressures will be permitted to trump the national interest, sound science, and one of the Nations most democratically run institutional and governing systems. The National Park system is destined to degenerate into a series of regional fiefdoms run by people who move through the system every 3 or 4 years, passing on to where they can no longer be held accountable – it is a flagrant abdication of National accountability.
America is already seeing failures resulting from management’s abdication of legal and moral, social and environmental obligations. In Big Bend National Park, where National Park standards were eroded through complicity between outside the park lobbyists and an in-service coterie of people, the Superintendent recklessly surrendered the Park to the climate of ecological and social conflict that characterizes mountain biking.
When conservation management of National Lands sinks to the level, as a National Park spokesman terms the Rule, of “a reasonable compromise”, it is illuminating to look at the money and lobbying trail. A compromise built on willful ignorance of conflict, cowardice in the face of intense lobbying by special interests like mountain bike dealers, manufacturers and promoters, and an indefensible disdain for scientifically sound land and wildlife protection standards, is not a compromise. It is malfeasance!
A mole is a person who insinuates him or herself into an organization or system for the specific purpose of elevating a single agenda, usually an agenda that person stands to personally gain from, above all others, with calculated disregard for the social, psychological, or environmental damages and costs imposed on other interests and agendas. The strategy is most common in the environmental regulatory world, and it is a practice that has been highly successful for the mountain biking lobby; through it they have broken down traditional, environmentally and scientifically sound, user compatible standards and activities on Public lands with remarkable regularity, as events in Big Bend indicate.
This cannot be viewed from a public perspective as a success or achievement, except in today’s perverse commercial and growth dominated agenda.
These mean spirited “I’ll trade off National Park integrity because I cant handle the flak that comes with saying no” actions are not accomplishments; they go into the lost-past and lost-future column, a place where Americans begin to loose something they have managed to (generally) hold above the every day ugly politics of greed and consumption for a century. It is tragic that, under the few Federal rule, a single person can now severely damage, and begin to alter Yellowstone or any other National Landscape, according partly to personal biases and whims. This unhealthy concentration of power will impact millions of Americans, and it robs future millions of Americans of the chance to experience a present day living landscape the likes of which do not exist anywhere else in North America.
It is alarming that the Park Service would introduce an anti national, decentralizing local-power rule, aimed specifically at forcing mountain biking into National Parks, in direct confrontation of decades of sound scientific study showing the acute and costly conflict between machines, their users, and bears and wolves as well as elk, mule deer, and sadly, all other species including birds and fish. After decades of intense effort by the American public, with collaboration by some government agencies including the Park Service, to recover grizzly bear and wolf populations in the Yellowstone ecosystem, efforts which can not yet be considered a success (an improvement yes, but success not yet), it is offensive to see the indifference and arrogance of senior planners and rule makers as they load additional human use and conflict into this delicately balanced ecosystem.
The change that will take over all of Yellowstone when mountain bikes begin to run freely will resemble a life altering shroud of social and user conflict. Contrary to the rote arguments by senior management and planners in the Park Service (see the rule) a decision to slip mountain biking into national parks is a federal decision that will significantly affect the quality of the environment. Gone will be the serenity associated with citizens that come to watch wildlife and walk in spectacular landscapes in peace; front country and backcountry solitude will be elusive, if not gone; the delightful anonymity that hikers and casual road side users exhibit, their generally quiet demeanor and friendly yet excited conservations, will far too often be over ridden by high fiving, whooping, and screeching mountain bikers, the constant clutter, bumping and squeaking of machines, and the visual offense of the garish garb of Tour deFrance wannabes. No two groups of people could be in greater contrast.
One group, American citizens that have enjoyed our National Parks for over a century, will lose a cherished park environment, while another, mountain bikers and their corporate backers, will take over a previously natural use landscape with machines and the bravado that accompanies them.
The Federal Register notice makes a feeble attempt to buff up the Park Service decision by citing one reference, and only one, and what a choice  it is. Absent entirely is any indication that an Environmental assessment examined the extensive impacts of the decision. The reference employed is scientifically and technically underpowered, was never critically examined by agency staff with scientific or law enforcement credentials, and stands as an outlier that began with a distinct bias – it was initiated and funded by the mountain biking industry. In what appears to be a deliberate attempt to manipulate the public’s perception and understanding of mtn bike impacts, the study, and Federal Register notice, focus on whether a bike tire or hiking boot causes more damage to a trail. It is the farcical equivalent of claiming that the only impact your car has on the world in which it operates is where its tires contact the pavement.
The Park Services zealous reliance on one piece of highly questionable work, a very short term effort with methodological problems, inadequate sample effort, absence of any statistically reliable analysis or results, and failure to incorporate cumulative effects, reveals not scientifically sound, professionally objective or socially responsible investigation, but a pathological ideology determined to ramrod mtn biking into National Parks and landscapes at any cost.
By focusing on “how many angels can dance on the head of a pin” the Park Service and mtn biking promoters have succeeded in distorting historical priorities and creating a smoke screen diverting attention away from the most significant and overarching issues and impacts. These should include 1) national public hearings about whether vehicles should ever be allowed to run freely on hiking trails, 2) whether traditional low impact users like hikers, nature enthusiasts, and admirers of natural landscapes should be forced off public lands by machines and their advocates, 3) whether cumulative effects on historical park users and natural resources should be ignored, and 4) whether the ecological and behavioral impacts of bikers and bikes on wildlife should be dismissed. By diverting attention to a fifth or sixth level issue, albeit a real one, like stationary tire impact on soil, the National Park Service has bowed to a flim flam campaign by mountain bike advocates and promoters.
The Federal Rule callously ignores reality; the daily range of mountain bikes far exceeds that of people on foot (or horseback), it allows bikes and bikers to outdistance and elude the “reach” of law enforcement, and it ignores the far reaching biker invasion of designated or de facto wildlife and human habitat security which National Parks have long provided. Mountain bikes represent not only a vastly different kind of human footprint, but they enable major expansion of the human footprint with negative ecological and wildlife population dynamics and population viability consequences.
To make the claim that the physical impact of mountain biking on soils is no greater than the impact of hikers and walkers is not only preposterous, but for the Park Service to hang their hat on it as though it were ordained by solid scientific investigation and subsequent evidence, is dishonest. To dismiss as irrelevant the weight loading on tire surface, the constant rotation movement, braking, sliding and skidding, says a great deal about the ideological spin the National Park Service has put on this issue. Unwittingly, I suspect, Park Service (and other agency) proponents of mountain biking contradict themselves and the “no greater impact” argument by immediately pointing to the need for drastic trail up-grading ,including “armor” plating, and constant maintenance necessary to accommodate biking. That begs the question then, just which is it, ladies and gents? No impact, or massive and intrusive trail construction and/or upgrades and heavy duty maintenance, which all lead to a sharp increase in physical (and ecological) trail size and presence, biker use, and subsequent erosion surface?
But this is only a small part of this effort to railroad public perception of bikes and biker impacts. By insisting that you and I hold a magnifying glass to the physical impact of bikes on soil (trails) they systematically ignore and misrepresent the three greatest areas of impacts; 1) conflict with traditional users, and the rapid displacement of hikers, walkers and people interested in the natural world and escape from machines and industrialization (isn’t that what National Parks are for?), 2) the vastly extended range of impacts on soil, waterways and vegetation that machines permit, and 3) the broad and intensive ecological and behavioral zone of impact (footprint, or better stated, machine and driver print) on wildlife that surrounds the trails and parking areas bikes and bikers use. This orchestrated misrepresentation and omission is as absurd as arguing that the only thing important about the elephant in your living room is the sole of its foot!
The displacement effect of these newly created habitat “pits” that form around mountain biking roads and activities, consisting of lost and degraded habitat effectiveness, will redistribute some if not many or all, of the members of existing wildlife populations, with ramifications for in Park and inter-jurisdictional conservation and conflict management. These negative changes will add cumulatively to existing stress on endangered species, populations, individual animals, their habitat and legally mandated recovery efforts.
The stunning ignorance imbedded in the argument “just let us build a super (bike)highway – bikers and their industry coyly insist on calling them trails – to high speed standards, multiple bike width, extreme construction durability, sometimes through previously unfragmented wildlife habitat, and then introduce bikers with an anti social “we deserve to have our machines here attitude”, and “we know there will be no environmental or social impact” indicates a deep seated attitude of denial, entitlement, ignorance, and disrespect. Equally as threatening to public lands and Americans who engage in traditional uses of those lands, is the acceptance of such a fraudulent claim by regulators like the National Park Service. Listening to and reading the Park Services rote infatuation with “non impact” mountain biking propaganda is akin to listening to Fox News discuss climate change science.
Any argument that bikers will have no impact when they are “shredding” – their word – a well built upgraded bike road 5x the width of a hiking trail that leads into habitat formerly without a road or which was previously a narrow or average park hiking trail, and that will be subjected to use by mechanical vehicles and receive traffic travelling 7 to 20 times the speed of a typical hiker, is an outright fraudulent claim.
The reality is that far too many land and wildlife management agencies and (particularly senior) people in those agencies , are mired in a chronically under informed vacuum that fails to serve the public interest or meet the serious needs of scientific, intelligent and aggressive conservation responses and actions now desperately required in Americas National Parks and public lands.
This view of industrial and vehicle impacts on landscapes and ecosystem is dependent on a long established agency / corporate insistence, still prevalent in middle and senior management, that the non human living world be regarded as an essentially mechanical system in which individuals lack the sensory and cognitive abilities of humans; in fact, the mammals, birds and fish that occupy Yellowstone, for example, have sensory systems and abilities / capabilities which are in many cases far superior to those of humans. This requires cognitive capacity, different than that of humans of course, to process the information they get from their surroundings, surroundings which increasingly are clogged with human presence.
The presence of mountain bikes on any landscape is an added threat to the appreciation and conservation of natural cultural resources – evidence of trail use by wildlife, for example – when one considers that these temporary signs of the natural world are obliterated by mechanization.
Humans have an evolutionary and cultural connection with wildlife, and while much of this is cognitive – a positive mental state of mind about wildlife – there is no question too that the setting – both the landscape and designated management agenda, as well as visual, auditory and olfactory signs – all elicit renewal and reinforcement of cognitive connection and enjoyment.
One of the immeasurably rewarding pleasures gained from walking in, or just thinking about, Yellowstone is not seeing evidence or examples or occurrences of mechanical contrivances, the kinds of things people in North America see on a hourly basis in most of their life. Escaping these stress-producing irritants is a major reason people use National Parks, wilderness areas, and other more well managed, less industrialized public lands. It is a treat, soothing to the soul and mind, to walk a trail and not see tire tracks, discarded parts of machines, or the high rate of debris vehicle users haul with them. Walking a trail and seeing tracks of a grizzly bear that might be just ahead of you, or passed by this morning traveling your way, or noting the tracks of a monster bison and wondering if it’s just around the corner, or simply admiring the delicate track of a pronghorn, brings a surge of pleasure and excitement to many hikers, me included. In this cumulative respect, the presence of mountain bikes on any landscape is an added threat to the appreciation and conservation of natural cultural resources – resources which are not always carved on a rock wall – and which I believe include evidence of trail use by wildlife, however temporary these signs of the natural world might be. These important signs and indicators are obliterated by mechanization like mountain biking.
It is approaching an act of desecration to think of a bison plop, or a pronghorn scraping, dissected or defaced by a mtn bike track. Using the words of George Bird Grinnell, one of the Parks earliest champions who fought to keep Yellowstone wild, mtn bikes will defile Yellowstone with their “unsightly traces of civilization”.
Bikers rage incessantly about “freedom” – in fact some of them rant on their websites and list servers, about their freedom to “not give a f*#k”!. But can driving all traditional trail users off the trail and causing significant physical,ecological, and behavioral damage to wildlife, landscapes, viewscapes and outdoor experiences, be propagandized into some twisted definition of freedom? Is so, freedom for whom? Certainly not for mature and elderly public land users, not children and mothers and families, not those who value their time in natural, non-industrialized surroundings, not those who value wildlife, and certainly not those who value National Parks for their fundamental historical, social and ecological purpose.
The threat that bikes and bikers pose to other users and wildlife should come as no surprise. The cognitive “envelope” around a person engaged in a seemingly simply yet demanding manual motor task like riding a mountain bike on a trail is disturbingly narrow; the task consumes most of the participants brain “power”, virtually shutting off input to that individual from visual, auditory and olfactory signals that originate outside that very restricted envelope. In other words, contrary to the proclamations of bikers about experiencing the outdoors and interacting with the natural world, they are virtually in a shroud created by subconscious innate, natural biological and neural demands on their senses; they see little, hear little, and smell very little. They are as distant and removed from “nature”  as if they were driving a car!
The list of impacts and conflicts associated with mountain biking keeps growing, and yet land and wildlife managers keep behaving as though they are without common,scientific or social sense, robotically repeating propaganda and misinformation from the biker lobby. Mtn bikers as a group are heavily disproportionately males, young males. Yet National Parks have so fare prided themselves in appealing to all sectors of American society, including females and all age classes. It is not uncommon, in fact, to see special programs designed to get all Americans interested and active in the outdoors. Mountain biking does exactly the opposite; the aggression and threats to emotional and physical well being bikers present on a trail disproportionately drives female hikers, outdoor activists and mature and elderly walkers to abandon trails and areas invaded by mountain bikers. Consequently, many hikers abandon areas sacrificed to mountain bikers, leading to displacement of woman of all ages as they abandon their public lands, their hiking trails, their favorite walks and their special areas, creating a sex aggravated impact.
Its time the Park Service came clean in a functional everyday sense and identified mtn bikes as vehicles; the recent rule threatening to turn bikes loose on Yellowstone (and all other parks) occurs under the heading in the Federal Register as “Vehicles – bicycles”, which is honest, probably by accident, and confirms my observation that functionally, and legally, mountain bikes are vehicles! Yet the Park Service has not been honest enough to concede in their everyday language and planning documents that mountain bikes really are vehicles, and they should be treated and managed like all other vehicles. In reality, proposals to permit mtn bikes in National Parks are proposals to give priority to these vehicles above traditional – historical use by humans without vehicles.
The tiresome claim that mountain bikers are being “denied access” to any area is another of the baseless and fact-free arguments common to promoters of the industry. Almost all bikers are, as elementary as it may seem to point it out, in possession of two legs and two feet and (most) are as capable of walking as hikers are. They have never been denied access to wilderness areas, protected areas, or National Parks. Like every other American, they can walk public lands under virtually all circumstances, the few exceptions being resource protection closures, and these are true exceptions!
6. CONCLUDING THOUGHTS
The National Park Service capitulation to lobbyists for mountain biking and local political interference advocating visitor growth turns back over a century of slow and incremental progress that has made America’s National Park system, a major part of which was strong dedication to national interests and conservation, the envy of the world. In a flagrant betrayal of that history and system, National Park Service senior management has unapologetically sold out the century long practice of placing people before and above machines.
Americans have already compromised away most of the land in their nation. After almost 200 years National Parks are the remnants of insatiable demand and compromise. They are priceless. And they harbor and, in cases like Yellowstone, anchor much of the Nations still ecologically functional landscapes. They are the end result of a century of conservation horse trading. Now another crack has appeared in the conservation dam.
At risk are still functioning, living ecosystems that stand to lose a great deal from any compromise. They need all their existing biological and evolutionary parts and processes to stay alive.
The net results of an off trail mountain bike invasion will be many, all negative. Ecologically significant parts of National Parks will come to be dominated by destructive land use and intense user conflict, much like other Federal lands (National Forest and Bureau of Land Management lands) are dominated by, for example, ecologically destructive grazing. The unfortunate appearance of the local decision-mountain biking Rule demonstrates a disproportionate influence over a regulatory agency that was at one time presumed to be there to protect the public interests; it will further aggravate bitter and unjustified conflict about who owns national lands and who should decide how and to what extent they are protected.
National Parks senior and middle management consists largely of people who, for structural as well a personal reasons, typically do not look down the political and economic power scale, to the people and citizens, for direction, empowerment, or approval.Quite the contrary; approval comes from up the scale, where obedience to the political agenda, not the public interest, is rewarded both career wise, personally and in agency culture, with the power associated with funding for things like buildings, roads and other forms of infrastructure. There are, occasionally, exceptions where administrators attempt to buffer the negative impacts of political directives and lobbying by special interests by pointedly pulling the public into the process via NEPA, thus balancing the steady inward push to mine National Parks for economic and political gain. Regrettably, this did not happen in the Roosevelt Arch process where the Superintendents decision not to proceed with an EA effectively divorced the public from knowing about and countering environmental impacts. Yellowstone Managements “desire” for paving and building near Gardiner, and designs to impose additional housing and visitor accommodation on Mammoth, are further examples of decisions lacking public scrutiny and sanction. The descent of decision making from Park Service headquarters and regional offices down to the Superintendent level in order to force mountain biking into places like Yellowstone, appears to be coming from special interests insinuated in the Washington and Denver offices of the Park Service; quite possibly descending all the way from (former) Secretary of the Salazar via the Chief of the Park Service and Deputy Directors. This is powerful political cover for a willing Superintendent and for pro development “moles” in the “planning” department.
America is suffering a crisis in regulatory decay brought on by government that has increasingly viewed and “managed” public lands as a distant by product of economic growth and consumption. Public lands and National Parks, Yellowstone in particular, were initially protected in the Theodore Roosevelt era because visionary people saw great value in public ownership of exceptional landscapes that protected (“stored”) and renewed watersheds, biodiversity (including wildlife and natural landscapes), clean air, and refuge for all citizens from the physical and mental poking and prodding of everyday work and survival.
The great vision and the ecological well being of public landscapes foreseen over a century ago began to slowly weaken in the 1960s when public lands began to be viewed as storehouses for extractable resources. National Parks, however, began to segregate themselves from this consumption agenda, establishing themselves in the eyes of the American public, as the best of special places and deserving of legal protection separating them from the agricultural, industrial and mechanical invasion that was degrading National Forest and Bureau of Land Management lands.
By the 1980s the march against public lands was intense, – I suspect Roosevelt would have been thoroughly offended by the multiple use policy of that period – but still National Parks, thanks in large part to growing involvement of citizens who had come to realize what was at stake, held the high road against industrialization by special commercial interests.
Absent the legal foundation to say no to virtually endless “development” proposals at a regional or National Level, no competent or efficient regulatory system can exist. As is now becoming far too evident, a local “regulatory” system, wherein one person can throw a park into ecological decline, is incompatible with the long term viability of ecosystems, including the protection of ecological, legal and social standards that have for over a century defined Americas national ownership of Parks. The pathological premise that expanded human (as at Mammoth) and industrial (as in mountain biking) consumption of the biocapacity of Yellowstone NP can be “managed” at the impact end (for example, on the trail, or after construction and ramped up visitation), as opposed to the pre development publicly accountable assessment end of decision making, threatens to dramatically interfere with the ecological function and visitor enjoyment of Yellowstone as we know it today.
One of the pressing needs in today’s world is the need for some positive social constants, as well as some ecological stability, and National Parks have played just such a role, helping stabilize the lives of millions of Americans. National Parks have acted as fire walls against the day to day impact of commercial, government, corporate, and self centered individual insanity that weighs heavily on Americans. Changes in National Parks like those in Yellowstone and Big Bend are striking at this stability and creating another layer of tension American don’t need and haven’t asked for.
The growing occurrence of incremental expansionary and consumptive development and “improvement” actions are irreversibly degrading National Parks, from Mount Rushmore to Joshua Tree to Yellowstone, each one taking another bite out of the Parks living systems and each degrading the quality of visitor experience with the natural world. Each one is contrary to the traditional National Park role of maintaining ecological function and unimpaired landscapes by keeping development out of and at a distance from National Park Ecosystems.
National Parks are amongst the few remaining landscapes on which society has committed itself to sharing physical and ecological space with other species. Now this commitment is under severe threat. Giving one person almost complete control of the regulatory and administrative apparatus that permits a decision that would change irreversibly the historical culture, management and philosophical orientation of not just one National Park, but the entire National Park system, is a critical failure of democratic governance.
It remains to be seen whether the American public has the will and determination to contain extreme behavior by public servants and resist the invasion of National Parks by special interests . It is an understatement to say that the future of National Parks as public and national institutions depends on it.
– – –
Dr. Brian L. Horejsi
An ecologist / wildlife scientist, the author began his science and advocate career at Montana State University in Missoula, with stops thereafter at the Univ. of Alaska and the Univ. of Calgary, where he earned a PhD in the behavioral ecology of large mammals. He has for over 15 near consecutive years spent several periods each year enjoying Yellowstone.
[1 ] See Supernaugh, W.R. 1998. Enigmatic icon: The life and times of Harry Yount. In Yellowstone National park History E-library, At http://www.nps.gov/history/history/hisnps/npshistory/yount.htm #28, And Punke, M. 2007. Last Stand; George Bird Grinnell , the battle to save the buffalo, and the birth of the new west. Univ. of Nebraska Press, Lincoln, NB.
 Until a year or two ago, there existed only one kiosk, but a second “temporary” kiosk was added in 2010 (?). The new kiosk is roughly the style of the original, and compliments it well.
 This intention is expressed openly in Park Service documents – for example, the Memorandum of Understanding” between the Park Service and local interests, including the Gardiner Chamber of commerce, and the Project Scoping document, to which the Park Service is a signatory, and within which this statement stands out: “There is a need to provide public restrooms and points of interests for visitors, safe walkways and access to local businesses, and to address deficiencies with infrastructure which are currently inadequate to handle summer visitation” [my italics] . This justification is repeated, although more obscurely, in an e mail from Yellowstone Superintendent Dan Wenk, dated 26 October 2011.
 Americans are entitled to wonder just what Yellowstone management priorities are. I see some managerial deception at play here. The second Kiosk, added just years ago, relieved much of the vehicle congestion between the entry station and the Arch, confining it to late summer. A third Kiosk (temporary if need be – after all the “problem” is short term, perhaps 4 to 6 weeks) could easily be added, at a cost of just tens of thousands of dollars, versus the millions it will take to build the new entry port closer to the arch. With a 3rd log Kiosk congestion would be virtually non existent, or at least significantly diluted.
 Lifted from : Punke, M. 2007. Last Stand; George Bird Grinnell , The battle to save the buffalo, and the birth of the New West. Univ. of Nebraska Press, Lincoln.
The author used this phrase to describe Grinnells sense of “land grabbers” schemes to gain title to land in Yellowstone for “improvement” purposes.
 Public Employees for Environmental Responsibility. Newsletter, 16 November 2012.
 See Punke, M. 2007. Last Stand; George Bird Grinnell , the battle to save the buffalo, and the birth of the new west. Univ. of Nebraska Press, Lincoln.
 See footnote 4, above.
 See Odum, W.E. 1982. Environmental degradation and the tyranny of small decisions. BioScience vol. 32(9): 728-729. Odum points out the insidious occurrence and impact of incremental “small” decisions, and how they become regionally destructive when national standards and discipline are abandoned.
 See Ostovar, K. 1998. Impacts of human activity on bighorn sheep in Yellowstone National Park. MSc thesis, MSU, Bozeman, MT. This study was instigated because the Park Service was considering relocating the road, either to the east or west of its present alignment through the Gardiner Canyon. The study suffered from a lack of baseline data, including historical displacement, distribution and movements, but still reported that sheep were displaced by humans and adult females were suffering from elevated levels of stress indicative corticosterone.
These impacts become even more substantive when viewed in the context of population status and viability; this sheep population is considered to be less than half of historical numbers.
 National Environmental Policy Act.
 National parks Conservation Association. 2011. Made in America, Investing in our National Parks for our heritage and our economy.
 The portends, in addition to burgeoning summer use, growing pressure on winter use limits.
 See: Yellowstone invites bids to provide lodging , retail, and other visitor services. Yellowstone National Park news release, 18 May 2012. This brief release states that the present contract holder (Xanterra) reported $90 million in gross receipts in 2011. I estimated that, with inflation and/or growing visitation, receipts will total over $2 billion in 20 years.
 There is relatively little documentation of the illegal activities that characterize off-pavement mountain biking activities. This void is largely attributable to willful blindness by land and wildlife management agencies, a good part of which has been cultivated through a campaign designed to dismiss or downplay the conflict ridden nature of, and environmental damages caused by mtn bikes and bikers. This campaign to escape accountability has been ongoing for several decades, starting when the IMBA and its corporate sponsors jumped way out in front of land and wildlife managers and successfully coopted ownership of the issue with a deliberate campaign to “throw the fox off the trail”. Like all good corporate campaigners, they realized that advertising and intense propaganda – capturing the labeling of the debate – are extremely effective means of swaying the public and government regulatory agencies and can effectively mask, distort and/or paralyze action on the results of scientifically and ecologically sound impact assessments and the evidence they might produce.
There are a few exceptions; One is: Hendricks, W.W., Ramthun, R.H., and D.J. Chavez. 199?. “To cross or not to cross: Mt. bicyclists’ resource trail etiquette behavior.” In their work, they documented violation of biking rules and regulations by 78 to 83% of bikers, respectively, who rode through a closed trail section when they were asked to walk, and who drove through a stream when they were asked to use a bridge.
See also: Newsome, D. and C. Davies. 2009. A case study in estimating the area of informal trail development and associated impacts caused by mountain bike activity in John Forrest National Park, Western Australia. J. of Ecotourism, Vol. 8(3):237-253. The authors conclude “aggressive and thrill seeking approaches to mountain biking, however, ….remain a constant problem for protected area managers.”
 Department of the Interior. 2012. Final Rule, Vehicles and Traffic Safety – Bicycles. 07 June 2012. National Park Service 36 CFR Part 4 [NPS-WASO-REGS-9886; 2465-SYM] RIN 1024-AD97.
 Public Employees for Environmental Responsibility. 2012. Big Bend breaks ground on single-track bike racing trail. News Release, 18 April 2012.
 Marion, J.L., Wimpey, J.F., and L.O. Park. 2012. The science of trail surveys. : Recreation ecology provides new tools for managing wilderness trails. Park Science 28(3) :60–65. Available online at http://www.nature.nps.gov/ParkScience/index.cfm?ArticleID=544.
 The Union of Concerned Scientists has concluded that 93% of the climate science coverage that appeared on Fox News in the first half of 2012 was “misleading”. See: Huertas, A., and D. Adler.. 2012. Is News Corp. Failing Science? Union of Concerned Scientists, September 2012.
 These are most often people that were educated 20 to 40 years ago when land and wildlife management was even more regressive than it is today, a time when conservation was just beginning to surface on the public agenda.
 See footnote 7, Punhke, p. 184.
This cognitive isolation is made even more acute by a helmet, which not only physically shields the rider from his/her environment, but provides the rider a sense of anonymity and consequently self imposed immunity, one of the foundations of aggressive and lawless behavior.
Dr. Ralph Maughan is professor emeritus of political science at Idaho State University. He has been a Western Watersheds Project Board Member off and on for many years, and also its President. For many years he produced Ralph Maughan's Wolf Report. He was a founder of the Greater Yellowstone Coalition. He and Jackie Johnson Maughan wrote three editions of "Hiking Idaho." He also wrote "Beyond the Tetons" and "Backpacking Wyoming's Teton and Washakie Wilderness." He created and is the administrator of The Wildlife News.
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