Comments on the 2011 Merced River Plan Workbook

written 12/13/11
YOSEMITE VALLEY CAMPERS COALITION
Brian H.Ouzounian, Co-Founder

If you would like to download this report as a PDF to read offline, please click HERE.

The following comments are in response to the questions and multiple choice “options” provided in the 2011 Wild and Scenic River Merced River Planning Workbook. NOTE: You can download the Plan Workbook as a PDF at http://www.nps.gov/yose/parkmgmt/upload/Merced-Wkbk-web.pdf .

As a general statement, our organization is disappointed that there is no option to “Repair the flood damaged campgrounds to their original condition, including and especially the Group Campground”. This request has been submitted time-and-time-again over the years during various workshops and open comment periods, and we were assured all the while that those comments would be brought forward to the next current planning project.

Attached to this document is a cost comparison prepared at the request of past U.S. Congressman George Radanovich to illustrate the feasibility of retaining those campgrounds/sites in the Valley. The numbers are compelling for repairing the flood damaged campgrounds to their pre-flood conditions. Something that the Workbook ignores is the cost feasibility of the ideas presented. This study illuminates one aspect.

SEGMENT 1: Merced River Above Nevada Fall
Management Considerations and Potential Management Options

text separator

Visitor Use Management Program (page 13)

separator

Segment 1 Wilderness Trails: High Encounter Rates

1A. NO
1B. NO
1C. Item lacks information in order to make informed comments. Overnight parking for these visitors cannot be addressed since the plan lacks a transportation plan and a study of user capacity. Need to define “high concentration rates” as there is no basis as to this standard of care for this statement. Again, lack of information

Recreational User Conflicts

2A. NO
2B. NO
2C.NO Helicopters are used in ample frequency for search & rescue. Astonished that this is an option but if there is some greater reason for this option, it needs to be explained in more depth. Item lacks information in order to make informed comments. User capacity study needed.
2D. Stock is vital for trail and wilderness campground maintenance and also for rescue. The interference with recreational visitors is minimal in the big picture of things. Also stock use is a historical component of our Park and has historical value, which should be part of the interpretive educational core. Trail maintenance for solid waste matter (feces) should be implemented, if not already in place, to protect the resources. Item lacks information in order to make informed comments.

Land Uses and Associated Developments (page 13)

Merced Lake Backpackers’ Campground: Use Levels

3A. NO
3B. NO
3C. YES but….
3D. This destination is a historical recreational site. Item lacks information in order to make informed comments. User capacity study needed prior to comments.

Merced Lake High Sierra Camp: Wilderness and ORV Impacts

4A-G NO. This destination is a historical recreational site. Item lacks information in order to make informed comments. A user capacity study needed prior to comments

Little Yosemite Valley Backpackers’ Campground: Crowding

5A-D. This destination is a historical recreational site. Item lacks information in order to make informed comments. A reasonable approach is minimization, not elimination. Day parking for these visitors cannot be addressed since the plan lacks a transportation plan.

SEGMENT 2.1: East Yosemite Valley
Management Considerations and Potential Management Options

Ecological and Natural Resource Values (page 15)

Clarks Bridge to El Cap Bridge: Large Woody Debris Management

6A, B., and C. unclear.
6D. Prefer to state the following: Allow/engineer/place logs to assist in mitigating riverbank erosion. Do not allow perpendicular to water flow. Fashion log placement to also facilitate recreational self-owned rafts and vessels and the safe use of such in seasonal months. Objective is not to create a totally safe river rafting condition but rather a safer more visitor friendly experience, such as the removal of cross-current logs in this stretch of river. For instance the condition where the Merced River intersects with Tenaya Creek and the one cross-current log consistently causes injury to visitors and self-owned rafts at the west end of North Pines Campground. Eliminate the concession rafting enterprise altogether.

River floating on the Merced River in this section of the river is a historical ORV for it has scenic value of the geology as well as recreational value, both ORV. It is an overwhelming experience when done in solitude on personal water vessels versus mass concession provided rafts with multiple visitors aboard.

Riparian Zone: Campsites

7A. No
7B. No
7C. Include the appropriate comments in 6D. and: Repair any flood damage campsites as Congress appropriated the funds post flood. Use engineering methods of erosion control for riverbank protection, which vary in form but are effectively implemented to facilitate both visitor recreational use and riverbank protection.

The river access to campers is an ORV! Camping as near as possible to the river is an ORV and the most desirable form of visitation for centuries. Whether it is sitting alone on a log reading, bird watching, meditating, napping, photographing, or river rafting, this is a prime Yosemite Valley ORV and needs protection and repair after the flood. The river will do what it wants to do each season and camping is the most compatible resource-based activity with minimal impact and with the ability to adjust to the spring run-offs.

The riparian management is subject to the natural flow. For the NPS to try to manage it to some philosophical level is unnatural. Each seasonal event either allows the riparian growth to remain or it scours it away by erosion. It is unfair to blame the campers for this natural event each season.

The unnatural placement of the current split-rail fences installed along the banks of Lower Pines and North Pines Campgrounds is a prime example. The NPS has bored holes into the fragile river banks, disturbing the root structure of the trees while trying to convince the public that it is saving riparian growth; an oxymoron to say the least. Did anyone have a conscience when the gas-powered post-hole auger bored into the banks cutting tree roots and riparian growth? One wonders. These fences need to be removed and the river allowed to do what it does naturally. These fences also concentrate river bank ingress and egress by visitors at the ends of the fences, overloading those areas, instead of allowing visitors access throughout the area. There is minimal visitor impact on these riverbanks to warrant such extreme measures as in this option.

Of the 81 miles of this river, certainly the portion from Clark’s Bridge to Sentinel Beach can be zoned for recreation as described above; a reasonable approach.

Since there is a lack of a user capacity study, further comments cannot be provided.

Opportunities for Direct Connection to River Values (page 15)

Cultural ORV: Visitor Use and Infrastructure

8A. No
8B. No
8C. Yes
8D. Camping by the Merced River is a Cultural ORV, although Park planners have not included these past comments in this workbook. Reference the thousands of comments on the petition by the Yosemite Valley Campers Coalition (www.yosemitevalleycampers.org). Repair these campgrounds to repair the omission of this Cultural ORV. Protection measures are encouraged to allow and facilitate this ongoing Cultural ORV. Science must not trump this ORV. Its preservation and repair are consistent with that of the commissioning of the Park in 1860 by President Abraham Lincoln via Frederick Law Olmstead, which I know the NPS has on hand. However, since there is a lack of user capacity study, further comments on this option are limited.

Visitor Use Management Program (page 15)

Valley: Camping Demand

9A. YES but not walk-in, rather drive-in and auto based
9B. YES in addition to 9A
9C. NO, NO, NO
9D. Please include the thousands of comments on the e-petition submitted by the Yosemite Valley Campers Coalition (www.yosemitevalleycampers.org) and the substance of the petition itself by repairing the flood damaged campgrounds and sites including Lower Pines, Upper River, Lower River, and especially Group Campground, to pre-flood conditions. Congress appropriated the funds for such repair and it needs to happen accordingly.

The demand for more family affordable auto-based drive-in campsites is overwhelming - and it has been for decades. Campers experience and become stewards of self-reliance in the most rustic forms for the most part. If the YNPS had more responsibly reached out to the campers for public comment, there would have been a huge response. Much of the would-be respondents are so fed up with YNPS disregarding their requests after attending the multiple open houses and planning sessions over the years that they regard their participation as pointless. In the past, there has been great participation, only to be reduced consistent with Park officials turning their backs on their requests. Those who have not been contacted are in the millions; they are those who have camped over the decades and those who were not successful in obtaining a campsite reservation. Many are day visitors who wanted to camp but must resort to day visits. (They are the ones most likely to know where to park their cars, by the way.) The first time visitors find themselves in confusion related to parking. Without a transportation and parking element in this study, further comments are postponed.

Land Uses and Associate d Developments (page 15)

Sugar Pine Bridge/Ahwahnee Bridge Road Berm: Free-Flowing Condition

10A. No
10B. No
10C. No
10D. These bridges are “Historical Structures” and belong on the Federal Registry for historical protection. They will also serve the access to those areas once the campgrounds are restored to pre-flood conditions. They will also serve as escape routes if and when there is disaster that demands evacuation; cut off these bridges and you cut off a major evacuation route. These bridges also would serve a campground east of the Ahwahnee Hotel recommended in the comments of Section 9.

Implement compatible engineering methods to accomplish free-flowing conditions as a best-possible compromise solution. This discussion and ideas are similar to those points made in sections 6 and 7, and may include but not be limited to rip rap, natural fallen log configuration, gabions, and/or any combination, and native rock/masonry diversion walls. Although this is not to suggest replacement of the bridges, an illustration is the past reconstruction of Sentinel Bridge that was rebuilt of similar style and materials to accommodate flooding and transportation. These bridges are also needed to accommodate bike and pedestrian visitor use as currently used.

This Workbook and public study is absent a transportation and parking plan, a major component needed to comment further.

SEGMENT 2.2: Yosemite Village Area
Management Considerations and Potential Management Options

Ecological and Natural Resource Values (page 17)

Housekeeping Camp: Riparian and Flood Plain Impacts

11A. NO
11B. YES to keeping all units but NO to the scenario to delineate river access as this plan concentrates damage and accelerates erosion.
11C. NO
11D. NO
11E. This facility should be allowed to be updated/improved but to its rustic fashion within its existing footprint. It is a historical family friendly low cost facility to visitors that include basic and rustic amenities for a visitor equation of well graded choices of resource based options. It is slightly less rustic than camping and less “high brow” than the Camp Curry cabins. To many, it too is a Cultural ORV.

The idea of controlling river access is incorrect. The split rail fences need to be removed as they concentrate ingress and egress at the ends of the fences and do not allow river access to be dispersed. They are unnatural, a blight, and disrupt the root structure where installed. Add bioengineered stabilization to the existing riprap where possible.

Upper and Lower River Campground Areas: 1997 Flood Impacts

12A. NO
12B. Yes to repairing pre-flood quantities of campsites but not to the other points.
12C. NO
12D. By infrastructure, I take it to mean restrooms and not campsites. If so, I agree. The sewer and water supply in place must not be removed. Repair riverside campsites as discussed above in 8D. Campsites must be repaired to pre-flood quantities and locations and expanded where possible and should include/expand areas to the north of each. Riverbank erosion and reconstruction should be implemented per ideas using proven engineering methods as discussed above in 6D and 7C,

Opportunities for Direct Connection to River Values (page 17)

Cultural ORV: Visitor Use Impacts

13A. NO
13B. NO
13C. NO
13D. In the past, we have found that agreeing to these measures, A or B or C, without locations & remedies specified in detail, results in granting open-ended licenses to Park Service czars to implement devices at his/her discretion. The methods proposed in this category are theoretical. They would have a negative impact on existing and future camping.

Visitor Use Management Program (page 17)

Valley Camping Demand

14A. YES but “Rivers” Campground (plural)
14B. YES but inside the Valley to the maximum extent possible and per comments on 9D.
14C. NO
14D. The options are not per the camping stakeholders’ requests. This option as written is regarded as disingenuous to the requests of the past. Campers have requested this to read

(14A.) Repair and return all flood damaged campgrounds and sites, including and especially group camping, to pre-flood condition.

Not just the Rivers Campgrounds! An abundance of documented comments to this end have been submitted to the NPS and, as such, warrant a correct inclusion in this workbook. These areas are now “damaged campgrounds” and are awaiting “repair.” The funds for such were appropriated by Congress for this end after the flood damage.

Land Uses and Associated Developments (page 17)

Camp 6 Intersection: Congestion

15A., B., C., D., E., Not enough information to comment; congestion caused by NPS eliminating and curbing other dispersed parking areas. Transportation plan is not included in the workbook as it would directly relate to this condition. Should have been part of the workbook

SEGMENT 2.3: Yosemite Lodge Area
Management Considerations and Potential Management Options

Ecological and Natural Resource Values (page 19)

Leidig Meadow: Informal Trail Impacts

16A. NO
16B. NO
16C. Install protection devices and boardwalks that have been proven effective. Wooden observation platforms are consistent with accommodating both. Provide picnic tables or observation benches to establish designated areas to view and experience the ORVs.

Swinging Bridge: Riparian Impacts

17A. A transportation plan is needed to properly assess this option. Not enough information provided.
17B. NO,
17C. NO
17D. NO
17E. See 17A

Visitor Use Management Program (page 19)

Yosemite Valley: Paddling and Floating

18A. NO
18B. NO
18C. NO
18D. NO
18E. Massive degradation at the Sentinel Beach picnic area has occurred from the rafts, the concentration of people, and the yellow school busses to this once pristine area. The NPS should

Valley: Camping Demand

19A. NO
19B. NO
19C. NO
19D. See the comments on the Yosemite Valley Campers Coalition e-petition at www.yosemitevalleycampers.org.
Develop new campgrounds as follows:

In addition,

Land Uses and Associated Developments (page 19)

Yosemite Lodge: Intersection Congestion

20A. YES
20B. NO
20C. NO
20D. An underground tunnel can be built, including handicapped accessibility, most easily. This is the best option.

SEGMENT 2.4: West Yosemite Valley
Management Considerations and Potential Management Options

Ecological and Natural Resource Values (page 21)

El Cap Meadow: Informal Social Trails

21A. YES
21B. NO
21C. NO
21D. NO
21E. Maximize the use of elevated platforms but add wood decks with observation benches for public viewing. Use the same type of platforms for picnic tables.

Visitor Use Management Program (page 21)

West Pohono Bridge: River Access

22A. NO
22B. NO
22C. NO
22D. Maximize parking and designate river access via curbing and boulder placement where appropriate.

Valley: Camping Demand

23A. No to Taft Toe. Make parking and picnic area on wood platforms with picnic tables and observation benches. Also:

23B. Yes in addition to previous campground requests ONLY. Not in substitution of.
23C. NO
23D. See above

Land Uses and Associated Developments (page 21)

Cathedral Beach Picnic Area: High Visitor Use

24A. NO,
24B. NO
24C. Redesign picnic area to increase visitor use with more picnic tables and observation benches. Designate formal access point using wood platforms without fencing off areas. Platforms will suffice. Insufficient information to comment further. Need user capacity study info.

Sentinel Beach Picnic Area: Visitor Experience

25.A-25C. NO
25E. Redesign picnic area to expand picnicking. Remove all commercial concession rafting and allow personal / private rafting egress, formalize vehicle access. Incorporate existing Valley Hybrid buses to include a stop here for purposes of day use and for picking up personal rafters who wish to raft to this destination. Add viewing wood platforms and benches near riverside.

SEGMENT 4: El Portal
Management Considerations and Potential Management Options

Ecological and Natural Resource Values (page 23)

Greenmeyer Sandpit: Flood and Riparian Plan Impacts from Fill Material

26A-26D. No comments as insufficient information

Infrastructure: Valley Oaks Impacts

27A-27D. No comments as insufficient information

Land Uses and Associated Developments (page 23)

Maintenance Administrative Complex: Roadside Parking

28A-D. No comments as insufficient information

SEGMENTS 5, 6, 7 AND 8: South Fork Merced River Wawona
Management Considerations and Potential Management Options

Ecological and Natural Resource Values (page 25)

Wawona Campground: Campground Activity Near River

29A. NO. The campsites are not too close to the river
29B. NO
29C. Expand campground with more sites. Add more near-river sites where possible. Plant more trees of various local species as campground lacks shade. Do not designate river access so as to spread impact and not concentrate it.

Opportunities for Direct Connection to River Values (page 25)

Camp A.E. Wood

30A-B. No comments

Visitor Use Management Program (page 25)

South Fork: Paddling and Floating

31A. NO
31B. Yes. Remove fallen timber hazards

Land Uses and Associated Developments (page 25)

Picnic Area Near Wawona Store

32A. Yes but insufficient information to comment further
32B. No
32C. Do designate river access so as to spread the impact and not concentrate it.

Impoundement: Effects on Free-Flowing Condition

33.A-B. No comments as insufficient information

River Management Challenges: YOUR IDEAS
Questions From Page 27

Ecological and Natural Resource Values (page 27)

Q: How can we protect and restore free-flowing conditions and hydrological function?
A: See the above answers

Q: How should we protect and restore meadow and riparian habitat?
A: See the above answers

Q: Which areas are high priority for ecological restoration?
A: The land where the concessions operate.

Q: How can we preserve our limited water supply?
A: The YNPS and concessionaire employees and families contribute to massive waste water usage. Also, the “fixed-roof lodging” facilities do the same. Laundry requirements necessitate massive amounts of water also plus lavatory, water closets, showers, etc. The special events that fill the fixed roof lodging surcharge the impact on the water supply. Reduce this impact and you preserve ‘our limited water supply’. Campers require minimal water use and make due as minimalists, making them the best user and preserver of resources.

Q: What best management practices must be in place to protect water quality?
A: Increase camping, reduce fixed roof lodging and support amenities.

Opportunities for Direct Connection to River Values (page 27)

Q:What measures should be taken to continue to protect cultural resource integrity, including archeological and ethnographic resources?
Q: How can we ensure that people have opportunities to experience quality connections to the river in ways that are protective of the river?
A: Eliminate rafting and allow private floatation vessels from Clarks Bridge to Sentinel Beach. Less impact and most likely less river use. Remove bicycle concessions and develop a transportation plan that includes and encourages privately owned bicycles and paved pathways from the east to the west ends of the Valley and all destinations in the Valley. Campers bring their bikes as a matter of routine and can even grocery shop on a bike if there is such a plan.

Enforce the current maximum allowable campers to six (6) per site so as to enhance the quality of the visitor experience. Would you want to camp next to 20 and expect to listen to the flow of the river, the birds, and the natural sounds around your campsite? The more there are in a site, the more distractions (stereos). Enforce the quiet time rules as well.

Limit animals should be boarded such as now present at the stables, not mixed with campers.

Visitor Use Management Program (page 27)

Q: If the NPS were to expand the existing parking inventory, by how much and at which locations would be appropriate?
A: Where is the YNPS transportation and parking plan? This has been a necessity for planning purposes and is not included in the workbook. It is needed to assist in forming opinions prior to these workbook sessions. Has anyone surveyed the visitors to ask their opinions on parking and transportation?

Q: Would you support bus services along new routes into the Park?
A: Absolutely not. Busses have unregulated diesel emissions. The roads are not engineered for busses but rather autos. Also, auto emissions are regulated and bus emissions are not. CNG busses would be great but they need refilling and most probably a refilling facility can not be built and maintained in the Valley. The mechanism of CNG busses must go in the undercarriage, which is where the heavy baggage is normally loaded on busses for weight distribution.

Q: If there were such services, would you use them? Why or why not?
A: No and why are you asking this without a transportation study? Have you surveyed the visitors on this matter? Have you asked those who ride the tour busses if they would prefer auto transportation? They serve the foreign visitor who “pay-to-play and not US Residents. They cost too much and the amenities that serve the riders are cost prohibitive, forcing eating at concessions and the need for fixed roof lodging. Campers cannot use buses to load their gear and get around. What about emergencies? Being confined to a bus is not enjoyment of the Park’s resources. Ask a young family with two children if they would rather ride a tour bus into the Park or take the family minivan? The answer is the minivan. Have you asked them by going throughout the Park with a survey?

Q: Would you support remote parking and shuttle services?
A: No No No.
Q: Why or why not?
A: Who wants to ride around the Park on a bus? Maybe foreign visitors who don’t know better and are booked by a travel agent. Maybe they are OK with taking pictures from a moving bus because there are few, if any, turnouts to stop and take pictures, save Inspiration Point (Tunnel View). Is this a market that the YNPS is targeting ... foreign visitors ... whereby increasing the profits of the concessionaires of which the Park gets a 15% cut? This begs the question as to what is the cost of such a system and who pays for it? Not the US Resident ... or will we via our tax dollars to the YNPS to subsidize this idea. Again, is anyone looking at cost feasibility?

This transportation mode would reduce the visitors into the park as most would not use them. Who wants to abandoned their cars in an unsupervised and travel a much longer distance into the park, possibly getting motion sickness……and with children? No way.

Also, consider the danger to the roads. Then imagine being in an auto trying to pass a bus on those winding roads that are really too narrow for busses! There will be more accidents, which would be a long way from emergency services.

I would not support tearing up land in the gateway communities for massive parking lots and/or structures. This would increase emissions into the parkland and surrounding communities; remember we campers had to reduce campfire hours to reduce particulate airborne matter? Bussing is contrary to reducing particulate emissions ... or can we lift the restraints on the campfires now to enhance the visitor experience?

Wasn’t this studied and stopped years ago? Why is it popping up again?

Q: If day use vehicular access were to be limited, are day use reservations appropriate?
A: No but not enough information is provided. This seems to be a loaded question as well as are the following related questions. Isn’t a transportation and parking study appropriate first? Don’t we need a user capacity study first, which was brought up at the Workshop meeting in the Park?

Q: Would you support the use of a day use parking/vehicle permit?
A: No
Q: Does this mean 1) Would you use a day use parking vehicle permit?
A: No
Q: OR 2)Would you support a day use parking/vehicle permit system?
A: No

Q: What types of recreation are appropriate in the river corridor?
A: Camping, picnicking, bicycling on private bikes, river floating on private vessels, hiking, walking, photography, hammock napping, bird watching, backpacking, fishing, private horseback riding, rock climbing, snow shoeing, Nordic skiing, wildlife enjoyment, log sitting along the Merced River while reading a book or napping on the log, sunbathing on that log. These activities are done best via privately owned automobiles which are quiet, emission regulated, and offer the freedoms of travel, gear access and the ability to evacuate in case of a personal or Park emergency.

Q: What is needed to support these recreation opportunities?
A: More affordable auto based drive-in camping and picnicking areas, such as repairing the flood damaged campgrounds, including and especially Group Campground. The current pay-to-play accommodations do not serve the original intent of the Park that President Lincoln envisioned.

Land Uses and Associated Developments (page 27)

Q: How can the NPS support the current mix of day use and overnight visitation?
A: Repair the flood damage campgrounds to pre-flood conditions including Group Campground as funds were appropriated by congress for their repair after the 1997 flood.

Q: How can we increase the availability of camping while ensuring that river values are protected?
A: Camping is a resource based ORV.

Why is there a “Concept Map” now issued with this exercise? It sends a message of predetermination. A marked up plan will be sent to accompany this report via U.S. Mail.

Q: What types of services and amenities are necessary to provide for both resources protection and management of user capacity in the Merced Wild and Scenic River corridor?
A: The presence and proliferation of fixed-roof lodging is not consistent with resource protection. Camping is an activity that has minimal resource impact. It allows best exchange of visitor enjoyment with the minimum amount of support and infrastructure.

What is the housing population of both YNPS and concessionaire employees combined with their families? These two groups make up quite a lot of the impact on the areas. Their basic overhead support is a huge day-to-day overload on the resources and it is probably growing verses diminishing. What minimal level of support is needed to preserve the resources and provide for the basic services they now offer? Fixed roof lodging requires massive vehicle trips and support services and create an unnecessary load on resources, whereas camping has minimal impact and requires very little oversight and support by comparison. Hotels require maintenance workers of various trades on a routine basis that is not required for camping. It is believed that there is a ratio of resource impact that is 10:1 of fixed roof lodging per night compared to the impact of camping per night, all services included!

Install ice and vending machines in campgrounds so as to limit vehicle trips to the market. Normally other staples can be done on a bike with a basket or a backpack.

Tour busses are not an amenity that is conducive to resource protection nor enjoyment. Their emissions are unregulated and the riders require massive concession support amenities such as fixed roof lodging, restaurants, internet, laundry service, “green dragon” tours about the Valley, stables, rafting concessions, swimming pools, etc.

Q: How can we consolidate functions to increase the efficiency of administrative land use in Yosemite Valley?
A: This makes no sense; define “efficiency.” Lacks basis for an answer.

Q: How can we prioritize land use for visitors while still ensuring operational needs associated with visitor and resource protection are met?
A: It is obvious that the public cries out for more camping, which has a minimal operational need and a maximum visitor satisfaction and the most resource protection, hands down. They do not cry for more tour buses and more fixed roof lodging.

It is feared that, from this difficult exercise, the Park Planners will develop alternatives that will not be altered. The planners had an opportunity to do it right but now it appears not to be the case. Unfortunately, campers remain un-notified and disenfranchised in the planning process, even after we have offered several methods of contact along the way. The responses have been courteous but the follow-through inadequate

 

 

Yosemite Valley Campers Coalition copyright 2010-2012 all rights reserved