Friends of Pathways appreciates this opportunity to comment during the scoping phase of Grand Teton National Park’s (GTNP) Moose-‐Wilson Corridor Comprehensive Management Plan process. Our board, staff, members, and supporters are dedicated to this mission:
‘Friends of Pathways supports a vibrant community by advocating the completion of a safe and sustainable pathways system for healthy recreation and transportation opportunities in Jackson Hole.’
Advancing this mission demonstrates our community’s longstanding and time-‐tested regard for natural resource conservation, land stewardship, and sophisticated care for our guests. We strongly support and endorse the goals our country has charged the National Park Service with advancing. Among those that are salient in the setting of the Moose-‐Wilson Corridor are non-‐motorized access, the protection of natural resources, and the enjoyment, education, and inspiration of this and future generations in Grand Teton National Park.
Overall, we ask that in this process of scoping, defining alternatives, and the eventual issuance of a record of decision, GTNP include the provision of a pathway to enable safe, non-‐motorized, human-‐ powered transportation as part of a positive solution to the management of the Moose-‐Wilson Road Corridor.
Wildlife and Pathways
We are passionate about pathways because they enable connections in our community, traffic reductions, healthy lifestyles, family recreation, attention to nature, and increased public safety. We are equally passionate about wildlife and the environment that make Jackson Hole and Grand Teton National Park so unique. Thoughtfully designed, context-‐sensitive pathways and important natural resources complement each other.
To educate ourselves about the balance between pathways and the environment, we sought a fact-‐ based analysis of the studies done on the existing pathways and their potential impact on wildlife. The result of the research FOP sought is a science-‐based review of the wildlife studies that were released by GTNP. That summary is included with these comments. It was important for FOP as well as the general public to know that overall, the existing data show that the impacts to wildlife can be de minimis, so long as the appropriate management steps are taken during construction and operation to reduce potential impacts to acceptable levels.
NPS Centennial Initiative 2016
From NPS communications regarding the President’s Centennial Initiative 2016: “In celebration of the 100th anniversary of the National Park Service in 2016, America invites the world to discover the meaning of national parks to their lives and inspires people to both experience and become devoted to these special places. (The) National Park Centennial Initiative (will) prepare national parks for another century of conservation, preservation and enjoyment. The National Park Service has asked citizens, park partners, experts and other stakeholders what they envisioned for a second century of national parks. To that end, from GTNP’s communications, these goals are included among many others in a key section of the prospective statement:
“What will GTNP do to meet these national goals? Grand Teton projects include:”
- ‘Establish pathways along road corridors that will connect the park with adjacent gateway communities and encourage non-‐motorized visitation’
- ‘Continue to be a National Park Service model in effective partnerships with local government, stakeholder groups, our Association and Foundation, and other government agencies’
We at FOP along with many in the community are gratefully supportive of this statement for the President’s NPS Centennial Initiative 2016. We are eager and dedicated to being a positive, supportive partner to GTNP and the NPS for the long term.
FOP appreciates the need to balance the National Park Service’s dual missions of “protect and preserve” with “use and enjoy.” Like the NPS, we want people to actively and memorably engage with national parks throughout our nation and become the future stewards of these jewels. NPS Director Jarvis has been a champion of non-‐motorized transportation, and certainly the inspiring ‘Let’s Move’ initiative of the First Lady to reduce obesity, especially in children, is a perfect fit for the potential Grand Loop of 30 miles of pathways in GTNP and Jackson Hole. The only missing link in this loop is the approximately 7 miles along the Moose-‐Wilson Corridor. The National Park Service’s success story of pathways in GTNP could be profiled perfectly as a winning part of the ‘Let’s Move’ program and would clearly be aligned with Director Jarvis’ support of non-‐motorized access to National Parks.
In GTNP’s setting adjacent to the gateway communities of Jackson, Wilson, and Teton Village, we believe a complete pathway within the Moose-‐Wilson Road Corridor is an important alternative for GTNP. We strongly urge you to study an alternative that would provide a complete, adjacent, but separate pathway in the forthcoming Draft Environmental Impact Statement. This improvement is needed for public safety, and would advance the goals of the Centennial Initiative for pathways by alleviating traffic congestion and sparking philanthropy and partnerships with gateway communities. If vehicular traffic is a problem, as is the case with respect to safe non-‐motorized passage through the Moose-‐Wilson Corridor, people on foot, bicycle, and in wheelchairs on a separated pathway are part of the overall solution.
2007 GTNP Transportation Plan FEIS
The 2007 Grand Teton National Park Transportation Plan FEIS was seen as a model for pathways and transit that could be used not only in GTNP, but also in other parks. The incredible success of these pathways, from their first full season of use in 2009 to the present time, should have been part of the scoping issued by the park for the Moose-‐Wilson Corridor. We were disappointed that no mention of the public’s good experience and wildlife compatibility with pathways was included in the scoping questions. We were further surprised and disappointed to notice the 2007 FEIS Record of Decision that approved a pathway on the southern half of the Moose-‐Wilson Road was not cited. The scoping notice fails to give the public clear information of the existing conditions and what approvals already exist.
We were also concerned as to why the Notice of Intent and the scoping information failed to give the public some ideas as to what the park was proposing for an action, why, and to what purpose. Consequently it was difficult for FOP to provide much information or comment on the topics, scope, and methods of analyses necessary to go forward. We also had some difficulty in understanding what existing public approvals would remain in force and what new approvals might be considered in the future.
If subsequent scoping efforts are undertaken or being contemplated, we ask you to fully include pathways as part of that effort. We ask that you respond to the significant input you are surely receiving about pathways in this scoping process, including this comment, by fully including pathways analyses, and existing pathways-‐related investigations, in the next steps of this NEPA process.
We also ask you to reincorporate GTNP’s own language and stated intent for the 2016 Centennial Initiative. There is an opportunity to complete the pathway from the Granite Entrance to Moose and perhaps name it the National Park Service Centennial Trail. Doing so would fittingly acknowledge the hard-‐earned success the NPS has achieved throughout our country in balancing conservation with visitor safety and enjoyment. A pathway in the Moose-‐Wilson Corridor is a challenge the NPS can meet at a high standard; this new pathway, together with the existing pathways in GTNP, will inspire other NPS managers and their supporters.
Since the scoping material did not include a proposed action or alternative, the imprecise process of the current NEPA effort has confused many in the community.
The FOP Board and staff committed our organization to remain positive in our messaging. We urged our members to support the slow, narrow, rural character of the Moose-‐Wilson Road. We have asked that public safety be prioritized, natural resources be protected, and a complete pathway be added.
As a pathway is approved under the 2007 ROD from the south entrance to the Laurance S. Rockefeller Preserve, and a soon-‐to-‐be complete circuit of non-‐motorized paths will connect Moose, Jackson, Wilson, and Teton Village, the lack of a separated pathway on the northern section of the Moose-‐Wilson would be incredibly unsafe as it would confine hikers, bicyclists, pedestrians, runners, photographers, wheelchair users, and others all together into a narrow channel along the road with moving vehicles.
Two people have already died in vehicle cyclist collisions where no pathway existed. Also included in this comment letter is the moving guest letter submitted by David Axelrad, the father of Gabriella Axelrad, a young girl who was tragically killed by an inattentive driver at the age of 13 while cycling in GTNP in 1999 with her family. It is important that the NPS prioritize public safety so Gabriella’s death, along with the death of Jeff Pool in 2001, are the last cyclist fatalities in this National Park.
We support the proposed action for this new EIS as suggested by the elected leaders of Teton County, Wyoming and the Town of Jackson, Wyoming in their joint letter dated February 6th, 2014:
“The purpose and need should set a goal of establishing maximum traffic volumes on the Moose-‐Wilson Road to maintain positive visitor experiences without disrupting historic uses and public access, and then identifying the best strategies for managing travel demand to meet those volumes. The purpose and need should also set a goal of providing safe bicycle and pedestrian access along the Moose Wilson Road.”
“The purpose of the project is to: (1) develop adaptive management policies to manage traffic along the Moose-‐Wilson road in a manner than maintains the visitor experience, minimizes traffic growth, reduces vehicle impacts on wildlife resources, and allows continued two-‐way traffic, (2) authorize realignment and construction of portions of Moose-‐Wilson Road to separate vehicle traffic from sensitive wildlife habitat; develop designated pullouts, walk ways and wildlife viewing areas on the east side of the beaver ponds, and (3) accommodate non-‐ motorized bicycle and pedestrian amenities along the full length of the Moose-‐Wilson Road.”
Positive community partnerships build trust as well as infrastructure. FOP, working with many local, state, and federal governmental agencies, is helping to bring about important, affirmative solutions for the future. We are dedicated to Grand Teton National Park as we are the greater Jackson Hole community. We are honored that more than 500 comments from people across all 50 states, and even a few from outside the US, are already on record in this scoping process – this demonstrates positive, national, grassroots support for a complete pathway. Completing the Moose-‐ Wilson Road pathway is good for our community, consistent with the mission of the National Park Service, and a matter of national importance.
Thank you for this opportunity to comment. We appreciate our partners in the National Park Service; together we can find an excellent solution that advances the mission of the NPS and promotes the lasting values of Grand Teton National Park.
On behalf pathways supporters, our community, and our visitors, we thank you.