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Yellowstone!

posted November 14, 2001
by Jason Robertson

In October 1998, American Whitewater asked the Park Service to consider reopening a handful of Yellowstone's rivers for limited whitewater recreation opportunities. Our proposal called for a paradigm shift in management of recreational opportunities in Yellowstone. In short, AW proposed that all recreation use in the park be subject to a non-degradation standard. The complete proposal is attached below. Though we submitted the proposal at the Superintendent's request, it was rejected in August 2000.

The Superintendent's negative decision relies entirely on unsubstantiated statements about potential conflicts and adverse impacts. Given the lack of evidence or documentation of these impacts, or public participation in the decision making process, American Whitewater is continuing to pursue our legal options in Yellowstone.

At present, boating in Yellowstone remains illegal.

American Whitewater's Yellowstone Proposal

Note that the files are in PDF format. This means that several are quite large. Therefore, the file size is listed after the title for your convenience.

Cover (42K)
Title Page (8K)
Table of Contents (7K)
Executive Summary (38K)
Background (8K)
Proposal (253K)
Analysis (581K)
Black Canyon Map (154K)
Back Cover (83K)

Evaluation of Superintendent Finley's Decision

The decision cites the Park's review of the 1988 analysis and 1950 decision, stating: "We have reviewed these past decisions and the ecological and visitor use rationale that was used to make them and have determined that the decision was based on sound reasons that support continuing the closures today."

The decision asserts that the preservation and potential impairment of park resources as core responsibility of park managers. It goes on to define "impairment" as an adverse impact on one or more park resources or values that interferes with the integrity of the park's resources or values, or with the opportunities that otherwise would exist for the enjoyment of them by the present or future generations.

The connection to whitewater canoeing and kayaking, and scientific justification of both assertions is tenuous at best. Neither assertion is supported by Park Service or other peer reviewed scientific literature on the potential impacts of limited whitewater recreation as presented in our proposal.

The park found, without evidence, that opening Yellowstone's rivers had the potential to:

1. adversely impact park wildlife,
2. adversely impact historical and archaeological sites,
3. conflict with other park users,
4. impact vegetation,
5. require infrastructure development,
6. create sanitation hazards, and
7. create safety hazards.

Black Canyon:

1. Statement: Important low elevation wildlife habitat used by variety of species throughout year. Claimed Correlation to Boating: displacement of wildlife. Evidence or Documentation of Potential Adverse Impact: none provided.

2. Statement: Numerous prehistoric archaeological sites are located along this river segment, some of which have been adversely impacted by existing recreational uses and bank erosion. Claimed Correlation to Boating: none provided. Evidence or Documentation of Potential Adverse Impact: none provided.

3. Statement: Trail along segment is popular with fishermen and hikers. Claimed Correlation to Boating: new use may conflict with existing users. Evidence or Documentation of Potential Adverse Impact: none provided.

4. Statement: Trampling vegetation at access points may increase the amount of disturbed or denuded vegetation. Claimed Correlation to Boating: Trampling could occur at access points. Evidence or Documentation of Potential Adverse Impact: none provided.

5. Statement: Safety of boaters and rescue personnel is of serious concern. Claimed Correlation to Boating: swift, deep, cold stretch of river for SAR personnel. Evidence or Documentation of Potential Adverse Impact: none provided.

Gardiner:

1. Statement: presents wildlife concerns, bighorn sheep use the river for feeding and watering below the 45th parallel and other wildlife use the riparian habitat along the river. Claimed Correlation to Boating: displacement of bighorn sheep. Evidence or Documentation of Potential Adverse Impact: none provided.

2. Statement: presents visitor concerns, segment is popular with fishermen and photographers. Claimed Correlation to Boating: conflicts would occur. Evidence or Documentation of Potential Adverse Impact: none provided.

3. Statement: presents vegetation damage concerns, damage to thermophyllic algae could occur in vicinity of proposed put-in at Boiling River. Claimed Correlation to Boating: none provided. Evidence or Documentation of Potential Adverse Impact: none provided.

4. Statement: creation of spectator sport. Claimed Correlation to Boating: spectator sports are inconsistent with park purposes and add to traffic congestion. Evidence or Documentation of Potential Adverse Impact: none provided.

Lamar:

1. Statement: crosses important wildlife habitat. Claimed Correlation to Boating: displacement of wildlife. Evidence or Documentation of Potential Adverse Impact: none provided.

2. Statement: section is popular with fishermen, birdwatchers, wildlife viewers, and photographers. Claimed Correlation to Boating: conflicts would occur. Evidence or Documentation of Potential Adverse Impact: none provided.

3. Statement: creation of spectator sport along road, which is visible from road. Claimed Correlation to Boating: spectator sports are inconsistent with park purposes and add to traffic congestion. Evidence or Documentation of Potential Adverse Impact: none provided.

Lewis:

1. Statement: area provides important wildlife habitat. Claimed Correlation to Boating: displacement of wildlife. Evidence or Documentation of Potential Adverse Impact: none provided.

2. Statement: section is popular with fishermen, from Lewis Falls to the head of the Lewis River Canyon. Claimed Correlation to Boating: conflicts would occur. Evidence or Documentation of Potential Adverse Impact: none provided.

3. Statement: creation of spectator sport at Lewis Falls, which is visible from road. Claimed Correlation to Boating: spectator sports are inconsistent with park purposes and add to traffic congestion. Evidence or Documentation of Potential Adverse Impact: none provided.

4. Statement: Lewis River Falls is a popular scenic pull-out. Claimed Correlation to Boating: conflicts would occur and add to traffic congestion. Evidence or Documentation of Potential Adverse Impact: none provided.

Other:

1. Statement: issues were documented in 1988 analysis and review of that analysis compared to proposal indicates that potential adverse impacts would occur. AW Response: 1988 analysis was founded on innuendo and was not performed using a realistic assessment of use or impacts. The report simply examined unlimited and uncontrolled use of all Park rivers, including an emphasis on heavy commercial use. Our proposal is for public access to about 5% of the Park's rivers, does not allow commercial use, and is based on a realistic assessment of demand.

2. Statement: proposal encourages additional use at time when the park already has concerns about existing uses. AW Response: Our proposal is both constructed under and advocates for the paradigm that all Park uses should be evaluated under a low impact evaluation. Under such a system, river use would likely have the least impacts to the ecology and terrestrial environment. River use is most consistent with a low impact ethic. If the park implemented the evaluative paradigm we proposed, then that would provide a baseline for evaluating other more controversial uses such as snowmobile use.

3. Statement: Looking at ways to reduce or mitigate the impact of visitor uses, not add impacts to the Yellowstone ecosystem. AW Response: See AW's response to Statement 2 above.

Jason Robertson
635 Joseph Cir
Golden, CO 80403-2349