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Counties assail draft of winter EIS for park region Federal document under fire over faulty statistics, lack of science and weak evidence By MICHAEL MILSTEIN Gazette Wyoming Bureau CODY, Wyo. - A preliminary draft version of the federal Environmental Impact Statement on winter use in the Yellowstone region generalizes about differing counties, compares statistics that are not comparable, lacks scientific basis and draws conclusions from weak evidence, according to an alliance of counties in the region. In six pages of comments, county consultant Paul Kruse also said that a week was insufficient time for county officials and him to digest the approximately 600-page document. Kruse submitted the comments on behalf of Park and Teton counties in Wyoming, Park and Gallatin counties in Montana and Fremont County, Idaho. The National Park Service has agreed to involve the five counties as cooperating agencies in the development of the EIS that will guide future winter use of Yellowstone and Grand Teton national parks. Federal officials sent each of the counties a preliminary version of the draft EIS, the final version of which will be released to the public later this summer. Kruse said in his comments that the document relies on unpublished studies and documents that remain unavailable to the public, which "could breed suspicion and undermine public confidence in the process." He said, for example, that the document cited snowmobile accident statistics out of context and did not provide enough consistent figures from year to year to draw any conclusions about trends in snowmobile traffic or accident rates. To honestly portray the consequences of winter recreation in the parks, officials must gather studies for "the full range of activities in the park," including park employee safety, which federal OSHA inspectors have found lacking. "Once the raw information is compiled, it should be broken down to determine whether the causes, including excessive speed, alcohol abuse, were preventable or unpreventable (i.e., acts of nature or mechanical failure)," Kruse wrote. "If people who were violating current rules and regulations cause the accidents, we would urge that resources be reallocated for enforcement. If current standards are inadequate, then the case should be made to change them. "In other instances, there is no site-specific data and therefore sound programmatic decisions cannot be made with any certainty of reliability," he wrote. "This paucity of foundational information for the various alternatives puts the credibility of the entire document into question." The document also inappropriately "lumps together" 17 counties in three states surrounding the national parks even after denying some of those counties the right to participate as cooperating agencies in development of the EIS. "If cooperating agency status had been granted, the counties could have provided precise information on a wide range of socio-economic effects that each of the alternatives would have in their particular areas," Kruse wrote. "This would have strengthened the DEIS by bolstering its foundation with site-specific data." And by combining social and economic data from all the different counties together, the document effectively dilutes the input from each individual county, he said. "Combining our socio-economic studies with data from 12 dissimilar counties taints the conclusions on key components of the DEIS," Kruse wrote. "This, in turn, undermines the credibility of the entire document." He argued that the document overlooks the contribution nearby counties and communities make to the operation of the national parks by, for example, serving as bases for employee housing and providing basic medical services the parks cannot provide alone. And he said that the information the document provides about wildlife suggests that "animal mortality is undesirable. "No discussion is given to the role of nature, including weather, or to the 'survival of the fittest' principle," Kruse wrote. "We would urge a discussion of how winter mortality ensures inter-generational vigor by eliminating the older, less-strong animals. In addition, a complete examination of the role of disease in the animal populations and how this correlates to various recreational activities is critical."
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