Comment from Camp Denali

Thank you for the opportunity to comment on RIN 1024-AF11, regarding vehicle use in Denali National Park. We are generally supportive of this amendment to special regulations to clarify and limit the number of vehicles per day that may be permitted along the Denali Park Road. We understand this as largely a procedural change or update to the existing Vehicle Management Plan of 2012. However, we have concerns about the amendment’s claim that the limit of 160 vehicles per day will “allow the NPS to meet growing visitor demand while maintaining a high-quality visitor experience.” We are also concerned that necessary data collection and monitoring during the resumption of road traffic along the entire Park Road will be impossible for the NPS to achieve when the Service is already behind in reporting out to the public the findings of the Plan and faces reduced staff capacity. The VMP’s adaptive management strategy was designed to continually monitor road use capacity relative to indicators and standards of visitor experience and wildlife impact. By design, vehicle use is meant to conform to limits that maintain acceptable levels of wildlife and visitor impact. Are sheep and caribou and bears tolerating a certain level of traffic? Do visitors feel the road or wildlife sightings are crowded? Maybe the level of vehicle use reaches 160 per day, but maybe it does not. In fact, some early modeling to test the Plan indicated that even 147 vehicles per day were “unlikely” to meet standards (VMP, Appendix C, p. 4). The rulemaking, however, implies that the new vehicle cap "allows the NPS to meet growing visitor demand while maintaining a high-quality experience,” suggesting that 160 vehicles will be entirely feasible and is a level that the NPS (and the bears, caribou, beavers, cliff-nesting falcons and park visitors) will need to accept in order to accommodate increased visitor demand. Denali National Park was established in 1917 to protect populations of wild mountain sheep and other animals, making this wilderness park a sanctuary for sub-arctic wildlife. Vehicle limits are necessary in order to maintain these populations, especially given the myriad stressors wildlife are experiencing in a rapidly changing landscape and climate. One of the objectives of Planning Goal 1 of the VMP was that the NPS "share monitoring findings with the public and inform them of management actions regarding the transportation system (VMP, page 8).” To manage for desired conditions, the Record of Decision assured that "comprehensive monitoring and data collection will take place...to detect any impacts attributable to changes made to the transportation system." At this moment, there are no publicly accessible reports since the 2022 season and Park staff at Denali are operating at 75% of their prior capacity. We are skeptical that the NPS will have the staff capacity to stand up the necessary and appropriate level of data collection, monitoring, data analysis, and reporting that the Park’s Vehicle Management Plan requires and that the public expects. Given the last 5 years of a foreshortened road due to the closure of the road at mile 45, the NPS could be slow to allow the resumption of traffic. Our observations of bears, caribou, moose, beavers, waterfowl and other nesting birds are that they have an increased comfort level with, and proximity to, the Park Road because it is currently so lightly used. The wildlife deserve a period of adjustment and the NPS could take this opportunity to evaluate whether the prior road-closure levels of traffic, especially along the western half of the road, are even still merited. Instead of assuming that more is always the better, acceptable, and expected trajectory, we urge the NPS to be prepared for indications that fewer vehicles than 160 per day is what will maintain a high quality visitor experience and optimal conditions for wildlife into the future.