Comment from Charlie Loeb

I oppose this rule change as written because it does not reflect the capacity determination that NPS made when approving the Vehicle Management Plan in 2012. My comments parallel those that are being submitted by the Denali Citizens Council, whose letter I support. I participated extensively in the planning process for the 2012 Vehicle Management Plan as a member of the public and a board member of the Denali Citizens Council. During that planning process, NPS was very clear that it was moving away from fixed numerical limits as a way to specify park carrying capacity, and adopting instead a program of adaptive management which involved determining a set of desired conditions for park resources and visitor experience and managing toward those conditions. The adaptive management standards - as summarized in Table 5 of the final Vehicle Management Plan - are the actual capacity limit as described by NPS in every document associated with the VMP. It is astounding that in the intervening years that NPS seems to have forgotten this entirely. The 160-vehicle-per-day limit was not even included in the draft VMP, and was only added after extensive public comment expressed fears that NPS would not be able to successfully implement and maintain the research program necessary for a functional adaptive management system. The 160 daily vehicle limit was conceived as a backstop in case of implementation failure, not as capacity limit itself. While traffic modeling suggested that 160 vehicles would be the most traffic that could theoretically be consistent with the plan's standards, to my knowledge NPS has never verified that estimate with real world measurements. To put that number in regulation by itself would be a terrible mistake. In short, the regulatory replacement for the 10,512 seasonal limit are the indicators and standards in Table 5 of the Vehicle Management Plan. A backstop number is also needed, but I don't believe there is any real-world evidence to support the number of 160 vehicles per day. Also, please note that the 160 was based on modeling a particular distribution of those vehicles by user type and time of day. This proposed regulation does not capture those nuances and is a major reason there needs to be more research to determine the proper number to use as a backstop. (For example, the modeling included 12 vehicles operating only in nighttime hours. If all 160 vehicles operated during the day, then traffic would likely violate capacity standards.) Please rewrite the regulation to include the actual capacity limit from the Vehicle Management Plan. I support an additional backstop daily number based on evidence from experience as opposed to modeling. I suspect that number will be lower than 160.