Comment from Steve Carwile

The limit of 160 vehicles per day on the Denali Park Road is a number that was added to the Final Vehicle Management Plan after the plan was drafted and after lengthy scientific studies informed the core of the draft VMP. The Adaptive Management Plan in the VMP is based on 1) indicators of quality to both the wildlife ecosystem and the visitor experience, and 2) standards to be monitored to ensure that quality. The Adaptive Management Plan is the meal recipe at a 5-star restaurant and the 160 is the calorie counter for that meal so you don’t overeat and have a heart attack. The traffic modeling that was done, in response to incorporating the 160 limit into the preferred alternative in the VMPEIS, could not find a way to stay within standards when running more than 87 concessioner buses, plus 10 Kantishna Lodge buses. The preferred alternative is based on 87 concessioner buses (VMPEIS, p.198). To assume that 60% more vehicle traffic can co-exist with the adopted standards denies the modeling results and will lead to unrealizable expectations in the tour industry. The only way to add more buses to travel the park road is to either 1) abandon the standards and kill the golden goose by providing a visitor experience that does not promote wildlife viewability, or 2) provide enough funding to monitor the standards, start the promised BACI studies, integrate next gen GPS technology for real time spacing of vehicles, do follow-up modeling on the vehicle movement parameters; all of which would use science to confirm the health of the wildlife community and then allow changes to the vehicle numbers. In sum, the 160 limit is in the Plan, but the description in the regulation should address that the daily vehicle limit is controlled by the plan standards, supported by scientific studies, and that 160 only comes into play when the standards are met and can still reach the allowance of 160 vehicles.