Comment from Joan Frankevich

Thank you for the opportunity to comment on the proposed rule regarding vehicle limits on the Denali Park Road. I am familiar with the 2012 Vehicle Management Plan (VMP) from my previous role working for a conservation organization, however these comments are my own only. I am concerned the 160 daily vehicle limit will override the main framework of the VMP which used scientifically based indicators and standards to determine vehicle limits. I know Denali National Park quite well. For over 40 years I have worked in or been a frequent visitor to the park - hiking, camping, backpacking, dog sledding and riding buses. To me, Denali’s gift to the world is accessible wilderness. The rustic park road allows visitors of all abilities to experience true wilderness, simply by looking out the window of a bus. Key to this wilderness experience is feeling uncrowded. For example, if you miss the opportunity to view a grizzly bear because several buses are in front of yours impeding your view, you leave disappointed. Just like we don’t expect a sold out concert to pack two people per seat, appropriate vehicle limits in Denali protect the experience visitors have come for. It’s critical to remember the VMP replaced the 10,512 seasonal limit with an adaptive management framework using indicators and standards to determine vehicle limits, not a hard number. Standards (for example how many vehicles can be at a wildlife stop without feeling crowded) are scientifically derived. The 160 number is not. It was simply added as a backstop in case the adaptive management system failed. Denali park staff are to be congratulated for implementing and monitoring the standards for compliance. My understanding is most standards are met most the time, with the notable exception of the sheep gap standard which has been challenging to consistently meet. These are the criteria that have been, and need to continue to be, what sets the appropriate number of vehicles. One of the advantages of this system is it requires buses to depart strategically throughout the day, instead of bunched together as has happened in previous years. If the standards can be met with 160 vehicles per day, then great, but if not, it’s the standards that must take precedence. Please rewrite this regulation to clarify the VMP’s adaptive management method using indicators and standards is the primary driver of vehicle numbers so that Denali visitors can continue to enjoy a positive and uncrowded experience on the Denali park road. Thank you for considering my comments.