Vehicle Use: Denali National Park and Preserve

The Main Street Foundation's Center for Regulatory Analysis and Engagement (CRAE) supports the proposed rule to modernize vehicle use regulations in Denali National Park by replacing a seasonal permit ceiling with a daily vehicle limit. They argue this change aligns with actual management practices and provide recommendations for increased transparency, regular reassessment of the 160-vehicle limit, and a focus on maximizing responsible public access.

The Denali Citizens Council supports the goal of codifying a vehicle limit for the Denali Park Road but argues that the proposed 160-vehicle daily cap is incomplete and insufficient. They request that the rule incorporate the full adaptive management framework, adopt a more conservative 145-vehicle limit, and include commitments to transparent annual monitoring and scientific studies.

The commenter expresses general support for the amendment to limit vehicle numbers on Denali Park Road but expresses skepticism regarding the NPS's ability to monitor impacts with reduced staffing. They urge the NPS to consider that fewer than 160 vehicles per day may be necessary to protect wildlife and maintain a high-quality visitor experience.

The Citizens' Advisory Commission on Alaska Federal Areas (CACAFA) opposes the proposed rule to codify a permanent daily limit of 160 vehicles on the restricted portion of the Denali Park Road. They argue that the rule lacks updated scientific data, fails to protect statutory inholder access rights under ANILCA, and removes the flexibility of adaptive management.

Doyon, Limited, a Native regional corporation and large landowner in Alaska, supports the proposed rule to align vehicle limits on the Denali Park Road with the 2012 Vehicle Management Plan. They also request formal consultation under Executive Order 13175, arguing that the rule has substantial direct effects on their interests as a "most directly affected" Native Corporation.

Paul R. Anderson, a retired Superintendent of Denali National Park, supports codifying the 160-vehicle per 24-hour limit but emphasizes that it must be tied to the specific requirements and monitoring programs of the 2012 Vehicle Management Plan. He argues that the limit must be presented in the context of meeting desired future conditions to avoid irreparable harm to park resources.

The commenter, a former conservation worker and frequent park visitor, opposes the proposed 160 daily vehicle limit because it overrides the scientifically based adaptive management framework of the 2012 Vehicle Management Plan. They argue that the regulation should prioritize the VMP's indicators and standards to ensure an uncrowded wilderness experience for visitors.

The commenter supports the 160-vehicle daily limit on the Denali Park Road, arguing that it is a necessary cap based on scientific studies and traffic modeling. They suggest that the regulation should clarify that this limit is contingent upon meeting specific wildlife and visitor experience standards.

The commenter opposes the proposed rule because it fails to incorporate the adaptive management standards and capacity determinations established in the 2012 Vehicle Management Plan. They argue that the 160-vehicle-per-day limit was intended as a backstop rather than a primary capacity limit and request that the regulation be rewritten to reflect the actual standards from the original plan.

The State of Alaska opposes the proposed rule because it lacks updated scientific justification for the 160-vehicle daily limit, risks violating statutory access rights for inholders and subsistence users under ANILCA, and creates a rigid cap that could stifle economic growth. The State requests that the rule be replaced with an adaptive management framework that exempts inholder and subsistence access from vehicle caps and allows for future flexibility.