Caldera Action’s Board of Directors sent the following message to the Valles Caldera Management on February 3, 2023. Please send your own comments to David_Krueger@nps.gov
NPS Managers:
We received the details from the Valles Caldera National Preserve regarding changes to the backcountry permit system and the expansion of the vehicle access for non-backcountry permit holders to the Cabin District. Some of these decisions, such as transferring the reservation system to recreation.gov and the hours open and number of vehicles are within the discretion of the Superintendent. Other aspects of this proposal fall under NPS policies and various federal laws.
This letter addresses legal compliance issues regarding the Cabin District and access issues related to the permits, hours, and road closures. This letter will be distributed on social media and to some media outlets.
Moving Visitor Center to the Cabin District
We have a few questions regarding the expansion of non-permit visitor access to the Cabin District. In general, we are puzzled that this work is happening before the VCNP’s General Management Plan is in place. It seems it would be much simpler to have the GMP released and have these front country changes as part of that plan. VCNP management have said the GMP could be released in 2025 or later.
Moving parking from the Entrance Station at La Jara to the Cabin District will have environmental impacts with more cars, buses, and RVs seeking parking. There is limited parking for these at the Cabin District currently. The Final Environmental Assessment for these changes has not yet been released to the public. Nor have the public comments. Normally these documents are released well in advance of ground disturbing work with the agency responding to public comments. It appears that the NEPA process may not have time to run its normal course before this spring. Our questions are these:
• Where will all these vehicles park at the Cabin District?
• Does the VCNP staff have landscape architects and engineers ready to quickly create parking in a truncated schedule to be ready by spring 2023?
• Is this schedule realistic?
• Have impacts to prairie dogs and other wildlife from increased vehicle traffic crossing the Valle Grande been analyzed?
• Has the NPS considered establishing a contact station/visitor center directly on Highway 4 to limit vehicle traffic into the Preserve and contact and serve more of the public?
The NPS NEPA Handbook Considerations:
“Determining when to begin a NEPA process can be difficult. You must start early enough to ensure that all steps of the NEPA process are finished so that it can serve practically as an important contribution to the decision-making process” and to ensure that the process is not “used to rationalize or justify decisions already made” (1502.5). However, a NEPA review should begin only after a proposed action is developed.” Pg 15.
“As set forth in DO-75A, parks and programs should engage in continuous, ongoing civic engagement outside of the NEPA process in order to reinforce the commitment of both NPS and the public to the preservation of heritage resources, both cultural and natural, and strengthen public understanding of the full meaning and contemporary relevance of these resources (DO-75A, V).” Pg 15
In the NEPA public review process, VCNP staff said that parking areas could be temporary and subject to removal if they don’t comply with the eventual General Management Plan. In this delicate high-altitude environment, making such changes in the future without negative impacts may be challenging.
• Have SHPO consultations been completed? Endangered species surveys complete?
• Are these available to the public?
Recreation.gov Permits and Public Access:
A large part of the mission of Caldera Action is enhancing public access to the VCNP. We recognize that these lands belong to the American public, including the Tribes, and that the public has a right to access their lands within the protective guidelines of the NPS Director’s Management Policies and the best judgement of the VCNP staff.
We are aware that the public can have many excellent experiences in the front country of the Valles Caldera. However, the public should not be blocked from seeing the backcountry of the VCNP unless there are compelling reasons to do so and based on a publicly available decision process.
Under the current system, the public may arrive at the VCNP between May 15 to November 15 and get a permit to drive beyond the Entrance Station if there are permits available. Under the new system, most permits will be reserved on recreation.gov and few will be available for spontaneous visitors, those without access to a computer, or those who don’t know about the permit system.
It appears that visitors who get reservations online will be able to enter the backcountry without contacting a ranger as we must now. We feel these ranger contacts are important to answer questions, establish authority, and offer education on the values of the National Park System.
While we strongly support regulating the amount of vehicle traffic on the VCNP, we question how the proposed number of permits, 35, was determined? It would be beneficial to know the rational for this limit given that it affects the public and their access. We think a higher number may be appropriate given that the VCNP has relatively few visitors compared to other NPS units in the area and these visitors disperse over a large area. Visitors in cars do not appear to be having a significant impact on the backcountry currently. If they are, the NPS should detail what those impacts are and how they could be mitigated. We assume these issues will be addressed in the General Management Plan.
Hours of Operation
The hours of operation of the VCNP, 9:00am to 5:00pm daily, significantly restrict public access to the Preserve. The public should be able to access the Preserve in all daylight hours to carry out legal activities of their choice. Fishermen and women prefer to fish in the early morning and the evening for example. Photographers prefer the shoulder hours of the day. People wanting to take a long walk or bicycle ride are restricted by the late opening hour and the early closure. We feel strongly that the VCNP gate should be open dawn to dusk with opportunities for night sky viewing and eventual camping. Other NPS National Preserves are open 24/7. While we don’t support this system for the VCNP, it does provide a contrast to narrow hours at the VCNP.
The backcountry is closed to vehicle access for much of the year under the current rules. For five months of the year, regardless of road conditions, the backcountry is only open to staff, contractors, and people entering without a motor vehicle. We note that the closest NPS Preserve, the Great Sand Dunes National Park and Preserve, has its Preserve portion open unless weather makes the road impassable.
We would like to understand the rational for having the backcountry open to motor vehicles for only half the year, regardless of road conditions. The public will support management decisions if managers are transparent with their rational.
Thank you for considering our comments.
