June, 2000

Extended Comments On 
Draft Yosemite Valley Plan, 2000

By David Curry, 18 Chancellor Place, Berkeley, CA 94705 (davcurry@flash.net)

First I want to thank NPS planners and management for an excellent, creative draft Yosemite Valley Plan, covering many bases and varied interests with both objective reason and obvious caring for the land and its visitors. We are all faced with David Siegenthaler’s question: How does one love Yosemite in the company of its many other lovers?

My own love for the Valley began by experiencing it as a kind of second home, spending several young summers with my grandmother—Jennie or "Mother" Curry—at her cottage, supported by Grizzly Club activities, the summer children’s rodeo, and hiking and fishing everywhere feet could take me. Later I added rock climbing in a modest way, lived in the Valley for a year, and worked part way up the employment ladder (meeting John Townsley as co-porter at Camp Curry was a high point) to finally manage Tuolumne Meadows High Sierra Camp in the summer of 1951.

Since then I’ve worked mostly in the fields of transportation planning, research, and especially economics, chiefly at Stanford Research Institute and with the consulting firm of Crain & Associates in Redwood City. Two of my projects were co-authoring the 1977 "AASHTO Red Book" (see footnote 1), and in 1979 leading the development of CalTrans’ system for developing state highway project priorities in California’s annual State Transportation Plan.. It is mainly from that professional perspective, and secondarily as a former Valley resident and worker, that I want to add something hopefully new to the strong case for a parking facility at Taft Toe. Then I’ll shift ground and comment briefly as a former Valley resident and subsequent family-raiser on the crucial importance of preserving a viable Valley community, even at the price of somewhat more employee housing than is now proposed in any of the alternatives.

The problem of multiple, incommensurate outcomes—environmental, visitor convenience, costs, etc.--is much the same in the Yosemite Valley Plan as in California’s annual State Transportation Plan, which must rank the relative desirability of project alternatives based, in most cases, on multiple outcomes. A sequential approach is highly recommended, starting with consideration of lower-cost alternatives and requiring higher-cost alternatives to prove their worth based on the added value of the added features that they bring to the plan. The next ideal step, to convert all values to equivalent dollars, is usually impossible or dicey. The fall-back ideal is first to calculate the added equivalent cost of any significant intangible differences between the least-cost alternative and the next most expensive alternative, and second to quantify the most important effects of the chosen vs. the rejected alternative in as meaningful a way as possible.

The draft Yosemite Valley Plan provides the necessary information for accomplishing both of these objectives, but does not at this time summarize that information in a useful way—and hence is not providing reviewers of the plan with the best guidance for helping them to make decisions among the alternatives. This point was illustrated by the two propositions in my public hearing comments (from the Sonora meeting, 6/2/00), first about the $184 million excess cost of Alternative 2 versus Alternative 3 (see footnote 2). The second proposition was about regarding parking as the highest and best use of the Taft Toe area.

One current limitation on summarizing cost or other comparative information about plan alternatives is that the National Park Service, unlike the Bureau of Reclamation for example, is apparently denied the use of benefit/cost analysis to consider environmental and other tradeoffs in project evaluation. Instead, the NPS describes the effects of each alternative. A "preferred" alternative must be identified, but not necessarily chosen later, because public responses and other later information may change the preference. Also, evaluating public response is not just a matter of counting votes—the significance of each comment is considered on its own merits, in terms of both desirability and feasibility.

The process just described leads to provision of exhaustive details in NPS plans about the consequences of each alternative, with extensive use of adjectives such as major, minor, favorable, and adverse to refer to the direction and intensity of the impacts. Yet the policy of avoiding summary comparisons can lead to uneven treatment of similar impacts. For example, the following comment appears on page 4-65 of the Plan, under the Taft Toe alternative, for the environmental consequence called "Park Operations:" "The costs for additional park personnel would represent a long-term major adverse impact." Yet these added costs are only $4.7 million/year for the Taft Toe alternative, less than half of the extra $9.7 million in added shuttle plus NPS operating costs for the preferred out-of-Valley parking alternative compared with the Taft Toe parking alternative—and that extra $9.7 million, more than double, is nowhere called out as a major long-term adverse impact. Seems inconsistent, and as already noted, such differences between the two plans add up to a very large number over 30 years, nearly $184 million.

The truth is that in the process of making a final choice between plan alternatives, all of the consequences and tradeoffs will be valued, implicitly if not explicitly. For example, if Alternative 2 is ultimately chosen, it means that the chooser or choosers have decided as follows:

Yes, environmental values such as avoiding overuse of El Capitan Meadow, having another quiet discovery zone for visitors, and avoiding disruption of local habitats and migration paths is worth an added $184 million in taxes and travel costs plus the added loss or "price" of 1) greater time and inconvenience to day visitors (especially the 30 to 50% who return to their cars and drive to the Valley anyway to take a different route out of the Park), 2) more bus noise and pollution in the East end of the Valley, and 3) 12.2 million extra gallons of fuel used (over 30 years) to service three out-of-Valley parking lots.

It is also true that there is no "objective" or value-free way in the world to make such a decision. The closest we can come, I believe, is to make it in the broadest possible concept and feeling of enlightened public interest, for present and future generations.

One possible advantage of deferring this tradeoff clarification until the final decision is that it seems to keep options more open during the public comment process. Too-early and explicit tradeoff analyses or statements might lead to biases and alliances forming around defense of one alternative, either inside or outside the NPS, rather than attempting to stay open to new information or viewpoints. It’s a judgment call, but I believe that this possible advantage is outweighed by three disadvantages:

  • The present lack of comparative information between plan alternatives forces every serious reader of the report to conduct an exhaustive and exhausting, error-prone search process through hundreds of paragraphs of information on the separate alternatives, looking for the differences between them. Better that this be done once and well, as a service to readers.
  • The average reader will not know how to summarize relevant economic and environmental data into a value-free format that simply clarifies the tradeoffs that are now only implied by the different alternatives.
  • The present practice of designating a preferred alternative without support of such a comparative analysis deprives the public of the best thinking—to date—and at least the tentative conclusions of the people most familiar with the problem. So long as the preference is tentative, as it is even now, the NPS will be free to change its preference based on new evidence or options, and the debate will be able to focus on real issues, such as the differences between plans and how to ameliorate any residual problems with the tentatively preferred plan.

These considerations lead me to the following

Recommendation: that the National Park Service conduct a post-evaluation of the Yosemite Valley planning process, with a view to devising and seeking constructive changes in its own planning study guidelines that will allow provision of more useful information for readers in the summary section of the finished document.


Shifting now to employee housing, I’d like to begin with a third proposition, following the two propositions included in my June 2 hearing statement.

Third Proposition: Just as it takes at least a village to raise a child well, without a viable Valley community, neither the National Park Service nor concessionaires can expect to continue to attract the caliber of management and service staff that has typified the Valley and Park in the past.

Living in Yosemite Valley has long been one of the fringe benefits that attract good people to work there, both for summer and year-round employment, in spite of the constraints and often-rustic facilities. However, the amenities of daily life have steadily eroded over the years as government policy supports an increasingly Spartan community infrastructure, and encourages privatization of federal housing. Also, new flood plain, rockslide, and environmental restoration constraints on housing developments have severely shrunk prospectively available space for employee housing.

In response, the National Park Service and concessionaires are laudably trying to upgrade housing and increase its density.

These measures to improve and increase the density of housing may be too little, too late, because all action alternatives in the Yosemite Valley Plan reduce employee beds in the Valley from 1,277 at present to 683, with a shift of about 700 to 900 beds to El Portal and, under Alternatives 2 and 5, about 200 to Wawona. On page 2-33, the option of removing the school from Yosemite Valley is rejected due to its need by Valley residents. Yet on page 4-60, it is stated that "Relocation of the concession headquarters would likely have long-term major, adverse impacts on the elementary school system by threatening the viability of the Yosemite Valley school." In fact, Valley residents from my personal contacts are already concerned with decline in the diversity of the school population from past movements of jobs and employee housing out of the Valley.

One recent loss, I hear, has been of the pastor’s Valley residence, and the medical clinic will be removed under all plan alternatives, a highly negative community impact. The gas station is long gone, reputedly because it was in the flood plain, forcing residents and visitors alike to travel to the Crane Flat or El Portal stations. But, you folks mostly must know all this and more, having lived or worked or visited there enough yourselves to witness these trends. I only want to add to employee housing considerations the issue of community viability and its importance to the recruitment of good people.

At present, the word community is hardly mentioned and never explicitly considered in the Executive Summary to the Yosemite Plan beyond a brief reference on page 4-23 to a contract between NPS and the University of Utah to "gather information on the social environment of Yosemite Valley, El Portal, and Foresta.." However, the results of 147 interviews by the consultants were evidently used for environmental impact analysis rather than interactive feedback with a view to modifying the Plan—not enough details are provided to say for sure. The discussion and analysis is all at the level of "employee housing" and the chances for survival of medical or educational facilities, plus some consideration of the effects on El Portal of further employee housing shifts from the Valley.

These examples should suffice to support the following

Recommendation: Give explicit and serious consideration to continuing viability of the Yosemite Valley community, and reversal of the proposed decline in employee housing there as a major means to that end.

Clearly, creative "outside the box" thought may be needed to implement this recommendation. Procedurally, the problem could be put out for competitive bids to architectural firms with interest and competence in the field. And here are a few closing, possibly off-the-wall, ideas: 1) How about: using the space that would have been used for 550 visitor parking spaces in Yosemite Village (Camp 6?) in Alternative 2 for employee housing, if Alternative 3 is chosen? 2) Would the principal concessionaire agree to keep its headquarters in the Valley to help survival of the school and community, assuming housing can be retained for headquarters staff? 3) Should a competition be invited for design of compact, attractive, safe, survivable flood plain housing (probably more at the edges than on the river bank, of course, and possibly emphasizing multi-family housing, like many intentional communities or co-housing developments, with some common spaces indoors and out). 4) How about a compact, attractive service station at the edge of the flood plain or at Taft Toe with an extra $1 per gallon fee, indexed to inflation, to help pay for the shuttle service and incidentally reduce the demand for gas in the Valley? 5) Bite the bullet and go for a large-scale employee residential hotel, as attractive but not as expensive as the Ahwahnee, that needn’t be hidden in the trees, preferably outside the flood plain and with underground parking. Finally, 6) sponsor in-house or broader-based brainstorming or "thoughtstorming" (similar to brainstorming but more focused on consensus) sessions to come up with the best housing and community ideas?

Thank you for your kind attention.

1. American Association of State Highway and Transportation Officials, A Manual on User Benefit Analysis of Highway and Bus-Transit Improvements, 1977.


2. That total cost was figured, by the way, with annual costs discounted over a 30 year period to present value at 4% interest, the accepted long-range cost of capital disregarding inflation and risk. A study period or project life of 30 years is widely used in highway economic studies.  By that time, many projects need extensive review or changes, though the relative stability of Yosemite could argue for a longer study period. Increasing the study period to 50 years would increase the extra cost by 22%, to $224.5 million. The main point should not be lost, however: saving Taft Toe for its alternative use as a scenic site will cost a bundle of money that is at present not highlighted in the Plan.