JUST BAN THE BOMB
Answer: “Exact date unknown, meeting continuing emissions and noise standards is impossible.”
The NPS released their ‘Proposed Rule to Implement Yellowstone and Grand Teton Winter Use Plan,’ last Friday.
I’ve read the proposed rule and it’s full of escape hatches for the Yellowstone Park Bombardier fleet. There are, however three problems with the ‘Bombs’ that can not be avoided. 1] “Beginning in the 2011-2012 season, all snowcoaches must meet air emission requirements, which will be the functional equivalent of having EPA Tier I emissions control equipment incorporated into the engine and drive train for the vehicle class (size and weight) as a wheeled vehicle.” This means that a Bombardier Snow Bus will have to be as clean as a Toyota mini-bus. FAT CHANCE, that’s why they are waiting until 2011! And, by then, they hope you hate snowmobiles to the point that you allow worse pollution from the Yellow tanks. 2] “In addition, all critical emission and sound-related exhaust components that were originally installed by the manufacturer must be in place and functioning properly. Malfunctioning components must be replaced with original equipment manufacturer (OEM) components where possible. If OEM parts are not available, aftermarket parts may be used if they are certified not to worsen emission and sound characteristics from OEM levels. In general, catalysts that have exceeded their typical useful life as stated by the manufacturer must be replaced unless the operator can demonstrate the catalyst is functioning properly.” Bombardier Snow Buses had no emissions control equipment when built. Conversion to contemporary automotive engines places a burden on the emission control system that wears out catalytic converters and mufflers at a rapid rate.The engines must run at twice design speed/mph. Costs to maintain Tier I compliance levels will be enormous and will be passed on to the consumer. Why does the park insist on this expense? 3] “Beginning in the 2011-2012 season, snowcoaches must meet a sound emissions requirement of no greater than 73dBA; test procedures to be determined by the NPS.” The design of the Bombardier Snow Bus track system is inherently noisy. The coachwork is a giant tympanic membrane, the hollow tires resonate with each bump in the road, the springs in the bogie cans are 1930’s tank technology and are uninsulated and rattle, the chains that hold the bogie cans clank unmercifully. Slop, slap, and rattle are built into the system in order to have any suspension at all. The combination of these factors mitigate against a quiet machine. Making these machines quiet would also cost extreme amounts of money. You can bet that it can’t be done in a cost effective manner. You can also bet that the NPS will devise a way to design test procedures that allow the obsolete machines to keep running – damn the spirit of the rule, it’s nostalgia that wins and the public & the park loses.
The big caveat for the Yellowstone fleet is couched in noble sounding phraseology that talks about the NPS Organic Act (16 U.S.C. 1). “The restrictions on air and sound emissions proposed in this rule are not a restriction on what manufacturers may produce but an end-use restriction on which commercially produced snowmobiles and snowcoaches may be used in the parks. . . .This exercise of the NPS Organic Act authority is not an effort by NPS to regulate manufacturers and is consistent with Sec. 310 of the Clean Air Act.” The cute part of this phraseology is including the phrase “commercially produced” – take it out and the spirit of the rule is the same. In fact why must there be any kind of distinction? If it meets standards then it should be allowed- right? Well, girlfriend, by adding the spurious phrase it opens the door for a “Significantly Modified” phrase to be inserted later in the rule-making-process. Then the ‘significantly modified’ snow coaches don’t have to meet standards because they are not ‘commercially produced.’ Just why does the NPS have to resort to this sort of chicanery? Because it’s in their green blood, and the green blood of their pet concessionaires.
Oh, what about those gas caps? The fuel containment system of Bombardier Snow Buses consists of one or two large sheet metal containers with neither crash proofing nor recirculating venting. Venting is through the gas cap – not Tier I complaint.
Vapor recirculation must include the fuel tanks to be complaint – this too, is a cost to be passed on to the consumer. The NPS and the snowmobile hater don’t really care about the park and emissions standards. Rather they care about a nostalgic ride in a loud and stinky tank. They would rather have a nostalgic ride in the park subsidized by the American Taxpayer, than have the park protected – shame on them.
Somehow they believe that skiers are a higher class of people than people who ride snowmobiles. Somehow the snobs in the planning office have forgotten the Constitution of the United States of America. Somehow the cheerleaders have convinced the NPS that skiers are saints and have never broken the law, and never molested wildlife, and never damaged the environment. And of course they know park rules better than the dummies on the sleds.
They never go to off-trail thermal areas, they never ‘soap a geyser’ to get it to erupt, and they never go skinny dipping in hot springs, and of course they would never traipse across bacterial mats – now would they? This must be true, otherwise why is the following section in the proposed rule?
“This guiding requirement will reduce conflicts with wildlife along roadways because guides are trained to lead visitors safely around the park with minimal disturbance to wildlife. Commercially guided parties also tend to be larger in size, which reduces the overall number of encounters with wildlife and reduces the amount of time over-snow vehicles are audible. Commercial guides are educated in safety and are knowledgeable about park rules. . . . Commercial guides use a “follow-the-leader” approach, stopping often to talk with the group. They lead snowmobiles single-file through the park, using hand signals to pass information down the line from one snowmobile to the next, which has proven to be effective. Signals are used to warn group members about wildlife and other road hazards, indicate turns, and when to turn on or off the snowmobile. Further, all commercial guides are trained in basic first aid and CPR. In addition to first aid kits, they often carry satellite or cellular telephones, radios, and other equipment for emergency use. In this way, guides will ensure that park regulations are enforced and will provide a safer experience for visitors. (Oh, by the way, stopping and starting increases pollution, so does variable speed travel, turning the machine on and off does too! What a silly rationalization these planners have used to demand that you pay guides.)
Just apply this rule to skiers and the spirit of the rule is certainly maintained – regarding winter use. And the truth of the matter is the same. Parties of skiers in two’s and three’s on trails move bison around and scare elk constantly.
They shout and holler and drink wine from their bota bags. Do they need a guide? Perhaps a single file line of 9 skiers with a guide is necessary too. They can use single finger signals, just like they do now.
Who could dare protest this egalitarian application of winter use rules? Why is there no study about this? Is pollution the scary part, or is it wildlife molestation, or is it destruction of park resources? Maybe it’s just another bit of elitism designed to reduce motorized winter visitation and increase profit for the concessionaires.
Someday I hope to be rich enough that I can afford to go to Yellowstone in the winter and go skinny dipping all alone without a ranger or tour guide to spy on me. Then I too can enjoy wonderland as the Organic Act meant for me to, just like the skiing saints.
And, of course how ’bout the lack of enforcement for summer visitors that get to do everything that’s illegal. There’s seems to be a pile of preconceived elitism and prejudice running rampant in the planning department at Yellowstone National Park.
Why is this? Job security? Who holds the planners accountable? Who holds the law enforcement accountable? Why are skiers and bicyclists such models of perfect park behavior? Or are they? Where is the outcry for molesting animals in the summer? Certainly not among the diesel bus tours, nor among the $500,000 mobile condominium set. Nor is it to be found among the clean and green bicycling public – saints, everyone of ’em.