STATEMENT OF KAREN TAYLOR-GOODRICH, ASSOCIATE DIRECTOR OF VISITOR AND RESOURCE PROTECTION, NATIONAL PARK SERVICE, DEPARTMENT OF THE INTERIOR, BEFORE THE SENATE SUBCOMMITTEE ON NATIONAL PARKS OF THE ENERGY AND NATURAL RESOURCES COMMITTEE ON S. 1774 AND H.R. 3022, BILLS TO DESIGNATE THE JOHN KREBS WILDERNESS IN THE STATE OF CALIFORNIA, TO ADD CERTAIN LAND TO THE SEQUOIA-KINGS CANYON NATIONAL PARK WILDERNESS, AND FOR OTHER PURPOSES.

June 17, 2008

Mr. Chairman, thank you for the opportunity to appear before you to present the views of the Department of the Interior on S. 1774 and H.R. 3022, bills to designate the John Krebs Wilderness in the State of California, to add certain land to the Sequoia-Kings Canyon National Park Wilderness, and for other purposes.

The Department supports H.R. 3022 and S. 1774 if amended in accordance with this statement.  Both S. 1774 and H.R. 3022 would designate additional wilderness areas in Sequoia National Park and Kings Canyon National Park, and would name one of the new wilderness areas after John Krebs, a former Member of Congress.  While we believe these designations are appropriate, we would like to work with the committee on amendments that would address concerns raised by some of the specific provisions in the bills. H.R. 3022, as passed by the House of Representatives, addresses many, but not all of our concerns.

Sequoia National Park, established in 1890, and Kings Canyon National Park, established in 1940, have been administered jointly since 1943.  The California Wilderness Act of 1984 designated about 723,000 acres in the two parks, or 84 percent of the land base, as the Sequoia-Kings Canyon Wilderness.  Both bills would designate as wilderness virtually all the remaining land in the two parks that is appropriate for that designation, adding about 114,488 acres.  With this legislation, about 97 percent of the land base of the two parks would be designated as wilderness.    

The area that the bills propose as the John Krebs Wilderness consists of the Hockett Plateau and Mineral King areas of Sequoia National Park, and totals about 69,500 acres.  The other area, which would add about 45,145 acres to the existing Sequoia-Kings Canyon Wilderness, consists of lands in and around the North Fork of the Kaweah River in Sequoia National Park and the Redwood Canyon/Chimney Rock area of Kings Canyon National Park.  The lands other than Mineral King and Chimney Rock underwent formal wilderness studies in the early 1970’s and are recommended by the National Park Service for wilderness designation.  The Mineral King and Chimney Rock areas underwent wilderness eligibility assessments in 2003 and both were found to have characteristics which support their designation as wilderness.

The Hockett Plateau protects vast rolling forests of lodgepole pine surrounding spectacular sub-alpine meadows, and is a favorite destination for equestrians, backpackers, and anglers.  This area, which has been part of Sequoia National Park since the park was established in 1890, includes the route of the old Hockett trail that was one of the first trans-mountain routes in the southern Sierra Nevada and is popular with hikers, fishermen, equestrians and backpackers. The Mineral King portion includes much of Mineral King Valley, a striking and spectacular example of sub-alpine and alpine environments unlike any other in the Sierra Nevada.

The North Fork Kaweah area includes extensive lower- and mid-elevation vegetation communities that are rarely represented in Sierra Nevada wilderness areas.  The area contains foothill oak woodland, chaparral, and low-elevation hardwood and conifer forest types. The river is an exemplary foothill river with beautiful pools, riparian borders, and is rich in wildlife including western pond turtle, bear, and mountain lion. The Redwood Canyon area includes all or part of eight Giant Sequoia groves including the Redwood Mountain Grove, the largest Giant Sequoia grove inside Sequoia and Kings Canyon National Parks.

We believe it is appropriate to name the Hockett Plateau and Mineral King area as the John Krebs Wilderness.  The National Park Service considers it a high honor to be permanently commemorated in a national park and seeks to reserve this honor for cases where there is a compelling justification for such recognition, as there is here.  Mr. John H. Krebs, who immigrated to the United States in 1946 and obtained his citizenship in 1954, served on the planning commission and the board of supervisors for Fresno County through the 1960’s and 1970’s and in the U.S. House of Representatives from 1975-1979.  In 1978, he secured passage of legislation that transferred management of the beautiful Mineral King Valley to the National Park Service. The Valley at that time was slated for development as a downhill ski area, and he led a hard-fought battle to assure the long-term protection of this very special place as a natural area.  Mr. Krebs currently resides in Fresno. 

We recommend changes to S. 1774 to mirror H.R. 3022, plus several additional changes to ensure that the National Park Service is able to manage the lands the bills would designate as wilderness consistent with the Wilderness Act of 1964 and the California Wilderness Act of 1984, as explained below.

First, we recommend that the bills be amended to provide for the treatment of roads and development in wilderness that conforms to the standard practice used in other wilderness legislation.  That would require revising the bills’ referenced maps in their depiction of the wilderness boundary delineated for Mineral King Road and cabins along the road. The maps for both H.R. 3022 and S. 1774 show a “cherry-stem” of Mineral King Road, a relatively quiet, 1½ lane-wide road, with a boundary at up to one-half mile (2,640 ft.) from center line of road and from one-quarter to one-half of a mile from cabin developments. The National Park Service and other wilderness land management agencies primarily use a road corridor exclusion area of 100 feet off both sides of the center line of a road for major roads, and from 100 to 200 feet away from existing developments. The standard road corridor exclusion is recognizable on the ground and provides for consistent, effective management.  It is also the boundary delineation guidance that Congress provided in committee report language (House Report 98-40) for the Generals Highway, a busy, two-lane-wide paved road, when the Sequoia-Kings Canyon Wilderness was established as part of the California Wilderness Act of 1984.

Second, S. 1774 excludes from wilderness designation four check dams located in the Hockett Plateau/Mineral King.  We prefer that the dams be designated as potential wilderness additions, as they are under H.R. 3022, rather than be set aside as exclusions. Designation as potential wilderness additions would allow Southern California Edison, the operator, to continue its hydroelectric power operation as long as it wants.  However, in the event that the operator of the dams ceases to operate them in the future, the National Park Service would have the option to convert the area to wilderness through administrative action. The designation of “potential wilderness addition” has been used in the existing Sequoia-Kings Canyon Wilderness and in other wilderness areas in similar cases of non-conforming uses. 

Third, Section 4(c)(1) of S. 1774 states that if nonmotorized access is not available or time is of the essence, nothing in the Act prevents limited motorized access to hydrologic, meteorologic, or climatological devices or facilities.  The existing Sequoia-Kings Canyon Wilderness addresses maintenance and access to these types of devices consistent with House Report 98-40.  This committee report language states that, “Modifications, relocations, adjustments and maintenance of these devices are therefore acceptable, but it should remain an objective to minimize any adverse impact of these devices upon wilderness resources where possible, especially as improved technology (e.g. miniaturization) and other factors permit.”  We prefer the language in H.R. 3022, which directs the National Park Service to continue managing maintenance and access to these devices and facilities consistent with the House Report 98-40, allowing current practice to continue throughout  both the previously designated wilderness areas and the new wilderness areas designated by this bill.

Fourth, Section 4(c)(2) of S. 1774 and Section 3(d) of H.R. 3022 address the use of helicopters for the operation and inspection of utility facilities. We recommend that these sections be struck, as they are unnecessary.  The use of helicopters in the vicinity of designated wilderness is permitted currently, when conditions warrant, as a means of access for inspection and maintenance of hydrometeorological facilities, pursuant to the minimum requirement provision of the Wilderness Act and also as provided in House Report 98-40.

Fifth, Sections 4(d)(2) of both S. 1774 and H.R. 3022 address nonwilderness activities outside of designated wilderness.  We are concerned that these sections could affect the National Park Service’s ability to protect the designated wilderness.  Exempting activities outside wilderness could affect the National Park Service’s ability to address noise, pollutants, or other undesirable effects on wilderness that come from outside the parks.  While we prefer the narrower language in H.R. 3022, which focuses on authorized activities by cabin owners in the Mineral King Valley area, or the property owners or lessees in the Silver City private inholding, to the broader language in S. 1774, we recommend that these sections be removed from the bills.

Sixth, Section 4(e) of both bills states that nothing in the Act precludes horseback riding in, or the entry of recreational commercial saddle or pack stock into an area that would be designated as wilderness under this bill.  The intent of this language is unclear and has been interpreted several different ways. It appears to limit the ability of the National Park Service to manage these operations consistent with the park’s enabling act as well as the Wilderness Act. By not clarifying this language, it could lead to management conflict by setting different standards for the previously designated wilderness areas and for the new wilderness areas that would be designated by these bills.  The parks have long recognized and documented that the use of pack and saddle stock is an appropriate and historically accepted recreational activity in wilderness.  The acceptance of this use has been reaffirmed in the parks’ 2006 General Management Plan. However, we strongly believe the National Park Service should retain the ability to determine the impacts of these operations on park resources and to take actions necessary to regulate their use when resources are being adversely affected. The language of Section 4(e) is ambiguous about the Secretary’s authority and we, therefore, recommend that it be deleted.

Finally, as technical matters, we note that H.R. 3022 correctly refers to the “Sequoia-Kings Canyon Wilderness,” the name of the existing wilderness area given by that act, and that the maps referenced by H.R. 3022 include map numbers in addition to titles and dates as is standard practice for legislative maps.  We would be happy to work with the committee on similar revisions to S. 1774.

Mr. Chairman, this concludes my statement. I would be happy to answer any questions that you may have.