Heads UP river runners! Your comments are needed! The National Park Service has revised all of its national policies, including its wilderness review and stewardship policies, and is soliciting public comments on new Draft policies until February 18, 2006.
Instead of wild, undeveloped places associated with solitude and self-reliance, under the new policies wilderness would be managed for intensive commercial recreation, scientific uses and special events. The National Park Service would actively promote and facilitate commercial services in wilderness. Facilities and new developments would be justified on the basis of improving visitor safety and enhancing visitor use. The fallout will be particularly onerous on the river in Grand Canyon if these policies are adopted.
The NPS oversees more wilderness acreage than any other agency, so PLEASE let the Park Service hear your thoughts and concerns!!
SUMMARY OF MAJOR PROBLEMS WITH THE NEW DRAFT POLICY:
- Defines public use as the primary purpose of wilderness. Downplays preservation of wilderness character as the singular statutory purpose of the Wilderness Act.
- The draft policies place major emphasis on encouraging and facilitating commercial uses in wilderness.
- Emphasizes visitor safety as a major goal of wilderness management, and allows all sorts of developments in wilderness to enhance safety -- administrative cabins, signs, trail developments, outfitter caches, toilets , developed camp sites -- even picnic tables!
- Modifies the current wilderness review process, making it easier for political appointees in the Executive Branch to shield areas from further consideration as wilderness by not forwarding complete information to the President for ALL areas that have undergone a wilderness suitability study.
COMMENT POINTS TO CONSIDER:
Purpose of Wilderness and the Wilderness Act
1. CRITICAL! The revised policies misconstrue the six "public purposes" (uses) listed in section 4(b) of the Wilderness Act as the primary "purposes" of the Act (i.e. recreational, scenic, scientific, educational, conservation, and historical uses).
Tell NPS that the statutory purpose of the Wilderness Act is singular, not plural -- the Wilderness Act is clear that the purpose of the Act is to preserve the wilderness character of each area in the National Wilderness Preservation System, not to promote any particular use!
2. CRITICAL! A primary emphasis in the policies is on "accomplishing" the six "public purposes" (uses) by accommodating, encouraging, and facilitating public use of wilderness.
Tell the NPS that NPS policies should emphasize appropriate types and amounts of public wilderness use to the extent that they are compatible with protection of an area's wilderness character, including the area's undeveloped, non-motorized qualities and wilderness solitude.
Wilderness Suitability Review:
Helpful Background: NPS does an initial screening of all NPS lands to identify those areas that have wilderness characteristics and are therefore suitable and eligible for further consideration as wilderness. NPS then conducts a more formal "wilderness study" of all lands identified by the initial screening as suitable and eligible for wilderness designation.
1. CRITICAL! The revised policies would allow a political appointee -- the Secretary of Interior -- to administratively shield suitable areas from further consideration as wilderness by not forwarding complete information to the President for ALL areas that have undergone a wilderness study. This means that if the Secretary does not recommend an area for wilderness designation then (s)he could simply decide not to forward any information about that area to the President for his review. However, the Wilderness Act explicitly requires the Secretary of Interior to forward recommendations to the President regarding both the suitability AND non-suitability for all areas that have undergone the formal wilderness study process. By not forwarding recommendations for those areas deemed by the Secretary to be unsuitable for wilderness, the Secretary inappropriately hinders the President's opportunity and statutory right to fully review and modify all wilderness recommendations made by the Secretary.
Please tell NPS this policy change is illegal under the Wilderness Act and that the Secretary MUST forward both suitable AND non-suitable recommendations on to the President for all areas that have undergone a formal wilderness review!
Visitor Safety, Use, and Developments
1. CRITICAL! The new policies focus intensively and inappropriately on assuring visitor safety as a central goal of wilderness management. The policies specify that improving safety is an appropriate reason to allow the development of recreational and administrative facilities in wilderness, including new trail developments, administrative cabins, trail shelters, signs, developed campsites, and toilets -- even picnic tables!
Tell NPS that the Wilderness Act intended wilderness to remain in contrast to our developed and highly regulated modern world. Tell NPS that wilderness should remain a place of challenge, discovery, risk, and self-reliance, not managed and developed to promote visitor safety! Developing facilities to enhance safety is inappropriate action in wilderness.
2. CRITICAL! The new policies place major emphasis on NPS encouraging and facilitating visitor use of wilderness, including promoting the use of commercial outfitting services.
Tell NPS that it's not their job to promote increased use in wilderness or market wilderness as a recreational playground. By law, their job is to preserve wilderness character and develop public awareness and appreciation for the qualities and values that make wilderness unique and different from non-wilderness national park backcountry that may be managed primarily as a recreational resource.
1. Administrative Facilities -- the new policy would allow permanent administrative equipment caches and construction and maintenance of Ranger cabins in wilderness if these are "necessary to protect an area's wilderness character." NPS frequently uses helicopters to access such facilities where they currently exist in wilderness.
Tell NPS that permanent caches and cabins are NEVER necessary to protect wilderness and in fact degrade and compromise wilderness character by intruding on the undeveloped, remote, qualities that make wilderness unique. Tell NPS that Rangers can access and camp in wilderness via the same non-motorized, traditional, self-reliant means that other wilderness visitors do. NPS should be leading the way in setting a good example for other visitors in regard to appropriate wilderness ethics and travel techniques.
2. Minimum Requirement / Minimum Tool Analysis -- NPS policies currently allow each park superintendent to devise their own method for conducting a "Minimum Requirement" Analysis to assess the need and appropriateness for various administrative activities in wilderness.
Tell NPS that most superintendents have no experience in designing a Minimum Requirement Analysis. A standardized Minimum Requirement worksheet should therefore be required and be subject to public comment and review in order to improve consistency, accountability, and public understanding across all park wildernesses.
3. Monitoring -- The new policies define the purpose of wilderness monitoring, in part, as "ensuring that the public purposes (uses) of wilderness are being met."
Tell NPS that wilderness monitoring is about preserving wilderness values and wilderness character, not about assuring that sufficient public use is occurring. Wilderness monitoring must focus on more than biophysical carrying capacity -- its central focus must be on assuring that the unique qualities and values of wilderness character are respected and preserved.
Your letter to the NPS is very important!
The draft policies are online at:
COMMENTS DUE: February 18th, 2006 (e-mailed by midnight MST, or postmarked that day, please include your full name and contact information)
SEND TO: email@example.com
Bernard Fagan, Room 7252
National Park Service
Office of Policy
1849 C Street, NW
Washington, DC 20240