To whom it may concern: I am writing to urge the Department of the Interior to abandon the rewrite of the National Park Service Management Policies. I love the outdoors, have great respect for the National Park Service, and am concerned that the new policies would harm America's national parks. The 2001 Management Policies unambiguously articulate the mandate of the 1916 Organic Act and the responsibilities of the National Park Service. It is unclear why those policies are being rewritten so soon, or why the new draft is being produced in such a rushed manner. The 2006 draft does not significantly clarify the 2001 policies, and only a tiny fraction of the changes address recent concerns about homeland security. Most importantly, the new draft weakens the Park Service's primary mandate of conservation and resource protection. The following are some specific points of concern. All page and line numbers refer to the comparison edition of the Draft 2006 NPS Management Policies. 1. Under the new draft, conservation is no longer the primary mandate of the NPS. The new policy represents a shift away from conservation and in favor of use. Three significant examples: - In several places (p.5, line 1; p.17, line 33), the new draft states that the NPS must now balance resource conservation and "visitor enjoyment." - In section 1.4.3 (p.17, lines 23-27), the new draft deletes language that states that Congress "has provided that when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant." - Also in section 1.4.3, the language that described how courts "have consistently interpreted" conservation to be the "predominant" goal of the Organic Act has been deleted. The deleted language unambiguously made resource protection the primary purpose of the NPS, and placed that purpose in the context of judicial precedent. Deleting it weakens the NPS's mandate. 2. The draft would loosen restrictions on use-related impacts. - In many places, the phrase "adverse impact" or "adverse effect" has been replaced by "unacceptable impact." For example, the sentence "NPS managers must always seek to avoid ... adverse impacts on park resources ..." has been changed to read "... must always seek to avoid ... unacceptable impacts ..." (p.17, lines 11-13). Comments (p.18, line 22) claim that "criteria for protection are at least as strong as the 2001 edition," but this is manifestly false, since the definitions of "adverse" and "unacceptable" imply that the NPS may allow adverse impacts that have not reached the threshold of unacceptability. - Similarly, several sections permit "impacts" as long as they do not cause "impairment." An impairment is defined as a "significant impact ... that would harm the integrity of park resources or values..." But the definitions do not clearly differentiate significant and unacceptable impacts. Can a significant impact be acceptable? Can an unacceptable impact be insignificant? How is a park manager to decide when an impact is unacceptable, or when it constitutes impairment? These definitions are unacceptably vague and will lead us down a slippery slope towards death by a thousand acceptable impacts. 3. The draft extends the range of "appropriate uses" of protected land, including "uses that have occurred historically in a park" (should logging be allowed again in Sequoia NP?) and "uses that may represent new technology." 4. The phrases "where practicable" and "when practicable" have been inserted throughout the draft to qualify conservation activities. This wording forces NPS managers to focus first on budgets rather than on conservation priorities, in contravention of the intent of the Organic Act of 1916. 5. Chapter 2 ("Park System Planning") has changed dramatically. For example: - Section 2.3.1.5 ("Science," p.43), relating to the scientific and scholarly basis for decisions in the park planning process, no longer exists. - The new Section 2.3.1.4 ("Public involvement") redefines the public's participation in the planning process. Whereas the NPS could consult with groups "for the purpose of exchanging views and information," it must now "give appropriate consideration to consensus advice" and encourage "consensus-based management." Curiously, the parties involved in consultation have changed: no longer "existing and potential visitors, park neighbors, and people with traditional cultures ties to the lands," but "state and local governments" and, more emphatically than before, "concessioners, cooperating associations, [and] other partners." 6. Chapter 4 weakens natural resource management. For example: - "Clear skies and natural soundscapes" are no longer physical resources, and "associated characteristics such as scenic views" are no longer denoted as "highly valued" (p.61). - The definition of "natural condition" is extended to include conditions that could arise in the presence of humans ("not necessarily in the absence of humans," p.61, lines 27-28), potentially rendering air pollution from vehicles and other human activity acceptable in national parks. - A pervasive emphasis on "practicability" limits park superintendents' goals in protecting park resources. - The draft would allow the NPS to intervene in natural processes "when necessary to provide appropriate visitor enjoyment so long as the intervention does not lead to unacceptable ... impacts" (p.63, lines 29-30). Given the vague definition of "unacceptable impact," this policy could lead to degradation of natural processes.. - Section 4.4.2.1 (p.78) would allow public hunting inside national parks to reduce animal populations, in sharp contrast to decades of resource protection policy. - Section 4.6.2 (p.89) requires that the NPS work "cooperatively" and "use the principles of ... consultation and communication" with state agencies to resolve disputes over water rights. Cooperation on water issues is likely to be a pleasant fiction, especially in the southwest. Without stronger powers, the NPS may be unable to protect park resources. - Section 4.7.1 (p.93) similarly emphasizes cooperation on the matter of air quality, and complicates the procedure to deny or modify construction permits for "major new air pollution sources." - Section 4.9 (p.100) weakens the NPS mandate to "preserve, to the greatest extent possible, the soundscapes of parks," states that "what constitutes unacceptable noise will depend on visitor sensitivities and expectations," and again emphasizes "practicability" and "cooperation" in reducing sound pollution. This policy will probably make it more difficult for the NPS to regulate motorized activity in national parks. 7. Chapter 6 weakens wilderness preservation and management. - It removes the following text: "All lands administered by the NPS ... will be evaluated for their suitability for inclusion within the national wilderness preservation system" (p.138, lines 1-9). - It removes language that required wilderness suitability assessments to be performed in a timely manner. - Section 6.3.1 (p.142, lines 6-8) states that "Lands that were originally deemed wilderness eligible, but which were not included in the wilderness recommendation sent to Congress, will no longer be managed under" wilderness provisions. This statement reverses text from the 2001 edition, deleted in the 2006 draft, whereby "For those lands that possess wilderness characteristics, no action that would diminish their wilderness suitability will be taken until after Congress and the President have taken final action" (p.137, lines 4-7). - Section 6.4.2, in reference to public enjoyment of wilderness, omits the phrase "while providing for acceptable use limits" (p.153, line 27). Further, in reference to tools for dealing with wilderness-use management problems, it replaces "generally" with "always" in the phrase, "education ... should generally be applied before more restrictive management tools," thereby restricting a park manager's ability to deal with urgent issues. - Section 6.4.3.1 (p.154) replaces "limited" with "managed" when referring to recreational use, and requires "consultation with the public; tribal, local and state governments; and other stakeholders" as part of the recreational use evaluation process. 8. Chapter 7 ("Interpretation and Education") emphasizes that educational programs "provide diverse perspectives" and be respectful of "different opinions and values" (pp.166-167). One hopes that this openness to different opinions won't come at the expense of a rigorous scientific exposition. 9. Chapter 8 ("Use of the Parks") raises some of the concerns already discussed in points (1) and (2) above. The definitions of "impact" and "impairment" are ambiguous, and conservation is de-emphasized relative to use. Some examples: - The following text has been deleted: "... laws impose on NPS managers a strict mandate to protect park resources and values ..." (p.171, lines 17-18). - "Providing opportunities for the public" to enjoy the parks has been elevated from "an important part" to "a core element" of the NPS's mission (p.171, line 27). - New text (p.173, lines 1-8) limits park management flexibility in the face of activity that causes adverse impact. The NPS must "seek first to manage the use in a way that will eliminate unacceptable impacts," and use "public involvement wherever appropriate" prior to restricting or disallowing the activity. - Section 8.2.2.1 (p.179, line 38) mandates that public use limits be established based not just on scientific research and supporting data, but also on public involvement. - Section 8.2.3 (p.184), regarding motorized equipment, removes phrases like "The Service will strive to preserve or restore the natural quiet" and "where [motorized vehicle] use is necessary and appropriate, the least impacting equipment ... should be used." In their place, we have "In some areas ... the use of mechanized equipment and mechanized modes of travel may be determined to be an appropriate use." 10. Chapter 9 lowers environmental standards for park facilities. Some examples: - It omits the phrase "the Service will demonstrate environmental leadership and a commitment to the principles of sustainability in all facility developments and operations." Practicability and financial sustainability, heavily emphasized in the draft, are certainly worthy goals, but the NPS should also be a leader and model of sustainable and environmentally friendly development. - The chapter lowers goals for environmentally responsible facility siting, sustainable energy sources, and other construction parameters, by introducing phrases such as "whenever practicable," "when cost-effective," and "where feasible." - Section 9.2.3.4 (p.243, line 19) demotes bicycle trails from an alternative to motor vehicle access to a mere "supplement" to motor vehicle access. - Section 9.3.1.2 (p.246) mandates that entrance stations should "reasonably accommodate the average peak season visitor traffic." This may lead to substantial new pavement in places like Yosemite and the Grand Canyon. - Section 9.3.4.3 (p.251) no longer recommends that downhill skiing, which requires substantial development and causes significant impact, only be provided outside park areas. The draft merely observes that downhill skiing "is generally provided" outside park areas. And no existing facility may be removed from a park unless "unacceptable impact" is demonstrated. Again, given the vague definition, unacceptable impact is in the eye of the beholder. - Section 9.3.5 (p.252) no longer discourages advertising and billboards on approach roads to national parks, but rather requires park managers to "communicate and collaborate with local communities, businesses, and transportation officials ... to help reduce the impacts of billboard advertising." 11. Chapter 10 similarly lowers standards for commercial visitor services. For example: - The introduction no longer states up-front that concession operations will need to "demonstrate sound environmental management and stewardship" (p.259, line 7). - The Director may, under certain (undefined) circumstances, exempt concessioners from an environmental management program (p.266, line 4). 12. Finally, the new draft introduces some curious wording changes. - The introduction (p.3, lines 11-23) states that "conserve," "preserve," and "protect" imply the same level of care and can be used interchangeably. However, in over 40 places, "protect" and "preserve" have been systematically replaced with "conserve." Surely, if the words are interchangeable, there is no need to replace one with another. - Throughout the document, "National Park Service" and "NPS" have been replaced by "Park Service" or simply "Service." It is unclear why the draft uses this more informal and arguably less respectful terminology. Few, if any, countries have had the foresight and historical opportunity to create a system as beautiful and valuable as America's national parks. It is every American's responsibility to ensure that the National Park Service preserve this heritage in the best possible way. I am convinced that the 2006 Draft Management Policies take the National Park Service in the wrong direction, and that they will harm rather than improve the national parks. Moreover, the 2001 Management Policies are well-written and still fully applicable to the present. Therefore, I urge the Department of the Interior to abandon the planned rewrite and maintain the 2001 policies. Sincerely, Massimiliano Poletto Cambridge, MA