Blurred lines. Subtle changes. Weakened standards. Preconceived goals.
In the past week alone, many comments have been delivered to the Interior Department about the revisions proposed for the National Park Service's Management Policies. And many of them, coming from members of Congress as well as individuals and advocacy groups, have cited concerns that the revisions, in total, drastically water down the Park Service's core mission, the preservation of resources.
Now, in perhaps the most thorough review I've seen, The Wilderness Society has submitted a voluminous comment as to why the revisions should be trashed.
In his cover letter to the 34-page dissection, TWS President Bill Meadows urges Interior Secretary Gale Norton to "withdraw this proposal immediately and abandon any further effort to rewrite and weaken the existing management policies. We believe this draft proposal comprises no less than a bad set of solutions in search of a problem."
Of Course This Is Emotionally Charged
To be sure, there's a lot of emotion tied up in this process. And that's easily understood. The national park system long has been cherished by Americans, for it preserves and protects slices of not just our country's landscape but also our heritage. Without that preservation and protection the nature of the landscape, and the moments caught in time of our heritage, would slowly deteriorate and one day vanish.
Too, some of these sites go beyond being simply "national" parks, for quite a few have been designated World Heritage Sites by the United Nations Educational, Scientific and Cultural Organization. These select parks, UNESCO has determined, capture "cultural and natural heritage ... considered to be of outstanding value to humanity."
And so it's understandable to see the uproar over revisions to the latest edition of the Management Policies that, since they were adopted five years ago, seemingly have done a good and fair job in guiding management of our national park system. The revisions, many fear, will lift a layer of protection from the national parks and open them up to deterioration, whether that be exacted by new forms of use, air or sound pollution, or overuse.
Top Park Service officials have said changes are necessary to give park managers both more flexibility and guidance in overseeing their parks. Too, they maintain that you can't manage Yellowstone the same as you would Independence Hall. You'll get no argument from me on that point.
But already within the existing Management Policies there is sufficient flexibility to allow variations in management from park to park. Yet at the same time, that doesn't seem to be playing out on the ground. It's almost as if DOI's political appointees are calling the shots, fearful of letting park managers and scientists determine what truly is best for their parks because those on-the-ground decisions...will be truly what is best.
For example, in Yellowstone the ongoing snowmobile debacle seems to have some park managers lining up behind supposed "best available technology" snowmobiles that still pollute much more than they're supposed to. And they've raised the limits for snowmobile noise in a move supposedly intended to reflect a "system-wide" noise standard.
Does that make sense? If you want increased management flexibility so Yellowstone's managers can make decisions specific to their park, why hold them to a system-wide standard?
And then there's the issue of mountain bikes in the parks. Park superintendents already have the flexibility to allow, or ban, mountain bikes, yet the Park Service felt it necessary to embark on a five-year pilot project with the International Mountain Bicycling Association to demonstrate that bikes and parks are compatible.
On its face, that move by Washington no doubt puts some superintendents' feet to the fire to allow mountain biking. Does that mean flexibility is OK as long as you follow Washington's lead?
What Is TWS Objecting To?
In concluding his letter to Secretary Norton, Mr. Meadows states that not only aren't the revisions needed, nor do they improve on the existing policies, but that, "At worst, the totality of the proposed changes will weaken the standards by which NPS management decisions have been made for decades, and will lower the standard of preservation that national park natural and cultural resources are entitled to under the 1916 Organic Act."
So, what wrong did The Wilderness Society find with the proposed revisions? Without going page by page, here are some of the highlights that I've gleaned from the document:
* "The single most fundamental flaw in the proposed changes ... is their failure to maintain (as was done in the 2001 edition) the clear intent and meaning of the 1916 NPS Organic Act that it conveys an unambiguous, separate and strong mandate to care for and maintain park resources."
* " ... the shift from referring to 'visitors' enjoyment' to 'recreation uses' carries several implications that are inappropriate to that which distinguishes the lands, waters and natural and cultural resources managed by the NPS from those managed under clearly differing philosophies by other agencies. Parks have visitor centers, ranger-led tours, and other programs to encourage the long-term commitment to conserve the park system. 'Using' the system just doesn't seem consistent with the mission -- the park system by law is far different than all other public lands, specifically based upon the preeminent preservation mandate."
* "At their core, the proposed changes would have the effect of insisting that the NPS evaluate all important management decisions based upon effects on visitor use, and substantially ignores the Organic Act's separate mandate to 'conserve...unimpaired.'"
* "Many of the proposed policy changes would have the effect of allowing more or different types of uses and developments in the parks, and only allow the NPS to evaluate them after they have become established use (with no likelihood that the NPS would have sufficient new funding to monitor the use, much less assess its effects)."
* "... it is clearly wrong to assert that the meaning of 'conserve,' 'preserve,' and 'protect' are the same; they are not the same in Webster's Dictionary, and they are definitely not the same in what they are commonly understood to mean when applied to public land management....As it has been used in a public land management context over much of the past century, 'conserve' refers to the careful, sustainable use of natural resources; 'preserve' generally is used to mean maintaining in an unharmed or original condition; and 'protect' usually refers to law enforcement or regulatory matters when referring to public lands."
* "...every place where the term 'preserve' appears in the 2001 version of the Management Policies it is proposed to be replaced with one of the other terms in the 2006 edition. Why even bother to suggest substituting 'conserve' for 'preserve' if one believes that they mean the same thing? If the administration truly did, then there would be no justification for the substitution at all. Obviously, a different meaning was intended or else NPS would have left the term 'preserve' alone in the 2001 edition of Management Policies."
* "The proposed definition in the 2006 version of 'impairment' seeks to suggest that any park impairment is to be judged both on effects on resources and on visitor enjoyment. This is not an accurate interpretation of the 1916 Organic Act's meaning, and if adopted, would set up a nearly un-reconcilable dilemma for park managers, since it is often park use that causes park impairment. Impairment of national parks should be evaluated solely on the basis of effects on park natural and cultural resources. Only those uses that are compatible with that analysis may be allowed in the parks."
* "Determining 'appropriate use' or 'unacceptable impacts' is left to the professional judgment of the park manager and based on science, which is fine. However, by explicitly requiring these decisions to be made through the NPS planning process, which currently has a 40-year backlog at current funding levels, and by allowing uses to continue or new ones to commence until the NPS has made a determination of appropriate or 'unacceptable' the proposed policies will assure that park resources could be impaired by use long before the NPS can make a management decision."
* In critiquing Chapter 8 of the Management Policies, which refers to "use of the parks," TWS points out that, "The basic flaw throughout the proposed changes in this chapter is the presumption visitors are not already enjoying their experiences in parks and therefore the NPS must allow more uses and activities."
A few paragraphs down the group adds that, "The thrust of the major changes to this chapter seems to be predicated on the notion that NPS should accommodate any use in the same way that multiple-use agencies like the BLM or Forest Service do. However, the clear distinction between the NPS and these multiple-use agencies is that the NPS has a legal mandate to put resource preservation above visitor use, and to allow only those uses that are compatible with its preservation priority.
"It would be a serious mistake, and patently illegal, to adopt NPS policies that assume this agency to be identical in scope and mission with the multiple-use federal land management agencies."
Are Politics, Not Need, Driving This Process?
The Park Service is caught in a bind. There are career employees who no doubt are saddened and chagrined by this odyssey down the proverbial rabbit hole that top political appointees have taken the agency.
If you didn't see his comment the other day, Bill Wade, chair of the Coalition of National Park Service Retirees' executive council, pointed out that the birth of the revisions actually dates to the earliest days of the Bush administration.
"During the testimony yesterday, Mr. Bill Horn (formerly Asst Secy of Fish, Wildlife and Parks and now a paid attorney and lobbyist for snowmobile and other OHV interests) revealed information that surprised even Deputy NPS Director Steve Martin. Horn said that within two weeks after the current administration took office, the 2001 NPS Management Policies were targeted for review and revision," said Wade, who also delivered testimony at the hearing held by the House parks subcommittee.
"This adds further to our contention that unlike previous revisions of NPS management policy, this revision was nearly 100% politically driven. We knew the drive started as early as April 2002, but were unaware that it actually started well before that."
A Dance of Misdirection
Since last summer top Interior Department and National Park Service officials have danced a dance of misdirection over the handling of the Management Policies revisions.
When Paul Hoffman, DOI's assistant deputy secretary for fish, wildlife and parks, wasted so much red ink on the first attempted revision of the 2001 Management Policies, the public uproar over his changes led Park Service officials to dismiss them as little more than devil's advocacy.
Never mind that Hoffman, in a previous life as head of the Cody, Wyoming, Chamber of Commerce, vehemently opposed the Clinton administration and Yellowstone officials when they wanted to ban snowmobiles from the park. And let's not forget that in his current job Hoffman told the American Recreation Coalition, a big lobbyist for motorized recreation on public lands, that the Park Service should focus more on conserving resources in a sustainable fashion rather than truly preserving them.
Oh, and I can't forget how Hoffman told reporters that the 2001 version of the Management Policies basically was "anti-enjoyment." (Reporters love guys like Hoffman. They're veritable quote machines.)
Now, I've tried to land an interview with Director Mainella to try to discern when she turned anti-preservation. After all, she once believed her agency's primary job was preservation. But I've been told that she doesn't want to have the Management Policies revisions debated in the media. Of course, the very day I got that message the director had written a letter to a Kentucky newspaper to challenge a columnist's take on the revisions, and she later granted The Associated Press an interview (I can understand that. I long worked for the AP and when you can attach 'AP' to your name it opens a lot of doors.).
If the Park Service doesn't want to insert itself into the comment period, why did it just the other day post answers to frequently asked questions about the revisions? Taking the same devil's adovcate's role that Hoffman supposedly played, I might question whether the NPS hasn't already made up its mind on these revisions since it already has the answers to the public's questions.
If that's the case, politics truly are driving this process and the agency not only is wasting quite a bit of money on a process that has a preordained conclusion, money that could be better spent in the parks, but also views those who are taking the time to comment as dunderheads.
What will be interesting in the weeks and months ahead is whether the agency takes seriously comments from TWS, the National Parks Conservation Association, senators, House members and the general public. As I understand, yet another draft of revisions will be forthcoming. Let's see if anyone in the Interior Department is listening.