National Park Designation is an Unholy Mess

Cuyahoga Valley National Park has attractive features, but does it really deserve to be National Park-designated? National Park Service photo.

Foreword: Last September, Sabattis and I collaborated on a Traveler article entitled “Are There Really 391 Units in the National Park System? You Won’t Think So After You Read This!”. Controversy is now swirling over proposals to redesignate (or “upgrade”) some existing National Park System units, most conspicuously Golden Gate National Recreation Area and Ocmulgee National Monument. This seems like a good time to remind Traveler readers just how ridiculously out of whack the National Park System unit nomenclature has already become. Is National Park System unit redesignation to remain nothing more than a political football that opportunists can kick around? Is it really too much to ask that Congress and the National Park Service put their heads together and come up with a National Park System unit designation system that actually makes sense?

The National Park Service says there are 391 units or areas in the National Park System. You’ll see this number used an awful lot, particularly when the National Park Service wishes to highlight the vast breadth and depth of the National Park System. Likewise, park advocates regularly use this number when quantifying the various threats to the National Park System as a whole.

Here is the official National Park Service breakdown of National Park System units by designation type. The number of units in each designation category is shown in parentheses.

National Historic Sites (79)
National Monuments (74)
National Parks (58)
National Historical Parks (42)
National Memorial (28)
National Preserves (18)
National Recreation Areas (18)
National Battlefields (11)
National Wild and Scenic Rivers and Riverways (10)
National Seashores (10)
National Military Parks (9)
National Rivers (5)
National Lakeshores (4)
National Parkways (4)
National Battlefield Parks (3)
National Scenic Trails (3)
National Reserves (2)
National Battlefield Site (1)
International Historic Site (1)
Other [unique] Designations (11)

Total Units = 391

Now, consider these facts in light of that “391-count.”

• There are 333 National Park System units (391-58 = 333) that do not have "National Park" as part of their official name.

• There are 30 kinds of designations for National Park System units. Of the 333 National Park System units named something other than National Park, 13 have designations that aren’t shared by any other park.

• Officially stated criteria notwithstanding, the distinction between units labeled National Park and those labeled something else is far from clear. There are many anomalies, even some bizarre ones. Consider, for example, that Cape Hatteras National Seashore, a large National Park System unit with one of the nation’s finest assemblages of nationally significant historic and natural resources, is not a National Park. At the same time, that label has been applied to Hot Springs National Park, a very small National Park System unit that preserves historic bathhouses.

• A goodly number of National Park System units, including at least one National Park, are of questionable national significance. Steamtown National Historic site and First Ladies National Historic site are often cited as examples of units that should be purged from the system. Many informed people believe that Cuyahoga Valley National Park has physical and cultural resources that are not up to the standards of a National Park System unit, much less a unit designated National Park.

• Congress has designated at least 20 National Preserves that are managed by the National Park Service, but only 18 are counted as units of the National Park System. The two that don’t count as units are the Jean Lafitte National Historical Park and Preserve and the Salt River Bay National Historical Park and Ecological Preserve. All of the land within each of these parks carries both of the title designations. That's right; Congress has given two different designations to exactly the same area of land and water, and they've done that more than once.

• Nez Perce National Historical Park consists of 38 sites. One of them, Big Hole National Battlefield is not only part of Nez Perce National Historical Park, but also counted as a separate unit of the National Park System. (To add to the confusion, the Bear Paw Battlefield is a sub-unit of both Big Hole National Battlefield and Nez Perce National Historical Park, but does not count as a separate unit towards the Park System’s 391 total.)

• If you were to visit all 15 sites comprising Golden Gate National Recreation Area, you’d be visiting three different National Park System units. Golden Gate National Recreation Area, Muir Woods National Monument, and Fort Point National Historic Site each count as one unit in the National Park System 391-tally.

• Nearly 40 components of the Wild and Scenic River System have been assigned to the National Park Service for management, but there seems to be no rhyme nor reason as to why some count as Park System units and others do not. Several of the rivers are wholly contained within Alaskan National Parks and don’t count, but the Middle Delaware National Scenic River is wholly contained within the Delaware Water Gap National Recreation Area and does count. The Great Egg Harbor Scenic and Recreational River in New Jersey is almost entirely locally managed and counts, but the Maurice Scenic and Recreational River in New Jersey is managed very similarly and doesn’t count.

• There are eight National Scenic Trails, but only five have been assigned to the National Park Service for administration, and only three count as National Park System units. For unknown reasons, the Appalachian, Natchez Trace, and Potomac Heritage National Scenic Trails all count as National Park System units, but the Ice Age National Scenic Trail and the North Country National Scenic Trail do not.

• Of the 18 National Historic Trails designated by Congress, only one, the Iditarod National Historic Trail was not assigned to the National Park Service. Of the remaining 17, however, the National Park Service doesn’t count a single one as a unit of the National Park System. This is despite the fact that many of the Trails have their own superintendents and some even have visitors centers (like the Lowndes County interpretive center on the Selma to Montgomery National Historic Trail.)

• Glacier Bay National Park and Preserve counts as two units of the National Park System. According to the National Park Service, this is based on the fact that a small area on the far western edge of the park (representing less than 2% of the total park acreage) is designated National Preserve and allows sport hunting.

• The Western Arctic National Park Lands is a National Park Service administrative designation that encompasses four units of the National Park System, including Bering Land Bridge National Preserve, Cape Krusenstern National Monument, Kobuk Valley National Park, and Noatak National Preserve.

• The White House counts as one unit of the National Park System.

• The superintendent of National Mall and Memorial Parks is actually one of two superintendents for a unit called National Capital Parks. At the same time, the superintendent of National Mall and Memorial Parks also has responsibility for Ford’s Theatre National Historic Site, the Franklin Delano Roosevelt Memorial, the Korean War Veterans Memorial, the Lincoln Memorial, the National Mall, the Thomas Jefferson Memorial, the Vietnam Veterans Memorial, the Washington Monument, and the National World War II Memorial – each of which is counted as a separate unit of the National Park System towards that figure of 391 units. Further adding to the confusion, this superintendent has responsibility for a number of other areas, including the District of Columbia War Memorial, the George Mason Memorial, the National Japanese-American Memorial to Patriotism During World War II, and the Ulysses S. Grant Memorial, none of which count as units.

• The other half of the unit called National Capital Parks is National Capital Parks-East. The superintendent of National Capital Parks-East also has responsibility for the Carter G. Woodson Home NHS, Frederick Douglass NHS, Fort Washington Park, Greenbelt Park, the Mary McLeod Bethune Council House NHS, and Piscataway Park. To complicate matters further, this superintendent also has responsibility for places like the Baltimore-Washington Parkway, Fort Dupont Park, the Kenilworth Park and Aquatic Gardens, and the Sewall-Belmont House National Historic Site, none of which count as units. The Sewall-Belmont House and Museum is in fact an Affiliated Area that does not include “National Historic Site” in its name, even though the National Park Service does, at least for some purposes.

Who is responsible for the unholy mess that is the official tally of National Park System units? Some of the blame surely belongs with Congress, which often designates units for political purposes (Cuyahoga Valley National Park anyone?) and often fails to follow the National Park Service’s conventions in designating units (which is why we have “The National Park of American Samoa” instead of “American Samoa National Park.”).

The Park Service deserves its own share of criticism for helping to perpetuate -- at least by chronic inaction -- a National Park System unit count that is at best unintelligible, and at worst manifestly inaccurate.

This is not a harmless failing. The present nonsensical way that National Park System units are designated and counted will continue to frustrate efforts by national park advocates to quantify the needs of the National Park System and draw attention to potential solutions. The first step to identifying your needs is to identify what you have, and with the National Park System’s method of counting, identifying what you have is nearly impossible.

Comments

Editor's note: In light of the reference to the National Parks Pass and the Golden Eagle hologram sticker, this writer's experience at Mount St. Helens evidently took place some years ago.

Imagine my surprise, then, as a visitor to your country arriving at Mount Saint Helens National Volcanic Monument with my newly purchased National Parks Pass (the best $50 you could ever spend) only to be told, that, no that pass won't work here because this is managed by the Forest Service. But if you spend another $15 on a Golden Eagle hologram, you'll be OK.

Had me confused for a while. Couldn't work out why a place as important as Mount Saint Helens was not run by the National Park Service.

Still, despite all the naming issues and pork-barrel politics, the National Park system of the United States is a superb endowment to the world - it keeps me coming back year after year.

I don't think that most visitors really care about the "official" governmental designation of a given NPS unit. I seriously doubt that someone visiting Cuyahoga Valley National Park would be concerned or even take note that it carries the same title as Yosemite and Glacier. They're there to enjoy a couple of hours of recreation on a Sunday afternoon in metropolitan Cleveland and don't really care what it's called. The same can be said for Hot Springs or even Petrified Forest (which was the first monument to be converted by a politician for purely economic purposes). I think people tooling down I-40 are still going to stop and check out the ancient logs regardless of its name either as a monument or a park. The care factor among the vast majority of the visiting public is zero.

As long as politicians are the ones responsible for creating parks and managing the funds you can expect this funny business in designations to continue. It is too easy for them to use their power to create economic plumbs for their districts and states by giving a place a more enticing sounding title so as to lure the masses to spend money on a visit to their newly minted national park.

As long as Washington, DC is in charge this situation will not be resolved and I'm betting that along with fat bonuses for AIG executives there will be a new national park in Bibb County, GA in the not too distant future.

I get your point(s), Beamis. However, with all all due respect, I will continue to believe that branding matters, and that having a designation system that makes sense is better than having one that does not.

With all due respect Bob, as long as Congress is involved the chances of that occurring are about slim and none.

Good post by the way.

Ford's Theatre now has it's own superintendent.

Bob,
While I love your current and past articles on this subject, and agree it points out the problem, I think it would be more helpful if someone with your expertise and many who read and write here, would offer solutions or fixes. Then even if some consenses is formed, send it to a helpful congressman (if there are any). I am sure many here would jump on the band wagon to help promote a change if they can see why it matters.
Dave Crowl

The essential point that Bob is trying to make here (as I see it) is that there must be CLEAR guidelines as to what the NPS is going to manage. Make it clear what can be a park and what cannot. The premise that Congress or politicians are innately going to mess things up is wrong. How parks are designated makes a BIG difference in how they are managed. Great write-up Bob.

rob mutch
---
Executive Director,
Crater Lake Institute
www.craterlakeinstitute.com
Robert Mutch Photography,
www.robmutch.com

I agree that his point is we need clear guidelines and why. My point is the next step is to write an article with several steps to a possible solution. Suggest Guidelines and ask us to help promote. I feel Bob Janiskee and many who post here have a great insight to the solution. I am just suggesting that they start a forum in the right direction. The article is a great start. It is the second time I have read this and I am only pointing out the direction that might bring change. Don't just point out the problem---- point out a possible solution.

Dave,

Your point is well-made and a valid one. We've actually got something in the formative stages that more than likely will do just that.

Nice comments Dave. This is a great start. We do have many great thinkers on this subject, such as Bob.

rob mutch
--
Executive Director, Crater Lake Institute
www.craterlakeinstitute.com

Bob Janiskee
On March 18th, 2009

I get your point(s), Beamis. However, with all all due respect, I will continue to believe that branding matters, and that having a designation system that makes sense is better than having one that does not.

Does the National Park Service and the federal government maintain a monopoly on the use of the term "national park"?

Here's a "what if?":

Say I buy a few thousand acres of land. Maybe many thousands of acres. Or perhaps more likely (because that wouldn't happen without a heavily taxed windfall) a group of concerned individuals creates a non-governmental organization to acquire the property. What's to stop them from designating their property a national park?

To digress: The federal government pretty much has a monopoly on open lands, what with the federal government's theft of Indian lands to turn over to the Dept of Interior and the Dept of Ag. But let's assume for this "what if?" that enough private land (or perhaps a privately owned sequoia or redwood grove) could be purchased and set aside for preservation.

And what if I do get the windfall and purchase a privately owned sequoia grove and decide to call it, oh, I don't know, Frankonia Grove National Park? Will the federal government take me to court to ban me from infringing upon its "brand"?

Certain NGOs (read: Nature Conservancy) have been highly successful at branding. Why should the federal government be the one to do the "branding"? (National parks are starting to sound more like cattle--a commodity--than land to be preserved in this discussion.)

My point?

A century of government monopoly and control of our natural treasures has endangered what it was supposed to protect. It's time for a change (and real change this time). Conservation trusts are not an experiment; they have a long track record of proven success. The federal government has a long track record of theft and mucking up natural ecosystems, and that same government is now on the verge of bankruptcy.

I wrote it before, and I write it again, even more certain in its inevitability: "I look forward to the day I go home and see the sign: WELCOME TO CRATER LAKE NATIONAL PARK - A CONSERVATION TRUST".

Interesting post, Frank, but your dreams of having a national park named in your honor are just that -- dreams. If you tried to use that name for your park, the Interior department would file charges on you for the fraudulent offering of federal services. Incidentally, there's been a lot of publicity lately about a national park trademark brouhaha at Hot Springs. You can read about it here.

Dave, as Kurt has said, the posts you'll see on Traveler fairly soon will address the NPS unit designation and redesignation issues in a more comprehensive and proactive way. Rest assured that we have some specific suggestions for improving and standardizing NPS unit designation. We assume that Traveler readers have also got some thoughts on this matter they'd like to share.

If you tried to use that name for your park, the Interior department would file charges on you for the fraudulent offering of federal services.

So "national bank" or "national title" or "National Car Rental" any other title/brand with "national" in it is not a fraudulent offering of federal services?

It's funny that so many people decry private monopolies (which really can't exist without government help) while embracing governmental monopolies.

Frank, I must admit that I'm out of my depth on this one. Perhaps a Traveler reader more familiar with these trademark and copyright issues might want to chime in?

The trademark database at USPTO lists 30 live entries including "national park". Pretty much all of them cover only a special visual logo, not a claim for the words as such. And their scope is very limited, mostly to publications, and many were registered by concessionaires which looks like they had permission by the NPS.

The NPS does not hols any current trademark - but had the Arrowhead emblem registered twice, both now expired. That is because trademarks need not be registered to be valid, just using a name for your goods or services over some time gives you an implied protection from any competitor who might wish to use the same name or one that might be confused with your name. And there can be no doubt that the National Park Service uses the name National Park for quite some while now to describe its goods and services.

The enforcement of an unregistered trademark is called Passing off and this description at Wikipedia is pretty good: http://en.wikipedia.org/w/index.php?title=Passing_off&oldid=271955473

An unregistered trademark is protected against infringement if the misrepresentation is damaging the goodwill of the legitimate user. Diversion of trade and dilution of goodwill is considered damage. So if a private 59th "National Park" attracts visitors that would otherwise visit a NPS National Park that would constitute diversion.

Thanks, MRC. I understand everything clearly now........... I think.

I find myself falling squarely on , err..., both sides of this issue. A few years back my wife and I decided to try to visit all the States in the USA, and we generally look for a National Park to visit when we go to a new state. (Next up: Congaree National Park, SC in mid-April 2009, I'm already excited about it! Only disappointment is that I haven't been able to find a historic hotel in the area to review. But I digress.) While there I take a lot of pictures and write about what I see, then put it on my website for friends, family and anyone else who can stand to look at it. At any rate, we are disappointed when we find that a State does not have a NP for us to visit as we consider a NP the highlight of our short trips. Is every State deserving of a NP? I would argue that every State, no matter how plain, has it's own ecosystem and "Original Appearance" which are worth preserving, if only just a small area of it. This allows a history lesson as future generations visit these areas and realize "this is what it looked like before logging, farming, or home building changed it." Seeing this historic approach has helped me to better understand why each State so badly wants, and perhaps deserves, a NP of their own. On the other side of the coin, I lived for many years within an hour drive of King's Canyon, Sequoia, and Yosemite NPs and have admittedly become a bit spoiled by the experience. Julie and I would often take a "long lunch" and drive up to Grant Grove Village in King's Canyon for a picnic lunch or maybe even lunch at the park coffee shop. We were frequent enough that the staff there knew us by name. But as a result of over-familiarization with that spectacular scenery, I find myself at times disappointed when visiting a new park and realizing there really isn't anything too exciting or different to see. That "back home" it would not likely be considered worthy of more than a regional preserve. So I don't know that there is an easy, or even a workable solution to the problem. The situation is that the Western USA is truly blessed with more awe-inspiring scenery, and so it really is difficult to try to set a uniform standard for the entire country.

Jess Stryker
www.Historic-Hotels-Lodges.com
www.JessStryker.com

Jess, I find it hard to accept that every state, a priori, "deserves" to have at least one national park. Political subdivisions have little to do with the distribution of natural and cultural/historical resources meeting the standards set for NPS units. That said, I do understand that there is enormous political pressure to s-t-r-e-t-c-h the standards or lower the bar (pick your metaphor) in this or that particular case in order to spread the wealth. We can therefore confidently predict that various national-parkless political subdivisions (Delaware, for example) will get the NPS unit they have long been denied. Glad to hear that you'll be visiting Congaree in April. You've picked a good month (mild weather, few skeeters). Be sure to do the Cedar Creek Canoe Trail (plan ahead to rent a canoe or kayak; there are none available in the park) as well as one the longer dirt trail hikes in the floodplain forest. The canopy height and sheer size of the forest giants will blow you away! Sorry 'bout the scarcity of historic hotels and inns in the Congaree vicinity.

I highly recommend a little book titled "National Parks: The American Experience" by Alfred Runte
Which one can read online here, though I prefer the hard copy, a comfortable chair, fire in the fire place and a glass of old brandy.

Good suggestion, RW. Environmental historian Alfred Runte has written a number of books that bear reading -- and rereading. One of my personal favorites is "Yosemite: The Embattled Wilderness." The 1993 paperback edition is still widely available.

Bob, can you point me to the disignation of Fort Moutrie als National Monument by congress, please? The General Management Plan of Fort Sumter from 1986 - http://www.nps.gov/fosu/parkmgmt/upload/FOSU_GMP_1998.pdf - states on page 11 that there never was any enabeling legislation for Fort Moultrie, so I am dubious if there ever was any kind of formal designation.

Wow, MRC; that's a great catch! Right there on page 14 of that GMP (page 11 contains only a map) it says: "No enabling legislation exists for Fort Moultrie." That's pretty darn unequivocal.

I just finished a pretty comprehensive (though not exhaustive) search of relevant historical sources and timelines without finding a shred of evidence that Fort Moultrie was ever proclaimed or officially designated a National Monument. What I did find was dozens and dozens of references to "Fort Moultrie National Monument" in a wide assortment of sources -- even Encyclopedia Brittanica. Now that is really interesting! It seems that this is one of those errors that's been repeated and repeated and repeated until it's assumed to be fact.

Over the years I've told many people --including Traveler readers -- that Fort Moultrie is a national monument, even though it is not now, and never has been, a national monument. For that I most humbly apologize and promise never to do it again.

Thank you, MRC, for putting me on the righteous path.

BTW, this seems to be what we can say with confidence about historic Fort Moultrie. It was a coastal artillery installation ostensibly guarding Charleston harbor (though inadequately armed for the job) until 1947 when it was deactivated. Nearby Fort Sumter National Monument was established in 1948. The National Park Service assumed responsibility for Fort Moultrie in 1960, and the site was placed under the supervision of Fort Sumter National Monument.

I got curious and looked a bit deeper at the usual places for such an information - the hit came pretty easily, wasn't more than ten minutes searching. And thank you for the summary of the really know facts. But one big question stays: How did the NPS get responsible for Fort Moultrie, if not by designation or proclamation?

Interesting question. Fort Moultrie was transferred to the state of South Carolina after it was deactivated in 1947. The state of South Carolina then transferred the site back to the federal government in 1960. Assigning it to the National Park Service for administration as a component of Fort Sumter National Monument would certainly be the logical thing to do in those circumstances. An administrative decision like that wouldn't require a proclamation or designation of the sort you'd need for establishing a new NPS unit.

Speaking of Ft. Moultrie, here's a new news clip about the Ft.

FORT SUMTER NATIONAL MONUMENT
Museum Exhibit On Slave Trade Opens

"African Passages," a newly-installed museum exhibit on the international slave trade at the Fort Moultrie Visitor Center, opened to the public this past weekend.

The new exhibit examines the role of Sullivan's Island as a quarantine station during the international slave trade, when Charleston was the main port of entry for captive Africans in North America. Historians estimate that slave ships brought 200,000 to 360,000 men, women and children into Charleston's harbor. Between 1707 and 1799, when arriving ships carried infectious diseases, their free or enslaved passengers were quarantined either aboard ship or in island "pest houses." This painful history makes Sullivan's Island a gateway through which many African Americans can trace their entry into America.

The exhibit includes the haunting Middle Passage charcoal works of Thomas Feelings and the exuberant Gullah art of Jonathan Green. West African objects, leg shackles and an 1803 slave identification badge are among the artifacts on display that are on loan from the collection of the Avery Research Center for African American Culture at the College of Charleston.

The story of Priscilla and her seventh generation granddaughter's return to Sierra Leone provides a modern day link from Charleston across the Atlantic and three centuries.

"The scholarship of historians Edward Ball and Joseph Opala uncovered this amazing connection from Sierra Leone to Sullivan's Island. The story of Priscilla puts a face on those oppressed by slavery," said Krista Kovach-Hindsley, NPS exhibit planner.

With text written by journalist Herb Frazier, the exhibits were fabricated and installed by Studio Displays of Charlotte, North Carolina. Seed money for the project was donated in 2004 by the Committee of Descendants, a foundation established by Ed Ball and his extended family. The Remembrance Committee of Charleston has also been instrumental in seeing the project completed.

"This is a story of national and international significance that is central to the birth and growth of the United States," said superintendent Bob Dodson. "It is a powerful story of strength and endurance that will touch people on a personal level. I am very grateful for the grass roots support of this long awaited exhibit. The Charleston community has been looking forward to the completion of this project for some time now. The exhibit builds on the commemorative marker installed in 1999 and Toni Morrisons Bench by the Road placed on park grounds in 2008.

Rick Smith

Surprised that no one has mentioned Parks Canada, where it's either National Park (primarily natural/scenic) or National Historic Site. Nice and clean and simple!

Alan Hogenauer

Two categories instead of 30 does have a certain appeal! Thanks for bringing the Parks Canada approach to our attention.

Further on the matter of Fort Moultrie. This morning while sorting through some old files I found an NPS tri-fold brochure distributed a long time ago (late 1980s or early 1990s) at Congaree National Park (then Congaree Swamp National Monument). This brochure, a listing of NPS units and Affiliated Areas in South Carolina, not only refers to "Fort Moultrie National Monument," but also provides a phone number and address. There is a separate listing for Fort Sumter National Monument, so there's no mistaking the intent.

Cape Hatteras National Seashore in not a bizarre anomaly. Rather Cape Hatteras was the first National Seashore. And the definition assigned to this new type of unit was as follows.

Primarily a seashore is a recreation area. Therefore in its selection, the boundaries should be placed in such a manner that the maximum variety of recreation is provided. Thus while provision for bathing may be the first consideration of these areas, it must be kept in mind that a far greater number of people will be more interested in using a seashore area for other recreational purposes. It is desirable therefore to provide ample shoreline for all types of beach recreation. The Cape Hatteras National Seashore provides such an area in that there is extensive shoreline for all forms of recreation both for immediate use and for future development.

http://www.nps.gov/history/history/online_books/unrau-williss/adhi4l.htm

I agree that the nomenclature is often confusing, but I don't see how streamlining the process would lead to better management. What's a bigger issue are areas like the Santa Monica Mountains National Recreation Area which have some administration by the NPS but also include several state- and county-managed lands. If there's a problem there, who can you contact?

I also take strong issue with the very notion that some of these parks don't have "national" significance. You identify issues where the national signficance is underappreciated, maybe. But lacking? I doubt that.