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National Park Service Urged To Follow The "Precautionary Principle" In Overseeing Cultural, Ecological Systems In The Parks

To fully embrace the "precautionary principle," the National Park Service could face tougher decisions on how best to manage its parks. NPS photo of Big Cypress National Preserve by NPS volunteer Cerisa Swanberg.

When Aldo Starker Leopold in 1953 published his report on how the National Park Service should manage wildlife resources, he wrote that, "(A) national park should be a vignette of primitive America."

While perhaps a laudable goal when Leopold wrote that, that vision seems to drift further away from possibility as society evolves and national parks become hemmed in by development. Roads crisscross many parks, cell towers are sprouting, national parks are becoming biological islands that need more intensive management of their species and landscapes.

Though it did not fully endorse Leopold's vision, the distinguished panel that wrote Revisiting Leopold: Resource Stewardship in the National Parks did call on the National Park Service to tread more carefully with its management decisions when they could impact the natural, and even cultural, worlds within the national parks.

"Because ecological and cultural systems are complex, continuously changing and not fully understood, NPS managers and decision makers will need to embrace more fully the precautionary principle as an operating guide," reads the report, which National Park Service Director Jon Jarvis requested to see how the agency might continue to evolve its resource management as it nears its second century.

"Its standard is conservative in allowing actions and activities that may heighten impairment of park resources and consistent in avoiding actions and activities that may irreversibly impact park resources and systems. The precautionary principle requires that stewardship decisions reflect science-informed prudence and restraint. This principle should be integrated into NPS decision making at all levels."

Loosely defined, the precautionary principle might be seen as, "first, do no harm," a phrase borrowed from the medical community. But how easily can that be accomplished and managed?

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Recreational snowmobiling in Yellowstone National Park is one activity that perhaps would not be considered "prudent" under the precautionary principle. Kurt Repanshek photo.

Across the National Park System, there are several high-profile approaches to managing resources that have drawn criticism and which possibly could run afoul of the Revisiting Leopold report's dictate due to their impacts on park resources.

At Big Cypress National Preserve in Florida, the agency is being sued for decisions concerning off-road vehicle access in landscapes considered to be key to more than a few plant and animal species listed as threatened or endangered. Foremost in this leafy and swampy wild kingdom is the Florida panther, which has been described as the most-endangered mammal in North America.

Back in July, a federal court ruled the Park Service acted without sound reasoning in 2007 when it reopened more than 22 miles of off-road vehicle trails in the preserve and ordered that the routes be closed.

Courts currently are reviewing the decision by preserve Superintendent Pedro Ramos to open much of the Addition Lands unit of Big Cypress to ORV use. The Addition Lands had been closed to both ORV use and ORV-assisted hunting ever since they came to the preserve in 1996 while officials worked on developing a management plan for the area. Of the thousands of species of flora and fauna found in the Addition Lands, nearly 100 plants are listed by the State of Florida as endangered or threatened while 29 animal species have federally protected status.

At Yellowstone National Park, the issue of recreational snowmobile access has been flogged for better than a decade at a cost of millions of dollars. While science has pushed the issue towards a resolution that inflicts the park's resources with far fewer impacts than were seen a decade ago, there remain issues relating to bombing mountainsides within the park in the name of snowmobile safety along with the sheer numbers of over-snow vehicles proposed to be allowed into the park on any given winter day.

Point Reyes National Seashore has been the focal point of a bitter battle over the future of a commercial oyster farming operation in an area of Drakes Estero being eyed for officials wilderness designation, a designation that normally would prohibit such things as oyster farms. More than a little science, and more than a little debate over the soundness of that science, has been conducted on the oyster farm's impact on the estero, and a decision on the fate of the Drakes Bay Oyster Co. is due any day now.

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Much thought and consideration is being given to the plight of wolves on Isle Royale National Park. Photo courtesy of Wolves and Moose of Isle Royale Project.

Just as easy to cite are instances where the Park Service is being cautious in its approach to managing resources.

At Isle Royale National Park in Michigan, much thought is being put into how, or whether, the agency should intervene to prevent the park's nine wolves from blinking out.

A great deal of thought, science, and consideration was put into the decision -- albeit, a highly controversial one -- at Cape Hatteras National Seashore into how best to manage the needs of piping plovers and sea turtles alongside those of off-road vehicle use on the beaches.

At Olympic National Park, the Elwha watershed is being restored to its natural condition. Two dams have been removed, and crews have been revegetating exposed sediments of the former Lake Mills and Lake Aldwell. The results so far have been impressive, with King salmon migrating back up the Elwha River into the park this summer for the first time in decades.

However, the Park Service is being sued over its plans to release hatchery raised smolts to bolster the Elwha recovery. In its story about that development, the Peninsula Daily News reported that the request for an injunction against the release argued that, “The large-scale releases of hatchery fish proposed to occur this spring will have severely deleterious effects on the wild fish population and their recovery potential."

Obviously, fully embracing the precautionary principle system wide won't be an easy task.

Gary Machlis, the science advisor to Director Jarvis, declined during a recent conversation to discuss the principle specific to Park Service decisions in places such as Big Cypress or Point Reyes. But as a general approach to management in the parks, he was optimistic it could be applied.

“I would tell you that the precautionary principles described by this committee, (the committee argues) that that precautionary principle is necessary as a guiding principle at all levels of the Park Service, not just in Washington, D.C., but at the individual park level," said Dr. Machlis.

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King salmon returned to the Elwha watershed in Olympic National Park in August. Photo by John McMillan, NOAA-Northwest Fisheries Science Center.

"And so I would think that if this report has traction, and if these recommendations are accepted, you would see the precautionary principle as a key focus all the way down the line in the Park Service," he continued.

The science advisor did acknowledge that there are times when adopting the precautionary principle into Park Service decisions will be opposed.

"A principle is always a guide in a democracy. There are always competing elements. And as the report clearly states, one of the key things that I think is an advance is the clarity of what this committee wrote about how the Park Service should make decisions," Dr. Machlis said. "And that was a combination of best available, sound sicence, accurate fidelity to the law, and long-term public interest. Not just one of those things, but all three of those things. And I believe that if the Park Service listens to this committee’s recommendations, it will have a very sound basis to make decisions."

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To answer your points.

1) fireroads are usually open to everybody, but as a cyclist, they're of no interest to me. We're looking for the same intimate connection with nature as hikers get on a narrow trail. So, I don't count fireroads in my very ballpark math. Fact is that there are 50m acres of wilderness not available to cyclists, plus the vast majority of all national park trails. This is not counting all the other local restrictions. So I'm 100% certain that hikers have access to a disproportionately higher mileage of trails in our country. In summary, the argument "why don't you ride the other countless other trails available to you" is not based on reality.

I certainly take exception with the lack of new wilderness. Proponents of wilderness are constantly asking for more. In my neck of the woods, the USFS, at the behest of the usual suspects (Sierra Club, etc.) is reviewing whether to manage as wilderness some parts around lake Tahoe. If the plan goes through the net effect: we'd be kicked of trails we've been riding for decades. And this goes on all over the country all the time. Fact is that there will never be enough wilderness to satisfy the Sierra Club and Audubon of the world.

2) Your second point may be based on law (although in the case of wilderness, not law but an administrative rule) and policy, but it's certainly not based on logic. That's my point. Bikes don't detract from the pristine environment other than in the minds of people who believe in the current rules. If you can somehow explain the logic behind this, I'd be amazed.

Obviously, if you're giving somebody a citation, the poor schmoe ain't going to argue with the guy who has the gun. I know I wouldn't, no matter how right my position is.

The good news: kids will pick up cycling over hiking (although the vast majority will simply eat doritos and play video games). So, demographics are on my side even if time may not be. :)

So, the real question should be: why can't you share some trails when you have exclusive access to 3 to 5 times as many trails as cyclists do?

Hmmm, that's really hard to believe. Where does that number come from? For the purposes of bikers, I'd also include 4WD, primitive or abandoned roads that are available. If you have a source, I'd be interested.

Beyond that, though, I cheerfully share all non-wilderness roads and trails with bikers and encourage anyone to get out on such paths in whatever way they choose. As a side note, to keep things at a respectful and conversational level, could we avoid words like "wildernuts" -- I mean, c'mon, it adds nothing to your argument and is just one of those meaningless but irritating provocations best avoided. I'm open to gentle irony though... . They (we) may ask for more wilderness but it's just not there. That's ultimately the probem.

The last is not a hole -- it's central to why bikes are not allowed -- backed by law and policy. You can argue strenuosly that it shouldn't be, but it is. You simply don't agree with the logic. Frustrating and, likely, monumentally irritating but there's no getting around it except by changing the law. It may happen -- and I know you believe it eventually will -- but I just think it's extremely unlikely. In 40 odd years, I've seen absolutely no serious move in that direction. That would seem to support an overall policy of "prudence and restraint" in what to allow. In fact, until starting to read this forum a year or two ago, I was totally unaware it was an issue. Even when giving a citation to the very occasional mountain biker (every one of which was walking his bike at the time -- the terrain is just too rough) I've never had one insist their activity was a basic right. They've all accepted it was wrong and not ever argued the point that bikes should be allowed.


Your argument is a well worn one that just does not measure up to reality. Hikers, and horse riders, have exclusive access to 50m acres of wilderness in the lower 48, and to pretty much all narrow trails in the national parks. And this is not enough, the wildernuts keep on asking for more wilderness, thereby reducing the amount of trails available to cyclists. So, the real question should be: why can't you share some trails when you have exclusive access to 3 to 5 times as many trails as cyclists do?

The other hole in your argument is that it implies that somehow bringing cyclists in wilderness/national parks makes the area less pristine and detracts from its conservation goal. There is simply no logic behind that assertion.

It's always the same thing: lots of words to cover the simple truth that you just don't want to share.

Not sure it's particularly relevant in the great scheme of things, but the modern preservation movement and NPS owes much more to Muir and the Transcendentalists and the Enlightenment than to anything related to puritans. Sure, puritans set the mood for the transcendentalists to, in a sense, rebel against but that's where the main influence comes from -- Muir, Emerson and Thoreau. American transcendentalists and our preservation and conservation movement then greatly influenced the rest of the world. The key difference is we had enough open space to fully develop both movements. As both movements spread throughout the world, they were applied according to both what they could actually set aside – very little in many fully developed countries – or what their own politics and established philosophies would allow. So to go elsewhere and experience what they’ve done is not especially relevant or informative to the American experience or our potential.

You can, for instance, mountain bike in huge areas of the country but why do you continually insist that activity must be allowed everywhere when there's a sizeable number of people -- I would argue a majority of NPS Wilderness users -- who just want areas without such intrusions? And who, yes, insist they are intrusions in spite of your repeated arguments to the contrary? We (the maligned purists) don't have anywhere near the real estate that mountain bikers do. Why do you want to take even these small islands of National Parks away?

Your example of areas in other countries and how they allow for multiple recreational activities is good. And, hey, we’ve got huge, huge tracts of land devoted to the exact same thing: USFS & BLM & State Parks & County Parks. We have only one type of land use devoted to fairly pure wilderness experience: designated Wilderness and National Parks. Why can’t you be happy with that?

The discussion by the same people tends to get kind of loopy and never seem to grasp the key difference between national parks (preservation) and BLM, USFS etc. (multiple use, conservation). Many of you seem to be arguing that NPS should become more like multiple use agencies. The problem is no one's making pristine land anymore.

For preservation and NPS, it's not so much a question of what's natural or human influenced. The original Leopold Report sums it up best with the quote Kurt used in his opening: National Parks are best managed as vignettes of a primitive America -- pre-euro-American contact. When managing at a micro-level, there's definite problems with this (influence of climate change; large terrain changes as a result of human influence upstream or previous logging etc), but as an overriding management approach it's pretty good and mostly avoids any consideration of what’s “natural” – the decision is instead made on what a place was like prior to European contact and if it’s possible to preserve that state. Thus, the influences of man (Native Americans) are also considered (especially when considering the influence of fire).

I think I see your point, imtnbke. I would add, in following your point--although we might disagree here--that puritanical, or fundamentalist, moral oppositions might not have anything to do per se with a description of wilderness in terms of the sacred. I think Hawthorne's very good in showing this. His ironic depiction of the Puritans removes their judging from any basis in divinity. In other words, the American discourse on nature in terms of the sacred doesn't imply a fundamentalist, or puritanical, opposition to what isn't wilderness. That opposition isn't built into the discourse; it may occasion the discourse, but it comes from elsehwere.

Hi, Justin H — That's a great reply, and thank you in particular for referring me to Cotton Mather's writings, complete with original spellings—that's marvelous. I often refer to Cotton and Increase Mather when making this point, so it behooves me to know rather better than I do what they said about this topic in particular, as opposed to their Puritan philosophy generally. I am aware of the Puritans' deep ambivalence (at best) toward wild places and their fear and dread of it as a locus of evil or at least peril, although I've heard less about their desire to civilize it.

My point wasn't, however, about how Puritans viewed wilderness, but about how we view capital-W Wilderness. That view, along with opinions about front-country national park acreage, is, I maintain, heavily influenced by Puritan and other fundamentalist forms of Manichean thought—the sacred versus the fallen. How many times have we seen references to sacred spaces or outdoor cathedrals in these forums and others too? I suspect you've read the writings of William Cronon and other people along these lines (although, since I haven't memorized Cronon chapter and verse, I'm hard put to quote him here without going back to his influential but outrage-producing "The Trouble With Wilderness" essay).

There ought to be a program under which people intensely devoted to these issues would spend two years in any other country, looking at how it administers its parks.

Of course, some of these countries would have bad conservation programs, but others would enable one to see that it's possible to have wonderful land preservation while not adhering to the unique and often rather strange park administration standards in effect since the NPS's Organic Act of 1916 and similar scripture. New Zealand, Canada, France, Australia, and Portugal all come to mind. But above all the United Kingdom, which has managed to meld conservation with activities people (beyond the seemingly ever fewer hikers and horsemen) want to do and boost local economies in a health- and environment-affirming way. Here's an example of a marvelous public-private partnership, the United Kingdom's Seven Stanes, that allows for widely appealing and exhilarating activities and preserves an area:

The Organic Act approach, cited approvingly above, has done much good but has also precipitated a lot of problems, one of the main ones being people's seeming inability to consider new conservation approaches, like the United Kingdom's Seven Stanes. It's rather like King Arthur's sword, with no one able to pull it out.

More important than the Act and its positive and negative aspects, our approach to land preservation is heavily informed by the United States' continued suffering under the yoke of the Puritan tradition, which, among other things, sets up Manichean separations between the sacred and the profane and easily attracts preservationist devotees to the maintenance of the former in national parks and forests. Here's a recent New York Times article on the subject:

I don't know, imtbke. For the most part, the Puritans viewed wilderness as a region of terrible fallen-ness to be redeemed only by "reclaiming it"--i.e. turning it into materials for the construction of civilization. Pretty much the exact opposite of the Organic Act. See Nash, Wilderness and the American Mind. Or right to some primary sources--Cotton Mather, Decennium Luctuosum: An History of Remarkable Occurrences in the Long War Which New-England Hath Had with the Indian Salvages; William Bradford, Of Plymouth Plantation, 1620-1647; etc. Even if Nash overstates the case, the Puritan attitude toward the natural world still ranged from fear and trembling to deep ambivalence. The Protestant work ethic described in the article you cite emerges out of this very motivation to destroy wilderness. So, if the Puritan mindset does persist in the American imagination, it would seem to be in its stark opposition to preserving wilderness.

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