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Released Jointly By
Coalition of National Park Service Retirees
National Parks Conservation Association
Natural Resources Defense Council
The Wilderness Society

PRELIMINARY ANALYSIS
June 2006 Analysis of Revised Draft Policies

Fundamental Mission of the National Park Service Restored

Based upon our preliminary analysis, the National Park Service’s long-standing mission of conservation and stewardship of the nation’s heritage has been restored in this current draft rewrite of the policies that govern management of our national parks. At the behest of park professionals, the American public, Congress, this coalition, and others, the National Park Service appears to have largely reverted back to the 2001 policies in virtually every section.

For instance, language in the existing 2001 Management Policies that specifies that conservation takes precedence over everything else in park decisions, which had been excluded from earlier drafts, has been restored in this draft. Moreover, some minor revisions have been made that improve upon the existing 2001 policies.

We reserve final judgment on this draft version until the Secretary of the Interior and the National Park Service Director finalizes the document. This will likely happen following three weeks of input from park staff.

FUNDAMENTAL PROTECTIONS RESTORED BACK TO 2001 POLICIES:

Commitment to Conservation
The existing 2001 policies explicitly state that the National Park Service’s fundamental mandates are conservation and prevention of impairment to resources. This new draft restores that significant language. This draft also retains language throughout the document that confirms the commitment to conserving resources unimpaired during planning and when determining which activities are allowable in park sites.

Protecting Natural Sounds
The October draft policies removed important language about the protection of “the atmosphere of peace and tranquility and natural soundscapes.” In fact, soundscape protection was diminished throughout the entire document. The June (or latest) version restores those protections for natural quiet in our national parks—a key reason many people visit these places.

Cooperative Conservation
Throughout the Hoffman and October drafts, the National Park Service was instructed to employ “cooperation” in the management of the parks, which was defined as giving outside entities equal weight during decision-making. While consultation and public involvement is welcomed at all parks, this language could have impaired park managers’ ability to make decisions to protect park resources when other entities disagreed.

For example, in Sec. 1.6, which addresses consultation related to activities outside park boundaries that affect park resources, the first draft inserted language on “cooperation” in places that create the impression that superintendents are constrained in their ability to oppose harmful developments because they must always achieve consensus. This new draft retains the cooperative conservation language, but includes a provision that if all cooperative efforts fail, superintendents can use their authorities and actions to take action (i.e. oppose development in favor of protecting a resource).

Maintaining Clean Air
The Hoffman and October drafts erroneously reclassified clean air in our national parks as a “value” instead of a resource, thereby diminishing its importance in a park manager’s decision-making, and put the onus on park managers to work cooperatively with those that might be proposing a new neighboring power plant so as to potentially “mitigate” the affects of such a harmful proposition. This new draft corrects these provisions by instead using the language from the existing 2001 policies.

Preserving Wilderness
The Hoffman and October drafts would have changed the way proposed and existing wilderness areas in our national parks are managed, essentially making it easier to allow off-road vehicles and other activities that would have conflicted with the goal of preserving wilderness in parks. This new draft incorporates the park-protective language found in the existing 2001 policies such as “The National Park Service will take no action that would diminish the wilderness suitability of an area possessing wilderness characteristics until the legislative process of wilderness designation has been completed. Until that time, management decisions pertaining to lands qualifying as wilderness will be made in expectation of eventual wilderness designation.”

ACCEPTABLE CHANGES TO 2001 POLICIES:

Fire Management
This new draft updates the discussion about fire management and provides improved guidance to park managers over that available in the 2001 policies.

Cell Towers in Parks
The June draft improves upon the 2001 policies by requiring park managers to consider the impact of towers on the setting and scenery of a park before approving a siting permit. It also requires that towers that are allowed be located where they will have the least impact on park resources and that their visual impact will be minimized.

Appropriate Use
The process for determining an appropriate use, based upon analyzing whether there are unacceptable impacts, is clearer and simpler, making it a better tool for decision-makers. It also unambiguously shows that when an activity is “unacceptable,” it does not need to rise to the level of “impairment” in order to be rejected.

Determining Unacceptable Impacts
The October draft rewrite introduced the flawed concepts of “appropriate use” and “unacceptable impacts” that sought to permit activities and mitigate problems associated with those activities like off-road vehicle use. These terms have been revised and under this draft, the new terms could aid park staff when determining whether an activity should be allowed by assessing the tranquility of an area—such as its natural sounds—and possible conflicts with other visitors.

CONTINUING CONCERNS WITH NEW DRAFT:

Planning for Natural Resource Management
Language in the new draft that only calls for only certain parks to develop plans for the long-term preservation of natural resources from such threats as invasive species and sprawl, instead encouraging all park managers to develop these important plans.

Harpers Ferry Center
Throughout this new draft, references to the National Park Service’s restoration and resource center in Harpers Ferry, West Virginia, have been deleted. We are concerned that this change reflects the National Park Service’s ill-considered response to funding constraints and its recent decision to relocate or retire the talented archivists, restoration experts, visual artists, and other skilled personnel in this facility, which serves as an in-house resource for parks nationwide seeking to create new signage, interpretive materials, and exhibits, or research and restore priceless artifacts.

MORE INFORMATION:

To learn more about the new draft rewrite of the parks’ Management Policies, please contact:

Ron Tipton, National Parks Conservation Association, cell: 202-669-9689
Rob Arnberger, Coalition of National Park Service Retirees, phone: 520-743-1717
Kristen Brengel, The Wilderness Society, 202-429-2694
Chuck Clusen, Natural Resources Defense Council, 202-289-2412


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