NPS SEEKS PUBLIC COMMENT ON CONTROVERSIAL MANAGEMENT POLICIES DOCUMENT
- 2. NPS SEEKS PUBLIC COMMENT ON CONTROVERSIAL �MANAGEMENT POLICIES� DOCUMENT On 18 October 2005 the National Park Service (NPS) released for public comment a proposed update of its key policy setting statement � "NPS Management Policies," a document that park managers use for policy guidance to achieve the Service�s mission to conserve park resources while providing for their enjoyment by present and future generations.
In a press briefing held at the Department of the Interior (DOI), Department and NPS officials announced proposed changes to the document, which was last updated in 2001. NPS Director Fran Mainella, several deputy directors and a number of career park professionals including regional directors, park managers, and rangers who were involved in the drafting process, participated in the briefing.
According to Mainella, �No one can enjoy the parks if they are impaired. Our updated policy guidance will help the 21st century managers conserve our natural and cultural resources while ensuring enjoyable and appropriate experiences for visitors. To manage parks emphasizing either conservation or enjoyment, to the exclusion of the other, imperils the national park concept.�
Mainella also announced a 90-day comment period in which the Service is �seeking review and comment from Congress, NPS employees, our partners and the public to help us refine and strengthen this critical stewardship document.�
Management Policies has been reviewed and updated several times in the past, most recently in 2001 and prior to that in 1988. The current revision to Management Policies was requested by Congress and is the product of a series of meetings allegedly among some �one hundred career professionals.� Reportedly, park managers had also urged some of the revisions in order to address the �changing needs and circumstances of parks� which, according to some critics, is code language for enhancing recreational use over preservation and conservation. NPS insiders report a slightly different view � that the document is largely the reflection of about two dozen and high-ranking NPS and DOI officials and that there was little input from regional offices or the field.
According to the National Park watchdog group, National Parks Conservation Association, �this proposal appears to be a significant improvement over earlier drafts but the true test is whether it is an improvement to the existing 2001 Management Policies.�
A preliminary analysis by the National Coalition for History (NCH) suggests that there are a number of new provisions and substantive changes that deserve close scrutiny, including several that may well weaken the agency�s mandate to preserve and protect historic sites and heritage. From the first page of the revised document�s �Introduction,� there is evidence of an effort to put the NPS on a new track with respect to managing park heritage resources: there is language that seeks to obfuscate if not negate outright the legislative distinctions between the carefully selected language crafted by Congress in the NPS Organic Act relating to �conserve, preserve, and protect.� The "Introduction" states that throughout the document, except where statutory language is quoted or cited, these words are �generally to be used interchangeably.�
In a glaring if not deliberate omission, nowhere in the Introduction is the language of the NPS Organic Act directly cited; rather, its meaning is paraphrased. A definition of �impairment� has been added: it means an action that �in the professional judgement of the responsible NPS manager, would harm the integrity of park resources or values, including the opportunity that otherwise would be present for the enjoyment of those
resources or values, in violation of the NPS Organic Act.� Similarly,
there is a definition of �appropriate use� defined as anything that does �not cause unacceptable impacts on park resources and values�; �appropriate use� is not described in terms of preservation or conservation nor is there present the statutory mandate to leave park resources �unimpaired for future generations.� Instead we see the language emphasizing visitor use:
�The concept of appropriate use is especially important with regard to visitor enjoyment.�
In the realm of Cultural Resources Management (chapter 5) the changes appear not so draconian, though language relating to the Service supporting its cultural resource professionals by �maintaining and improving their disciplinary knowledge and skills in promoting professionalism through continuing education, graduate level courses, seminars, training, teaching and attendance at professional conferences...� has been struck. There is new language relating to nominations for World Heritage list designation, and new language in a number of sections relating to the consultation process. For example, decisions relating to �user capacity� and �treatment of cultural resources� are no longer left to NPS professionals, disciplinary experts and traditionally associated peoples, rather, they are to include affected �partners, communities...and other interested individuals and groups. �
The notice of availablity of the draft Management Policies document has been published in the Federal Register and is accessible for review and comment for 90 days at http://parkplanning.nps.gov/waso or it can also be viewed at http://www.nps.gov . The NCH has filed a Freedom of Information
(FOIA) request for a side-by-side comparison version that indicates any and all changes, additions, or deletions to the Management Policies guideline currently in place (2001 version) and the public comment release version made available 18 October.
Judy and Bob Huddleston
10643 Sperry Street
Northglenn, CO 80234-3612