Impaired for Future Generations: A radical proposal threatens to undermine our national parks
By DENIS GALVIN
AN HISTORICAL DOCUMENT: Denis Galvin served under three presidents as Deputy Director of the National Park Service: Ronald Reagan from 1985 to 1989; Bill Clinton, from 1998 to 2001; and George W. Bush, from 2001 until his retirement in 2002. He wrote this article specifically for the summer 2005 issue of our C.E.P. (Conservative Environmental Policy) Quarterly.
Paul Hoffman, a political appointee in the Bush administration’s Interior Department, has personally undertaken the task of radically altering the basic meaning, purpose and mission of the National Park Service (NPS). If implemented, these changes — proposed by a former Chamber of Commerce staffer with no national parks experience — will negate more than a century of conservation philosophy that has been revered and emulated around the world, and has been called “the best idea America ever had.”
At the core of this threat is how the concept of impairment — a legal requirement that the national parks be preserved unimpaired for the enjoyment of future generations — is treated in the NPS management policies, which serve as an everyday operations guide for Park Service staff. The requirement is contained in the 1916 Organic Act that created the National Park Service.
Stephen Mather, the first NPS Director and his Deputy Director, Horace Albright, the second NPS Director, drafted the first NPS Management Policies. From 1918 until 2001, roughly every decade or so, the professional staff of the National Park Service generally reviewed and updated as necessary this basic understanding of how the Park Service is supposed to do its job.
The 1918 Management Policies were prefaced by a letter from Interior Secretary Franklin Lane, which directed, in part:
“First, that the national parks must be maintained in absolutely unimpaired form for the use of future generations as well as those of our time; second, that they are set apart for the use, observation, health, and pleasure of the people; and third, that the national interest must dictate all decisions affecting public or private enterprise in the parks.”
The first section of the 1918 NPS Management Policies states that,
“Every activity of the Service is subordinate to the duties imposed upon it to faithfully preserve the parks for posterity in essentially their natural state.”
The manual has become longer and more detailed over the ensuing decades, but the NPS understanding of the meaning of the 1916 Organic Act has remained remarkably unchanged and consistent.
The 1988 edition of NPS Management Policies, issued by the Reagan administration, and the 2000 edition, issued by the Clinton administration, are virtually identical in their interpretation of the key language of the NPS Organic Act and of the meaning of impair- ment. Both versions, prepared by NPS professional staff and reviewed by the public, accurately quote the Lane letter as setting out the fundamental intent of the Organic Act, which the Service has called its “Creed.”
Hoffman’s politicized draft revision to NPS Management Policies, which was written with virtually no knowledge or input from career NPS professionals, fundamentally would alter the very concept of “National Park” by twisting the concept of impairment. The draft would provide that public use of the national parks must remain unimpaired by NPS management of the parks, not the parks themselves.
A political appointee in the Bush administration’s Interior Department has personally undertaken the task of radically altering the basic meaning, purpose and mission of the National Park Service.
One key proposed change redefines impairment as “probable irreversible damage” or as “permanently and irreversibly adverse.”
This would make it much more difficult to protect against any impact to parks that theoretically could be reversed. For example, cell towers or power lines could be erected in natural areas because, one day, they might be taken down.
National parks are intended to permanently protect America’s natural and historic heritage.
For more than 130 years, through both Republican and Democratic administrations, the basic management philosophy of national parks has been consistently understood to mean that the parks, all 388 of them, are intended to be conserved, unimpaired, for present and future Americans. It has been clear from the beginning that national parks were to be managed differently from national forests or other multiple-use public lands.
To be sure, the national parks are intended to be enjoyed, appreciated, and understood by all Americans. Recreation, both passive and active, both physical and spiritual, is certainly a part of the purpose. But when there is a question of priority between the preservation of park resources and uses of them, preservation always must trump use. Only those uses that are fully compatible with the statutory standard to “conserve… unimpaired” may be allowed.
The extensive rewrite that political appointees are seeking also includes many more explicit statements that would place recreation above preservation in NPS decision-making. For example, the NPS would not be allowed to re-introduce native species of wildlife into parks (such as the wolf re-introduction in Yellowstone) where they had been lost unless it “does not lead to long term closures or loss of visitor enjoyment, access, or recreation opportunity.”
Hoffman’s politicized draft revision, written with virtually no knowledge or input from career NPS professionals, fundamentally would alter the very concept of “National Park” by twisting the concept of impairment.
Another change would deny natural land restoration in national parks except “when parks are of sufficient size and ecological diversity that they are or nearly represent a complete ecosystem.” Smaller parks, such as the Congaree Swamp National Park in South Carolina or Saguaro National Park in Arizona, would likely not qualify for any restoration under this policy.
Further, the proposed policy changes would allow exotic species to remain in national parks if they were originally introduced by the state. Thus the devastating invasion of Australian pine or Brazilian pepper trees (originally planted as windbreaks along state highways in Everglades National Park) could be judged acceptable. Similarly, the exotic vine kudzu, which threatens to overrun much of the South (originally planted by state highway departments to control erosion on steep road cuts) could be approved to remain in Great Smoky Mountains National Park.
The national parks also include numerous important battlefields of the French and Indian War, the American Revolution, the War of 1812, the Civil War, Indian wars, and World War II. Since the first battlefield was put under NPS’ care, it has been the agency’s policy to treat these places where Americans have died as hallowed ground, managed with a memorial atmosphere. The Bush administration changes to NPS Management Policies would repudiate this policy, thus allowing staged amateur re-enactments of these battles on the very ground where blood was shed for our country.
Among specific recreation activities that the proposed policy changes would authorize are snowmobiles, with the addition of a new section of Management Policies stating that snowmobiles are to be allowed in national parks on any roads where cars and buses travel at other times of the year. Thus the Going-to-the-Sun Road in Glacier National Park and the Tioga Road across the High Sierra in Yosemite National Park would automatically be opened to snowmobiles.
The extreme nature of these proposed changes to National Park Service Management Policies does not reflect a conservative frame of mind, but rather a reckless and selfish “live-for-today” philosophy, which is decidedly out of step with mainstream America’s love of their national parks. My former colleagues in the Park Service will need all the strength and support they can muster to ensure these changes don’t become policy.
Theodore Roosevelt would turn over in his grave if he knew the extent to which his own party’s administration threatens his legacy of conservation of our great national park system.