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Commenting on the Management Policies: Will Anybody Listen?


    An interesting question was posed to me the other day: What can opponents to the proposed revisions to the National Park Service's Management Policies do to see that the revisions are not made permanent?
    Good question. You might not like the anwer, though.

    The short answer is that those opposed to the revisions should contact the Park Service with their comments by mid-February. (You can find a web address for submitting those comments over in the lefthand column). However, the ugly little secret about this process is that the Park Service officials behind these changes really don't have to listen to your concerns.
    Officially, I've been told that all comments the Park Service receives, from both the general public and from Congress, will be "reviewed, analyzed, and organized" by the agency's policy staff. From there, recommendations on how the comments should be treated will be presented to the agency's senior leadership team, which will decide what to do.
    Once the leadership team has made up its collective mind, it will post a summary of the public comments on the Park Service's website, along with the official agency response to those comments. And then the agency will come up with its final revision of the Management Policies. Apparently, if you request that you be notified of the final version, the agency will email you when it's available.
    If it's any consolation, the Coalition of National Park Service Retirees also is wondering how the Park Service leadership plans to react to public comments, and they'll push the agency for a good answer.

    What Changes Would I Like to See?

    There are many parts of the revision that need to be toned down or tossed out. In fact, there are literally dozens, and likely hundreds. But a key one is the provision that the general public, or advocacy groups, cannot go to court to try to hold the Park Service accountable to the Management Policies. If you comment about nothing else, demand that this section be tossed. I mean, what good are the policies if the agency doesn't have to worry about being held accountable to them?
     As for other changes....
        *I'd also definitely insist that the full wording of Section 1.4.3 be returned, the part that says:
"Congress, recognizing that the enjoyment by future generations of the national parks can be ensured only if the superb quality of park resources and values is left unimpaired, has provided that when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant.
    "This is how courts have consistently interpreted the Organic Act..."

       * I'd also like the Park Service to return to the old wording concerning air quality. The revised language
defines "natural conditions" as conditions that exist "not necessarily (in) the absence of humans," whereas the old standard was conditions that occurred "in the absence of humans." Seems to be a pretty big difference to me. I mean, with all the air pollution that we're generating these days, I'd feel a lot better if the agency adhered to a standard of the natural conditions that existed before we fouled them up.
        * And I'd call on the agency to go back to every section where it replaced "preserve" or "protect" with "conserve" and ask that they switch the words back. There is a difference in the definitions of these words. In many sections the revisions also substituted the word "minimize" for "mitigate." Again, big difference in definitions. Let's stick with the original wording.
        For additional insights into what's wrong with the current revisions, visit the National Parks Conservation Association web site and the Coalition of National Park Service Retirees'  site. Both have great sections that point out what's wrong with the revisions and what needs to be corrected.
    Finally, it wouldn't hurt to contact your congressional representatives and ask them to take a stand against the revisions. Some members of Congress already have voiced their concerns to NPS and Interior Department officials. But more voices wouldn't hurt.

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