Commentary on Wilderness Act
February 17, 2006
Bernard Fagan
Office of Policy
National Park Service
Room 7252
1849 C Street, NW
Washington, DC 20240
Dear Mr. Fagan:
On behalf of the Center for a Sustainable Coast, I am sending these comments objecting to the proposed management policy revisions
for administering wilderness areas within national parks. We base our objections on the degree to which the proposed revisions
fundamentally contradict the legally established reasons for designating and maintaining wilderness areas under the federal Wilderness Act.
Preservation of wilderness character is a basic statutory purpose of the Wilderness Act, yet this purpose has been subverted in the proposed
revisions by various forms of "public use." By encouraging and facilitating visitation at wilderness areas, the proposed policy revisions
undermine the legislatively established objectives for wilderness. Instead of serving the public interest of setting aside special areas
as pristine wilderness, dominated by healthy natural systems that are undisturbed by human impacts, the new policies promoted intensive,
inappropriate activities that are inherently harmful to wilderness. When analyzed in terms of their ultimate consequences, the proposed
policies would severely compromise if not destroy the qualities that we seek to sustain through wilderness designation.
By emphasizing visitor safety as a major goal of wilderness management, a logical consequence of promoting higher visitation and recreational
use of wilderness areas, these policies endorse blatantly inappropriate imposition of facilities that would cumulatively obliterate the
wilderness experience. Among these facilities are cabins, toilets, developed camp sites, and picnic tables - all features that are properly
placed in other types of Park Services properties, but clearly contrary to wilderness character By imposing human domination in wilderness
areas, such facilities undermine the very founding purpose of the Wilderness Act.
The proposed policies are a dangerous example of "mission drift" if not outright intentional redirection through ill-conceived administrative
reforms that would override the explicitly stated legislative intent of existing law. The statutory purpose of the Wilderness Act is clear:
it is to preserve the wilderness character of each area in the National Wilderness Preservation System, not to promote any particular use.
Wilderness is for the benefit of our citizens, but all levels and types of use must be compatible with protection of an area's wilderness
character, providing wilderness solitude undisturbed by intrusive human activities such as the use of motorized vehicles and permanent structures.
Wilderness should remain a place of personal challenge, discovery, informed risk, and self-reliance, not managed and developed to promote
visitor safety as in conventional "parks." It is woefully inappropriate for the National Park Service to promote increased use in wilderness
areas and to market wilderness as a recreational playground. By law, the National Park Service is obligated to preserve wilderness character
and to develop public awareness and appreciation for the qualities and values that make wilderness unique and different from non-wilderness
backcountry within the park system. There are ample non-wilderness holdings that may be managed by the NPS primarily as a recreational resource.
As a non-profit organization supporting the conservation and appropriate use of coastal Georgiašs natural resources in the public interest,
we strongly object to these proposed policy changes. In our region they would severely compromise the uniquely beautiful appeal of the Cumberland
Island National Seashore, which is unfortunately already threatened by unwise management decisions in the recent past. If we honor the important
national legacy established by the Wilderness Act, Wilderness monitoring must include more than biophysical carrying capacity - its central focus
must be on assuring that the unique qualities and values of wilderness character are respected and preserved, especially among those who are
responsible for managing these areas.
In keeping with these concerns and consistent with legislative history, a standardized "Minimum Requirements" documentation process for managing
wilderness areas should be required. This process should be subject to public comment and review in order to improve consistency, accountability,
and public understanding about the functions and values of wilderness across all such NPS designated areas.
In reconsidering federal policies governing wilderness areas, we genuinely hope that your agency will take seriously these and other comments made
on behalf of the public. As our region and nation continue to grow, the value of true wilderness will undoubtedly escalate. We cannot afford to
adopt policies that are ill-conceived and misinformed about the unique importance of the National Wilderness Preservation System. Now more than ever
before, we must honor our nationšs wilderness legacy and strengthen our resolve to sustain it.
If you have any questions about our remarks, please feel free to call.
Sincerely,
David C. Kyler
Executive Director
The Center For A Sustainable Coast
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