The National Park Service (NPS) faces many challenges in its Centennial year of 2016. While the illustrious history and the public benefits of the National Park System (System) will be widely celebrated this year, these remain difficult times, both politically and financially, and the System cannot thrive without help from others. The Coalition will continue to focus on the issues outlined below. Almost certainly, more will emerge in the months ahead. Recent advocacy by the Coalition has included a wide variety of written material. Much of this can be found in the “News” section of the Coalition website.
Issues Impacting Multiple Agencies or Jurisdictions
These are broad, often politically-driven issues that could impact multiple Federal agencies or jurisdictions, including the NPS. Typically, major national or regional conservation organizations often will play an active role in developing and coordinating the response of like-minded organizations. When such issues pose threats to national park resources and values, the Coalition may collaborate with other conservation organizations on a coordinated response, but may also act independently to focus our commentary on potential park-related impacts and concerns.
Antiquities Act Revisions
The Antiquities Act of 1906 is a powerful conservation tool that gives the President of the United States the authority to, by presidential proclamation, create “national monuments” from public lands to protect significant natural, cultural or scientific features. This executive authority has been used many times since 1906; there are currently 80 national monuments administered as units of the National Park System. In addition, 51 parks were initially protected as national monuments, including such “crown jewels” as Acadia, Grand Canyon, Olympic, and Zion National Parks. Various bills have been introduced in Congress in recent years that would require State and Congressional approval of all new national monuments. Since 2015, the Coalition has been working with like-minded organizations in opposing such legislation, which would, in effect, weaken the President’s authority under the Antiquities Act and significantly limit growth of the National Park System. Our efforts have included meeting with Members of Congress, their staffs, and members of the Administration to voice concerns about the legislation. We have also participated in an op-ed that ran in The Hill’s Congress blog. The coalition will continue to collaborate with other conservation groups in the months ahead to oppose any legislation that would change and weaken the Antiquities Act.
In recent years, legislation has repeatedly been introduced in Congress that would exempt U.S. Department of Homeland Security from compliance with most all significant environmental protection laws and give U.S. Customs and Border Patrol authority over virtually all activities within 100 miles of the border with Mexico and Canada. Most recently, in 2015, companion versions of the Arizona Borderlands Protection and Preservation Act have been introduced in the House and the Senate, which would provide Customs and Border Patrol agents with 100 percent access to conduct field operations, including motorized patrols, on all public lands administered by the Departments of the Interior and Agriculture within 100 miles of the Arizona/Mexico border. The Coalition is partnering with the Borderlands Coalition, a network of conservation and faith-based organizations, to oppose the provisions of the legislation that would weaken the protection of pertinent national park areas.
Clean air and spectacular vistas have long characterized our national parks and monuments. That is why 48 national parks and 108 wilderness areas are designated as Mandatory Class 1 areas receiving the highest degree of protection under the Clean Air Act. Despite this, 36 of the 48 national parks currently have air quality that is periodically unhealthy due to “moderate” ozone levels or higher; and a number of notable park vistas are often obscured by haze or smog caused by coal or oil burning power plants located upwind of the parks. The Regional Haze Rule is the U.S. Environmental Protection Agency’s (EPA) long-term game plan for reducing – and eventually eliminating – the human-caused air pollution affecting these 48 national parks and 108 wilderness areas. Once a decade, states must revise plans to lower air pollution in these places, aiming for natural air by 2064. In 2016, EPA has begun the process to revise the rule and clarify and strengthen how it works. A stronger Regional Haze Rule will mean clearer skies in national parks, healthier air throughout the country, and decreases in pollution driving climate change. The proposed rule is expected to be released in the next few months for a 60-day public comment period. The Coalition will submit comments and collaborate with other conservation groups on a public information campaign to encourage public support for improving the Regional Haze Rule; and continue to advocate for improving air quality in national parks, as appropriate.
Supreme Court decisions in 2001 and 2006 created judicial loopholes and uncertainties about which waterways were subject to Clean Water Act protections. As a result, a variety of organizations asked the EPA to clarify its regulations related to clean water enforcement. The issue has been of particular interest to the Coalition, as more than half of the 407 units of the National Park System already have waterways deemed “impaired” under the Clean Water Act. In May 2015, despite much opposition in Congress, the EPA finalized the new Clean Water Rule which re-establishes protections of the Clean Water Act for the headwater streams and wetlands that provide drinking water for one in every three Americans. The expected improvements in headwater stream water quality will be a tremendous benefit to the many affected downstream national parks and gateway communities. The Coalition submitted written comments supporting the rule as written and published an op-ed in The Hill praising the benefits of the rule. We will continue to support implementation of the final rule and monitor for potential legal challenges and legislative threats.
Defense of Public Lands
A number of national parks are bordered by public lands administered by other federal and state land management agencies. These areas are often large landscapes where management policies and practices are different than those applied in national parks. The presence of public lands adjacent to national parks generally provides for protection of watersheds, view sheds, and habitat for flora and fauna that are important to their sustainability and vitality. This is also true with regard to cultural landscapes where park boundaries were drawn in such a way that important cultural areas were not completely included within the park. In order to adequately protect parks resources, it is sometimes necessary that adjacent lands employ management practices that are consistent with the goals of the Service. In the coming months the Coalition will continue to partner with like-minded organizations in advocating for protection of park resources by influencing how resources and human activities are managed on lands adjacent to parks.
Erosion of Existing Conservation Laws
Events of recent months, such as the unlawful takeover of Malheur National Wildlife Refuge in Oregon, highlight the ongoing tensions between federal land management policies and the anti-federal government movement, particularly in western states. Many members of Congress have declared their intent to reduce the perceived constraints of federal conservation laws on private enterprise occurring on and around Federal lands. Potential targets of this movement include the National Environmental Policy Act, the Endangered Species Act (ESA), the Wilderness Act, the National Historic Preservation Act, the Wild and Scenic Rivers Act and the NPS Organic Act. While wholesale revision of the underlying conservation laws is not likely, we expect to see ongoing Congressional attempts at targeted reductions in or waivers of environmental compliance requirements inserted into legislation authorizing non-conservation activities on conservation lands, or as riders in bills that may otherwise be unrelated to the site affected by the rider. The Coalition will continue to collaborate with other conservation groups to monitor legislative proposals that would weaken or limit the implementation of existing environmental protections and pose a threat to the protection of park resources and values. As appropriate, the Coalition will act to oppose passage of such legislation through letters, op-eds, Congressional outreach, or other measures.
Federal Transportation Funding
The Federal Lands Transportation Program (FLTP) was established in 23 U.S.C. 203 to improve the transportation infrastructure owned and maintained by a number of federal land management agencies, including the National Park Service (NPS). Many of these systems have been in a steady state of decline over the past couple of decades due to chronic underfunding; yet in recent years Congress has been reluctant to reauthorize or extend this important funding authority. It is the position of the Coalition that transportation facilities located on or operated in national parks are federal facilities that should be taken care of by the federal government. In December 2015, the Fixing America’s Surface Transportation Act of 2015 (“FAST Act”) was signed into law replacing the previous program authority. While passage of the Act is a step in the right direction, the Coalition will continue to advocate for adequate funding for park roads and related transportation facilities as part of the regular appropriations process.
Land and Water Conservation Fund (LWCF)
The authorization of the LWCF expired on September 30, 2015 and Congress has so far failed to reauthorize it. Some legislative “solutions” have proposed a major overhaul of the LWCF funding program, which has traditionally been used for state and federal conservation land acquisition, that would allow LWCF funds to be used to address the NPS deferred maintenance backlog. The net effect of such action would be to significantly reduce the possibility of future acquisition of private lands and reduce the need for Congress to adequately fund NPS facility maintenance needs through the appropriations process. On a more promising note Section 5002 of the bi-partisan Energy Policy Modernization Act of 2015 (S. 2012), which is currently moving forward in the Senate, contains a straight-forward proposal to reauthorize the LWCF. It is hoped that Senate action will take place soon and help spur House action to continue this important program in its existing form. The Coalition has actively supported reauthorization of LWCF through outreach to Congress and submission of various op-ed pieces. We will continue to advocate for reauthorization of this important conservation fund source, while opposing diversion of LWCF funds to replace appropriated funds to address NPS’s long-term facility maintenance needs.
Energy Development Near Parks
For some time the Coalition has monitored efforts of the Bureau of Land Management (BLM) to move forward on a variety of oil and gas leasing projects near national park areas in Colorado, New Mexico, and Utah. We are concerned that a consequence of some of these projects, unless properly planned and managed, will be serious harm to the resources and values for which many of these parks were established. In 2010 BLM introduced a very effective planning process, the Master Leasing Plan (MLP), which takes into account and addresses the potential impacts of proposed leasing on adjacent conservation lands and protected resources. However, not all BLM Field Offices have embraced the MLP process. In July 2014 the Coalition sent a letter to the Secretary of the Interior advocating for the consistent use by BLM of the Master Leasing Plan process when contemplating oil and gas leasing near national parks. Now, as planning for proposed leasing moves forward at a number of BLM-managed areas adjacent to national parks, we continue to monitor those activities and participate in the respective planning processes through the submission of written comments and through collaboration, as appropriate, with other highly capable national and regional conservation groups that are focused on this issue.
Proposed Pipelines-through-Parks Legislation
The Mineral Leasing Act, as amended, requires specific Congressional approval before an oil or gas pipeline can be built through any unit of the National Park System. However, the proposed National Energy Security Corridors Act, which is currently under consideration in Congress, includes an amendment that would eliminate the Congressional approval requirement and thereby promote the construction of natural gas pipelines through parks. The Coalition and other conservation groups are working together to oppose the pipelines-through-parks amendment and will continue to monitor both the House and Senate versions of the bill. Most recently, we submitted a joint letter to the House Natural Resource Committee opposing the pipelines-through-parks provision in H.R. 2295, the House version of the Act.
Proposed Transfer(s) of Public Lands to States
Over the past few years, a movement in western states to “take back” federal lands has been gaining support, fueled, in part, by the anti-federal government sentiments personified by the recent illegal occupation of Malheur National Wildlife Refuge. Much of the legislative activity has occurred at the state level, including a variety of laws and resolutions that are essentially symbolic in nature. In March 2015, the U.S. Senate passed a budget amendment sponsored by Sen. Lisa Murkowski, R-Alaska, the Chair of the Energy and Natural Resources Committee, supporting the idea of selling, transferring or trading federal lands to the states. The amendment did not require any specific actions, but sent a clear signal that Congress is willing to consider such bills and attach them as riders to larger bills. The Coalition is opposed to any legislation that would turn over large parcels of federally-managed public lands to state control, especially those lands adjacent to or within units of the National Park System. We will continue to collaborate with other conservation groups to monitor new legislative initiatives that could include amendments related to transfer of public lands to the states and take action, as appropriate, to oppose such legislation.
R.S 2477 Claims
An 1866 federal mining law (R.S. 2477) included language that allowed roads to be built on federal lands for the purpose of the public “crossing the country.” This outdated legislation was repealed in 1976 and federal agencies, such as the NPS, have since taken steps to restrict or manage off-highway vehicular use of some of these routes in order to better conserve and protect natural resources. Since then, there have been numerous “R.S. 2477 claims” filed by western states and counties against federal agencies alleging that continued public use of the closed routes is still protected under the obsolete law. The Coalition considers the ongoing R.S. 2477 claims to be a serious threat to the ability of the NPS to manage its parks consistent with the NPS Organic Act. A Utah case involving a state law requiring “property disputes” to be brought forward within 7 years of when they accrued has reached the Utah Supreme Court. Conservation groups assert that the law’s 7-year statute of limitations applies to R.S. 2477 claims, which, if true, would be grounds for dismissing R.S. 2477 claims filed after 1983. The state and two Utah counties argue that the law does not apply to R.S. 2477 claims. The Coalition has collaborated with Park Rangers for Our Lands to file an amicus curiae brief with the Utah Supreme Court that addresses the impact of R.S. 2477 claims on federal public lands. Oral arguments before the court are scheduled in April 2016, with a decision expected later this year.
Tennessee Lands Unsuitable for Mining
The State of Tennessee petitioned the U.S. Office of Surface Mining Regulation and Enforcement (OSMRE) to designate as “unsuitable for mining” over 67,000 acres of state-designated conservation lands in northeastern Tennessee. The proposal would provide a variety of conservation benefits, including improved water quality and protection of riparian habitats, for the conservation lands and for two units of the National Park System that lie downstream of the petition area: Big South Fork National River and Recreation Area and Obed Wild and Scenic River. The Coalition submitted written comments to OSMRE strongly supporting the State’s petition; and will continue to participate in this issue until its conclusion.
Working on a Landscape Scale
Increasingly the National Park Service has recognized the interrelationship and connectivity of park resources within the larger landscape. Scaling up the work of the NPS to address challenges to natural and cultural resources from urbanization, extreme weather, and climate change is critical. National Trails, National Heritage Areas, and partnership parks are just some examples of this approach. Program legislation for National Heritage Areas has been a legislative priority for the NPS and a bill with bipartisan co-sponsorship already been introduced in the House (H.R. 581). The Coalition supports H.R. 581. Also important is the Administration’s interagency Collaborative Landscape Planning proposal. The FY 2017 budget proposal would use a portion of the LWCF fund to support this initiative. The Secretaries of the Interior and Agriculture have evaluated and proposed landscapes for investment in the collaborative landscape planning process. Seven landscapes have been selected for discretionary and mandatory funding in 2017: Florida-Georgia Longleaf Pine; High Divide in Idaho and Montana; Island Forests at Risk in Hawaii; National Trails in California, Hawaii, Idaho, Montana, Oregon, and Pennsylvania; Pathways to the Pacific in Oregon and Washington; and Rivers of the Chesapeake. Many of the seven landscapes contain park units, trails, and heritage areas within the NPS portfolio. The Coalition can play a role by supporting these appropriations and assessing the impact of major projects proposed within these landscapes.
National Park SYSTEM-wide Issues
These are broad service-wide issues, often based on Congressional action (such as legislation or appropriations), that could likely impact many parks if not the entire National Park System. The Coalition may collaborate with other advocacy groups in presenting a coordinated response, or may respond independently from its unique perspective as the “Voices of Experience” regarding park management matters.
NPS Appropriations and Centennial Legislation
The Consolidated Appropriations Act of 2016 (H.R. 2029) provided increases to the NPS budget for FY16, an important step in addressing long-term NPS funding needs. In addition, the proposed National Park Service Centennial Act (Act) includes a number of provisions important to the NPS. The Act would:
- Establish the “National Park Centennial Challenge Fund” to support NPS construction, maintenance, and education projects by matching private contributions with federal dollars. NPS funding for this program would come, in part, from an increase in the cost of the lifetime senior pass and a new senior annual parks pass.
- Establish the “Second Century Endowment for the National Park System,” an endowment at the National Park Foundation. Only a percentage of the principle could be expended for approved NPS projects.
- Protect NPS “intellectual property” and allow the Secretary of the Interior to enter into agreements for the creation of reproductions of NPS museum objects. Funds collected from this program would be used at the park where the museum object(s) are held.
- Provide clear authority and direction for NPS interpretation and education programs by consolidating a number of disparate authorities and directing the agency to expand the availability and utilization of the highest quality interpretation and education programs.
- Raise the upper age limit for participation in the Public Lands Corp from 25 to 30; and expand the non-competitive hiring status afforded to former Public Land Corps members from the current 120 days to two years after the member’s service is completed.
- Lift the existing $3.5 million authorization ceiling for the NPS Volunteers in the Parks Program.
- Modify the roles of the Secretary of the Interior and the NPS Director to that if ex officio members of the National Park Foundation board and authorize appropriations of $25 million for the Foundation while limiting the use of these funds to non-administrative expenses.
The Coalition is actively working with partners as part of the Second Century Coalition to support the Centennial legislation.
Government Accounting Office Report on NPS Funding and Revenues
In April 2014, a trio of U.S. senators asked the Government Accountability Office (GAO) to review the NPS’s administrative structure and Recreation Fee program, and to identify ways in which NPS could reduce its ever-growing deferred maintenance backlog. During the review, the Coalition provided information to GAO about NPS funding distribution priorities, needs and trends. In its report published in December 2015, GAO found that NPS’s total funding did not keep pace with inflation for Fiscal Years 2005 – 2014, even with increases in revenues from fees and donations. In order to help NPS improve management of recreation fees, GAO recommended that Congress amend the Federal Lands Recreation Enhancement Act (FLREA) to allow federal agencies to adjust the price of a lifetime senior pass; GAO also recommended that NPS revise its guidance on recreation fees so that the agency periodically reviews its entrance fees to determine whether the fees are reasonable, and that individual park units provide information to NPS headquarters on why they are choosing to not increase entrance fees or increase them by an amount less than the fee schedule. NPS has replied that it intends to comply with the GAO recommendations. The Coalition will continue to monitor this issue as it progresses.
The current Congress continues to play an assertive role in the oversight of Federal agencies, including the NPS. Potential targets of oversight hearings include almost anything from broad service-wide issues (such as the budget, deferred maintenance backlog, and policy issues) to individual park management decisions, and sometimes even NPS actions taken related to field activities such as law enforcement and resources management. The Coalition will monitor oversight committee activities, communicate with NPS and others as needed, and collaborate with other conservation groups as appropriate to support the adherence of NPS to a long-term pattern of consistent decision-making based on the best available science and applicable laws, regulations, and policies.
In recent years many factors have contributed to making NPS employee morale among the lowest of any Federal agency. The Coalition firmly believes that improving career opportunities and benefits for experienced seasonal and temporary employee would be a step in the right direction and would correct the longstanding absence of a clear gateway to career employment with the NPS. Toward this end, in the past year the Coalition submitted written comments to the Office of Personnel Management in support of a proposed rule that would extend the Federal Employee Health Benefits Program to Federal employees working full-time on temporary appointments and to certain employees on seasonal and intermittent schedules; and sent letters to House and Senate committees in support of the proposed Land Management Workforce Flexibility Act, which would provide a clear and direct career entry path for experienced temporary employees to transition into the permanent workforce. The Coalition will continue to support laws, regulations, and policies that would contribute to the development and retention of a well-qualified workforce.
Growing the National Park System
Recent actions by the President to create more national monuments as authorized by the Antiquities Act (the Act) has – as in the past – invited critical comment, as well as proposed legislation to constrain the President’s authority to create new national monuments under the Act. Common criticisms include diluting the quality of the system, overextending an already inadequate budget, and the perceived, by some, lack of Congressional involvement and support in the monument designation process. The Coalition supports well-reasoned and highly selective additions of new park areas to the System, as described in an August 2015 op-ed posted on our website. We will continue to work with other park advocacy groups to provide information to members of Congress and others about how the park system has been constructed over the past century, with special emphasis to the benefits that can result from appropriate additions to the National Park System.
Historic Preservation Fund Reauthorization
Created in 1976, the Historic Preservation Fund (HPF) derives its funding from Outer Continental Shelf leases rather than tax-payer dollars. The HPF achieves its preservation mission of documenting, preserving and utilizing America’s legacy of historic sites by providing funding to State and Tribal Historic Preservation Officers and through, at times, competitive grants to identify and rehabilitate historic resources. The authorization of the HPF expired on September 30, 2015. While there are several legislative proposals to reauthorize the fund, Congress has been slow to act. On a promising note, Section 5003 of the bi-partisan Energy Policy Modernization Act of 2015 (S. 2012), which is moving forward in the Senate, would permanently reauthorize the HPF. It is hoped that Senate action will take place soon and help spur House action to continue this important program. The Coalition is actively supporting reauthorization of the HPF through collaboration with like-minded historic preservation organizations and outreach to Congress.
Hunting in Parks
The “Bipartisan Sportsmen’s Act of 2016” (S. 659) proposes to open more Federal lands to hunting, shooting, and fishing. While many of its provisions do not apply to units of the National Park System, since hunting and shooting are prohibited in most parks, the legislation would specifically authorize people to carry and transport bows and crossbows on and through NPS lands, a significant change from the current prohibition. The bill was reported by committee in January 2016, but has not yet come up for a vote on the Senate floor. It remains to be seen what amendments, if any, may be added to the bill that could adversely impact parks. The Coalition will monitor this legislation and advocate for the exclusion of parks from any expansion of hunting or shooting activity on park lands should such action appear needed.
At least two NPS concessioners have either applied for, or received, copyrights from the U.S. Patent and Trademark Office for the use of national park names or names of features or facilities within national parks. The concessioners assert that their trademark-controlled use of the names have significant economic value that must be considered by NPS when negotiating contract issues, such as buy-outs, with the respective concessioner. This complex topic has received national attention in the ongoing legal battle between the National Park Service and Delaware North over trademarks to iconic place names in Yosemite National Park. When it lost its bid for a new concession contract to another operator, Delaware North insisted on $51 million in compensation for the trademarks it had previously obtained without NPS knowledge, and asserted that the trademarks gave them the exclusive commercial use of the names of well-known NPS-owned facilities. While the Yosemite case will inevitably play out in the court system, the underlying ambiguity of who owns the rights to the names of features and publicly owned facilities in national parks could impact other units of the National Park System. The NPS is working diligently with its legal advisors to resolve this complex, multi-faceted issue. The Coalition believes that the names of iconic park features and publically owned facilities belong to the American people and should not be allowed to become trademarked for the exclusive use of for-profit operators. We have gathered background information and will continue to monitor this situation.
Native American Collecting Regulations
In April 2015 the NPS issued a proposed rule that would allow Native American tribes to collect and remove certain plants and plant parts from national parks for traditional uses, a reversal of the existing 1983 regulation that generally bans collecting of park resources by anyone. The final rule is yet to be published. While the Coalition supports, in concept, the intended policy goal underlying the proposal, we oppose the Proposed Rule itself. Our opposition was set forth in detail in our written comments on the Proposed Rule. Our concerns are based largely on our belief that the proposed gathering activities clearly conflict with the conservation mandate expressed in the NPS Organic Act and the Redwoods amendment. We assert that creating the authority for NPS to allow the proposed gathering activities requires a change in statute, not merely a regulatory amendment. In addition, the rule, as proposed, contains inadequate guidance to ensure that the NPS could manage such plant gathering activities on a consistent, service-wide basis. The Coalition will continue to monitor and comment on the issue as it progresses.
These are typically issues related to management plans, special regulations, park-specific legislation, or other policy-based actions with the potential to negatively impact park resources and values. Because our capacity to engage in park-specific issues is limited, the Coalition is necessarily selective in deciding, in accordance with our criteria, which park-specific issues to engage. The Coalition has previously taken actions on the following issues. We anticipate continued involvement during 2016.
Big Cypress National Preserve Management Plans and Wilderness Studies
Recent management plans at Big Cypress have mischaracterized the Preserve’s enabling legislation as a “multiple use management” requirement, an unprecedented directive for a unit of the National Park System that is clearly at odds with the “conservation mandate” of the NPS Organic Act of 1916 and has significant implications for other units of the National Park System. Foremost among the offending plans at Big Cypress was the highly controversial 2011 General Management Plan/Wilderness Study/Off-road Vehicle Management Plan for the Addition lands, which opened large portions of the Addition to off-road vehicle use that had previously been closed and significantly reduced the amount of eligible wilderness that had previously been identified. The NPS plan was upheld in U.S. District Court and an appeal of that decision is now pending before the 11th U.S. Circuit Court of Appeals where the Coalition has submitted an amicus curiae brief in support of the earlier lawsuits brought by other conservation organizations. Pending the resolution of that case, the Coalition has commented on other recent planning documents that continue to incorrectly portray the Preserve’s enabling legislation as a “multiple use management” requirement.
Cape Hatteras National Seashore – Off Road Vehicle (ORV) Management
After more than 30 years of non-compliance with ORV management requirements, the NPS completed an ORV management plan (2010) and special regulations (2012) that minimize the impacts of recreational ORV use on beach nesting wildlife and provide more diverse opportunities for pedestrians to experience a vehicle free beach. The Coalition participated in an advisory committee that provided ORV management advice to NPS, but was unable to reach a consensus recommendation. The subsequent ORV plan was a step in the right direction but highly contested by ORV groups. The plan withstood legal challenge, but then ORV supporters were successful in pushing through a “Cape Hatteras amendment” in the National Defense Authorization Act for 2015. The bill required NPS to “review and modify” (i.e., reduce) the size and duration of that protect beach nesting birds and sea turtles and to consider other changes in the final ORV rule that would increase ORV access at the Seashore. The NPS recently conducted, and the Coalition commented on, two separate planning processes to comply with these requirements. We will continue to monitor the issue and advocate for science-based decision-making that is conducted in accordance with applicable laws and NPS policies.
CCC / WPA Theme Study
Between 1933 and 1942 the Civilian Conservation Corps (CCC) planted nearly eight billion trees; halted and reversed erosion; constructed buildings, roads, bridges, and trails in nearly 800 local, state, and national parks and forests; provided a healthful environment and gainful employment for more than three million young men of all races and creeds in every state and territory and put food on the table for their families; was the most popular program of President Franklin D. Roosevelt’s New Deal; and is remembered by many as the best federal youth program of all times. Between 1935 and 1943 the Works Progress Administration (renamed Works Projects Administration in 1939 and hereinafter WPA) provided subsistence with dignity to almost eight million unemployed workers creating public works during the depths of the Great Depression, significantly including important works of art. Although evident in places throughout the nation, nowhere is this great story preserved and interpreted in a unit of the National Park System dedicated to the subject. Coalition members and others are encouraging NPS to study the “theme” of the CCC and the WPA in American history in order to identify places that meet new NPS criteria of significance, suitability, and feasibility and to recommend the best places representing this theme for addition to the National Park System.
Colonial National Historical Park – James River Transmission Line Proposal
The Coalition has joined the fight in opposing Dominion Virginia Power’s proposed new high-voltage transmission line across the James River near historic Jamestown. The proposal includes 17 huge transmission towers, as tall as the Statue of Liberty and topped with flashing red lights, that would cross the river within view from various historic properties. The U.S. Army Corps of Engineers (USACE) is the permitting authority for the proposal and has not yet decided what level of National Environmental Policy Act (NEPA) compliance is needed to evaluate the potential impacts of the project. Recent Coalition actions have included: writing the decision-maker at USACE to oppose the project; and joining forces with conservation and historic preservation groups to support legislation in the Virginia House of Delegates that would better protect historic resources by strengthening the State’s requirements related to approval of new high voltage transmission lines. The Coalition will continue to monitor the issue and collaborate with like-minded organizations to advocate for the preservation of the scenic vistas surrounding the site of America’s first permanent English colony.
Colorado National Monument – Professional Bicycle Race
Since 2010, the NPS has appropriately resisted local community and political pressure and declined to issue a special use permit that would allow a professional bicycle race, the USA Pro Challenge, along the park’s historic Rim Rock Road. The commercial race and all the logistical and media support activities associated with it, if held on the park’s primary road, would be highly disruptive to park visitors and likely cause a variety of resource impacts. In the past, the Coalition has actively supported the park superintendent’s decision to deny the requested permit. Local organizers continue to periodically resurrect the idea of hosting the race, most recently in 2016; however, these recent efforts have been deferred until 2017. The Coalition will monitor this issue and continue to encourage and support the NPS denial of a special use permit to hold a commercial bike race in the park.
Grand Canyon National Park – Tusayan Roadway Easements
In June 2015, the Coalition, along with over 200,000 other commenters, strongly opposed a permit request from the Town of Tusayan and a commercial development corporation (Stilo Development Group USA, LP) for an easement to improve roads through Kaibab National Forest (KNF) near Grand Canyon National Park (GRCA) in Arizona. The proposed roads and other improvements would have enabled the construction of over 2,000 dwelling units and 120 acres of commercial development on currently undeveloped land just a stone’s throw from the park’s popular South Rim. Citing strong opposition to the proposed development, Kaibab National Forest recently announced its decision to deny the road easement request. This decision, while heartening, likely does not spell the end to such challenges to the well-being of GRCA, as other commercial development and resource extraction schemes remain a possibility on lands surrounding this iconic national park. The Coalition will continue to monitor these threats both through official processes and, equally importantly, through the eyes and ears of our members.
Grand Teton National Park – Moose-Wilson Corridor Management Planning
The National Park Service (NPS) has been working toward creating a shared vision for managing the Moose-Wilson corridor in Grand Teton National Park, while receiving significant external pressure to increase the level of road and trail development along the quaint, but popular, road that runs through increasingly important wildlife habitat. In October 2015 NPS issued the Draft Moose-Wilson Corridor Comprehensive Management Plan/Environmental Impact Statement (DEIS), which identified the NPS preferred alternative as one that would limit further development, manage use at current levels, and protect wildlife habitat. The NPS proposal has resulted in intensified local and regional pressure from developers and state politicians calling for NPS to reverse course and give more weight to a more aggressive development approach to managing the road corridor. The Coalition has participated in the planning process since its inception, submitting comments each time the opportunity presented itself; and also prepared an op-ed piece for publication in the local news media. We have consistently advocated for the conservation of important wildlife habitat while allowing well-managed visitor use along the Moose-Wilson corridor. We support the NPS preferred alternative and will continue to participate in this planning process as it moves forward with the goal of assuring that preservation of park values and park resources is given the highest priority when final decisions are made.
Grand Teton – Applicability of Hunting Regulations on Private Property within the Park
For decades wildlife management on about 950 acres of private land within Grand Teton National Park boundaries was subject to NPS regulations, which meant that all hunting, with the exception of legislatively authorized hunting of elk, was prohibited. These policies are consistent with many years of legal precedence, including several court decisions, for NPS regulation of hunting on private lands within other parks. By virtue of a reinterpretation of regulations at Grand Teton, NPS leaders have recently decided that NPS hunting regulations should no longer apply on private land within the park. As a result, hunting of wildlife on private property within the Grand Teton boundary is now considered by NPS to be under the jurisdiction of the Wyoming Game and Fish Department. This means that state-sanctioned hunts for bison, mountain lions, mule deer, waterfowl and other game may soon be permitted. The Coalition will continue to monitor the issue and evaluate options for constructive engagement.
Yellowstone and Grand Teton National Parks – Proposed River Paddling Legislation
For many years, the majority of rivers and streams in Yellowstone and Grand Teton National Parks have been closed to recreational paddling in order to preserve these corridors in a pristine condition, and to provide relatively undisturbed wildlife habitat and wildlife viewing opportunities for park visitors. In recent sessions of Congress, legislation has been introduced that would force the National Park Service to open many of these rivers and streams to recreational paddling. Most recently, the Yellowstone and Grand Teton Paddling Act (H.R. 974), supported by pro-paddling advocates, would direct the Secretary of the Interior to promulgate regulations to allow the use of hand-propelled vessels on certain rivers and streams that flow in and through the two parks, was reported by House Committee in October 2015 and awaits consideration by the House. The Coalition has collaborated with other conservation groups to oppose previous versions of the legislation; and will continue monitor the issue and remain vocal in our concerns.
POTENTIAL STRATEGIES FOR COALITION ENGAGEMENT
Many of the issues we engage in involve review, analysis, and comment on proposed management plans, regulations, or legislation that would directly impact one or more units of the National Park System. In addition to formal comments, the Coalition has long chosen from a variety of communications tools to educate policy makers, stakeholders, and the public on national park issues. News releases, op-ed articles, interviews, and other news media contacts can be especially effective, especially when park issues potentially impact park users. The Coalition has retained the Hasting Groups public relations firm to assist in creating and distributing media materials. Social Media (Facebook and Twitter) are increasingly used to share our concerns. Meetings and letters to Department of the Interior and National Park Service officials, members of Congress and their staffs, and others, can sometimes be the most effective strategy to express our concerns. Often, but not always, we join with other stakeholders and advocacy groups toward achievement of our common goals. All of the above involve actions taken on behalf of the Coalition as a whole; and, of course, from time to time we encourage our membership to individually participate in letter writing and other forms of advocacy from all members of the Coalition.