September 06, 2019

Phyllis Green, Superintendent
Isle Royale National Park
800 East Lakeshore Drive
Houghton, MI 49931

Subject:  Comments on ISRO Nonwilderness Cultural Resource Management Plan and Environmental Assessment

Dear Superintendent Green:

I am writing on behalf of over 1,700 members of the Coalition to Protect America’s National Parks (Coalition), a non-profit organization composed of retired, former, or current employees of the National Park Service (NPS). The Coalition studies, educates, speaks, and acts for the preservation of America’s national park system. As a group we collectively represent over 40,000 years of experience managing and protecting America’s most precious and important natural and historic resources. Among our members are former NPS directors, regional directors, superintendents, resource specialists, rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

We offer the following comments and observations regarding the Isle Royale National Park (ISRO) Nonwilderness Cultural Resources Management Plan / Environmental Assessment(CRMP).  First, we commend the NPS staff and others involved in preparing the CRMP. Within the constraints of its identified scope, the document presents a thorough and thoughtful treatment of the issues and possible alternatives. However, we are deeply concerned by the decision to omit consideration of the cultural resources contained within the portions of the park designated as wilderness. Given that this applies to 132,018 acres, or nearly 99 percent of the park’s land area, we consider this decision short-sighted.

Managing cultural resources within a wilderness area presents the NPS with a particularly sensitive challenge. The mandates of the Wilderness Act—to manage an area in such a way to present the impression that “…The earth and its community of life are untrammeled by humanswith the imprint of humans’ work substantially unnoticeable would seem in direct conflict with the preservation of cultural resources. However, a July 2018 U.S. Court of Appeals for the Ninth Circuit ruling involving historic cabins in the Olympic National Park wilderness established conclusively that wilderness management policies do not override NPS responsibility for historic preservation (Wilderness Watch v. Sarah Creachbaum, 3:15-cv-05771-RBL).

This ruling provides clarity to the agency’s dual responsibilities under the National Historic Preservation Act and the Wilderness Act in parks like Isle Royale where wilderness areas contain significant cultural resources. We understand satisfying the requirements of both statutes can be challenging, though not impossible, to discharge; and clearly requires careful planning and attention to all facets of human and natural environment. However, we have seen numerous occasions throughout the national park system where the highly specific requirements of the Wilderness Act, combined with the agency’s ever- present shortfalls of maintenance funds, have worked to the severe detriment of the cultural sites and structures within the wilderness boundaries.

Recent scholarship by environmental historians such as William Cronon, James Feldman, and Laura Watt have examined this challenge in detail at parks such as Point Reyes National Seashore and Apostle Islands National Lakeshore. As Cronon wrote about  Isle Royale’s Lake Superior neighbor,

If visitors come here and believe they are experiencing pristine nature, they will completely misunderstand not just the complex human history that has created the Apostle Islands of today; they will also fail to understand how much the natural ecosystems they encounter here have been shaped by that human history.

This concern applies equally to Isle Royale, where natural forces and human history are entwined throughout the entire park, not just the small portion outside the wilderness boundary. Omitting sites and structures within wilderness from consideration in this plan runs a substantial risk that these resources will be treated as afterthoughts in future management plans. Instead, the CRMP should provide clear and affirmative guidance from the start to ensure that the park’s full spectrum of cultural resources will be preserved and managed unimpaired. We urge that the planning team develop an alternative that accomplishes this goal.

Thank you for considering these comments.  Please let us know if we can be of further assistance.





Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks