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April 1, 2020

Dear Chairmen Murkowski and Grijalva and Ranking Members Manchin and Bishop,

I am writing to you on behalf of almost 1,800 members of the Coalition to Protect America’s National Parks (Coalition), a non-profit organization composed of retired, former, and 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, cultural, and historic resources.

The purpose of this letter is to comment on S. 2924, the “Bandelier National Park and Preserve Establishment Act,” and to specifically express our strong opposition to provisions in the bill that authorize hunting in a portion of the existing national monument. We believe that these provisions will set a dangerous precedent for the entire national park system.

Generally, we are ambivalent about the proposal to change the name of Bandelier from a monument to a park. As you know, there are well over a dozen different names assigned, for one reason or another, to more than 400 areas administered by the National Park Service. However, in accordance with 54 U.S.C. 100101(b), these sites are part of one national park system and are managed under the same set of Management Policies. Exceptions to general policies are made in both laws, and within the contents of that single book of management policies.

Throughout our careers we appreciated the distinction between national parks, monuments, recreation areas, historic sites, rivers, and other designations. In recent years, however, the lines defining each type of park area have blurred at an accelerating pace as legislators throughout the country have sought to re-designate NPS sites in their districts or states as national parks. We understand the political and economic motivations to take that path. That said, and as we have asserted in every way possible, actions by Congress to create new or expand existing national park areas, no matter their name, should always recognize that increased visitation brings new threats to park resources, and requires more funding to accommodate those changes. As you know, such efforts to increase funding are never fully achieved, and there is no guarantee that Bandelier will fare differently if this bill becomes law.

We strongly oppose, however, the provisions in this bill that would re-designate approximately 4,011 acres of the current Bandelier National Monument as a national preserve even as the rest of the monument is re-designated a national park. This provision weakens the protection of park resources that are now fully protected. We understand the history of adding lands to parks and designating them as preserves to permit hunting and trapping on areas added to the national park or monument. Many of our members worked in Alaska in the 1980’s and were required to manage and explain the often confusing and controversial laws that permitted subsistence and recreational hunting in large portions of park areas throughout the state. We are aware, as well, of efforts to modify the name of all or portions of NPS areas in the “lower 48” to accommodate locally driven desire to hunt and trap. We believe, however, that the proposed changes for Bandelier take this legislative exception too far. In essence, and quite simply, this provision of the bill is an effort to carve a piece of land from a long-protected monument so hunters can hunt there.

One of the criteria that the Coalition applies to decisions whether to engage on a park issue is the extent that a proposed action may serve as a precedent to harm the entire national park system. We believe that the provision in the Bandelier National Park and Preserve Act that authorizes hunting on lands now fully protected meets that threshold. Would passage of this bill result in more efforts to carve out a few thousand or more acres so that hunters can kill game in Yellowstone, Glacier, Big Bend, Shenandoah, or other national parks and monuments?  We are concerned that, over time, the answer may be yes, and that proponents will point to decisions made about Bandelier as a rationale for doing so. For this reason, we strongly urge that all language that would authorize hunting in Bandelier National Monument be removed from this bill.


Phil Francis Signature




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