March 3, 2022

The Honorable Deb Haaland
Secretary of the Interior
U.S. Department of the Interior
1849 C Street, N.W.
Washington DC 20240

Subject: Comments on American Conservation and Stewardship Atlas, Docket No. DOI-2021-0016

Dear Secretary Haaland:

I am writing on behalf of over 2,100 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 40,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. 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 about the proposed American Conservation and Stewardship Atlas for your consideration.

The biodiversity of the lands and waters of the United States is outstanding globally, and national parks promote the highest levels of protection of species and ecosystems. Our national parks should serve as core areas or the foundation that anchors the 30 x 30 initiative. It is these areas and their juxtaposition with other existing or newly established conservation areas where we study and compare the dynamic interrelationships between natural/near-natural landscapes and socio-economic processes, with the hope of achieving functioning ecosystems. These special places and the diversity of their ecosystems support our well-being. National Parks are core conservation areas for the nation and exemplify our legacy for future generations.

Conserving the richness and abundance of the nation’s biodiversity is more important than ever under current and changing climate conditions. Actions that ensure species and ecosystems not only survive but thrive can be achieved by focused and collective effort. We recommend that the 30×30 Initiative address the following:

  1. Identify what and where existing conservation areas are located both within and outside of the National Park System and determine their juxtaposition relative to other protected lands (federal, state, local, or private) – This identification process appears to be the primary purpose for the development of the American Conservation and Stewardship Atlas. To further this product, we recommend that you:

• Use the IUCN Protected Areas categories for characterizing the status of all conservation lands and cross walk them with U.S. designations
o Treat National Parks (IUCN Category II and 1b) and Wilderness (IUCN Category 1b) areas (without consumptive/extractive allowances) as core areas
o Identify and map IUCN Category 1a areas, if any.

• Inventory landscape systems across the nation, conduct a gap analysis of ecosystems and identify underrepresented ecosystems in parks or other biodiversity hot spots
 o Identify and map refugia, especially refugia that isn’t currently under federal management or other protective status
o Identify and map critical habitat, especially refugia that isn’t currently under federal management or other protective status
 o Identify and map migration routes, especially refugia that isn’t currently under federal management or other protective status
o Identify and map what species (range and distribution) and ecosystems are at risk and what threatens their existence
o Identify federally permitted activities that threaten or stress any of the above

• Look for ways to geographically connect these areas with nearby established protected areas and prioritize these gaps for protection status or acquisition (i.e., establish conservation corridors between existing protected areas)
• Incorporate State 30×30 plans into the Atlas to the extent that such information is available. Recognize that some states may not cooperate with information sharing; and be prepared to look for alternative sources of information
• Identify all federal, state, and local conservation lands acquired through expenditures of the Land and Water Conservation Fund (LWCF). See map of LWCF-funded places through April 2020:
o Restore and revive the online NPS Crystal Reports to enable users to know whether open space near designated protected areas was acquired as a result of an LWCF grant
o Map these areas and include within the American Conservation and Stewardship Atlas

• Identify sentinel sites for monitoring to detect how ecosystems are changing over time because of climate, human activities, or unexpected events
 o Increase the NPS Inventory and Monitoring (I&M) program by $16M
 o Assure that core areas have a monitoring program in place to measure change
 o Where appropriate, standardize field data collection and modernize data analysis
 o Bring 15 additional units of the National Park System (“parks”) into I&M program
 o Building of the Sentinel Site network will inform and allow for a fully representative set of managers and researchers engaged at private, local, state, and federal field stations and other long-term monitoring sites to expand the map of current sites and refine needs for strategic additions of sentinel sites

2. Protect and restore existing national park biodiversity

• Fix broken lands – many parks are degraded and require restoration (“rewilding”) to be ecologically functional
 o Increase the NPS NRPP program by $1M to support funding for projects that add ecosystem resilience or adapt for or mitigate climate change effects
• Submit wilderness studies to Congress for approval.
• Expand Marine Protected Areas (MPAs) in waters adjacent to coastal and ocean parks (i.e., Olympic NP, Point Reyes NS, and Channel Islands NP). Establish new MPAs in waters adjacent to coastal parks (i.e. Canaveral NS, Acadia NP, Cape Cod NS, Cumberland Island NS, Cape Hatteras NS, etc.)

3. Identify conservation priorities for parks and other biodiversity hot spots

• Create new conservation areas that are not currently protected, especially within Level III of EPA’s Ecoregions
• Using the American Conservation and Stewardship Atlas, identify and create buffers around parks by reducing or eliminating consumptive activities to assure that the core size of the protected area provides maximum ecosystem and/or species protection
• Look for opportunities to establish cross-boundary designated Wilderness on federal lands
• Using the American Conservation and Stewardship Atlas, identify connectivity between conservation units to prevent fragmentation and improve the horizontal and vertical movement of species.
 o Add new lands, and/or designate federal lands (non-NPS) as national monuments (i.e., USFS lands that connects Yosemite NP with Sequoia Kings Canyon NP)
 o Remove stressors on adjacent lands, specifically grazing, harvesting and dewatering

In closing, we greatly appreciate the opportunity to provide comments about the proposed American Conservation and Stewardship Atlas. We look forward to working with you to achieve the goals of the America the Beautiful initiative. If you have any questions or would like to meet with us, please contact us at any time.


Michael Murray signature



Michael B. Murray, Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013