January 24, 2023
Superintendent Clayton Jordan
Sequoia and Kings Canyon National Parks
47050 Generals Highway
Three Rivers, CA 93271
Subject: Comments on Visitor Access Management Plan for Sequoia and Kings Canyon National Park
Dear Superintendent Jordan:
I am writing to you on behalf of over 2,300 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 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.
The purpose of this letter is to comment on the early stages of the Visitor Access Management Plan for Sequoia and Kings Canyon National Parks (SEKI). Our comments focus on Question 3 and also provide additional thoughts on monitoring the effectiveness of visitor use strategies.
On behalf of our members and followers, we applaud SEKI for beginning this effort towards a much-needed Visitor Access Management Plan. As users of SEKI, we appreciate the thoughtful work the park has done over the years to improve the visitor experience while protecting park resources, including the work done to restore Giant Forest. Since this is a plan focused on the front country, we support any combination of strategies focused on peak usage times, which the park has identified as weekends, holidays, and the winter season. Strategies could include timed entry, day-use reservations, and expansion of the already successful shuttle service to other busy front country areas, especially Grant Grove.
We encourage the park to create opportunities for adaptive management strategies as new information is collected on the effectiveness of these strategies. We encourage SEKI to develop established capacities to ensure desired conditions of fundamental resources and values are maintained at set thresholds. As a group dedicated to concerns regarding national parks, we encourage the planning process to develop effectiveness monitoring as part of the Visitor Access Management Plan.
We hope that this planning process will be guided by the founding legislation of the National Park Service (NPS) (text excerpted from 2006 NPS Management Policies):
[The National Park Service] shall promote and regulate the use of the Federal areas known as national parks, monuments, and reservations hereinafter specified… by such means and measures as conform to the fundamental purpose of the said parks, monuments, and reservations, which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations. (16 USC 1). Congress supplemented and clarified these provisions through enactment of the General Authorities Act in 1970, and again through enactment of a 1978 amendment to that act (the “Redwood amendment,” contained in a bill expanding Redwood National Park). The last two sentences of the provision state, “Congress further reaffirms, declares, and directs that the promotion and regulation of the various areas of the National Park System, as defined in section 1c of this title, shall be consistent with and founded in the purpose established by section 1 of this title [the Organic Act provision quoted above], to the common benefit of all the people of the United States. The authorization of activities shall be construed and the protection, management, and administration of these areas shall be conducted in light of the high public value and integrity of the National Park System and shall not be exercised in derogation of the values and purposes for which these various areas have been established, except as may have been or shall be directly and specifically provided by Congress.” (16 USC 1a-1)
As stated in the above text, we strongly encourage SEKI to ensure that cultural and natural resources and “superlative environmental quality” are protected from derogation and to create a Visitor Access Management Plan that sustains resource integrity and accommodates quality visitor experiences.
We appreciate the opportunity to provide comments during this early stage of the planning process.
Michael B. Murray
Chair, Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013