February 2, 2023
Denver Service Center
National Park Service (NPS) Planning, Design and Construction Management Office
12795 West Alameda Parkway
Lakewood, CO 80228-2838
Subject: Comments on NPS National Long Range Transportation Plan
Dear Denver Service Center:
I am writing to you on behalf of the Coalition to Protect America’s National Parks (Coalition). Our membership is comprised entirely of National Park Service (NPS) retirees, former and current employees, and NPS volunteers, 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.
First, we applaud the NPS for looking strategically towards the future of transportation within units of the National Park System. It is obvious that with increased visitation and the need to address in-house sources of carbon emissions that contribute to climate change, such a strategy is necessary. We believe this national strategy and any further visitor use management planning related to it is key to implementing the direction and mandates established in NPS management planning documents, respective park units’ enabling legislation, and NPS policy and law.
Second, we strongly recommend that this planning process be guided by the guiding principles of the NPS Organic Act. (Text below excerpted from Section 1.4.1 of NPS Management Policies 2006.)
The most important statutory directive for the National Park Service is provided by interrelated provisions of the NPS Organic Act of 1916 and the NPS General Authorities Act of 1970, including amendments to the latter law enacted in 1978. The key management-related provision of the Organic Act is as follows:
[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 Redwood amendment added the following two sentences to the General Authorities Act provisions:
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 the NPS to ensure that cultural and natural resources and “superlative environmental quality” are protected from derogation and to create a Long Range Transportation Strategy that sustains resource integrity and accommodates quality visitor experiences.
In addition, we offer the following comments in response to the specific Topic Questions listed on the Project website (https://parkplanning.nps.gov/document.cfm?parkID=415&projectID=113120&documentID=124896).
- From your perspective, what are the key transportation challenges for the National Park Service in the near and long-term?
The key challenges relate to funding the creation of new or updating of current transportation options for National Park Service (NPS) units. Not one option or form of transportation will work for all NPS units. While in one unit, a shuttle bus system will make sense and can be efficiently operated, in others, this may not be the case. Specific activity focused bus systems to trailheads, for example, may be more useful and reduce the need for additional parking areas. Funding must be tied to scientifically based visitor use monitoring and rigorous planning efforts where thoughtful considerations, such as parking availability, bus infrastructure potential, partnership possibilities, and connectivity to support services through park apps. These factors need to be weighed to determine what is best for each unit. NPS wide goals and objectives should drive decisions related to reduction of fossil fuel-based systems, which also will require the ability to establish or expand the infrastructure, such as for EV charging stations, Overall the NPS, needs to support and fund more climate friendly transportation options. Improving the flexibility of program funding coupled with more streamlined processes to financially support unit transportation needs is vital. Financial support will be needed annually to operate and maintain these transportation systems and has not been available in the past for parks attempting to engage in new transit systems. Developing national partnerships that could support improved infrastructure or climate friendly fleets would benefit all NPS units.
- How should the National Park Service measure progress towards its priorities of protecting the climate, enhancing visitor experience, as well as reinvesting in the system?
To promote adaptive management strategies as the planning process progresses, we encourage the NPS to establish scientifically based and peer-reviewed indicators, standards, and thresholds for measuring emission reductions, visitor experience, and resource conditions in critical areas where transportation options are needed or in operation. Resource impact and effectiveness monitoring will ensure success and public credibility as the Long-Range Transportation Strategy is implemented and will help determine if more complex strategies are needed in the future.
- How can the National Park Service improve access for traditionally underserved or underrepresented groups?
Developing transportation systems that seamlessly link all regional communities to park units is vital to addressing this issue. A combination of creative marketing of transportation options far outside NPS units, as well as development of connectivity options will be necessary to accomplish this. Local gateway communities already are implementing extensive global marketing to promote NPS units. This type of focus also should be given to traditionally underserved and underrepresented groups. Information about transportation options from doorstep to park units needs to be developed and shared. NPS infrastructure, public information, interpretive programming, and focused activities need to be improved to provide a more welcoming, inclusive experience. Ensuring the NPS is at the table when state, county, and city transportation planning is critical to the success of all these factors. The use of the NPS Rivers and Trails Conservation Assistance (RTCA) would be important to the success of building more inclusion for traditionally underserved and underrepresented communities.
- What strategies should the National Park Service consider to better integrate with state/local transportation systems and seamless access to gateway communities?
Developing state/local relationships is vital for any park manager. The NPS could encourage and improve integration through grant programs focused on partnering to develop regional transportation systems that support not only park visitors, but community members and visitors to other local recreation attractions. While some states provide such grant programs, they are limited in scope. The NPS needs to better promote how working with park units would be of benefit to such entities as tourism boards. Ensuring the NPS is at the table when state, county and city transportation planning is critical to the success of all these factors. The use of the NPS RTCA would be critical to the success of this integration.
- What emerging challenges or opportunities in transportation warrant additional focus or investments?
The Coalition cannot emphasize enough the importance of funding flexibility and streamlined processes. This not only includes flexible, streamlined funding guidance, but also working with each unit to develop the best strategy for apportioning of entrance fee revenues that makes the most sense to support park operations and transportation services. Improving the efficiency of contracting also will help to complete infrastructure improvements in support of more climate friendly fleets. Developing national partnerships that could support improved infrastructure or climate friendly fleets would benefit all NPS units. Improving the efficiency of NPS purchasing and contracting also will help to complete infrastructure improvements in support of more climate friendly fleets. For example, purchasing an electric bus can now take years to get one operating in a park.
- What approaches should the NPS take to meet its mission to protect the climate and advance resource protection?
Develop clear goals and objectives to reduce private vehicle use in park units where possible. Develop clear goals and objectives that direct NPS units towards climate friendly shuttle systems over parking lot expansions while ensuring current parking areas are retrofitted to reduce off road parking impacts. This not only means flexible funding for transportation options, but also ensuring park staffing is adequate to manage vehicle traffic issues. Developing national partnerships that could support improved infrastructure or climate friendly fleets would benefit all NPS units.
- What approaches should the NPS take to meet its objective to enhance visitor experience and connect diverse communities?
The Coalition cannot emphasize enough the importance of funding flexibility and streamlined processes. This not only includes flexible, streamlined funding guidance, but also working with each unit to develop the best strategy for apportioning of entrance fee revenues that makes the most sense to support park operations and transportation services. Improving the efficiency of NPS purchasing and contracting also will help to complete infrastructure improvements in support of more climate friendly fleets. The use of the NPS RTCA would be critical to the success of enhancing visitor experience and building more inclusion for traditionally underserved and underrepresented communities by providing the additional support needed for park units.
- What approaches should the NPS take to reinvest in its transportation system and make legacy investments?
Developing national partnerships that could support improved infrastructure or climate friendly fleets would benefit all NPS units. Thorough reconsideration and adjustment of NPS FLREA guidance, including apportionment of park entrance fees, needs to be reviewed and adjusted. Parks cannot continue to be blocked in their efforts to manage park operations efficiently by funding guidance that hampers unit level creative management. This may require consideration of the raising of entrance fees and more creatively tiering entrance fees to provide more investment potential. The Coalition cannot emphasize enough the importance of funding flexibility and streamlined processes. This not only includes flexible, streamlined funding guidance, but also working with each unit to develop the best strategy for apportioning entrance fee revenues that makes the most sense to support park operations and transportation services. Improving the efficiency of NPS purchasing and contracting will also help to complete infrastructure improvements in support of more climate friendly fleets.
In closing, we appreciate the opportunity to comment on this important plan.
Sincerely,
Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks
2 Massachusetts Avenue, NE, Unit 77436
Washington, DC 20013
(202) 819-8622