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January 15, 2024

Charles Sellars
New River Gorge National Park and Preserve
National Park Service
Post Office Box 246
104 Main Street
Glen Jean, WV 25846

Re: Excess Structures and Deferred Maintenance

Dear Superintendent Sellars:

I write to you on behalf of more than 2,500 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 National Park Service (NPS) directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

We offer the following scoping comments regarding the demolition of 35 dilapidated and excess structures with 21 of these structures either listed or eligible for the National Register of Historic Places. We appreciate the New River Gorge National Park and Preserve (NRGNPP) effort to carefully evaluate the proposal and conduct a public process for a final decision.

As former National Park Service (NPS) employees, we realize the dilemma parks face regarding the deferred maintenance backlog and lack of funding to carry about rehabilitation and cultural resource protection needs. NPS’s growing $22.3 billion deferred maintenance backlog restricts the agency’s ability to carry out its mission to conserve our national parks and provide a safe and quality visitor experience. It also puts the NPS in an untenable position to make hard choices.

The lack of adequate funding by Congress has been a major roadblock to keeping our park’s infrastructure in good condition. Also, the lack of adequate funding for general park operations adds to the crisis. NPS staff capacity has declined by 15 percent over the last ten years and is at a critical tipping point. Increasing visitation and declining staff resources are in an untenable position. For years, our national parks have been trying to manage dramatically increasing visitation with inadequate operating budgets and staff reductions in parks, program offices, as well as regional and central offices.

As the NPS continues with its planning processes for this proposal at New River Gorge National Park and Preserve, we urge you to ensure that the National Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA) are fully implemented and public voices are heard prior to making final decisions about the 21 structures that are listed in or eligible for listing in the National Register of Historic Places. Consultation with the State Historic Preservation Office (SHPO) and documentation of these eligible historic structures also must be fully documented as required by NPS policy and law.

Phil Francis signature.



Phil Francis
Coalition to Protect America’s National Parks