National Parks Conservation Association, Alaska Wilderness League, Badlands Conservation Alliance, Californians for Western Wilderness, CalWild, Coalition to Protect America’s National Parks, Continental Divide Trail Coalition, Friends of the Boundary Waters Wilderness, Friends of Nevada Wilderness, Glacier Two-Medicine Alliance, Grand Canyon Trust, Minnesota Division of the Izaak Walton League of America, Mountain Mamas, Natural Resources Defense Council, New Mexico Wild, North Fork Preservation Association, Rocky Mountain Wild, San Juan Citizens Alliance, Sierra Club, Southern Environmental Law Center, Washington Wild, Wild Cumberland, Wild Montana, Wyoming Wilderness Association
August 14, 2026
Docket No. NPS-2026-0100
Submitted electronically via public participation portal to: https://www.federalregister.gov/documents/2026/06/15/2026-11958/national-park-service-level-2-wilderness-stewardship-policy-review-directors-order-41#open-comment
RE: National Park Service Level 2 Wilderness Stewardship Policy Review: Director’s Order #41
On behalf of the undersigned organizations and our millions of members and supporters nationwide, please accept these comments regarding the National Park Service’s (NPS) Level 2 Wilderness Stewardship Policy Review: Director’s Order #41 (DO 41).
In this notice, NPS is broadly seeking “information and recommendations regarding whether updates, clarifications, or other revisions to existing wilderness stewardship policy may be appropriate.” However, the June 15, 2026 Federal Register notice provides no context or explanation for why NPS is seeking this information or whether there will be future public comment opportunities should future revisions be proposed. The undersigned organizations therefore take this opportunity to urge NPS maintain and focus on improving implementation of its existing wilderness stewardship policy.
Under DO 41, NPS has reliably carried forward wilderness conservation and stewardship management practices. Wilderness stewardship is essential to fulfilling and upholding the agency’s mission to conserve natural and cultural resources, including some of the most sensitive and diverse areas in the country, while managing the land and its resources to leave them unimpaired for the enjoyment of current and future generations. Wilderness is a place for solitude and primitive backcountry recreation that can offer inspiration and renewal for park visitors. It can be experienced from afar, including looking into iconic national park wildernesses from viewpoints in Grand Canyon National Park to Everglades National Park, and provide solace to Americans in knowing intact wilderness still exists across our nation to be appreciated and enjoyed by current and future generations. It can provide refuge and habitat for wildlife, including rare and imperiled wildlife habitats, protect deep human history and cultural resources, provide clean water and clean air, foster ecosystem and cultural landscape level connectivity, and offer immense opportunities for scientific study. Maintaining wilderness quality lands and wilderness character as natural and wild among competing demands, interests, purposes, and impacts, both within and beyond park boundaries, requires sound stewardship and management. Careful management will both protect these priceless resources and enrich the National Park visitor experience by allowing people to continue to enjoy our nation’s rich natural and cultural history.
The stated purpose of DO 41 is to provide accountability, consistency, and continuity in NPS wilderness stewardship program, and to guide service-wide efforts in meeting the requirements of the Wilderness Act116 U.S.C. 1131-1136. DO 41 clarifies provisions of the 2006 NPS Management Policies through specific instructions and requirements and governs wilderness stewardship actions and plans. DO 41, in its entirety, is important to ensure land managers have adequate direction to best protect park resources, though there are several specific sections of the policy we highlight as critical for NPS to uphold its obligations to the Organic Act of 1916.
I: Section 5, Management and Designations of Wilderness Characteristics
Wilderness stewardship under DO 41 plays a vital role in NPS fulfilling its obligations under the 1916 Organic Act 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.”216 U.S.C. 1, 2, 3, and 4 Specifically, DO 41 supports and upholds park values, including by protecting viewsheds, dark night skies, natural soundscapes, solitude, and natural and cultural resources.
Since the Wilderness Act took effect in 1964, park managers have evaluated all lands administered by the agency for wilderness eligibility and inclusion in the National Wilderness Preservation System (NWPS). As a result, NPS currently stewards approximately 70 million acres—more than any other land management agency–of wilderness quality lands across the country from Glacier National Park to Great Smoky Mountains National Park.
Section 5 of DO 41, Identification and Designation of the Wilderness Resource, sets forth direction for parks in carrying out documented wilderness eligibility determinations through an interdisciplinary approach. This process is critically important for preserving the ability to not only formally protect and steward these lands in the NWPS, but also for upholding and fulfilling the NPS Organic Act to manage the lands to leave them unimpaired for future generations and for visitor use and enjoyment.
The process prescribed in Section 5 directs NPS to first evaluate lands for eligibility based on the statutory definitions of wilderness, relying on and utilizing park foundation documents, general management plans, natural resource plans, and cultural resources plans, in addition to public notification, as a preliminary step in determining lands eligible for wilderness to preserve their wilderness character. This step is best characterized as a general evaluation of park lands. If lands are found eligible, NPS then conducts a more thorough wilderness study for those lands found to possess wilderness character. This step builds on the eligibility assessment to more accurately account for lands possessing wilderness character and includes more thorough investigation such as field work and a public comment and NEPA process, i.e. Environmental Impact Statement (EIS) and Record of Decision (ROD). This intensive review concludes with the ROD identifying lands to be forwarded to the NPS Director to make their wilderness designation proposal to the Secretary of Interior. Going forward, these lands are managed and stewarded to preserve their eligibility for future potential designation in the NWPS by Congress. The evaluation process also includes management direction for potential wilderness – areas with the existence of a non-conforming use within an area otherwise found to possess wilderness character. The use of potential wilderness is essential to wilderness stewardship as these non-conforming uses may in the future be retired making the area suitable for inclusion in its surrounding wilderness quality lands. Importantly, DO 41 prescribes robust opportunities for meaningful public engagement throughout the evaluation process. The current process implemented under Section 5 rightfully upholds wilderness character stewardship and management as a keystone component to the agency fulfilling its mission as outlined in both the Wilderness Act and the Organic Act.
These many safeguards provide a predictable and responsive approach to wilderness stewardship and management on NPS lands. Given the many complex considerations involved in wilderness management and the relative rarity, uniqueness, and specialness of these places, we strongly encourage the agency to retain DO 41 in its current form to ensure a durable, predictable, and effective continued approach to wilderness stewardship and management on NPS lands.
II: Section 6, Wilderness Stewardship
Section 6 provides for the planning, management, and monitoring of areas identified through the Section 5 process to have wilderness character. Under Section 6, all lands identified to have wilderness character must be managed to preserve their eligibility for designations into the NWPS. As emphasized throughout these comments, wilderness conservation is a valuable tool for protecting some of the most sensitive and diverse areas in the country, including rare and imperiled wildlife habitat. Protecting areas with wilderness character is also vital to safeguarding the National Park visitor experience. Under DO 41, NPS has reliably managed these areas to provide backcountry and remote recreation opportunities for visitors to connect with the nation’s rich natural and cultural history.
DO 41 Section 6 meets these demands by explicitly recognizing national parks as belonging to larger ecosystems and cultural landscapes extending beyond park boundaries, including instances where NPS wilderness boundaries adjoin wilderness administered by another land management agency. Stewardship of wilderness character therefore necessitates a commitment from NPS to invite and participate in cross-agency collaboration, along with state and local land managers and Tribal Nations. As an example, natural sounds and night skies, which are critical to the primeval character of wilderness for providing visitors with a strong sense of solitude and remoteness – experiences that are rare in our world – requires a commitment to working within and beyond NPS wilderness areas and beyond NPS boundaries writ large. Section 6 integrates this commitment to collaboration and public engagement from the planning to the project level, an essential approach for preserving wilderness character, and therefore upholding the NPS mission to conserve lands unimpaired for the benefit and enjoyment of current and future generations. Another important component of wilderness stewardship is maintaining objective measures for monitoring to ensure management actions support parks in meeting their planning objectives. Through this approach, NPS wilderness management integrates the concept of wilderness character into park planning, management, and monitoring efforts.
Tribal Nations should have meaningful opportunities to participate throughout the wilderness planning process, beginning at the earliest stages of plan development and continuing through implementation and monitoring. To this end, we believe park leadership should initiate consultation with Tribal Nations and THPOs at the earliest pre-decisional stages to ensure collaboration with Tribal Nations on a Wilderness Stewardship Plan to ensure inclusion of Indigenous Knowledge and opportunities for agreements such as co-stewardship. Affirming the Secretary of the Interior’s Standards for managing cultural resources and consultation, Tribal Nations should also have meaningful engagement as active participants to inform cultural resource planning in the Wilderness Stewardship Plan.
Under DO 41 Section 6, all management decisions affecting wilderness must apply the concept of Minimum Requirements Analysis (MRA), which comes from Section 4(c) of the Wilderness Act and ensures that no inappropriate uses occur within the applicable wilderness area3NPS’s Minimum Requirement Decision Process involves two steps. The first step must be completed to determine if the second step is needed. The first step is to determine if any administrative action is necessary to meet minimum requirements for administration of the area for the purpose of the Wilderness Act. If an action is deemed necessary, the second step is to determine the minimum activity (method or tool) needed to accomplish the action which will have the least impact to the wilderness resource, character, and purposes. See https://www.nps.gov/subjects/wilderness/upload/NWSC-White-Paper_Min-Reqs-Decision-Process_508.pdf. If a prohibited use is found necessary for the administration of the wilderness area through the MRA process, the agency must carry forward that use in the least intrusive manner possible to preserve wilderness character.
The MRA is therefore essential for protecting wilderness character and can been seen in key wilderness management activities including wildlife management, invasive species management, scientific research, reclamation of abandoned mine lands for public safety, trail maintenance, and climate mitigation, adaptation, and resilience projects. These actions help maintain and improve wilderness character as well as enhance the park visitor experience, especially in instances where intensive management for resiliency and connectivity at a landscape level are warranted to retain natural ecological processes and preserve wilderness character.
6.7 – Fire Management
The NPS’s existing policy adequately provides practical and commonsense fire management in areas with wilderness character. DO 41, and the accompanying Director’s Order 18: Wildland Fire Management (DO 18), outline clear procedures to ensure wildfire response within an area managed as wilderness prioritizes firefighter and public safety. Under DO 41, all fire suppression and mitigation actions should be consistent with the “minimum requirements” concept laid out in the Wilderness Act. Actions taken to respond to wildfire in wilderness should use the minimum requirements necessary to protect life, safety, and any natural and cultural resources. As DO 18 outlines: “The potential disruption of wilderness character and resources will be considered before, and given significantly more weight than, economic efficiency and convenience. If a compromise of wilderness resources or character is unavoidable, only those actions that preserve wilderness character and/or have localized, short-term adverse impacts will be acceptable, unless human life is threatened.” We believe these commitments to the NPS legal obligation to uphold the Wilderness Act should continue to be upheld. The Order should also encourage early and ongoing engagement with associated Tribes in the development of fire management strategies such as Tribal co-stewardship as a valuable tool for advancing culturally sensitive fire management, protecting important cultural resources, incorporating Tribal knowledge and expertise into wilderness stewardship, and communicating any cultural resource impacts from fire management activities in wilderness to Tribes.
6.13 Native Americans and Consultation
The agency must maintain the government-to-government consultation with Tribal Nations early, at pre-decisional stages and continue through implementation and monitoring. The policy should remain strong with the obligation to consult with any federal action including; policy, guidance, and/or operational activity that affect tribal cultural practices, lands, resources, or access to traditional areas of cultural or religious importance on federally managed lands. We support consultation for Tribal Nations who have concerns about natural and cultural resources that may not necessarily be addressed during the Section 106 process. The agency should allow agreements such as co-stewardship opportunities, where appropriate, with interested Tribes, consistent with Joint Secretarial Order 3403 and Director Order 71C, enhancing the Wilderness Stewardship management.
To support proper implementation of 6.13 Native Americans and Consultation, NPS should collaborate with Tribal Nations to ensure Wilderness Stewardship Management respects Tribal sovereignty, incorporates Indigenous Knowledge, and includes opportunities for collaborative stewardship with Tribal Nations, where appropriate. The agency should maintain the current language affirming Section 106 regulations and consultation with THPOs and Tribal Nations on federal actions.
III: Section 7, Wilderness Use Management
7.3 – Commercial Services
We are supportive of the criteria that are laid out to authorize commercial services in wilderness. While there are commercial services that can help an area realize its wilderness purpose, they must always be approved with a documented process that determines the activities are the minimum amount needed. However, as DO 41 lays out, these activities may also be deemed too impactful to wilderness character, and should be disallowed if such a determination is found. Motorized use in wilderness, especially for commercial use, should continue to be prohibited. We also agree that commercial air tours are inconsistent with preservation of wilderness character.
Conclusion
The existing wilderness management policies are critically important to protecting park resources across the national park system. Rather than undermining existing protections, the Department of the Interior and the NPS should focus on maintaining and improving implementation of its existing wilderness stewardship policy. These policies must continue to ensure that future generations of park visitors will be able to experience the extraordinary wilderness character current and previous generations have been able to. While some very limited improvements to DO 41 might be made to improve public engagement and NPS compliance with other guidance, the vision for untrammeled wilderness management must remain intact. This review period cannot be seen as an opportunity for NPS to make any policy changes that would undermine their conservation mandate to conserve and protect these places as laid out in the Wilderness Act. We welcome any future opportunity to work with NPS on this or any efforts to protect America’s wild places.