ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW
Submitted via: https://www.regulations.gov/commenton/NPS-2026-0100-0001
August 3, 2026
Michael P. Michener
Deputy Associate Director, Visitor and Resource Protection
National Park Service
1849 C Street NW
Washington, DC 20240
Subject: Comments on National Park Service Level 2 Wilderness Stewardship Policy Review: Director’s Order #41
Dear Mr. Michener:
The Coalition to Protect America’s National Parks (Coalition) is comprised of more than 5,100 members, all of whom are retired, former, or current National Park Service (NPS) employees or volunteers who collectively represent more than 50,000 years of national park management and stewardship experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are numerous former employees of many parks that have Wilderness areas.
As required by existing law, the Wilderness Preservation System protects more than 111 million acres, just 5% of the entire United States, and roughly 2.7% of the contiguous United States. Of the 433 NPS units across the country, only 50 NPS units have designated wilderness areas. Additionally, 25 other park units contain lands identified through public processes that exhibit wilderness characteristics and are eligible for wilderness designation. Thus, only a small percentage of parks have wilderness status because of the careful legislative and agency processes for selection, refined over time.
The Coalition strongly supports the Department of the Interior’s and NPS’s existing wilderness stewardship policies. We are not recommending any changes to NPS Director’s Order 41 (DO41). We urge the Department to uphold proven wilderness management standards consistent with federal law and long-held policies, and to maintain the integrity of Wilderness areas.
We strongly feel that existing NPS policies and guidance provide an effective, balanced framework for managing wilderness and wilderness-quality lands and for complying with relevant laws such as the NPS Organic Act, the Redwood Act, the Wilderness Act, the Clean Air Act, and the Federal Land Policy and Management Act. DO41 has been carefully refined over the past decades to fulfill statutory responsibilities, ensure consistent management of wilderness lands, and allow appropriate recreational use. Maintaining this public-generated framework, created over the decades, promotes certainty for agency staff, businesses, local communities, and stakeholders. In addition, current policies ensure that wilderness characteristics and values are appropriately identified and managed alongside other public land uses, as federal statutes require.
Wilderness and recognized wilderness-quality lands across the NPS conserve some of the nation’s most critical ecological, cultural, scenic, and recreational resources. These lands receive the highest protection under current legal and policy frameworks. These undeveloped landscapes protect critical watersheds, preserve biodiversity, offer unique recreational opportunities, and secure intact wildlife corridors. Intact forests and wetlands sequester carbon and absorb heavy rainfall, mitigating downstream flooding. Protected landscapes provide clean water and air for millions of Americans.
Wilderness areas also serve as vital regional economic engines for communities. Public lands drive a sustainable outdoor recreation economy that contributes $1.2 trillion to the American economy and supports over 5 million jobs. Overall, outdoor recreation in and around wild areas supports millions of jobs in climbing, guiding, outfitting, and hospitality. Wilderness areas provide unique recreational opportunities that bring a broad range of users, from hikers to climbers. For example, Yosemite National Park, which is largely wilderness, generates over $600 million in economic benefits and more than 6,000 jobs.
As former managers, scientists, interpreters, and law enforcement officials of the NPS, we urge the Department of the Interior to maintain and continue implementing the framework outlined in DO41. The current agency policies have successfully guided wilderness stewardship for generations, successfully balancing conservation and public access. No compelling justification has been provided for substantially revising or weakening this policy and guidance. If the NPS decides to alter DO41, we urge that any potential changes be reviewed in a public process that details them.
Thank you for considering our input on this important issue.
Sincerely,
Cheryl A. Schreier
Chair of the Executive Council
Coalition to Protect America’s National Parks
Email: Ed****@********ps.org
Mail: 2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Web: www.protectnps.org
Phone: (202) 819-8622