01.22.2013 - Comments on Revisiting Leopold
January 22, 2013
Director Jonathan B. Jarvis
National Park Service
1849 C Street NW
Washington, DC 20240
Dear Director Jarvis:
Thank you for the opportunity to comment on Revisiting Leopold: Resource Stewardship in the National Parks, prepared by the National Park System Advisory Board, and finalized in August 2012. We commend the Advisory Board for taking on this project, and you for tasking them with this review. It is forward-thinking and contains many excellent observations and recommendations.
At our December meeting both you and Dr. Machlis indicated that the report is final and that we should direct our comments towards implementation. We have tried to do that herein, but many, if not most, of the comments we received from members were directed at specific parts of the report. We offer some of these, not expecting the report will be changed, but hoping that actions associated with implementing the report might address them. Also, because of the way we collected and consolidated comments, we have grouped comments as general/natural, or cultural.
General and Natural Resource Based Comments
The Goal. The 1963 Leopold Report was transformative to the National Park Service and endured as a foundation for natural resource management for nearly 50 years for at least three reasons. First, it was completed by a distinguished committee of scientists that had great credibility. Second, it embraced the fledgling concept of ecosystem management as the guiding principle for resources management in parks. This principle had been expressed previously in various forms by Joseph Grinnell and George Wright, among others, so there was a seed of that concept within the Park Service when the report came out. The report was, however, the tipping point for a major transition of action and thinking. But third and most importantly, the report presented an easily understood, concise, and very visual goal: “…we would recommend that the biotic associations within each park be maintained, or where necessary recreated, as nearly as possible in the condition that prevailed when the area was first visited by the white man.”
While this goal has been maligned, nit-picked, and questioned, particularly in recent years, it was a clear benchmark for park and resource managers and it propelled the Park Service forward in many areas including fire management, reintroducing extirpated species, controlling exotic species, and halting well-meant, but damaging practices such as bear feeding and predator control.
In contrast, Revisiting Leopold offers a different goal: “…to steward NPS resources for continuous change that is not yet fully understood, in order to preserve ecological integrity and cultural and historical authenticity, provide visitors with transformative experiences, and form the core of a national conservation land- and seascape.”
While more all-encompassing and reflecting the increasing complexity of both the Park System and the external issues facing it, this goal is not nearly as clear for a park or resource manager in applying it to daily or long term management. Because of this, we doubt it will be as transformative or enduring as the goal in the original Leopold Report. Some of our members have called this goal confusing. Some have said that it leaves too much discretion to managers which could lead to inconsistency. As part of implementation, we recommend that this goal be clarified.
< The report recommends undertaking a major, systematic, and comprehensive review of policies. We are not convinced this is necessary, particularly based on the substance of the report. We believe existing NPS Management Policies remain relevant and provide the flexibility to implement all aspects of Revisiting Leopold. There may be other reasons to revise Management Policies, but the recommendations in this report by themselves do not provide a compelling reason to do so. Administratively revising Directors Orders or reference manuals should be considered instead.
We are pleased with the recommendation of greater utilization of the “precautionary principle” and recommend this be built into Park Service decision-making processes. Recent examples are the Handbook on Adaptive Management and perhaps the related topic of the “environmentally preferred alternative” in D.O. 12, NEPA Handbook. This will provide an expectation that park managers make decisions in a careful, transparent, deliberative manner.
We fully endorse this action, and recommend that you immediately initiate a strategic plan to accomplish this. Revisiting Leopold is not the first report to recommend a substantial expansion of science capacity in the Service. There have been many (the Vail Agenda, NPCA’s National Parks: From Vignettes to a Global View (Gordon report), The Commission on Geosciences, Environment and Resources, among others). However, the Park Service has made only incremental progress, and our science capacity remains well below what is needed.
We recognize that this may require new resources or a redistribution of existing resources, but it seems imperative that this occur. The complexities of managing park resources, both cultural and natural, are only increasing. Park Managers will need data and scientific understanding to address the issues of the future.
In recent years it has become very clear that science used for management decisions must withstand outside scrutiny and be defendable. Towards this end, we urge you to examine existing organizational structures within the Service and determine the best structure for this effort. The existing inventorying and monitoring (I&M) networks should be examined closely, as should the Cooperative Ecosystem Studies Units (CESUs). In the I&M networks, Dr. Fancy has done a good job of ensuring the scientific integrity and peer review of monitoring protocols. Similar oversight is needed for all science within the Service. Also, for small and mid-sized parks, this type of structure may be the only way that many of them can receive the science capacity they need.
Cultural Resource Based Comments
We agree with most of the conclusions reached in the introduction to the report, particularly: “Many, if not most parks include both natural and cultural resources…” and “Natural and cultural resource management must occur simultaneously and, in general, interdependently.” We will say, however, that likely all of the parks contain natural and cultural resources. We also agree with the observation: “…individual parks…are--regardless of size--embedded in larger regional and continental landscapes influenced by adjacent land and water uses and regional [and we would add “national”] and regional cultures and [we would add the historical context in which they developed.] Connectivity across these broader land- and seascapes is essential for system resilience over time to support animal movements, gene flow, and response to natural disturbance.” Likely this larger connection is meant when the authors write later: “Cultural history transcends park boundaries.” We note that this theme is continued at the end of the paragraph on page 10 when the authors say: “Similarly, cultural resources extend beyond iconic buildings, historic sites and landscapes to include indigenous values, sense of place, historical meaning, diverse forms of cultural knowledge, and the recent past.” We urge that the artificial boundary between natural and cultural resources be addressed and that meaningful action to manage them equally be implemented. Additionally, we believe that Heritage Areas can and do make a significant contribution to the protection of these larger landscapes and should be encouraged and embraced as significant partners in this effort.
We emphasize these references to expand the attention to new and emerging scientific disciplines as well as new and emerging historic, curatorial, architectural and archeological fields of study. We note that an organization that is science-informed and scholarship-informed at all levels will support the understanding that all parks are both natural and cultural. We believe that this emphasis should be recognized as an integral part of the policies and the actions necessary to implement the report and to best preserve the parks for the future.
In the policies section, we heartily endorse the precautionary principle as an operating guide. We have seen many buildings and archeological sites destroyed for expediency sake, only to recognize later the contribution they could have made. Some of these mistakes have become part of our national vocabulary in song (…they paved paradise and put up a parking lot”) but many more have been brushed aside cavalierly and many of us were part of, or complacent to, the sacrifice. We encourage restraint and irreversibility whenever possible.
We also endorse the broadening of our representation of American culture and scope both within and beyond park boundaries. For cultural resources, this will mean broader scholarship within the NPS as well as connections with academic institutions in order to identify important, but heretofore unrecognized or unprotected, buildings, sites and objects, whether for addition to the NPS or for others to protect.
We agree with the statements about historical authenticity but caution that too literal an interpretation of the words “…to be an accurate representation of a specific cultural time and place…” could lead to restorations that obliterate important changes to a building or site or object over time. In fact, one of our readers opined that to him this could mean a return to replicas or facsimiles, rather than “authenticity” which should be the standard. Here we again reiterate the precautionary principle.
In the actions section we would encourage that any new and diverse cohorts include cultural resource specialists from the full array of scientific and scholarly disciplines necessary for sound cultural resource management. We have lost a large number of specialists in parks due to the reduction of staff and the necessity of individuals serving many roles. This has led to a reduction in scholarship within parks and a loss of historic and archeological expertise in parks. Little scholarship goes on in many parks, reduced by the time demands of other roles. We agree that the research and careers of these specialists should be supported and rewarded. We also encourage meaningful connections to scholarly groups outside the NPS.
The law and policy surrounding cooperative agreements needs to be re-examined to ensure that the law and policy encourages collaboration without improper favoritism. The present approach is not successful.
Identification and monitoring are crucial to the long-term protection of cultural as well as natural resources. We do not advocate the approach that every square mile of parkland needs to be inventoried; however, significant and targeted surveys do need to be made in some areas. Collections, too, have been much better protected in the last few years but we must not let that falter. Regarding collections, the NPS holds remarkable collections of cultural artifacts that the public almost never sees. A more organized and supported approach should be implemented to ensure that a greater percentage of these treasures is shared with the public.
We underline the recommendation that NPS professionals, especially park superintendents, should be required to possess and maintain significant scientific and scholarly (read here history, archeology, engineering, anthropology and curation) literacy in order to understand the meaning and the effects of their actions.
Finally, we urge the National Park Service to address climate change as it affects cultural resources. It is not merely acid rain adversely affecting sculpture and buildings, it is sea level changes that erode or destroy archeological sites, fires that destroy buildings and sites and the climate changes that ruin fragile paper, fabric, pottery, cultural landscapes, historic gardens and landscape architecture etc., not to mention energy conservation’s impact on historic buildings (pro and con).