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Draft Management Policies

Discussion in 'Land Use' started by Gold Rush, Mar 2, 2000.

  1. Gold Rush

    Gold Rush 1/2 ton status

    Feb 17, 2000
    Likes Received:
    ----- Original Message -----
    From: C Boucher <ccboucher@home.com>
    To: C Boucher <ccboucher@home.com>
    Sent: Wednesday, March 01, 2000 11:17 AM
    Subject: United alert 1 of 1

    > As always, this form letter and alert are available at
    > Thanks to Brian Swearingen and the Wisconsin Four Wheel Drive Association
    for their
    > support of the form letter site. Without their hard work and assistance I
    > provide these form letters on-line!
    > And as always, for those without access to the Internet, the form letter
    appears at the
    > bottom of this message.
    > MEMO TO: United Four Wheel Drive Assocations
    > FROM: Carla Boucher
    > RE: Legislative Advocate Special Report (4-00)
    > DATE: February 29, 2000
    > WHAT: The National Park Service has published its Draft Management
    > HOW IT EFFECTS UFWDA: The National Park Service (NPS) is updating its
    Policies which were
    > last done in 1988. Policies are used to set the framework and provide
    direction for the
    > management of public lands under the jurisdiction of the National Park
    Service. The NPS
    > has stated that, "The update will allow our policies to keep pace with new
    laws that have
    > been enacted, changes in technology and American demographics, and new
    understandings of
    > what we must do to protect the natural and cultural resources of the
    national parks. I
    > point this out, and have added emphasis to these two areas in particular
    because I think
    > it is important to note.
    > The Clinton administration would like the public to believe that American
    > have changed drastically over the past few decades which has resulted in
    less "open green
    > spaces" which are in need of increased protection. The "new
    understandings" which have
    > come about since 1988 (the last time the Policies were updated) in the
    land use arena have
    > more to do with politics and implementation of the Wildlands Project, than
    they do with
    > good science.
    > One of the changes to the Draft Policies is the simple deletion of one
    very important
    > word - SIGNIFICANT. The 1988 Policies (scroll down to Visitor Uses)
    state, "Routes and
    > areas may be designated only in locations where there will be no
    significant adverse
    > impacts on the area's natural, cultural, and scenic resources and values
    in consideration
    > of other visitor uses".
    > The Draft Policies state, "Routes and areas may be designated only in
    locations in which
    > there will be no adverse impacts on the area's natural, cultural, scenic,
    and esthetic
    > values in consideration of other visitor uses". Notice how the NPS has
    deleted the word
    > "significant", so that now OHV use will be permitted only where there is
    no "adverse
    > impacts" not "significant adverse impacts".
    > This change, especially in light of the Bluewater Network petition to ban
    all OHV use on
    > NPS units, is a serious problem. This change could pave the way for the
    NPS to close
    > large areas to OHV use (in response to the Bluewater petition) simply by
    stating that in
    > accordance with its "policies" the OHV use causes adverse impacts and
    therefore must be
    > prohibited.
    > Therefore, I have prepared a form letter that you can send to the NPS
    asking them to add
    > the benchmark of "significant" back into the Draft Policies. The letter
    will also ask the
    > NPS to use the terminology of "impairment" and "derogation of resources"
    instead of
    > "impact". Impairment means damage and derogation means to depreciate or
    devalue. These
    > terms are in keeping with the NPS Organic Act and other subsequent laws.
    These terms also
    > do a better job of capturing the standard to which OHV decisions should be
    in line with.
    > It is a much better alternative for the NPS to prohibit OHV use in areas
    where significant
    > "damage" (impairment) or a "depreciation in the value of the resources"
    > occurs than simply where "adverse impact" occurs.
    > The form letter must be sent before March 20, 2000.
    > Bernard Fagan
    > National Park Service
    > Office of Policy, Room 2414
    > Main Interior Building
    > 1849 C Street, NW
    > Washington, D.C. 20240
    > ******************
    > Bernard Fagan
    > National Park Service
    > Office of Policy, Room 2414
    > Main Interior Building
    > 1849 C Street, NW
    > Washington, D.C. 20240
    > February 29, 2000
    > Dear Mr. Fagan,
    > Thank you for the opportunity to provide comments regarding the Draft
    National Park
    > Service Management Policies published in the Federal Register on January
    19, 2000 (Volume
    > 65, page 2984).
    > Please make the following changes to the Draft Policies:
    > * Section should delete the words "adverse impacts" and substitute
    the words
    > "impairment" and "derogation of values" as provided for by the NPS Organic
    Act of 1916
    > and the National Park System General Authorities Act, as cited in Section
    8.1 of the Draft
    > Policies.
    > *Section has deleted the word "significant" from the 1988
    Management Policies.
    > This benchmark of impairment should be retained in the Draft Policies.
    > Therefore, section should be changed to state, "Routes and areas
    may be designated
    > only in locations in which there will be no significant impairment or
    derogation of
    > values.
    > Thank you for the opportunity to respond to the Draft Management Policies.
    Please make my
    > comments part of the permanent record. I look forward to working in
    cooperation with the
    > National Park Service as these Policies continue to be developed.
    > Sincerely,


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