Comments on 2001 NPS Management Policies

The Organization of American Historians submitted comments on the proposed revision of the 2001 National Park Service Management Policies.

Mr. Bernard Fagan
National Park Service
Office of Policy
1849 C Street NW, Room 7252
Washington DC 20240

Dear Mr. Fagan:

With this letter, the Organization of American Historians (OAH) offers its comments on the proposed revisions to the 2001 National Park Service Management Policies. Founded in 1907, the OAH is the largest professional society dedicated to the teaching and study of American history. Our 9,300 members include college and university professors; students; pre-collegiate teachers; archivists, museum curators, and other public historians; and a variety of scholars employed in government and the private sector. In addition, for more than a decade the OAH has had a cooperative agreement with NPS, through which the two agencies have collaborated on more than fifty historical projects. Through this program, OAH has served the National Landmarks Office, the Historic American Engineering Record, multiple NPS regional offices, and park units including Independence NHP, Gettysburg NMP, the Statue of Liberty NM, Redwood NP, Grand Teton NP, and the U.S.S. Arizona NM.

Because of our long relationship with the National Park Service, we have a great interest in the management of the agency, particularly with regard to cultural resources. We understand that generally NPS management and planning documents are intended to have a life of ten-to-fifteen years, and thus we question why the 2001 Management Policies are being revised in the first place, after less than five years. Because we do not see any pressing need for the revision and because the revision seems to be a digression from standard NPS procedure, we urge NPS to abandon these revisions and allow the 2001 Management Policies to remain in place.

If, however, the agency chooses to pursue these revisions, the OAH offers these specific comments regarding the proposed changes.

Initial Comments

At the outset, the OAH would like to endorse the feedback already submitted by the National Coalition for History, a copy of which is available at:

http://www.h-net.org/~nch/comments-nps.html

The OAH is a member of this coalition of history and archives organizations, and we concur with all of the comments provided by this agency.

The comments given below stand in addition to the comments offered by the National Coalition for History.

Introduction

Page 3, lines 10-23: This newly added section argues that "in the context of these Management Policies," the words "conserve, preserve, and protect" are interchangeable. However, in common usage, the word "conserve" connotes a lesser standard of care than the words "preserve" or "protect." This common usage, coupled with the disturbing fact that in these proposed policies the words "preserve" and "protect" aresystematically replaced with the word "conserve" (while the words "preserve" and "protect" nowhere replace "conserve") suggest that these words do indeed carry different meanings. The words "preserve" and "protect" should remain in place wherever they appear in the 2001 policies.  

Chapter One: The Foundation  

Throughout: The word "scientific" is used repeatedly to mean expert opinion, but this term excludes experts in cultural resources, such as historians, archeologists, curators, ethnographers, and preservationists. We recommend using the term "scholarly and technical" in place of the word "scientific" throughout Chapter One and the rest of the document. Specific instances include:

• page 4, line 12
• page 5, line 19
• page 13, line 8
• page 17, line 22
• page 17, line 39
• page 18, line 24
• page 21, line 12
• page 34, line 13

Page 19, line 31: Any impact "that, in the professional judgment of the responsible NPS manager, would harm the integrity of park resources or values" would be a significant impact; thus, the word "significant" should not be added. To include it implies that there could be such a thing as an insignificant harm to the integrity of park resources and values.

Page 20, line 11: The word "special" should be removed from the phrase "special significance." Any identified significance of a resource—not just "special significance"—should be considered in determining whether an impact constitutes an impairment.

Section 1.8: Civic Engagement and Section 1.9: Partnerships (pages 34-35): Both of these sections urge the inclusion of various constituencies in park management decisions. While the desire for inclusive decision-making is a good one, allowing for a democratic sharing of ideas, the current wording of these sections does not adequately provide for the protection of natural and cultural resources, even in the face of public pressure to do otherwise. We urge you to rewrite these sections to specifically include professional and scholarly communities among those constituencies to be consulted and to emphasize the preservation of resources for future generations over the accommodation of public demands in the present.   

Chapter Two: Park System Planning

Page 39, line 23: Add "recognized experts" or "the scholarly community" to the list of constituencies to be consulted when crafting a park's foundation document.

Chapter Three: Land Protection

Chapter Four: Natural Resource Management

We have no comments for these chapters.

Chapter Five: Cultural Resource Management

Page 106, lines 8-16: The paragraph being deleted offers a much stronger commitment to disciplinary training and proficiency for cultural resource managers than Section 1.7.5, which is intended to replace the deleted paragraph. As such, we must insist that lines 8-16 remain. To remove this paragraph is to threaten the nation's cultural resources through uninformed stewardship.

Section 5.1.3.2.1 (page 110):  We applaud the NPS commitment to nominating eligible park resources to the National Register of Historic Places. In addition, we would like to see a written commitment, in this section, to updating existing National Register forms for park resources, to more fully document the resources and represent all themes and contexts in U.S. history.

Page 112, line 30: Requiring park managers to "cooperate. . . with outside parties having an interest in the park's cultural resources or in proposed NPS actions that might affect those resources" is a directive that could have dire consequences for future generations. We urge the removal of the word "cooperate," so that managers are required simply to "communicate and consult with" outside parties.

Chapter Six: Wilderness Stewardship

We have no comments for this chapter.

Chapter Seven: Interpretation and Education

Page 168, lines 15-22: While the proposed management policies continue to ban battle reenactments, they no longer explain the traditional reasoning behind this decision ("Battle reenactments create an atmosphere inconsistent with the memorial qualities of the Battlefields and other military sites placed within the Service's trust"). The new explanation—concerns about visitor safety—is insufficient and introduces the troubling concept of reenactment "authenticity."  Thus, this section should be returned to the form it took in the 2001 policies.

Chapter Eight: Use of the Parks

Page 174, lines 25-33: This section presents the concept of "authenticity" as a basis for conceptualizing the visitor experience. However, authenticity is an inappropriate criterion to apply to historical interpretation.Accuracy is of the utmost importance.  How can a modern-day interpreter authentically present the past? Thus, we recommend that this section be reconceived.

Page 174, line 31: In this same section, the goal for historical interpretation is described as "historical events and places presented accurately and without contrivance or judgment." However, the craft of professional history demands analysis of facts, in which historians rely on their professional judgment to interpret the evidence. Just as biologists use their judgment to determine whether a given animal population is failing to thrive or to determine whether a specimen constitutes a new species, so do historians use their judgment to make meaning of past events. We advocate the removal of the words "and without contrivance or judgment."

Concluding Remarks

Overall, the proposed revisions to the 2001 NPS Management Policies elevate visitor enjoyment at the expense of resource protection. In our opinion, this goes against the intention of Congress in establishing the National Park System. Because the National Park Service is consistently among the most esteemed of government agencies, it seems that the American public concurs with the Service's preservation mission. We urge NPS to hold true to its role as steward of the nation's heritage.

Sincerely,

Vicki L. Ruiz
OAH President

Lee W. Formwalt
OAH Executive Director