Defend the Park Service's core wilderness policy
National Park Service Level 2 Wilderness Stewardship Policy Review: Director's Order #41
National Park ServiceFederal Register 2026-11958 ↗
The National Park Service is rewriting its core wilderness management rules, and the public has a short window to weigh in.
What’s at risk
Wilderness areas inside national parks could lose strong protections if the revised policy weakens how the NPS identifies, plans for, and stewards these lands. The outcome will shape on-the-ground management decisions for years.
If this goes through
If the revised policy rolls back existing protections, it could open wilderness areas in national parks to more damaging uses and set a precedent that is difficult to reverse.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
9 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- Section 6.13 requires government-to-government consultation with tribes for Federal actions affecting tribal cultural practices and traditional areas, yet the document does not specify what happens if a tribe objects to a wilderness stewardship decision or how objections are resolved. The order states consultation is required but provides no binding process for incorporating tribal input or addressing conflicts, leaving the standard for meaningful consultation undefined. The agency should clarify the decision-making process when tribal consultation reveals opposition to proposed wilderness actions.
- Section 6.7 requires parks lacking an approved Fire Management Plan to suppress all wildfires with consideration for wilderness character impacts, but simultaneously prohibits those same parks from using resource objectives as a primary consideration when selecting suppression strategy. This creates a logical contradiction: parks must consider wilderness character when choosing suppression methods, but cannot prioritize resource protection. The agency should clarify whether wilderness character impacts constitute a permissible primary consideration in suppression strategy selection for parks without an FMP.
- Section 6.2 requires wilderness character baseline data and monitoring every five years, but the document does not specify consequences if parks fail to establish baselines or maintain monitoring schedules, nor does it define which specific metrics must be measured. This leaves enforcement and accountability standards undefined. The agency should establish a binding timeline for baseline completion, specify the mandatory metrics for each wilderness character quality, and clarify enforcement mechanisms for non-compliance.
- Section 7.3 requires parks to make a documented determination of necessary commercial services using an interdisciplinary approach, but provides no standard for how to weigh preservation of wilderness character against commercial service demands when capacity limits are reached. The section states commercial services may be limited to preserve primitive recreation but gives no methodology for making that determination. The agency should develop explicit criteria or a decision framework for resolving conflicts between commercial service necessity and wilderness character preservation.
Show all 11 points from the document
- Section 6.5 states scientific activities will be encouraged if benefits outweigh impacts, but does not require parks to conduct a cost-benefit analysis or establish decision criteria for what constitutes sufficient benefit to justify wilderness character impacts. The order mentions developing a database to track cumulative effects but does not specify how cumulative impact thresholds are determined or what triggers mandatory denial of scientific proposals. The agency should establish explicit benefit-impact evaluation criteria and cumulative impact thresholds for scientific activity authorization.
- Section 5.2 states that completed wilderness studies may result in revised eligibility determinations and changed land identifications compared to the initial eligibility assessment, but does not require that revised determinations undergo the same public notification process as the original assessment. The order requires two public notifications for eligibility assessments but is silent on public notice for revisions made during the study phase. The agency should clarify whether revised eligibility determinations resulting from wilderness studies must receive independent public notification and comment opportunity.
- Section 6.12 requires cultural resource management in wilderness using minimum requirements analysis, yet states measures must preserve other wilderness resources and character without defining how conflicts between cultural preservation and wilderness character preservation are resolved when both cannot be fully achieved. The order requires specialist participation but does not establish decision authority or criteria for prioritization. The agency should specify the hierarchy or decision process for resolving conflicts between cultural resource protection and wilderness character preservation requirements.
- Section 6.6 requires superintendents to develop climate change strategies that uphold wilderness values, but the document does not address whether ecosystem interventions to maintain resilience (such as species translocation or assisted migration) would constitute prohibited developments or uses under the Wilderness Act. The order directs action without clarifying the legal boundaries of permissible climate adaptation management in wilderness. The agency should provide explicit guidance on which climate adaptation activities are permissible within wilderness boundaries and which would violate wilderness preservation requirements.
- Section 6.10 identifies natural sounds and night skies as critical components of wilderness character and notes that anthropogenic noise and light travel long distances, yet the document does not require or describe how parks should manage noise and light impacts originating outside wilderness boundaries. The order acknowledges the problem but does not assign responsibility for addressing external sources. The agency should clarify park authority and responsibility for mitigating external noise and light impacts on wilderness character, and specify coordination requirements with external noise and light sources.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
The National Park Service (NPS) seeks public comment on Director's Order #41: Wilderness Stewardship, which provides policy direction for the identification, planning, stewardship, and administration of wilderness managed by the NPS. Comments are now being accepted from the public, and local, State, Tribal, and Federal agencies.
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