Comment from Marsha Langford

I am writing to comment on the review of Director’s Order #41 (Wilderness Stewardship), which has guided consistent, science-based management of wilderness across the National Park System since its most recent update. I urge NPS to use this review to strengthen, not weaken, DO #41’s protections. I am increasingly concerned about the protection of our public lands, wildlife and wilderness. We need to preserve these wilderness areas and not open to actions that can cause irreversible damage to wildlife, land, and the environment. DO #41 exists to fulfill the mandate Congress gave the Park Service under the Wilderness Act: to identify, recommend, and manage wilderness so as to preserve its untrammeled, undeveloped, and natural character, and to provide outstanding opportunities for solitude and primitive recreation. Any revision should: •Preserve the rigor of the Minimum Requirement Analysis (MRA) process. MRA is the mechanism that keeps administrative and commercial shortcuts — motorized equipment, mechanized transport, permanent structures — out of wilderness except in genuine emergencies. Loosening the MRA standard, or expanding the exceptions to it, would erode the “untrammeled” character the Wilderness Act was written to protect, without any act of Congress. •Keep “wilderness study,” “recommended,” “proposed,” and “eligible” lands under full interim protection. These categories exist because Congress directed NPS to evaluate all its lands for wilderness suitability; until Congress acts, these lands must be managed as if they were designated wilderness. Any revision that narrows this interim protection, or makes it easier to strip these designations administratively, would let development and motorized use into places identified as wilderness-quality without the congressional review the Act requires. •Maintain, not dilute, training and accountability requirements for superintendents and regional staff so that stewardship decisions are made by people trained in wilderness law, not left to ad hoc local judgment. •Ensure any final revision goes back out for public comment before adoption, given how consequential changes to this policy would be for millions of acres of national park wilderness. I ask that any updated Director’s Order #41 hold the line on these protections rather than use this “clarification” process to quietly expand permitted uses inside wilderness. Thank you for considering these comments.