8   A HESITANT START AT IMPLEMENTATION

The legislative struggle for the Wilderness Act might be over, but the park wilderness story was merely entering a new stage that would challenge the Park Service in different ways. Now the service could not, as it had for so long, avoid the issue by pronouncing that everything not developed was wild. That approach had been forcefully rejected. Law now required that it examine the land under its management and decide what should be officially designated as wilderness. And having done this, the decision on whether or not its recommendation would be accepted and the wilderness boundaries established was largely out of its hands. Interest groups and the politicians who listened to them would decide whether a park would or would not be wilderness and where the boundaries would lie.

To this point in its history the Park Service had developed a fierce pride in its professionalism. It had faced many challenges and had done its best to deal with them. Many in the leadership and rank and file of the agency were certain they had done what was right and proper, and they regretted what they perceived as a great, or at least a potentially great, loss of autonomy from the Wilderness Act. Never before in its history had the Park Service suffered a loss like this. Now the “park men” might lose what they considered their professional prerogatives—managerial control of part of their domain. Zahniser and the other Wilderness Act advocates had tried hard to reassure agency managers that designated wilderness would remain under their control, but many had not been convinced. Now that legislation was on the books, all would learn what its consequences would be.

THE WIRTH ERA ENDS

Conrad Wirth would not be in charge of this new phase of the park wilderness story. Events had overtaken him, and he had retired nine months before President Johnson signed the Wilderness Act. Wirth's selling of his Mission 66 program to the Eisenhower administration and Congress, and the launching of it, had been the high point of his years at the Park Service helm. He had enjoyed the support of nearly everyone concerned about national parks as he campaigned for the funds to upgrade the long-neglected infrastructure of the system. When the work began, however, critics began to appear. He found himself increasingly at odds with conservationists over some Mission 66 projects, and his support from that sector eroded. The Sierra Club and National Parks Association clashed sharply with him over upgrading the Tioga Road in Yosemite, a project long sought by commercial interests east of the park. They offered him advice on how the project might be modified to be less intrusive, and he ignored them. He was, at least in their view, more interested in recreational tourism than in resource protection. His stance on national park wilderness seemed another indicator of this. The issue of hunting in national parks came up, and Wirth vacillated on this most emotionally potent of national park issues. His suggestion in 1961 that hunting be explored as a way to manage deer in the proposed Great Basin National Park brought a strong retort from conservationists. Ultimately he pronounced that hunting was not reconcilable with national park values, but his flirting with the idea only increased doubts about him in the conservation community.

Wirth no doubt would have liked to see Mission 66 through to its conclusion, but politics made that impossible. The transition to the next director, National Park Service veteran George B. Hartzog Jr., was orderly, and Wirth “retired.” His departure was not entirely voluntary, since Stewart Udall considered him out of step with the times and encouraged his retirement. It is an understatement to say that Wirth was not enthusiastic about the move toward a National Wilderness Preservation System, while the Kennedy administration and Secretary Udall were solid backers of it. Wirth also thought that he and the National Park Service could and should oversee the national outdoor recreation agenda, but the Outdoor Recreation Resources Review Commission and Secretary Udall did not agree. A new Bureau of Outdoor Recreation would do that work. The Kennedy people, led by Udall, embraced a “new conservation” that broadened the vision of the conservationist mission of past decades and raised questions about conventional definitions of progress. Ron Foresta, in his study of the post–World War II National Park Service, has written that the Mission 66 program “reflected a great faith in progress rather than a healthy distrust of it. Its building program reflected assumptions about the harmony of development and wilderness which were no longer in fashion.”1 In the mid-1950s Wirth had responded to the challenge of repairing park system damage inflicted by the war, and he was succeeding in this work. But even as he was doing this, a sea change swept the conservation movement and he found himself increasingly at odds with it. This ultimately brought an end to his tenure.

An emergent and growing ecological consciousness in the early 1960s began modifying the goals of conservation and contributed to Wirth's problems. His stumble over the hunting issue led Secretary Udall to request a study of the wildlife management policies of the National Park Service. Wildlife in national parks had generated many issues over the years, arguments about predators foremost among them. The Park Service had begun by eliminating predators and managing for animals the public loved to see, such as elk and bison. Biologists like Joseph Grinnell, Harold Bryant, George Wright, Carl Russell, Ben Thompson, Adolph Murie, and Victor Cahalane, all but Grinnell with the Park Service, had for nearly four decades advocated with little success a park management based on ecological concern for the viability of natural communities in the parks. As the decade of the 1960s opened, with conservationists’ growing interest in wilderness and ecology, views on the purpose and nature of national parks changed. Scenery and recreation continued to be important park values, but as Richard Sellars has so thoroughly explained, the ideas of wildlife biologists who “focused on preserving ecological integrity in the parks while permitting development for public use in carefully selected areas” were finally given more credence. As support for wilderness grew, the idea of national parks as areas intended primarily for “recreational multiple use” eroded. The view that national parks should be minimally developed gained support. For decades the management ideas of the wildlife biologists had been overwhelmed by those of landscape architects and recreation-oriented managers. The wilderness movement contributed to a change in this. Biologists, as Sellars points out, “defined ‘unimpaired’ in biological and ecological terms, a concept more compatible with that expressed in the 1964 Wilderness Act.”²

Udall in 1962 called for scientific assessments of the situation. He asked the National Academy of Sciences to review the “natural history research needs and opportunities” in the parks. He also appointed the Advisory Board on Wildlife Management. The chairman of this board was wildlife biologist A. Starker Leopold. On March 4, 1963, the committee submitted its report to Secretary Udall. The Leopold report argued that the primary goal of national parks and monuments should be “to preserve, or where necessary to recreate, the ecologic scene as viewed by the first European visitors.” Achievement of such a goal would require new levels of historical and ecological understanding that could be achieved only by scientific work on a scale exceeding anything the Park Service had done before. It should conduct research “oriented to management needs,” which should then guide management policy. Roadless sections of the parks should be “permanently zoned,” and nonconforming uses, most of them associated with recreational development, should be “liquidated as expeditiously as possible.”3 While this report did not figure materially in the drive toward the Wilderness Act, it certainly pointed toward changes in national park management priorities that would be served by designating “permanent” wilderness zones in the national parks.

The National Academy Report, released five months after the Leopold report, was not as directed at management but severely criticized the Park Service's failure to support science. It emphasized the ecological challenges of national park management that could be addressed only by more and better science. These two reports initiated a new phase in national park history that involved a protracted struggle over the role of science in management, a new emphasis on “naturalness” in management, and a new casting of the nature and purpose of national park wilderness. Conrad Wirth, in Stewart Udall's view, was not the man to preside over the National Park Service response to this new set of challenges.

George B. Hartzog Jr. became director on January 8, 1964. He was a lawyer who had risen from the ranger ranks to become superintendent of Jefferson National Expansion Memorial. In this position he resurrected a nascent Gateway Arch project and saw this monumental effort through to completion. He met Secretary Udall in 1961 when the secretary visited the Ozarks, where Hartzog's work on a proposal for an Ozark Rivers National Monument impressed him. In 1962 Hartzog left the Park Service thinking that his opportunities lay elsewhere, but in a casual meeting with Udall in August the secretary sounded him out about becoming director. With Eivind Scoyen retiring, the search was on for a new associate director to Wirth, and this job would go to Hartzog with the understanding that when Wirth retired he would become director. Wirth was to announce his retirement at the superintendents’ conference in Yosemite in October 1963.

The ambitious Hartzog was delighted at the opportunity and embraced it. Wirth announced his retirement at the conference, but this was overshadowed by controversy generated by the keynote speech of Assistant Interior Secretary John Carver, who blasted the Park Service and by inference its outgoing director. Carver's remarks were leaked to the press and appeared nationally the day before he delivered them at Yosemite. The story suggested that Wirth was being forced out, and Carver's remarks seemed to confirm this. The Park Service was shocked at this whole development, not so much because Wirth was leaving but because of the way in which the administration was handling the situation. Udall denied that Wirth was being forced out and eventually the storm blew over, but many suspected that Hartzog was being brought in to oversee a change in direction, to carry out an agenda that people in the Park Service had not developed. This, to Park Service veterans and knowledgeable park observers, seemed to be high-order political meddling.

Undoubtedly Udall wanted a man in the director's chair more supportive of the directions he thought appropriate for the national park system than Wirth had been. He also wanted a young, dynamic leader more in the mold of the Kennedy team, and George Hartzog seemed to fit this bill. So much suspicion was generated by the Carver speech that Scoyen wrote an account for his Park Service colleagues of the change in the directorship, documenting the history of Wirth's decision to retire and the process of Hartzog's selection. He assured his Park Service colleagues that Hartzog had been chosen on his merits and had played no role in Wirth's ouster. Scoyen thought the whole episode had seriously affected Park Service morale, and he hoped his assurances might help improve it.4

George Hartzog was no wilderness hand. Born and raised in the East, his park experience had been primarily in eastern, urban settings, and he was devoted to the idea of bringing the parks to the people. Conservationists in general and wilderness advocates in particular expressed no strong concern at Wirth's departure as they had a decade earlier when Drury was forced reluctantly into retirement. While Wirth had not proven as disastrous to preservationist interests as some had predicted when he was appointed in 1952, most were not sorry to see him go. They viewed him at best as an obstruction ist to their wilderness protection goals. One reason conservationist concern may have been muted about Hartzog's appointment despite his lack of a record on wilderness issues was that Secretary Udall seemed a strong supporter, and with prospects for the wilderness legislation brightening, advocates appeared to be in a much stronger position than when Wirth became director. If the legislation passed, they would have a potent tool to force the National Park Service to live up to its long-espoused wilderness protection ideals.

One of the new director's first major policy changes was the establishment of a three-part classification system for the national parks. There would be recreational, historical, and natural areas “so that resources may be appropriately identified and managed in terms of their inherent values and appropriate uses.”5 Robert Sterling Yard would have approved of this, for while the “natural area” category was not called “primeval” as he would have preferred, it constituted recognition that the national park system consisted of parts with quite distinct resource values that required different management priorities and skills. Most significantly, it seemed to recognize that in some parts of the system “recreation” would not be of paramount concern. This policy decision held out the possibility that in some areas preservation of natural values would not compete with recreational values. It might promise a resolution of the perennial conflict between the “conserve” and “provide for the enjoyment of” elements of the National Park Service Act of 1916.

Foresta and others regard this new approach as a “milestone in park management policy because it prompted the Park Service to adopt a preservationist orientation in a large number of parks.”⁶ It was, in their view, a response to the criticisms of Mission 66 that the service was sacrificing natural park values to accommodate visitors. Roads had been the greatest concern, and Hartzog publicly disavowed support for road building in parks where natural values were paramount. Addressing the crowding in Yosemite Valley and alternatives to automobiles for transportation in the parks, he proclaimed that “people want some alternative. No more roads will be built or widened until these alternatives are explored.…We need to limit access to parks and wilderness. We've simply got to do something besides build roads in these parks if we're going to have any parks left.”7 Under Hartzog the Park Service view of roads took a turn that has been maintained since. There would be new roads and new euphemisms for roads such as “motor nature trails,” but the era of extensive road building in national parks was over.

The new classification system, conveyed as a directive from Udall to Hartzog in July 1964, was a response to the growing environmental concern soon to be called “environmentalism” in contrast to an earlier “conservation.” Udall's memo to Hartzog notes that “in recent decades, with exploding population and diminishing open space, the urgent need for national recreation areas is receiving new emphasis and attention.” The Park Service would, he directed, address this with recreation areas where provision of access would be a central goal. In natural areas, the recommendations of the Advisory Board on Wildlife Management would be implemented. Physical developments would be limited “to those that are necessary and appropriate.” As for wilderness, “Park management shall recognize and respect wilderness as a whole environment of living things whose use and enjoyment depend on their continuing interrelationship free of man's spoliation.”⁸ The secretary declared that “the concern of the National Park Service is the wilderness, the wildlife, the history, the recreational opportunities, etc., within the areas of the System and the appropriate uses of these resources.” He thus directed the agency and its new leader to respond to the emergent ecological concerns reflected in the Leopold and National Academy reports as well as to the soon-to-be-passed Wilderness Act. It was, at the same time, to respond to the growing demand for outdoor recreation. Hartzog may not have been primarily interested in preservation of wilderness and wildlife, but his instructions were clear. He would have to find a way to manage parks as both playgrounds and preserves.

THE WILDERNESS ACT

President Lyndon Johnson signed the Wilderness Act on September 3, 1964, and the federal agencies began analyzing what would be involved in its implementation. They needed to start immediately because Section 3(c) stipulated that the Department of the Interior review every roadless area of 5,000 contiguous acres or more in the national park system within ten years and report to the president on the suitability or unsuitability of those areas for preservation as wilderness. Similar instructions and deadlines were issued for national forest primitive areas and wildlife refuges. The Park Service was to complete one-third of the reviews within three years, not less than two-thirds within seven years, and the remainder by the ten-year deadline. The president, in turn, was required to convey his recommendations based on these reviews to Congress, which would then decide whether or not an area would become part of the National Wilderness Preservation System. The act required that “nothing…shall, by implication or otherwise, be construed to lessen the statutory authority of the Secretary of the Interior with respect to the maintenance of roadless areas within units of the national park system.” Here was the provision, inserted to allay Park Service concerns expressed early in the debate over the legislation, assuring that no action under the act would lessen protection of parks mandated by earlier legislation. This was restated even more specifically in Section 4(a). Should any change be made in a wilderness established by Congress, it could be made only by affirmative action of that body. Thus was all discretion for setting wilderness boundaries removed from agency purview once a wilderness had been congressionally established. An agency could recommend but not decide.

Another reason for the Park Service and other agencies to get to work was that Section 3(d) required that the public be involved in agency wilderness reviews. This would involve public hearings and the processing of the information gathered at these hearings and from all other public officials with an interest in proposed wilderness designation. Such public participation was up to this time unheard of in the practices of the federal land-management agencies, and it would prove to be a large, politically charged, and time-consuming process. Congress expected the agencies to listen to the people on wilderness proposals and to incorporate what they heard into those proposals.

The review to determine which roadless areas to recommend for the National Wilderness Preservation System would require application of a definition of wilderness, and agreement on a definition had always been and would continue to be a problem. Section 2(c) provided a definition:

A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain.9

This was a definition of an ideal, and Congress recognized that the ideal was rare if it existed at all. Attempting to balance the ideal with the real out on the federal lands, the drafters of the legislation further defined areas to be considered as land “which generally appears to have been affected primarily by the forces of nature, with the imprint of man substantially unnoticeable” (italics added). The intent of Congress was to create a system that incorporated the ideals of wilderness philosophers like Muir, Leopold, and Marshall but without adding too many qualifications to the definitions.¹⁰ Still, anticipating that too pure and ideal a definition would impose severe limitations on what might qualify for the wilderness system, drafters left some room for interpretation, which would lead to other problems.

The opening statement of the act was a clear and unambiguous refutation of the Park Service's long-held position that it was providing, under existing law, all the protection necessary for wild parkland. Section 2(c) begins,

In order to assure that an increasing population, accompanied by expanding settlement and growing mechanization, does not occupy and modify all areas within the United States and its possessions, leaving no lands designated for preservation and protection in their natural condition, it is hereby declared to be the policy of the Congress to secure for the American people of present and future generations the benefit of an enduring resource of wilderness.

Congress agreed with Zahniser and others that, with growing visitation and responses to it like the road building of Mission 66, the long-term protection of national park roadless areas was by no means assured. More protection was needed, and one intent of the Wilderness Act was to provide that protection.¹¹

Use of wilderness areas was taken up in the act's Section 4. Its purpose was to be “within and supplemental” to the purposes for which existing units of the national park and other public land systems were established. Wilderness was to be devoted to recreation, scenic, scientific, educational, conservation, and historical use. Prohibited uses were catalogued with qualifications such as “except as necessary to meet minimum requirements for the administration of the area for purposes of this Act.” This and other qualifications would lead to difficulty later when areas had been designated and management policy was developed. Specifically, the act stated that “there shall be no temporary roads, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such areas.” As the Park Service proceeded to develop its wilderness proposals during the review period, many questions would arise regarding “chalets,” shelters, and docks, which the Service often ruled excluded an area from wilderness and thus must constitute an “enclave” if within a proposed wilderness unit. Section 4 also stated that some uses that might affect national parks were expressly permitted, including established uses of aircraft and motorboats, actions to control fire, insects, and disease, and “commercial services…to the extent necessary for activities which are proper for realizing the recreational or other wilderness purposes of the area.” Mining was addressed at length in Section 4(d) but applied primarily to national forests, since most national park lands were withdrawn from mineral entry. There were at the time of the act's passage six national park system units that were open to mineral entry, and they posed a problem that would be addressed later. As implementation of the act unfolded, all of these provisions would raise a flock of issues that would slow progress and lead to many conflicts between the Park Service and conservationists.

The act specified that national forest “wilderness,” “wild,” and “canoe” areas would by its approval be designated wilderness, thereby creating fifty-four national forest wilderness areas totaling 9.1 million acres. It stipulated that national forest primitive areas were to be managed according to regulations in effect when the act was approved until Congress determined whether they would be designated as wilderness. Nothing was said about management of Department of Interior lands to be reviewed, thus creating some confusion.12 The Department of the Interior was thereby given more latitude than the Department of Agriculture in managing the roadless areas it must review. Park Service road plans would consequently be closely watched by conservationists during the review period. A proposed road in Great Smoky Mountains National Park would, right at the start, be a very contentious issue.

To this point in its history the National Park Service had managed to avoid what it saw as the conceptual constraints of “wilderness” as defined by people outside the service. Robert Sterling Yard had wrestled mightily with terminology, but while he might have been unsure what term to use, he knew what he wanted it to mean—preservation in roadless condition of the as yet pristine and mostly unchanged backcountry of the national parks. Aldo Leopold and Bob Marshall conceived of wilderness similarly but added the idea that such land would serve a particular recreational approach—primitive travel on foot or horseback without modern amenities. The Park Service had recognized these ideas and catered to them to some extent, but it was also engaged in what came to be called “industrial tourism.” It would protect the wilderness as long as it could—most Park Service people thought (and hoped) that would be a long time, perhaps forever in some places—but if the public demand grew so as to require development even of remote places, it wished to be free to exercise its professional judgment on how that development might be done. The Wilderness Act defined the purpose of wilderness preservation in a more clear and restrictive way. It established “a national policy of maintaining a system of areas where natural processes could operate as freely as possible. Recreational use was an appropriate use of these areas only so long as it was consistent with this purpose.”13 This policy should pose no problems for the Park Service, which had for so long claimed to be protecting nature in its parks, but it would continue to have difficulty as it attempted to comply with the act.

THE DEVELOPMENT OF REGULATIONS AND PROCEDURES

With passage of the Wilderness Act, the land management agencies’ first job was to establish policies and procedures for implementating it. How should the new mandate to review roadless areas and recommend wilderness designations fit into the ongoing planning the Park Service was doing? How should the Wilderness Act implementation relate to the many other initiatives under way in the park system, such as implementation of the Leopold report, development of management guidelines for “natural areas,” new area studies (and politics) in places like the North Cascades and Sawtooth Mountains, and the National Recreation Plan being developed by the Bureau of Outdoor Recreation? How would the new work be accomplished with no new resources to dedicate to it? The National Park Service was required to develop and apply a complex, bureaucratic procedure involving public input on a new scale for review of fifty-seven areas.

The Park Service did not swing into immediate action on this. Minutes of Director Hartzog's staff meetings make no mention of wilderness until a February 1965 discussion of master planning, where it was noted that master planning would have to be accelerated because of the schedules of the Wilderness Act and the National Recreation Plan. In late 1964 Hartzog had sought answers to several questions from Secretary Udall. He proposed to develop no special organization within the National Park Service for wilderness and would incorporate planning for wilderness into established master planning procedures. Udall thought that would be fine. Should a moratorium on development and road construction be put in place while park system lands were classified? Udall did not think this would be necessary. Should the Park Service proceed with efforts to upgrade national monuments such as Death Valley, Glacier Bay, and Organ Pipe Cactus to national park status while wilderness review and associated mining studies were being done? Udall thought they should. Hartzog told the secretary that the Park Service review would begin with those parks having the most clear-cut wilderness sections, such as Great Smoky Mountains and Yellowstone. Udall thought that a fine approach and requested that a schedule for review be prepared and submitted to him as soon as possible. Hartzog was satisfied that the Park Service was set to proceed.14

As the Park Service launched this effort it was several years into its new role as partner to the Bureau of Outdoor Recreation. The bureau had taken over national recreation planning and as part of that was applying a national land classification system that had been developed by the Outdoor Recreation Resources Review Commission. The Park Service was attempting to use this system in its planning, adapting it as necessary to suit its special needs. It was mapping existing land uses and ORRRC land classifications for each park as well as in the region adjacent to the park, which required delineation of various land classifications within the parks and rationales for these classifications. All of this was being fitted into master planning.

The classification system included the following categories:

Class I, or High-Density Recreation Areas, were places such as Camp Curry in Yosemite Valley or Grand Canyon Village at Grand Canyon National Park that featured a road network, parking, stores and shops, and administrative facilities, among others things. A high level of development was the defining characteristic of this category.

Class II, General Outdoor Recreation Areas, encompassed less intensively developed areas of a park that received heavy recreational use. These were developed areas with two-way roads, parking and picnic areas, campgrounds, marinas, even administrative facilities, but in a less dense pattern than Class I.

Class III, Natural Environment Areas, included lands used for activities dependent on qualities of the natural environment, such as sightseeing, hiking, nature study, and mountaineering. The Park Service Master Plan Handbook stated that the primary objective of such areas was “to provide for traditional recreation experience in the out of doors.” Acceptable development might include “motor nature trails,” trails, interpretive shelters, and “minimum” sanitary facilities. The Park Service considered this category to be the “wilderness threshold,” about which more will be said later.

Class IV, Outstanding Natural Features, were unique areas, usually of limited size, of exceptional or irreplaceable nature such as Old Faithful or Devil's Tower. They might be developed only for research, though the actual features might be surrounded by Class I or II (as at Old Faithful). This category was reminiscent of the “sacred areas” of early park master plans.

Class V, Primitive Areas, were the wild and undeveloped lands, those free of commercial use and mechanization of any kind, and large enough for visitors to have a “wilderness experience.” These were the areas to be studied for wilderness classification (at least in Park Service plans; conservationists thought large portions of Class III should also be considered).

Class VI, Historic and Cultural Sites, were places of historical or cultural significance. Management's aim was preservation and restoration, with all development governed by these goals.

This, then, was the system the Park Service would have to work into its master planning and wilderness review, with Class V most important to carrying out the review mandate of the Wilderness Act.15

Speaking to the National Park Service Superintendents Conference in Gatlinburg, Tennessee, in September 1965, Assistant Director Theodore Swem addressed the general subject of master planning and the challenges to it posed by the Wilderness Act. He pointed out that for the first time “we will have to consider wilderness as a very precise thing and recommend it on that basis” (italics added). Master planners, said Swem, could no longer think of wilderness as what was left over after planning for development but must precisely define and designate it as a land allocation unit. This must be done thoroughly and carefully, and “it will be necessary by the time we propose lands for wilderness classification that our planning thinking be refined enough that we may recommend the commitment of lands to basic types of use for what we must assume for all practical purposes to be in perpetuity.”¹⁶ Swem made clear to his colleagues the importance of the decisions they would be making—once the recommendation for wilderness went to the president from National Park Service planning teams, decisions regarding what would or would not be wilderness would be out of agency control. Swem was personally a supporter of wilderness and a sitting member of the governing council of The Wilderness Society, but he refrained from any advocacy in this speech. Still, he strongly stated the importance and nature of the wilderness review that was beginning in 1965.

Director Hartzog addressed the same conference and spoke directly to the wilderness review. He noted that the Bureau of Outdoor Recreation had directed that wilderness be a subdivision of Class V.

There is not an overwhelming difference in the day-to-day management of primitive lands and wilderness lands. There is, however, an all-important difference in the legal significance of primitive lands and wilderness lands. Primitive lands may be classified and re-classified through administrative procedures. Wilderness lands, on the other hand, may be classified and re-classified only by legislative enactments of Congress. We can no longer lump wilderness lands and primitive lands together.17

One year after the Wilderness Act was signed, the general was informing his troops of the nature of the work to be done. “Our responsibilities for wilderness management are strengthened and heightened under the Wilderness Act,” Hartzog continued. “We are cognizant that more than ever we must evolve new and dynamic concepts of management to attain the goals that have been laid down.” If any of his listeners thought that it would be business as usual in regard to wilderness, he put that idea to rest. “We are not satisfied that we have yet developed adequate wilderness management programs.”¹⁸ Hartzog told the superintendents that doing this job would likely involve more regulation of visitors and more and differently trained rangers and naturalists. Then he brought up an idea that went back to Wirth:

We intend to experiment further with the concept of the wilderness threshold. The wilderness threshold implies both a physical location and a kind of experience. It can serve not only as a buffer for the wilderness but also as a zone of orientation where the newcomer may explore the mood and temper of the wild country beyond that beckons him.…The wilderness threshold provides unequalled opportunity for interpretation of the meaning of wilderness.¹⁹

Hartzog also announced that the first wilderness review and proposal—the pilot for this program—would be the master plan and wilderness proposal for Great Smoky Mountains National Park.

A process to prepare a wilderness proposal for Great Smoky Mountains and other parks had to be developed. In February 1966 the secretary of the interior formally delegated authority to the Park Service to make the wilderness studies and approved procedures for doing them. The first task was to conduct a “field study,” which involved examining the master plan and the purposes and management of the park under study. A land classification plan, using the Bureau of Outdoor Recreation system, was then prepared, followed by a wilderness proposal drawn on a map of the area. The wilderness review team applied the definition of “roadless area” as in the federal regulations, which specified that it was a “reasonably compact area of undeveloped federal land which possesses the general characteristics of a wilderness and within which there is no improved road that is suitable for public travel by means of four-wheeled, motorized vehicles intended primarily for highway use.”20 A wilderness report was written by the team, incorporated into the master plan, then reviewed by the park superintendent and regional director. This was then passed on to the Washington office, where it was analyzed “in terms of its wilderness threshold concepts, ecological implications, regional planning, legislation, inholdings, water rights, and grazing and contiguous lands.”²¹ Next it was passed to the Wilderness Committee (which comprised six Park Service Washington office specialists in relevant fields), the director, and finally to the assistant secretary of the interior for fish, wildlife, and parks. If the proposal got by all of this scrutiny, it was then released to the public, a public hearing date was set, and the hearing was held. After the hearing the Park Service analyzed letters received and statements heard and prepared its wilderness proposal, which went to the secretary and last to the president, who, after tweaking it, would send it on to Congress.

This eighteen-step bureaucratic process would have to be repeated at least fifty-seven times if the Park Service was to comply with the mandate of the Wilderness Act. The agency would be very slow in doing its reviews and would be accused of intentionally dragging its feet. This may have been a fair accusation, since one would expect that the Park Service would be able to go through the early stages of the process fairly quickly with the intimate knowledge of its parks derived from long management of most of them. At the same time, scrutiny at so many levels prior to public hearings and then afterward surely contributed to a nearly glacial slowness in review of all fifty-seven park units. Finally, the sheer scale of the task indicates what a strain this must have added to the staff of the Park Service. Congress had given them a huge task, with no additional resources with which to carry it out. At a director's staff meeting in August 1966 devoted to wilderness review, Park Service Associate Director Clark Stratton remarked, “So far, I might say that we haven't received the first nickel to help us out financially in preparation of all the data that's necessary [to do the reviews].”22

Had the Park Service been willing and able to get right to work on its review, it would have been delayed while waiting for regulations governing application of the Wilderness Act to come from the Department of the Interior. These were not forthcoming until February 17, 1966, seventeen months after passage of the legislation. Thus nearly a year and a half of the ten years allowed for the work passed before the Park Service could begin its review. Why did it take so long to draw up the regulations? Proposed regulations were published in the Federal Register on July 28, 1965, with a revised draft circulated in November. Conservationists had many issues with the original draft: the definition of “roadless area” was too restrictive; a regional planning approach was absent; there would be inadequate access to information about agency proposals; the public notice period for hearings was too short; issues involving mineral surveys were unresolved. The November draft responded to many of the conservationists’ concerns, but they were still unhappy. They especially feared that the Interior regulations might open the door to mineral exploration of the national park and refuge systems. They argued that the regulations did not reflect the language of the Wilderness Act. These concerns were raised and some were resolved, but the process of resolving them took time. Definitions from the act were included in the regulations, terms such as “roadless area” were clarified, and the public notice period was increased from six weeks to sixty days.²³ Finally, after months of wrangling, the regulations were issued and the “pilot” national park wilderness hearing, for Great Smoky Mountains National Park, could be held.

EARLY STAGES OF THE REVIEW

The Great Smoky Mountains proposal would be a test for everyone. Conservationists would be primed to judge whether the Park Service was applying the law as rigorously as they thought it should. The Park Service would be testing its procedures, but more important would be attempting to blend its interpretation and application of the Wilderness Act with its other duties as it perceived them. Great Smoky Mountains National Park, as the largest intact mountain wilderness east of the Great Plains, offered much potential as a candidate for inclusion in the National Wilderness Preservation System. How would things go there?

Hearings were held in Gatlinburg, Tennessee, and Bryson City, North Carolina, in June 1966. The Park Service presented its plan, and a hearing officer took testimony. “Conservationists the world over are looking to our National Park Service for exemplary leadership in the field of safeguarding the beauty and character of natural lands and sites,” said Stewart Brandborg of The Wilderness Society in his testimony. “It would be most unfortunate if the Park Service were unable to fulfill this role in the Smokies.”24 Testimony quickly revealed that many thought the Park Service fell far short of this role with its proposal.

The proposed wilderness would include 247,000 acres in six blocks ranging from 5,000 to 110,000 acres. The wilderness was chopped up by a proposed new trans-mountain highway across the park from North Carolina to Tennessee. The main line of the road and inner loop roads were excluded from proposed wilderness. Conservationists knew this was coming, since George Hartzog (despite his protestations about no new roads) had announced the proposed road in 1965. The road was not a new scheme and had been debated in one form or another since the mid-1940s, but here was a classic confrontation of the two forces central to the park wilderness issue from the beginning—roads for recreation versus protection of primeval landscapes. The Park Service seemed to confirm the worst fears of its critics and to throw down the gauntlet on the issue of development versus wilderness. It seemed arrogant because it could hardly have begun the review process with a more controversial case. Earlier, in his exchange with Udall, Hartzog had characterized the Great Smoky Mountains proposal as a straightforward one. He could hardly have been more wrong.

Conservationist opposition to the proposal was unified and vocal. Testimony was heard from 184 people (52 in favor and 132 against), and 5,400 letters were received. Those testifying for the proposal were primarily local officials and boosters happy at the economic prospects that would come with the new road. The Appalachian Trail Conference, National Audubon Society, Izaak Walton League, National Parks Association, Nature Conservancy, The Wilderness Society, and Sierra Club were all opposed. Conservationists thought no new road should bisect the park's wilderness, which should be at least 350,000 acres. Three major counterproposals were brought forward. When the Park Service completed the transcript of the hearing, it totaled 992 pages.

Two months after the hearing on the Smokies, a director's staff meeting was devoted to discussion of wilderness review. In Director Hartzog's absence, Associate Director Clark Stratton presided. Lessons learned from the Great Smoky Mountains experience were discussed. One obvious lesson was that conservationists were doing their homework and would challenge any weaknesses they perceived in agency proposals, which surprised no one. One participant in the meeting said that “we are in sort of an adversary position with the conservation groups who are our friends.” John Reshoft, in charge of the whole wilderness review process at this point, observed that most people involved in the hearing wanted “more wilderness, not less.”25 Perhaps most revealing was a comment by Stratton that “we had the Transmountain Road which practically overshadowed the Wilderness Proposal that we were trying to put forward.” This seemed to him a “complicating factor” unique to the Great Smoky case. In Stratton's mind the road and wilderness proposals seemed separate issues, a remarkably naive view for a senior Park Service official at this stage in the wilderness game. No one in the long discussion that August day, except perhaps Reshoft, seemed to grasp that the central lesson from the Smokies experience might be that any effort to minimize wilderness in the national parks would be seen as such and strongly challenged. Stratton summed up what he thought the Park Service had learned:

Since many of the conservation organizations are already studying these same areas that we are coming up with, it necessitates us having all of our ducks in a row and really doing a good job, or the summaries that come in are going to result in overwhelming proposals, in some cases, against what the Park Service is proposing.²⁶

To Stratton, the problem seemed procedural. If the “ducks” were lined up—that is, if the plans and rationales were well organized and procedures dutifully followed—all would be well. He would be proven very wrong in this assessment.

Ten days before this director's meeting, Hartzog had issued planning procedures for national park wilderness that would prove the seed of much conservationist discontent. The seed had been planted by the Bureau of Outdoor Recreation's classification system and would grow to cast a shadow over nearly the entire national park wilderness review process. Hartzog made the grand claims that the “wilderness concept has under-girded the management of national parks for nearly a century” and that the national park movement had been “a focal point and fountainhead for an evolving wilderness philosophy within our country.” He went on to say that “the basic philosophy influencing the use and management of the parks is one of preserving large areas of wilderness, while at the same time providing it with a surrounding natural setting or environment—or ‘wilderness threshold.’”27 The Park Service had, of course, used the term “wilderness threshold” since 1962 (before the Bureau of Outdoor Recreation classification system) when Wirth's Long Range Requirements Task Force had introduced the term into the planning lexicon. It had been presented in the National Park Service Plan at the Conference of Challenges, the superintendents’ conference convened at Yosemite in October 1963. The three-category national park system scheme had also been unveiled at that time. Of the “Goals for Scenic and Scientific Parks” presented at this meeting, one was, “To continue to reserve the primitive, roadless wilderness for all visitors willing to use the wilderness on its own terms.” A second was, “To encourage wider enjoyment of the less rugged portions of the back country by making more accessible the ‘Wilderness Threshold’ lying between developed areas and the primitive wilderness.”²⁸ Nearly a year before final passage of the Wilderness Act, the Park Service was embracing an intermediate concept of land use that it hoped would allow it to locate wilderness boundaries to assure more management flexibility than if there were just two categories of land use, or “zones” as it called them—developed and “wilderness.” There is surely irony here, since the Park Service had so long insisted that there were only developed and undeveloped or “wilderness” areas of the parks.

Back in 1959 Wirth had decided that regardless of whether a wilderness bill was ever to be approved, “we should proceed on our own with analysis of the [national park] areas to find out which areas we want to define as ‘developed areas’ to meet terms of the bill.” The aim was to look far ahead and project where new roads and other developments would be needed and put them in the master plans. If a wilderness bill was passed and parts of the parks went into a National Wilderness Preservation System, it would be difficult to designate any new roads and developed areas. Discussing how wide road corridors should be, Wirth thought that a half mile on each side of a road should be enough.²⁹ Some work was done on this in the context of master planning, but the significance of Wirth's approach is that well before the Park Service found itself faced with wilderness reviews, it was trying to figure out how it might reduce the impact of a wilderness act on its ability to accommodate the increasing numbers of automobile-borne visitors that were coming to the parks. This was not an unreasonable approach, but the idea of “wilderness threshold” that came out of it was to be a big headache when the Wilderness Act was approved and the Park Service maneuvered to retain some of its management autonomy through the use of “thresholds” and other stratagems.

There is no doubt that, in addition to pushing back the boundary of wilderness defined by the Wilderness Act, some in the Park Service thought they could define their own concept of wilderness. At the director's staff meeting in August 1966, John Reshoft commented that one “important thing to keep in mind on wilderness threshold is that the Wilderness Act does not require all agencies to necessarily have the same kind of wilderness. There might be a different kind of wilderness, in one sense, in some national parks.”30 Exactly what Reshoft meant by this is not clear, but this remark in the context of their exploration of the threshold concept suggests that there was interest in floating such ideas to see if they might give their agency some room to maneuver in its balancing of the preservation and recreation missions as it did its wilderness reviews.

The Great Smoky Mountains wilderness hearing was followed by hearings for Craters of the Moon National Monument in August, Lassen Volcanic National Park in September, Sequoia and Kings Canyon in November, and Isle Royale at the end of January 1967. The trans-mountain highway controversy in the Smokies eclipsed all other issues there, but the wilderness threshold became a high-profile issue at these subsequent hearings. Sierra Club Conservation Director Mike McCloskey devoted much of his Lassen testimony to it. He pointed out that since the 1920s the Park Service had been claiming that the national parks were “seas of wilderness with merely occasional threads of development running through them; ‘step back ten feet off the road,’ they said, ‘and you are in the wilderness that runs back miles.’” Now, with the Park Service applying the Bureau of Outdoor Recreation classification system and the threshold idea in its planning, it seemed to view wilderness not “as the sea within the park boundaries—but rather as a series of islands within a sea of various levels of development.”³¹ The threshold, McCloskey argued, was a wilderness buffer as the Park Service was proposing it at Lassen and elsewhere, and it was a buffer outside the wilderness rather than within it. The Sierra Club believed the wilderness boundary should be adjacent to roads, not some distance back from them as the Park Service was proposing.

In defining the boundaries for its wilderness islands, generally the Washington office has withdrawn wilderness boundaries by a mile or more from existing roads to place the buffer outside the wilderness. Generous Class III areas for light development are reserved. Because the current master plan does not indicate that development is planned or approved in these areas, the areas serve merely as an unspecified hedge against the future to allow greatly expanded development. This is what the Wilderness Act was designed to prevent.32

The Sierra Club thought the Park Service proposal designating less than half of Lassen as wilderness was far short of what it ought to be. It considered the wilderness threshold as nothing but a ploy to allow for “light development.”

The same opinion about thresholds was held by at least one National Park Service veteran. S. Herbert Evison had enjoyed a long career with the Park Service, serving as its chief of information services from 1946 to 1958. Initially he had thought the threshold a good idea—it would allow the uninitiated to be introduced to wilderness. But as the wilderness hearings began, he changed his mind. He had been disappointed, he wrote, to learn that “though the threshold of a house is part of the house, the Service considers the wilderness threshold not a part of the wilderness and is willing, in the Great Smokies at least, to build so-called ‘motor nature trails’ into it at half a dozen or more points—thus greatly reducing the area within that park that would meet the wilderness standards established by the Wilderness Act.”³³ Evison was chagrined to find provision for thresholds even in the wilderness proposal for Isle Royale National Park. In a letter to the hearings officer, he wrote that “service policy seems to be to provide for public use of ‘wilderness threshold’ by construction of ‘motor nature trails,’ but, since motor vehicles are not used on Isle Royale, even this poor excuse for the exclusion of de facto wilderness seems to be lacking.”³⁴ Not only was his revered agency misguided in its policy, but it seemed to be engaged in sloppy preparation of its proposals.

Evison tried to convince George Hartzog to reconsider the approach he was taking. Thresholds in parks were one thing, but to propose “motor nature trails” in them was quite another. This confirmed suspicions of conservationists long skeptical of the Park Service commitment to wilderness that it would use any way it could to reduce park areas eligible for protection under the Wilderness Act. Evison wrote Hartzog that motor nature trails in wilderness thresholds “seemed to justify doubts of the validity of the Service assertions that areas not included in designated wilderness could continue to get adequate protection.”³⁵

Hartzog's mind was not changed. In April he addressed the Tenth Biennial Wilderness Conference in San Francisco and claimed that from the beginning of the national park system Congress had intended there to be “enclaves of development” for the accommodation of visitors and “transition zones” between development and “untrammeled, primeval wilderness.” He reiterated Albright's claim that since the beginning “wilderness preservation has under-girded the management of our National Park System,” that the national parks have remained wild and, in some cases, such as Sequoia, had become even more so. He described the classification system and explained the rationale for wilderness thresholds; they would be invaluable for research, interpretation, and to provide a “foretaste of the wilderness beyond.” He mentioned the light development planned for the thresholds, including “one-way motor nature trails.” Visitors to the national parks, he concluded, would find them “unimpaired” and “enjoy the finest wilderness in our Nation—lands and waters that meet the highest standards yet devised for wilderness preservation.”36 His audience was not convinced.

The Wilderness Society's Stewart Brandborg also approached the podium at this conference. He praised the Park Service in general for its planning procedures, especially its pledge to open its master planning to more public involvement. He complained of “confusion introduced by the classification system and the use of thresholds.” Brandborg said that “there continues to be an underlying basic question as to whether any land in the National Parks should be designated for high density, recreation use.”37 Brandborg, in this comment, revealed a fundamental issue of the wilderness review. Some conservationists believed that no further development of national parks should occur and would try to use the Wilderness Act to achieve this goal. Many in the Park Service, on the other hand, believed that pressure of visitation on the parks would continue to grow, and one way to address this demand was to keep open as many options for development as possible. This was, on one level, a clash between some who thought that the only way to protect the parks was to close them to further development and those who felt that national parks were the people's parks and as more people came to them there would of necessity be more development to meet this demand. On the other hand, nearly everyone could agree that another way to meet growing demand was to create more parks and to create them as close to the people as there was parkland available. This work was ongoing and was common ground for all parties interested in the future of national parks. Drives were under way both for new wilderness parks and for recreation areas close to the people.

The first review period during which the Park Service was to review one-third of its wilderness ended September 3, 1967. The review fell short of the goal because of slow development of regulations and procedures. Only ten field hearings had been held by this date. The goal had been nineteen. No penalty was exacted for falling behind schedule, but this meant the schedule would be more crowded during the next review period. Every National Park Service wilderness review proposal except one had been smaller than conservationists thought it should be. A tally prepared by The Wilderness Society reveals this (see table 1). The Park Service revised its proposals after hearings, usually adding acreage, but it continued to designate thresholds and its proposals continued to be controversial.

For forty years the Park Service had successfully avoided drawing boundaries around the portions of the national park system that were “unimpaired.” As the reviews mandated by the Wilderness Act revealed, it had succeeded in keeping large parts of the system sufficiently unimpaired to qualify as wilderness according to Wilderness Act definitions. Now, when it faced a legal mandate to draw wilderness boundaries, or at least recommend to Congress where it thought wilderness boundaries should be, it found itself unprepared for the task. Reluctant to even now yield any of what it perceived to be its professional prerogatives, despite the long and politically complex debate that led to the Wilderness Act, it tried many tactics to minimize what it perceived as damage to its authority and autonomy.