11   A NEW SORT OF NATIONAL PARK WILDERNESS

When the new wilderness boundaries were drawn on the maps of Alaska, not much changed on the ground. This was the case partly because little management was actually under way or even possible in most of the new park areas and because, while the Park Service might have had an inclination to launch its management there, it lacked the means to do much. As mentioned earlier, few new personnel were allocated to “manage” the vast new wilderness areas. Ten years after ANILCA, The Wilderness Society's T. H. Watkins, writing in Wilderness, noted that the staffing of new park units had been hopelessly inadequate for a decade. He reported that in 1990 Yellowstone National Park had one full-time employee for every 4,436 acres while the Alaska parks had one for every 297,332 acres. This discrepancy was a bit misleading in that the use pressure on Yellowstone was vastly greater per acre than that in any Alaska park; thus the problems associated with the discrepancy might not be as acute as Watkins suggested. On the other hand, it did reveal a problem—the Park Service in Alaska could do little to actively manage its vast domain with the level of staff it had available. Watkins also reported that a persistent problem in these parks was poaching, and in 1990 the Park Service had, for instance, one ranger-pilot to patrol the huge Wrangell-St. Elias National Park. It could hardly monitor hunting or the condition of wildlife populations with one plane to cover an 8.3 million acre park.1 Even had resources been showered on the new parks, the policy of the Park Service in Alaska and elsewhere was not to take action that would have a lasting effect on resources until a general management plan was developed and approved.2

The Park Service knew quite a bit about the land it now had to manage. It had been studying the landscape for years and during the d-2 period had worked with the Bureau of Land Management (BLM) on interim management of proposed park areas. When President Carter proclaimed the national monuments in 1978 the service was thrust into management more precipitously than it had expected to be, and this brought challenges. For one thing, the proclamations brought no new budget and personnel with them. For another, everyone knew the monument status was intended to be temporary, allowing time for Congress to work out a more permanent arrangement. Thus the Interior Department did not even request a supplemental appropriation but asked instead to reprogram existing funds, which was denied. Not much could be done during the first winter the monuments had been established, though Park Service officials set out to build a relationship with communities they knew to be opposed to the monuments. They also responded successfully to the Great Denali Trespass, a protest in early January.

The following summer, in the face of congressional inaction on Alaska legislation, twenty-one rangers, all commissioned law enforcement officers from various parks and offices in the system, were dispatched to Alaska, with the home parks picking up the cost. The detail was called the Ranger Task Force. Seven task force members were assigned to the field, the rest to the Anchorage office. Out in the monuments, Alaskans had assumed that, given their temporary nature, the new units would allow “business as usual,” whatever that business might be. When they learned that the Ranger Task Force meant to enforce rules that forbade some of their long-established activities, they became hostile. The rangers encountered this hostility in many forms but went about their business of patrolling, answering questions, conducting search and rescue operations, and issuing citations for illegal hunting in the monuments. During the summers of 1979 and 1980, the task force established a Park Service presence in prospective Alaska parklands and indicated that it would protect the resource values that defined them as resources of national significance, including wilderness.3 Hostility was not entirely dissipated over these two seasons, but it lessened as the local people came to know the park personnel. The rangers knew that a big part of their job was establishing relationships with neighbors, and they went about this delicate task carefully and effectively.

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“INSTANT WILDERNESS “ MANAGEMENT

When ANILCA was finally approved, the process of permanent staffing went forward, handicapped not only by a dearth of resources but also by a lack of infrastructure. Back in the 1970s the Park Service had appointed what it called “keymen” for each projected park with the intention that these experienced and knowledgeable hands would play a key role in setting up new area management, but the d-2 process dragged on so long that by 1980 most of them had moved on to other assignments. This meant that most of the staff of the new parks were new to Alaska and had much to learn about the parks and the people. Moving to Alaska has been likened by historian G. Frank Williss to moving back in time to the days of early national parks when rangers lived isolated, often rather primitive lifestyles on the “frontier.” In Alaska in 1980 park personnel found themselves living a lifestyle far removed from the modern world they were accustomed to. They were far from the few urban centers of Alaska, the winters were long, cold, and dark, and amenities were few. Williss describes one case:

Jim Hannah, district ranger at Chitina in Wrangell-St. Elias, typifies the experience of the new Park Service employees in Alaska. Hannah, who came to Alaska from Big Bend National Park in Texas, found himself living with his wife and two teenaged daughters in a cabin with no indoor plumbing, and heated only by a woodstove. For the entire family, a considerable amount of energy would be spent in simply surviving.4

Thus park managers, charged with establishing mostly wilderness parks, found themselves living very close to that wilderness.

ANILCA established thirteen new areas, eight of them with “instant wilderness” totaling over 32 million acres. A complete description of how the Park Service approached the huge task of “managing” this vast and diverse area is beyond the scope of this book, but it is important to get some sense of how it went about this work. Consider, for instance, Katmai National Park and Preserve, a 4.2 million acre unit with nearly 3.5 million acres of instant wilderness. A national monument since 1918 when its unique volcanic landscapes were protected, it lay approximately 250 miles southwest of Anchorage at the beginning of the Alaska Peninsula. The monument had been expanded several times in its history to include 2.7 million acres and was already popular for sport fishing, river trips, and sightseeing. It had a concession that operated two lodges and a fishing camp. A tent camp at the Brooks River was a popular destination for people intent on viewing some of the exceptional population of brown bear that inhabited the area. Katmai was not then a new area to the Park Service, but ANILCA greatly enlarged it and made it mostly wilderness. It consisted of nearly 4 million acres of park and 308,000 acres of preserve, with sport hunting allowed in the latter.

The Park Service had begun deploying backcountry rangers at Katmai in 1972, their primary responsibility being to protect wildlife during the spring and fall hunting seasons. Summer backcountry duty had begun in 1978. ANILCA brought modest increases in budget and staff. In 1979 the monument's budget had been slightly under $300,000, with three permanent staff: a superintendent, a chief ranger, and a maintenance foreman. Fourteen seasonal staff came in during the summer. By 1983 the budget had grown to $680,000, three new permanent staff had been added, and seasonals were up to twenty. Budget growth stalled in the mid-1980s, but by 1992 permanent positions had increased to thirteen.5 The biggest problem for the new park was poaching, since ANILCA had extended the Katmai boundary to include areas used by trappers and hunters who would not stop their activities unless they were required to do so. Rangers were sent to patrol areas of potential problems and, in most cases, the locals responded to the Park Service presence by moving to areas outside the boundaries where they could hunt and trap legally.

Park Superintendent Dave Morris moved his rangers throughout the year to where they were needed most, usually where visitor concentrations necessitated some enforcement of park regulations. In 1982, for instance, a ranger camp was established at the outlet to Nonvianuk Lake, a popular launch point for float trips on the Nonvianuk River. Here rangers offered advice and education about the park rules. As in other wilderness areas the principal way wilderness rules were enforced was simply by establishing presence and explaining good wilderness behavior and the reasons for it. At other times a ranger presence was established along the Big River and the Kamishak River during big salmon runs. Here again the presence of the Park Service increased the likelihood that visitors would behave themselves and observe the wilderness regulations.

Dave Morris tried, in the early 1980s, to put in place interim regulations to address access issues in Katmai. The principal mode of access all over Alaska was (and is) the airplane. Powerful and maneuverable planes with big tires or floats could land in many remote areas, accessing fish, wildlife, scenery, and other resources. Traditional modes of access like this were guaranteed by ANILCA, but there were times and places where landings were so disruptive of wildlife or visitor experiences that the Park Service thought them inappropriate or even a danger to resources. The issue of airplane access was, in Alaska, a major wilderness management issue for the Park Service, different than anywhere else in the National Wilderness Preservation System where planes were simply forbidden to land (with some, though few, exceptions to the rule). Morris's attempt in 1981 to restrict aircraft landings was intended to protect areas with heavy bear populations. He also tried to deny and restrict motorboat access in some areas of the park, again for protection of wildlife and secondarily to protect the wilderness experience of visitors. His efforts were vigorously opposed by natives and sportsmen, and he ultimately dropped the effort. The issue of aerial access would come up again in the planning that would soon be undertaken as required by ANILCA.

Alaska was no different than anywhere else in the National Park System in that visitors concentrated around a limited number of attractions and amenities. This was true at Katmai, where the primary visitor point had for many years been the Brooks River, a rich fishery popular with sportsmen and brown bears. All the attention paid to Alaska in the long fight over the d-2 lands had attracted national interest, and with passage of ANILCA, visitation to the new areas began to grow. This meant that in places like Brooks River the encounters between bears and visitors increased, which could be serious for both visitors and bears. Improved concession services were achieved, with concessionaires offering package tours that added to the growth in visitation. Fly-in anglers and others on day trips to visit the Valley of Ten Thousand Smokes increased pressure in a few areas. Most of the park, however, was relatively unaffected by growing visitor pressure. All of this meant that the Park Service had to marshal its limited resources very carefully, focusing them where they would do the most good. With relatively few people in the Katmai backcountry and potentially serious crowding at places like the Brooks River, most Park Service effort was spent dealing constantly with managing the most accessible areas, at least during the times of heavy visitation, sending rangers into the wilderness majority of the park only when a problem occurred or was anticipated. Out on the ground, then, the enlargement of Katmai and designation of much of it as part of the National Wilderness Preservation System did not result in major changes in management, but it did increase pressure on some park resources and staff.

New parks like Gates of the Arctic and Wrangell-Saint Elias posed an altogether different challenge, since they had no previously established Park Service management except the skeletal cooperative effort of several years working with the Bureau of Land Management. The Ranger Task Force had initiated a small Park Service presence, and the long process of study of these areas had given the service knowledge of the land, resources, and some sense of use patterns, but management had to start from scratch. The Bureau of Land Management approach had been to manage loosely, if at all, so there was much creative work to be done. At Gates the staff spent the entire 1981 season living out of briefcases and backpacks in their effort to figure out what proper management might involve. Patrols were dispatched to the remote northwest areas of the park about every ten days to determine levels of use, develop information about resources, and provide visitor services to people traveling the Kobuk and Noatak Rivers.

Young, ambitious, and adventurous Park Service professionals jumped at the opportunities offered by the new Alaska parks. Bill Paleck was one who responded. He moved to Alaska in 1979 from his position as chief ranger of Wupatki and Sunset Crater Volcano national monuments in Arizona. Paleck's first Alaska jobs were in the regional office, but he soon found himself one of the two initial staff at the vast Wrangell-St. Elias National Park and Preserve where he wore the hats of chief ranger, deputy superintendent, and chief of operations. He had hoped to go to Kenai Fjords National Park, but Regional Director John Cook thought him a better fit for the challenges of Wrangell-St. Elias. Paleck was a big, imposing man who had considerable experience in the field. He would, thought Cook, be able to stand up to any troublesome locals he might encounter, and that would be important at this stage of asserting a Park Service presence. Cook instructed Paleck and Chuck Budge, the superintendent, that they were to establish “custodial management” of the new park and preserve and equipped them with a Chevrolet Luv pickup truck, one four-wheel-drive vehicle, and a Cessna 185 aircraft. Paleck had earlier, on his own initiative, earned a pilot's license knowing it would be an invaluable asset in Alaska, and it would indeed be essential to ranging over more than 13 million acres of park and preserve. Of this area,8.7 million acres had been designated as wilderness, and most of the rest was de facto wilderness.

Paleck and Budge first had to learn the geography and become acquainted with a local community that hardly welcomed them. In the BLM days prior to the park a ranger station had been burned. The plane being used by the 1979 task force members in the area was also burned. During the first two years of park operation a ranger was beaten so badly that he was forced to retire, and yet another ranger station was set afire. At first the locals would not even sell Paleck aviation fuel he needed for his plane. Hostility was so great that some Alaskans went so far as to say that “the only good parky is a dead parky.” This may have been bluster and bravado, but these early Alaska park staff found themselves in a situation not for the faint of heart. To counter such primal emotion, Paleck and Budge spent their first months driving around introducing themselves to as many locals as they could find. They worked to identify the problems that needed immediate attention and to determine what initial management priorities should be. In their meetings with people they tried to explain how the new parks and preserves could be assets to local communities by offering them search and rescue services, EMTs and pilots who could assist in emergencies, and an eventual infusion of tourism dollars that would be a sustained economic benefit. Most locals were doing what they enjoyed doing and were not impressed, but the public relations effort that continues to this day had begun.

One of the biggest challenges was learning the ANCSA and ANILCA legislation and the regulations that emerged from them. Another was applying these regulations in a situation involving airplanes, snow machines, and hunting, all of which were largely alien to traditional national park culture. Paleck and his colleagues—the staff grew from two to twenty-eight during his six years there—had to be careful not to declare an approach to management that could not be enforced. Initially the Park Service took a light-handed approach to enforcement. Paleck describes how, during the 1979 and 1980 task force periods, they could have prosecuted dozens of hunting cases but chose instead to develop three airtight cases that would stand up in court. Rangers at Wrangell-St. Elias worked for two years to figure out how to chase and stop cagey hunting guides engaging in illegal activity. When they finally caught one they did not issue a citation but gave a warning that they had the game figured out and next time would crack down on the offenders, which they subsequently did. When rangers located illegal traplines they would spring the traps and leave a business card. If they found the line a second time, they would confiscate the traps.

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In these early post-ANILCA years the Park Service also wisely made local hires, men who knew their way around in the bush. Professional rangers may have been strong and tough and skilled, but they needed expert help dealing with the extreme conditions of the Alaska winter. Local people needed the jobs, and they proved invaluable in establishing the “credentials” of the Park Service in the field across rural Alaska. Further, they understood the nature of subsistence to a degree impossible for anyone from “outside.” Members of the Alaska community gradually began to make important contributions to the infant park management enterprise.

As to wilderness management in these early days of the new parks, the field people saw the challenge as becoming adept at managing in the wilderness as much as managing for it. Vast wilderness surrounded small human communities that literally derived their livings from those wild lands. All park and preserve regulations merited enforcement, but some activities threatened the wilderness more than others and needed more attention. Mining, long the principal human activity in the new park, topped the list of threats to park resources. In 1976 Congress had passed the Mining in the Parks Act, which authorized the secretary of the interior to establish stringent regulations governing mining in the National Park System. Production of minerals was not widespread in the park system, but there were areas such as Death Valley and Glacier Bay national monuments where mining was present. The new Alaska parks raised the mining problem as never before on national parklands. The number of mining claims in Wrangell-St. Elias alone exceeded the total number of claims in all the parks outside Alaska.

The Mining in the Parks Act resulted in regulations to protect natural features when valid mineral rights were exercised on parklands and prohibited further mining entry. It required that acquisition costs and environmental consequences of working all patented claims be determined and that the validity of unpatented mining claims be established before any further mining activities proceeded. Further, recommendations were to be developed for acquisition of claims or boundary adjustments to minimize the impacts of mining on park resources. The heyday of mining in most Alaska parks, including Wrangell-St. Elias, had passed, but there was still scattered activity that added up to much work for the skeletal Park Service resources that could be allocated to carry out the mandates of the act. First the level of threat to park resources had to be assessed and strategies developed for enforcement of the inevitably unpopular regulations governing mining. Most miners were back in the Alaska bush because they wished to be far from the complex constrictions of less remote places, and mining was what they did for a living. Their options were very limited. Decisions painful to both the miners and federal agents had to be made. Because all of this was taking place in the 1980s, the pain for the Park Service was worse than it might have been at some other time, since it was being pressured from one political direction to tread lightly on the public while pressure from the other side called for strict enforcement of environmental protection laws. In 1985, for instance, a federal court found that the Park Service was violating its own regulations in approving plans for mining operations. It ordered closure of mining in all Alaska national parks until adequate environmental studies could be done and proper permits could be issued.6 The early park stewards at Wrangell-St. Elias and elsewhere in Alaska did what they could, with limited resources, to “manage” issues and problems like this in the wilderness. Strongly proactive management for the wilderness would have to wait for a while.

National Park Service veterans of these early post-ANILCA years, like Paleck, look back fondly on their Alaska service. The work in an often uncomfortable, cold, remote, and hostile environment was hard on families. It was sometimes dangerous. The area was so vast—the Yakutat Ranger Station was 240 miles from Wrangell-St. Elias headquarters at Glennallen—that sometimes the idea of “managing” such a landscape seemed absurd. Paleck figures that in the first couple of years he achieved no more than a 20–25 percent success rate in even traveling from one place to another in the huge park. Still, the work was rewarding. They were on a frontier physically, socially, and historically in the sense of new types of parks and new ideas of wilderness. Administrators back in civilization at the regional and federal headquarters allowed them to push park ideas rather than papers to an unprecedented degree in a federal bureaucracy—at least for a while. Their work initially was on the ground rather than in the office, a delight to people who often were in the Park Service because they loved to be out in the country. These people were, in many ways, pioneering. As Paleck, now a recently retired senior superintendent nearly twenty years after his Alaska service, summarizes his experience, “It was like being in a Jack London novel.” Most of these post-ANILCA “pioneers,” having proved themselves in this frontier crucible, went on to senior Park Service posts and long careers in the agency.

The stories of both old and new Alaska park units reveal how high the learning curve of the National Park Service had to be in Alaska in the early 1980s. Its experience managing land under the dictates of the Wilderness Act was, to this point, relatively little anywhere, since few areas elsewhere in the National Park System outside Alaska had been placed in the system by Congress, and most of those were very recent. The Alaska situation was complicated by the special provisions that made the Alaska wilderness management challenge different than elsewhere in the National Wilderness Preservation System. The scale of the challenge in terms of sheer area was beyond anything early wilderness advocates had even imagined. Add to this the relative scarcity of resources available to actually manage on the ground, and the challenge that faced the initial group of post-ANILCA Alaska park managers was daunting.

On the other hand, at least initially, several factors buffered the challenge. One was the fact that visitation to Alaska park units was, compared with that elsewhere in the National Park System, very light. The cost of going to Alaska parks from the Lower 48 was high, and it was even more costly to go into the backcountry by the usual means, which was by air. Relatively few visitors could or would go to the expense of traveling to the Alaska parks, though the number who did rose each year after ANILCA. The visitation pattern was different from the Lower 48 in another way. While a park and preserve like Katmai might be over 4 million acres in extent and Gates over 8 million, tourists visited only a tiny fraction of this area (though subsistence users traveled much more of some units). Thus park managers did not have to “manage” for the whole park in this initial stage. They could focus on the known areas of highest use and do what was minimally necessary to protect park resources until staffing and management plans could be developed that would allow a more thorough approach to carrying out the mandates of the various laws under which they had to operate.

“Wilderness management” in Alaska was initially and would continue to be different in some ways from that in the rest of the National Wilderness Preservation System. The most obvious difference was that in Alaska the wilderness was “inhabited.” That is, ANILCA allowed subsistence use of wilderness there, which meant that some hunting and motorized travel was allowed even in the most remote areas. Initially the Park Service could only study and monitor what went on as it tried to figure out how to handle this unique situation. What would be the impact of subsistence use on visitors who came for the ultimate wilderness experience? How could any conflicts that might arise around this situation be minimized? A second difference was that in Alaska, wilderness was accessed by a most modern vehicle—the airplane. In the Lower 48, the only place airplanes were allowed in wilderness on a regular basis was in the Boundary Waters area of Minnesota. Airplanes would be everywhere in Alaska wilderness. What limits, if any, should be placed on use of planes? As Dave Morris had learned at Katmai, efforts to restrict access by air would meet strong resistance, and of course air was the only way that most people could even gain access to places they wished to visit. There seemed a built-in contradiction in the Alaska wilderness experience—it was viewed by many would-be visitors as the ultimate wilderness experience since it involved travel into vast areas that had been changed little by humans, yet getting to this “ultimate” experience required modern technology that was itself intrusive on that experience. This dilemma seems to symbolize the nature of the challenge facing Park Service wilderness managers in Alaska.

WILDERNESS IN GENERAL MANAGEMENT PLANS

The Park Service had to be extremely careful in addressing wilderness management challenges on the ground in the initial stages of setting up under ANILCA. Moving too aggressively could bring retribution from the hostile Alaska congressional delegation, which could significantly set back the work. Regional Director John Cook took the approach of doing what was necessary to protect resources and facilitate visitation while tackling the policy issues in the planning mandated by the act.7 The Park Service was given five years to develop general management plans for its thirteen ANILCA areas. The act stipulated that “within five years from the date of the enactment of this Act, the Secretary shall develop and transmit to the appropriate committees of the Congress a conservation and management plan for each of the units.”8 These plans should specify the management practices and programs to address the goals of the parks and preserves. Wilderness was singled out as the key resource.

The Park Service had extensive experience at management planning and was quite expert at it. Further, it had been gathering information about the lands that were in the new parks and preserves over nearly two decades. It had much to work with in this planning effort. As the keymen worked at early plans in the 1970s they became aware that, while traditional park planning approaches and concepts applied in Alaska, the unique opportunities and challenges there required, or at least offered, an opportunity for new management regimes. They “recommended a more flexible, experimental, and evolutionary approach to Park Service planning and management in Alaska, one that would not have an irrevocable effect on new parklands.”9 They envisioned what one planner, Bill Brown, called a “wealth of landscape mosaics,” which included parks meeting traditional Park Service expectations, an intermediate type of park “where access and visitor aids are rudimentary” as in wilderness parklands in the Lower 48, and “outback spaces where visitors will be entirely on their own—wilderness in the absolute sense, compounded by size, weather, and terrain factors only approximated elsewhere.”10 Only the few developed areas in existing parks would fit the first category, parks relatively close to Anchorage or to the limited Alaska road system would be in the second, and most of the park system would be of the third category. Not everyone in the Park Service agreed that Alaska required new approaches—the long debate about recreation versus preservation continued, though at relatively low volume—but the opportunity to preserve large ecosystems and the growing interest among scientists and conservationists in doing so influenced the planning in Alaska. G. Frank Williss describes this as a “shift away from recreational development” that reflected a similar shift elsewhere in the National Park Service's approach to its work, but “the movement toward preservation was … considerably more pronounced in Alaska.”11 Complications for planning came from the need to preserve traditional uses of the land, from the constant anti-preservation pressures of the Alaska community and its congressional delegation, from an administration in power in Washington, DC, that did not believe wilderness was a good idea, and from severely limited resources. The Park Service, in the face of all this, set to work on its management plans.

Initially, with the shortage of resources in Alaska, the regional office there passed the key responsibility to the centralized planning arm of the Park Service, the Denver Service Center. Alaska personnel had all they could do to establish initial management. The responsibility for plans would devolve back to the regional office in 1983. The decision was also made to take an approach that would propose such small-scale actions that an environmental assessment would be sufficient in the planning process rather than a full-scale environmental impact statement (EIS).12 The service had already prepared such detailed environmental impact statements back in the 1973–75 period. The assessment would determine whether the action proposed by the agency was significant enough to require an EIS as mandated by the National Environmental Policy Act (NEPA) or would have no significant impact. This was an important decision for wilderness because it meant that the impact of proposed management upon the wilderness resource when it was primary (as it was in most of the new parks) would be minimal. In this early decision the Park Service signaled that it meant to minimally change the status quo for most of the land.

The management planning process for parks in Alaska, as elsewhere, followed the NEPA dictate that the planning process would determine the scope and significance of issues to be addressed in assessing the environmental impact of a proposed action. This involved collecting public comments, drafting management alternatives, holding public meetings, and, on the basis of input gathered, selecting a preferred management alternative. This final plan was then submitted through the various bureaucratic levels of the Park Service and the Department of the Interior to the president and ultimately to Congress, as required by ANILCA. The Park Service was well schooled in this long and involved process, as has been seen in examining the wilderness reviews that had been done in the Lower 48.

The Park Service followed this process, with minor variations dictated by the circumstances of each area. So how did wilderness factor into all of this, and what does the way they handled this indicate about the Park Service stance on wilderness in Alaska? Plans were developed for thirteen areas, and the individual stories of each area cannot be described or even summarized here. Gates of the Arctic National Park and Preserve (which was nearly named Gates of the Arctic Wilderness Park but for the objections of the Office of Management and Budget to another park classification) provides an interesting and informative example. ANILCA placed most of this park in the National Wilderness Preservation System as instant wilderness and specified that its management emphasize wilderness. First in the legislation's statement of purpose for the park was that it should be managed “to maintain the wild and undeveloped character of the area, including the opportunity for visitors to experience solitude.”13 In its legislative deliberations on ANILCA the Senate Committee on Energy and Natural Resources “recognized that the wilderness values of Gates of the Arctic are paramount and provide a special value to the National Park System.”14 Remote, with relatively little visitation and over 7 million acres of designated wilderness, Gates offered the best opportunity the Park Service would ever have to develop and implement a model wilderness management plan.

The process began for the park and preserve with a Draft Statement for Management that was circulated in May 1982, which was built on an earlier such statement prepared in 1978. In that 1978 statement Gates keyman John Kauffmann had written that “the greatest resource of this park is space: unique recreational space for wandering and solitude and adventure. It is a major reserve of wilderness, the last of such caliber among America's dwindling wilderness resources.”15 The challenge was how to preserve this resource while providing for visitation and accommodating the provisions of ANILCA regarding access and subsistence.

The 1982 draft statement identified several issues. Management would, because of the vast area involved, require use of aircraft. Some areas of the park, such as Arrigetch Peaks, Walker Lake, and the Noatak and North Fork Koyukuk rivers, had already experienced concentrated use and resource damage, yet options for controlling use and encouraging restoration without interfering with the wilderness experience were limited. Should access by air to wilderness, which ANILCA permitted, be restricted and, if so, how? How much regulation of visitors for their safety or for resource protection was too much? To what extent and in what ways could traditional National Park Service approaches to management and the park experience, such as interpretation, be used? All of these issues derived from the challenge of maintaining both the wilderness experience and the wilderness resource. The draft statement proposed management objectives:

•   Allow wilderness recreation with “minimal formal regulatory requirement.”

•   Base resource management on research and monitoring with the goal of maintaining “a primitive environment where natural processes regulate the ecosystem.”

•   Determine optimal use levels that would not damage physical resources or cause “serious disturbance to the wilderness experience.”

•   Provide “adequate and feasible” access to visitors.

•   “Monitor the effect of aircraft use on the wilderness experience and modify that use as necessary to minimize impact on the wilderness experience.”

•   Use visitor programs and interpretation as tools to insure safety and resource protection but not to intrude or promote.16

 

Thus the Park Service identified key issues related to management in general and wilderness in particular and suggested how it might address them.

This statement solicited considerable comment. A letter from the Fairbanks Environmental Center counseled the Park Service to recognize Gates “as the Park unit on the farthest end of the ‘paved to pristine’ spectrum.” It should be the “most protective of natural values” of anywhere in the National Park System. Nothing should be done to promote visitation or to accommodate “convenience-oriented use.”17 Roderick Nash, who had recently visited the park, concentrated many of his suggestions around the management of aircraft, which he saw as the biggest challenge in making access and the wilderness experience compatible in this and other Alaska parks.18 A resident of Bettles, a village on the edge of the park, wrote to say, among other comments, that the Park Service was already promoting too much with a brochure on fishing that “will pave the way for over-fishing of the Gates’ low productivity lakes.”19 Destry Jarvis of the National Parks Conservation Association offered a comment that summarized the views of many about the Draft Statement for Management and the plan the Park Service should develop.

People should not be a dominating subjugative presence and should adapt themselves in such a way that enables them to become an integral part of the whole wilderness and natural resource experience. These resources should not be manipulated and compromised to suit the demands of people.20

Superintendent Dick Ring and the planning team digested these and other comments and proceeded to the next stage.

The Draft General Management Plan for Gates was released in March 1985. It addressed how the Park Service would manage a range of issues over the next ten years, protection of the wilderness resource foremost among them. The draft offered a preferred alternative and three others. Alternative C was the proposed management approach. These alternatives ranged from minimal Park Service action to protect resources to active management.21

Under the proposed alternative the Park Service would “as necessary prescribe visitor behavior or use limitations to ensure that outstanding wilderness opportunities and natural resources remain undiminished.”22 Visitors would be encouraged to register voluntarily, group size would be limited to twelve for river running and six for backpacking, and visitors could stay only three nights in a campsite. Further limits would be placed on groups around heavily used areas like the Arrigetch Peaks. No limits would be placed on fixed-wing aircraft landings within the park, though routes and minimum altitudes would be recommended. Use of snow machines and motorboats could continue for subsistence and access to private lands. No recreational use of snowmobiles would be allowed, and recreational motorboats could be used on only one lake. No structures, permanent camps, roads, or trails would be built.

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The Park Service recognized, in this draft, that while Gates had been designated to protect wilderness, “its designation is also a magnet that will attract an increasing number of visitors.” It continued:

Future land use changes around the park and preserve will delineate the now indistinguishable boundaries. These pressures necessitate active management by the National Park Service, although it is recognized that National Park Service actions can also diminish wilderness. Many major factors are beyond the control of the National Park Service; thus, the proposal and alternative vary only slightly in the future scenarios of the wild and undeveloped character of the area.23

The Park Service concluded that its proposal would maintain the wilderness status quo, “neither significantly improving it nor allowing it to deteriorate.”24

Comment on this proposal, as on all such draft general management plans for Alaska parks, ranged across the spectrum from complaints that the proposal was too restrictive of use and too anti-people to concern that the wilderness resource would be placed at risk by too lax an approach to controlling visitation and, in particular, use of aircraft. John Kauffmann, now retired, wrote that the preferred alternative “is only a palliative for the erosive problems that are appearing in the park or that can be anticipated.” He thought the most restrictive alternative the only one that “stands a chance of holding on to the present wilderness quality of the park and restoring it from some of the wear that has already occurred.”25 He was especially concerned that no visitor permits would be required. How could visitation be effectively controlled, or even monitored, without mandatory permits? He and other protection-oriented critics wondered if all the reference to protection of wilderness in the draft plan was merely rhetoric. The goals were good, but the means to achieve them, they thought, were lacking.

After comments were reviewed, a revised draft was circulated for still more comment, and in 1986 the General Management Plan (GMP) was finalized and published. There were no major changes from earlier drafts, only more detail. The plan stated that “Gates of the Arctic is destined to be America's premier wilderness, and it will remain a wild, undeveloped land” and that “visitor use will change the wilderness experience and the natural environmental integrity, yet the National Park Service must continue to provide opportunities for wilderness recreation. Thus managers must contend with the question ‘What degree of change is acceptable?’”26 The Park Service intended that Gates be the ultimate wilderness in the national park system, thus its management would be the ultimate attempt to manage for wilderness. But the service admitted that it had a limited understanding of how it could achieve its goals. As always, even in the most remote and wild park in the system, the Park Service had to balance use and resource protection. At this stage in its Alaska experience it faced many unanswered questions about wilderness management, some specific to Alaska, some general across the roadless and wild areas of all the parks. What was the carrying capacity of a wilderness park in Alaska or anywhere? What was “carrying capacity” anyhow? How much regulation of use of the wilderness resource, which many visit to experience a freedom not possible elsewhere, was too much? The GMP attacked these and other questions. One objective for Gates, for instance, was to “maintain the wild and undeveloped character of the park and preserve.” A standard for judging whether this was achieved would be that “disturbed/impacted campsites and fire rings do not occur along lakeshores or river/ hiking corridors.”27 The Park Service offered a list of objectives and standards for visitor use management and indicated that it would attempt to apply the standards but fully expected that they would be modified and new standards developed as their experience grew. “If monitoring and research indicated numerous standards are being exceeded … despite reasonable management actions, a new approach to recreational visitor use management may be needed.”28 Clearly the Park Service planners recognized their limitations here. Even as the managers in the field were struggling with challenges of managing wilderness on the ground, the planners, advised by this field experience, were trying to look ahead and decide what needed doing in the long term.

Several years after the GMP for Gates was completed, John Kauffmann published a book about the Brooks Range in which he commented that though the plan “honored nearly all of the precepts planned for this ultimate wilderness park,” prevention of damage, the “cornerstone of all park planning,” had been abandoned. Reasons for this, he thought, were political pressure and the fact that the Park Service “does not like to say no to visitors.” The consequences would be great, for if damaged resources increased (and Kauffmann thought they already had) and capacities that led to such damage were established, “the politics of trying to roll back use will be horrendous.” He continued, “With no policies or mechanisms for control short of disaster, the National Park Service apparently had to adopt the management principle known as acceptable rate of change, with use and development patterns left to evolve without strict adherence to standards.”29 Commenting on a draft of Kauffmann's book, Boyd Evison, who as Alaska regional director had presided over the general management planning process, revealed the complexity of the environment in which the agency was trying to plan and implement the plans.

“Acceptable rate of change” sounds a little like “rate of acceptable change.” I don't believe either has been established as policy for Gates—but the latter is not necessarily bad. It would require definition … and probably regulations. “Acceptable rate of change, and evolutionary development” was, in effect, what Alan Fitzsimmons (Horn staffer) tried to force into National Park Service management policy, but he didn't make it. We don't accept it for Gates.30

The Horn to whom Evison referred was William Horn, assistant secretary of the interior for fish, wildlife, and parks, who had led the Reagan administration drive to frustrate implementation of ANILCA in Alaska since the days of James Watt. Kauffmann and Evison and other Park Service staff past and present in Alaska seem to have been working hard to promote a strong wilderness resource preservation approach there. But, as Evison indicated, those in power had other priorities.

Review of the general management plans for Gates and other Alaska parks indicates that in the mid-1980s the Park Service was taking the wilderness planning and management challenges there very seriously. In the face of strong political pressure from Washington to do less protection rather than more, it was trying to implement the vision developed in the 1960s and 1970s of a flexible, experimental, and evolutionary approach to management. It was not following the recreational development approach that had led to controversial encroachment on wilderness in earlier episodes of the national park wilderness history. On the other hand, as John Kauffmann repeatedly pointed out, it was not doing all that it should do to protect wilderness, though perhaps it was all that it could do under the political circumstances. Another Evison comment to Kauffmann suggests this conclusion:

Your vision of Gates of the Arctic as it might be is a nice one. I guess I'm being defensive when I say I'd rather you didn't seem to be suggesting that the NPS can actually achieve it by unilaterally undoing what is provided for by ANILCA. Senator Stevens told the [Alaska] legislature that he got 80% of what he wanted in ANILCA. I suspect that's about right. Bureaucratic fiat won't overcome it.31

There were limits to what the Park Service could do no matter how much it might be committed to objectives of wilderness protection in Alaska.

The case of Gates of the Arctic National Park and Preserve is offered as one example of how the Park Service addressed its general management planning challenges in Alaska. Each park was different, but the process was the same, and the issues were also generally similar. Emphasis on wilderness was, both legislatively and managerially, a higher priority at Gates than at other areas, but wherever there was “instant wilderness,” the Park Service took the general stance toward future management of it that is manifest in this Gates case. Evison's comments were applicable across the Alaska national park system.

WILDERNESS SUITABILITY STUDIES

As it worked on its management plans, the Park Service also did the wilderness suitability reviews mandated by Section 1317(a) of ANILCA. The act directed the agency to examine all lands in the Alaska parks and preserves not designated as wilderness, decide which were suitable for wilderness designation, and make recommendations to the secretary and thus to the president, who in turn was required to make his recommendations to Congress before December 2, 1987. The suitability reviews were included in general management planning, with recommendations presented in the draft and final GMPs. After the general management plans were approved in 1986, the next step was to prepare an EIS to evaluate the impacts of designating additional wilderness in the parks and preserves.

Since a detailed explanation of what happened for each of the thirteen areas is too much to describe, Gates of the Arctic National Park and Preserve once again offers a good example of this process. First the Park Service had to specify criteria to be used to decide what would qualify for wilderness designation. ANILCA stated that the definition of wilderness should be that of the Wilderness Act, with special wilderness provisions that would apply only to Alaska: existing public use cabins could remain and new ones could be built under certain conditions; navigation aids and research facilities could be constructed (no enclaves in Alaska wilderness); and aircraft and motorboats could continue to be used for traditional activities. To qualify as wilderness in Gates the area must be greater than 5,000 acres and be federal land. Minor disturbances from past activity and little-used, unimproved roads and off-road vehicle trails could not disqualify an area, nor could uninhabited cabins or minimally improved landing strips (no “purity” here either).

The draft GMP reported that the Park Service found 1,009,638 acres in Gates that met the criteria and 190,023 acres that did not. Subsurface mineral rights, all-terrain-vehicle easements, and heavy subsistence use disqualified some places as wilderness. The draft GMP was revised, and the wilderness suitability recommendation did not differ in the final plan. This final GMP stated that “all lands determined suitable for wilderness designation will be managed under the terms of ANILCA to maintain the wilderness character and values of the lands until designation recommendations have been proposed and Congress has acted on the proposals.”32 This policy was important, since pressure was always present to allow activities in de facto wilderness that would depart from the strongly preservation-oriented management line that the Park Service was taking.

Next came the impact assessment process and wilderness recommendation. The Park Service had found 80 percent of nonwilderness land suitable and now had to recommend all or part of that area for possible addition to congressionally designated wilderness. The draft EIS was released for comment on April 15, 1988, with comment accepted until the middle of July. The final EIS was issued in August. Much to the surprise and chagrin of conservationists, the recommendation was for 330,846 acres, or 31 percent of the area judged suitable. Four alternatives were considered: no action, which the Park Service said would result in fragmentation of wilderness-suitable areas and loss of wilderness values; the preferred alternative; a “majority wilderness” alternative that would recommend 90 percent of the suitable area; and a maximum wilderness recommendation that would include all of the study area found suitable.

The alternative selected was on the side of less protection and raised the question of why the Park Service, which had so far seemed to take a protective stance, would settle for less rather than more additional wilderness. The EIS stated unequivocally that the preferred alternative would have significant negative impact on wilderness values.

Because no wilderness would be designated by law in these [southwestern and northeastern] areas, policy over the long term would vary and competition between the objectives of preserving park values and allowing and providing for recreational use would result in trade-offs in values…. The integrity of the area would decline as the parts became disconnected by corridors of activity and development nodes…. The overall character of the area would gradually change and much of it would become essentially nonwilderness in character.33

Not surprisingly, no answer appears in the EIS to the question of why the Park Service would recommend less rather than more wilderness.

Someone preferred that new wilderness be minimized, and judging from the language in the EIS it was not the Park Service. The agency said all it could about the consequences of its recommendation. What it could not say, of course, was that it was being pressured by the politicians to recommend less wilderness than it might. Among these were the Alaska congressional delegation, which had always opposed any wilderness, and their friends and allies in the Reagan administration. In April 1981 then Secretary of the Interior James Watt issued a directive forbidding the Bureau of Land Management to consider any wilderness in its domain (it was not mandated to do so by ANILCA but could have if it chose to). Next, in 1985, the director of the Fish and Wildlife Service instructed the Alaska regional office to consider only minimal wilderness recommendations in the refuge planning process. Bill Horn in 1986 instructed the National Park Service to consider only unique resources or characteristics that might have been overlooked by Congress. His memo stated that “in view of the thorough review conducted by Congress, I would not anticipate there to be a significant amount of land proposed for wilderness designation.”34 This seemed to contradict the congressional intent. The wilderness review provision of ANILCA had originated in the House, where the Interior Committee had expressed its expectation that reviews would result in more wilderness. “It was recognized that essentially all of the public lands within these [conservation system] units possess high wilderness value and that significant additions to the National Wilderness Preservation System should be made to protect those values. Therefore … the Committee included provisions for study of such areas in conservation system units.”35 So the Park Service did what it was instructed to do, but politics put it in the position of subverting its own analyses and the recommendation it had to make at Gates and elsewhere. Writing to John Kauffmann, who was keeping a watchful eye on this whole business and letting his thoughts be known, Boyd Evison confirmed this strategy. “It appears that our subversion is working—at least on people who read with care. This is off the record, but you should be aware that the specters of development on non-wilderness were inserted to make clear the mischief that could be done by the concerted efforts of … another very pro-development administration. The ‘recommended’ alternatives were imposed directly by Bill Horn … and used some phony criteria given us, in writing, by him.”36 Evison expressed his hope that the Washington office of the Park Service would recommend a Record of Decision for maximum wilderness in all units, but he doubted that Secretary of the Interior Donald Hodel would sign off on it.

This situation reveals a strong pro-wilderness bias in the Park Service right to the top in Alaska. It believed that the intent of ANILCA was to protect wilderness in Alaska parks and that opening any of the wilderness for development was to be avoided if possible. They continued to hope for additional congressional help, as Evison told Kauffmann, and knew they were running some risks. In his comment about the Record of Decision, Evison observed that if Secretary Hodel did sign off on such a decision, “It will put us on record [for maximum wilderness] (and probably incense the Alaska Congressional delegation, at cost to the National Park Service that can't be predicted).” Quite a battle went on behind the scenes over the wilderness recommendations, but whatever the outcome, it showed that in Alaska the Park Service was deeply committed to protection of wilderness. If it had been ambivalent about wilderness in its past (and no doubt it was still so in some of its areas elsewhere), in Alaska it embraced its mission of preservation with determination and resolve. In the end, though, this wilderness review came to naught, as Table 3 indicates.

The suitability reviews of all Alaska parklands concluded that 16 of nearly 19 million acres qualified for wilderness designation. Assistant Secretary Horn cut the proposed figure to 7 million, then to 4.7 million acres. In one park, Wrangell-St. Elias, the suitability review found that 3,174,000 acres qualified. The recommendations then dropped precipitously until, in 1989, Secretary Horn had reduced the proposal there to a mere 60,960 acres, even proposing that 109,000 acres of existing wilderness be removed from the system.37 The secretary of the interior, by directive of ANILCA, was to report on wilderness suitability in five years and the president was to submit his recommendation in seven, but these deadlines passed and no action was taken. The hostility of the Reagan administration to any additional wilderness continued through the first Bush administration. Bill Clinton was elected in 1992 and conservationists hoped for action, but his administration failed to act in its first two years. Then in 1994 the Republicans took control of Congress, dashing any hopes for movement toward additional wilderness. Alaska congressman and dedicated foe of wilderness Don Young became chairman of the House Resources Committee, and the archenemy of ANILCA, Alaska Senator Ted Stevens, assumed the chair of the Senate Interior Committee. Though an administration more sympathetic to wilderness preservation occupied the White House, no progress could be made toward any additional Alaska wilderness designation.

Meanwhile, the Park Service followed a generally preservation-oriented management strategy for potential wilderness in its domain.38 Its policy nationally was to maintain the integrity of wilderness study areas throughout the National Park System, and it applied that policy to Alaska. Despite this, conservationists feared that precisely what the Park Service suggested in its environmental impact assessments, the gradual degradation of wilderness under a multitude of pressures, might happen. Lack of action on any wilderness recommendation because of politics was, in effect, the “no action” alternative described in all the impact assessments. In concluding its assessment of this alternative for Gates the Park Service wrote, “Over the long term this alternative would result in major deterioration of wilderness character, reduction of wilderness size, and destruction of some wilderness values that would be irreparable. A large part of the study area would become semi-wilderness, and some non-wilderness in character.”39 This eventuality was precisely the goal of opponents of additional wilderness designation.

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A DIFFERENT AGENCY ATTITUDE ABOUT ALASKA WILDERNESS

The National Park Service, in this ANILCA stage of its history, stepped up to the mission of wilderness management and planning as it never had before. It was less conflicted than it had ever been about overt designation of and management for wilderness. There were several reasons for this new stance. First, congressional directives regarding wilderness—the Wilderness Act and ANILCA—had been superimposed on the Organic Act. Throughout its history the Park Service had wrestled with the problem of balancing recreation and preservation, as has been amply demonstrated. The Organic Act had not elevated one mission or the other but left it to the Park Service to strike the proper balance. The Wilderness Act and ANILCA removed the responsibility for such balancing. Thus in Alaska the issue for the Park Service was not whether parks should be designated wilderness but how they should, as wilderness, be properly managed in the short and long term. The wilderness suitability reviews were, of course, the same challenge in Alaska as elsewhere, but the experience of the landscape up there and the obvious wilderness value of park and preserve areas not designated as wilderness in ANILCA made wilderness advocates out of most Alaska Park Service planners and managers.

Second, in most of the Alaska parks, the pressures for development and recreation were less than elsewhere in the system. They were certainly not absent but simply not as strong. Some areas, like Brooks Camp in Katmai and the Kantishna and George Parks Highway areas of Denali, felt strong pressure, but on the whole the Park Service could comfortably embrace wilderness values without running into the level of conflict with its constituency that it might elsewhere. It had time to embrace wilderness without the prospect of a rapidly rising tide of visitors overwhelming it. Visitation would certainly grow, but because of the remote location of Alaska, its climate, and its economy, the future of use in Alaska seemed to be quite different than in the more accessible areas of the Lower 48. The prospect of meeting the expectations and needs of visitors into the foreseeable future with modest development of services seemed good.

Third, many of the attractions of the Alaska parks for these visitors required wilderness. At few parks in the Lower 48 was wildlife the major attraction. With the exception of Everglades National Park, no parks there had been established with wildlife protection and presentation as primary values. If people wanted monumental scenery, glaciers, spectacular geological features, and the challenges and thrills of mountaineering and river running, they could find all of them in parks in the Lower 48. If they wanted a reasonable assurance of seeing free-roaming brown bears, caribou, wolves, musk oxen, humpback whales, sea otters, Dall sheep, and moose in their natural habitats, they must go to Alaska. If these creatures were to remain viable and “viewable,” they needed wilderness, and large expanses of it. The Alaska parks offered experiences that depended on wilderness in this way, even if visitors only rode the bus at Denali, took a cruise in Glacier Bay, or flew into Katmai for a few days of bear and salmon watching. With attractions like these the Park Service should not, it thought, have difficulty selling its visitors on the need to contain development and maximize wilderness.

A fourth reason some in the service embraced wilderness in Alaska was that they saw the opportunity to preserve a part of the American heritage in ways impossible elsewhere. As long ago as the 1820s a pioneering scientist on the Stephen H. Long expedition to the Great Plains had reflected on the possibility of protecting bison and the plains Indians and their relationship. Thomas Say wrote that the plains, “unfit for tillage of civilized man … may for ages afford asylum to the cruelly persecuted Indian and its immense herds of Bisons.”40 A few years later artist George Catlin expressed a similar idea when he wrote, “What a beautiful and thrilling specimen for America to preserve and hold up to the view of her refined citizens and the world, in future ages! A nation's Park, containing man and beast, in all the wild and freshness of their native beauty!”41 Despite such ideas, when the national park system was constructed, no such preservation of indigenous life in the “wilderness” was possible, for by the time parks were made the Indians and most of the wildlife were gone or, in the case of the Indians, banished to reservations. Yet in Alaska, late in the twentieth century, indigenous people still roamed the wild lands, making a living off them. The concept of “inhabited wilderness” would require adjustments for many both inside and outside the Park Service, but the opportunity to preserve a part of the heritage of all Americans, indigenous and otherwise, was a great opportunity that would never come again.42 While park planners and conservationists were thinking mostly about preserving wildlife and wilderness, some saw the opportunity in the necessity of preserving the subsistence lifestyle of native Alaskans. Thus, ironically, the Park Service could at the same time help protect the rights of a people while protecting wilderness, though how they might do both there together was a puzzle and a challenge.

Another “last chance” for the Park Service was the opportunity to protect “ecosystems.” This goal emerged early in Park Service studies for possible Alaska parks. When planners realized that ecosystems remained intact and relatively unchanged by human activity to a degree greater than anywhere else in the United States, they saw an opportunity. They were studying this in the 1960s and 1970s when an ecological awareness was beginning to penetrate national park management as never before. The environmentalism that emerged in the 1960s was heavily influenced by ecological ideas, and people began to think about parks and their values in new ways. As work on the d-2 lands progressed, the Park Service was realizing the value of trying to consider ecosystem processes in drawing boundaries for new parks. In the Lower 48 they were struggling with problems, as at Everglades National Park, that might have been avoided by a more successful ecological drawing of that park's boundaries. The water necessary to bathe the “river of grass” was unreliable because much of it came from outside the park. At Redwood National Park logging outside the park was severely threatening the resources within it. Alaska offered the opportunity to design parks with attention to ecological systems. If wildlife populations, which were such a central feature of many Alaska parks, were to be maintained, such protection was imperative.

A final and obvious reason for its pro-wilderness stance in Alaska was that the Park Service was responding to a real if intangible shift in national values. These had appeared in the 1960s and had been manifest in the directives of Secretary Udall. By the late 1970s the Park Service had everywhere shifted to a more resource-protective orientation than in earlier periods. The debates over balance between use and protection raged on, but in the “age of environmentalism” of the 1960s and 1970s, protection had been more strongly embraced. In Alaska, for all the reasons previously mentioned, the Park Service could further this protection in a relatively remote and as yet undeveloped region. Alaskans and their politicians might rage, but the public generally supported wilderness protection in Alaska. Boyd Evison and others like him could honor their convictions about what the right course should be while sending a signal to the conservation community that the Park Service was, in a political environment hostile to environmental protection, with them.

All of these reasons, to a large or small degree, can be offered to explain why the Park Service embraced wilderness in Alaska as never before. The central park resource there was wilderness on a scale beyond anything it had experienced before. People like John Kauffmann understood this from the beginning of the park planning process, and by the time ANILCA was finally approved, the centrality of the wilderness resource in Alaska had come to be fully appreciated by most in the Park Service.

Throughout its history the Park Service interpreted its mandates and addressed them as it thought right for the time and place. Sometimes this meant it emphasized recreation more than preservation; at other times it was the other way around. In the 1980s in Alaska, in the service's initial management and planning, it embraced wilderness preservation. It had little choice in such a wild and remote place where the principal resource was wildness itself. In this remote corner of the National Park System there was more parkland than everywhere else combined, so the Park Service could not have thought its stance on wilderness there would go unnoticed.