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**Guidance White Paper Number 2**
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**Issue: WHAT CONSTITUTES APPROPRIATE** **CONSERVATION**

> **AND RESTORATION ACTIVITIES IN WILDERNESS?**

Date: February 2004

**Introduction to the Issue**

The re-establishment and maintenance of natural ecosystem components and
processes on national park lands through intervention has become an
increasingly important resources management function. This is reflected
in National Park Service Management Policies (NPS 2001: 4.15, 4.4). The
reasons for increasing intervention include: (1) Additions to the
National Park System of units where natural ecosystem components and
processes have been altered by past human activities; (2) increasing
fragmentation of the natural ecosystems of which national parks are a
part; (3) increasing pervasiveness of regional and global anthropogenic
stressors such as contaminants, light and sound pollution, and climate
change; (4) new scientific and technological advances that improve the
likelihood of successful intervention; and (5) improved understanding of
and appreciation for the relationship among elements and processes in
fully functioning ecosystems.

The nature of conservation activities has included: Reintroduction of
extirpated native plants and animals; recovery of species listed under
the Endangered Species Act; removal or control of introduced species;
control of native species where natural control mechanisms have been
lost; restoration, by means of prescribed burning or mechanical
thinning, of vegetative and fuel structures to that which would have
occurred without fire suppression; restoration of hydrologic regimes;
liming acidified waters.

National Park System lands that have been designated or are managed as
wilderness (the Wilderness Act of 1964, P.L. 88-577) may nonetheless be
anthropogenically altered systems, some to a great extent. These altered
wilderness lands may benefit from the conservation and restoration
activities described above, sometimes leading to more fully functioning
natural systems and enhanced wilderness character over the long run.
However, both short-term restoration efforts and long-term conservation
activities can negatively affect wilderness character and conflict with
the directive of the Wilderness Act that those lands be "untrammeled."
Consequently, the relationship of NPS conservation activities to
wilderness law and policy is complex. This paper provides guidance on
determining how and when to proceed with conservation actions in
wilderness.

**Relevant Laws and Policies**

**The Wilderness Act**

With regard to both the activities of ecological restoration and the
long-term outcomes of those actions, the Wilderness Act has a number of
apparently relevant passages (passages edited for space; emphases
added):

*Section 2 (c):*

"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** .... An area of
wilderness is further defined to mean ...land **retaining its primeval
character and influence**, without permanent improvements..., which is
protected and managed so as to preserve its natural conditions and which
...generally **appears to have been affected primarily by the forces of
nature**, with the imprint of man\'s work substantially
unnoticeable\..."

*Section 4 (a)(3):*

"...the designation of any area of any park, monument, or other unit of
the national park system as a wilderness area pursuant to this Act
**shall in no manner lower the standards evolved for the use and
preservation of such park, monument, or other unit of the national park
system** in accordance with the Act of August 25, 1916, the statutory
authority under which the area was created, or any other Act of Congress
which might pertain to or affect such area\..."

*Section 4 (b):*

"Except as otherwise provided in this Act, each agency administering any
area designated as wilderness **shall be responsible for preserving the
wilderness character of the area** and shall so administer such area for
such other purposes for which it may have been established as also to
preserve its wilderness character. Except as otherwise provided in this
Act, wilderness areas shall be devoted to the public purposes of
recreational, scenic, scientific, educational, **conservation**, and
historical use.."

*Section 4 (c):*

"Except as specifically provided for in this Act,\... there shall be no
permanent road within any wilderness area designated by this Act and,
**except as necessary to meet minimum requirements for the
administration of the area for the purpose of this Act**, \...there
shall be no temporary road, 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
area."

**National Park Service Management Policies**

*4.1 General Management Concepts:*

Biological or physical processes altered in the past by human activities
may need to be actively managed to restore them to a natural condition
or to maintain the closest approximation of the natural condition in
situations in which a truly natural system is no longer attainable.
Prescribed burning and the control of ungulates when predators have been
extirpated are two examples. The extent and degree of management actions
taken to protect or restore park ecosystems or their components will be
based on clearly articulated, well- supported management objectives and
the best scientific information available.

*4.1.5 Restoration of Natural Systems:*

The Service will re- establish natural functions and processes in human-
disturbed components of natural systems in parks unless otherwise
directed by Congress. Landscapes disturbed by natural phenomena, such as
landslides, earthquakes, floods, hurricanes, tornadoes, and fires, will
be allowed to recover naturally unless manipulation is necessary to
protect park developments or visitor safety. Impacts to natural systems
resulting from human disturbances include the introduction of exotic
species; the contamination of air, water, and soil; changes to
hydrologic patterns and sediment transport; the acceleration of erosion
and sedimentation; and the disruption of natural processes. The Service
will seek to return human- disturbed areas to the natural conditions and
processes characteristic of the ecological zone in which the damaged
resources are situated. The Service will use the best available
technology, within available resources, to restore the biological and
physical components of these systems, accelerating both their recovery
and the recovery of landscape and biological- community structure and
function\...

*4.4.2 Management of Native Plants and Animals*

Whenever possible, natural processes will be relied upon to maintain
native plant and animal species, and to influence natural fluctuations
in populations of these species. The Service may intervene to manage
individuals or populations of native species only when such intervention
will not cause unacceptable impacts to the populations of the species or
to other components and processes of the ecosystems that support
them,\...

*4.4.2.2 Restoration of Native Plant and Animal Species*

The Service will strive to restore extirpated native plant and animal
species to parks whenever \[stated criteria\] are met.

*4.4.2.3 Management of Threatened or Endangered Plants and Animals*

The Service will survey for, protect, and strive to recover all species
native to national park system units that are listed under the
Endangered Species Act. The Service will fully meet its obligations
under the NPS Organic Act and the Endangered Species Act to both
pro-actively conserve listed species and prevent detrimental effects on
these species.

*4.4.4.2 Removal of Exotic Species Already Present*

All exotic plant and animal species that are not maintained to meet an
identified park purpose will be managed--- up to and including
eradication--- if (1) control is prudent and feasible, and (2) the
exotic species \[possesses one or more stated attributes\].

**Reference Manual RM 41: Wilderness Preservation and Management**

*6.3.7 Natural Resources Management:*

The principle of non-degradation will be applied to wilderness
management, and each wilderness area's condition will be measured and
assessed against its own unimpaired standard. Natural processes will be
allowed, in so far as possible, to shape and control wilderness
ecosystems. Management should seek to sustain natural distribution,
numbers, population composition, and interaction of indigenous species.
Management intervention should only be undertaken to the extent
necessary to correct past mistakes, the impacts of human use, and the
influences originating outside of wilderness boundaries. Management
actions, including restoration of extirpated native species, altered
natural fire regimes, controlling invasive alien species, endangered
species management, and the protection of air and water quality, should
be attempted only when the knowledge and tools exist to accomplish
clearly articulated goals.

*Appendix VI - Definitions:*

Minimum Requirement Concept: The minimum requirement concept is a
two-step process that documents 1) the determination as to whether or
not a proposed management action is appropriate or necessary for the
administration of the area as wilderness, and does not pose a
significant impact to the wilderness resources and character; and,

2\) the selection of the management method (tool) that causes the least
amount of impact to the physical resources and experiential qualities
(character) of wilderness.

**Analysis and Guidance**

In the wilderness community recently some have contrasted "natural" with
"wild." Both Cole (2000) and Landres et al. (2001) find a significant
difference between these words, particularly as applied to wilderness,
while Turner (1996) argues that "wild" precludes intentional human
intervention. These authors emphasize leaving nature alone to manage
itself. On the other hand, Graber (1985, 1995, in press) has argued, as
did McKibben (1989), that the pervasive and insidious magnitude of human
activity has largely rendered the distinction between "wild" and
"natural" moot. This is particularly true in many of the small, eastern
lands Congress has set aside as designated Wilderness. There is, for
example, very little wild about Cumberland Island Wilderness on
Cumberland Island National Seashore, which includes roads, motor
vehicles, many introduced species, and several key species extirpated.
Yet through time, if this were desired, alien species could be removed,
natives species reintroduced, a natural fire regime re-started, and
human construction removed. Similarly, some other small designated
wildernesses, as well as larger ones adjacent to development, suffer
substantial deviations from aboriginal wilderness character. They may
require urgent intervention and long-term maintenance simply to preserve
what remains of their original native biodiversity, and sometimes what
remains is quite irreplaceable. To put it another way, a case can be
made that their value as managed reserves of biodiversity exceeds their
value as "wilderness."

The *appearance* (Sec. 2\[c\])of wildness is in the eye of the beholder:
An ecologist or scientifically educated naturalist sees anthropogenic
alteration where someone not so schooled does not, while many
conservation actions are quite obvious to the casual observer. The use
of "untrammeled" in the Act refers to *intentional* control or
manipulation of the "community of life" (Zahniser 1963, Scott 2001) but
ecological consequences ensue regardless of the degree or distance of
intention. Wilderness landscapes have always been and will continue to
be subject to both natural and anthropogenic changes. The pace of
landscape change in the United States and the rest of the world is
accelerating. So is human appropriation and alteration of nature. Yet
locally, although perhaps only temporarily, those changes can largely be
stopped, even reversed, with sufficient knowledge and effort. The
disturbances introduced by ecological restoration---the loss of
wilderness character---need not represent permanent loss.

**A way to evaluate the appropriateness of restoration and other
conservation activities in wilderness:** The outcomes of conservation
activities can be considered to offer varying degrees of benefit to
wilderness ecosystems, while the activities themselves impose varying
magnitudes and longevities of compromise to wilderness character.
Unavoidably, determining which actions should proceed and which should
be avoided will be location specific and subjective. The following
classification scheme is intended merely to help structure the analysis.
It provides three artificial categories of conservation activities and
examines the relative impacts and benefits of each. It is intended only
as a guide.

**Class I:\
Short-term wilderness disturbance\
Long-term wilderness character enhancement**

This class of activity entails one-time reversals of anthropogenic
changes that, once accomplished, are self-sustaining. Users of
wilderness might well encounter restoration activities that would
typically result in impacts to wilderness character lasting a season to
perhaps several years. Often, these impacts include temporary markers
such as flagging, or tags and radio-collars on animals. Some of this,
such as dam removal, may require heavy equipment. Upon completion,
however, traces of the restoration activity would be extinguished over a
short period of time, while the benefits of "re-wilding" and naturalness
to wilderness character would be long-term.

*Examples:*

-   Reintroduction of self-sustaining native species

-   Extirpation of invasive alien species

-   Restoration of natural fire regimes

-   Restoration of natural hydrologic regimes

**Class II:\
Long-duration or recurring entry**\
**Benefits and costs to wilderness character**

Many ecosystems that include wildernesses suffer anthropogenic
disturbances for which we lack the knowledge, the legal authority, or
the financial resources to correct permanently at the present time. For
example, introduced weedy plants often invade natural areas from
adjacent lands, and require regular removal and frequent monitoring.
Periodic liming of some eastern streams mitigates acid precipitation and
permits continued survival of native fish and amphibians which otherwise
would be entirely eliminated from the ecosystem---at least until the
source pollution is eliminated. Pyrophytic ecosystems the lie adjacent
to developed lands may no longer receive sufficient natural fire
ignitions, or those ignitions are no longer socially acceptable;
however, periodic managed ignitions may accomplish most of the
objectives of maintaining the natural structure and composition of the
native biological community. Small, anthropogenically isolated
populations of large mammals, such as mountain sheep, may lack the
demographic or genetic size for long-term viability. However, periodic
infusions of additional animals can help assure survival. These
nature-maintenance activities reflect the sad reality that many
designated wildernesses, and other kinds of nature reserves, are simply
too small or disconnected to sustain their full suite of ecosystem
functions without intervention. The National Park Service manager must
ultimately weigh the restoration benefits to the ecosystem against the
impacts to other aspects of wilderness character.

*Examples:*

-   Periodic control of persistent introduced species

-   Indefinite extent of planned ignitions

-   Reintroduced species requiring continuing support

-   Mitigation of acidified waters

**Class III:\
Support of laws or NPS policies\
Don't directly enhance wilderness character**

These activities represent substantial impacts on wilderness character.
They clearly violate the intent of the Wilderness Act. Some of these,
such as control of pests, reflect the incapacity of some landscapes
designated as wilderness to function as such either ecologically or
politically. On the other hand, some severe interventions, such as the
removal of native organisms for restoration elsewhere, illuminate the
fundamental and unavoidable connections between many wildernesses and
their surrounding, more modified landscapes. Ultimately, decisions in
this category may require a public review for their resolution.

*Examples:*

-   Habitat modification for endangered species

-   Regulation of predator or prey numbers when an area is too small for
    natural regulation or natural controls have been lost

-   Control of native pests or dangerous species to protect life or
    property outside wilderness.

-   Removal of native organisms in support of restoration elsewhere.

None of the activities in any class is necessarily precluded by statute,
regulation, or policy. However, when one is considering the activities
listed in Class III that invoke *Section 4(c)* of the Wilderness Act,
you must carefully weigh the benefits against the significant impacts on
wilderness character, and consider whether the proposed restoration
activity is sufficiently beneficial to outweigh those impacts. An
excellent and comprehensive discussion of the management and restoration
of wilderness ecosystems is provided by Franklin and Aplet (2002).

**Literature Cited**

Cole, David N. 2000. Paradox of the primeval: Ecological restoration in
wilderness. Ecological Restoration 18:2, 77-86.

Franklin, Jerry F. and Gregory H. Aplet. 2002. Wilderness ecosystem. Pp.
263-285 in *Wilderness Management: Stewardship and Protection of
Resources and Values*, 3^rd^ Edition. Hendee, John C. and Chad P.
Dawson, eds. Golden, Colorado. Fulcrum Publishing..

Graber, David M. 1985. Managing for uncertainty: national parks as
ecological reserves. George Wright Forum 4:3, 4‑7.

Graber, David M. 1995. Resolute biocentrism: The dilemma of wildness in
national parks. Pp. 123-135 in *Reinventing Nature?: Responses to
Postmodernism Deconstruction.* Soulé, Michael E. and Gary Lease, eds.
Washington, D.C. Island Press.

Graber, D. M. 2003*.* Ecological restoration in wilderness: Natural
versus wild in National Park Service wildernesses. George Wright Forum
20(3):34-41.

Landres, Peter; Brunson, Mark W.; Merigliano, Linda 2001. Naturalness
and wildness. the dilemma and irony of ecological restoration in
wilderness. Wild Earth 10:4, 77-82.

McKibben, Willam. 1989. *The End of Nature*. New York. Random House.

Scott, Douglas W. 2001. " Untrammeled," "wilderness character," and the
challenges of wilderness preservation. Wild Earth. Fall/Winter
2001-2002. 11:4, 72-79

Turner, Jack. 1996. *The Abstract Wild*. Tucson. University of Arizona
Press.

Zahniser, Howard 1963. Guardians not gardeners. The Living Wilderness.
83, 2.