A Discussion on the Proposal to Re-designate The Delaware Water Gap National Recreation Area to a National Park and Preserve
The proposal to redesignate the Delaware Water Gap National Recreation Area (DEWA) to a National Park and Preserve touts several main reasons that it should be done: Prestige, Protection, Equity, and Honoring the First Nations People. Below, these points are addressed as well as several other concerns.
“Prestige” to bring more funding
The proposal puts forth the premise that a redesignation will bring DEWA more funding. There is no guarantee of funding by virtue of a designation change. Funding for NPS units is based on a complicated rubric involving the size of the unit, the infrastructure demands of the unit, the personnel necessary to manage the unit, visitation numbers, and more. National Park Designation is irrelevant to this funding rubric. Of the 423 NPS units across the Nation, 2 of the top 5 funded units are National Recreation Areas, and DEWA itself ranks 27th in funding, ahead of 423 NPS units including 48 National Parks. Yes, DEWA needs better management and better funding, but this can be done WITHOUT changing the designation and bringing an estimated 600,000 to one million new visitors each year.
For an example, we can look to New River Gorge in West Virginia. New River Gorge was redesignated from a Recreation Area to a National Park and Preserve in 2020 on an omnibus Covid Bill (the CARES Act). Since then, the park unit has received no additional federal funding, with an increase of visitors putting additional stress on the infrastructure of the park as well as local EMS services. A more in-depth article on the subject can be read HERE.
Furthermore, DEWA currently has a deferred maintenance backlog of $160 million. Nationwide, the National Park Service currently has a $22 billion deferred maintenance backlog. The chances of DEWA receiving $160 million for the necessary repairs and improvements just to accommodate current visitation numbers, plus additional funding to expand on infrastructure to accommodate an increase in visitation seems highly unlikely. Additionally, there is currently a 5 year gap between request for funding and receiving that funding, provided that the funding is granted.
In November 2023, The Federal Government passed its fiscal year spending bill and cut the budget for the NPS nationwide by 12.5%. For the park service nationwide, this means “fewer staff to ensure visitor experience and safety, shuttered facilities, and fewer resources to protect our beloved natural and culturally historic sites.” [source] These factors lead to lower quality visitor experiences. How can we expect DEWA to receive $160 million for its deferred maintenance backlog, PLUS additional funding to create necessary infrastructure for a new National Park & Preserve? The National Park Service is currently struggling to maintain what it already has. Creating new park units with additional costs only further strains the decreasing resources the National Park Service has access to, and leads to lower quality visitor experiences.
A note on visitation numbers: The National Park Service, and the proposal, claim that DEWA receives 4.5 to 5 million visitors per year, as many visitors as Yellowstone National Park. That seems like a large number. Evenly divided by 365 days, this equates to over 13,000 visits per day. If we take out three months of winter, that number jumps to 18,000 visitors per day. Where are all these visitors? DEWA certainly experiences an overflow of parking and crowds during the summer season, but any visit to a National Park out west, with hundreds of cars backed up, giant parking lots, shuttle bus services, and in some cases, limited and timed entry to visit, will put that number into perspective. A quick google image search of “Yellowstone crowds” will illustrate this point.
So how does the NPS arrive at this visitation number? In DEWA, daily commuters (of which there are thousands) and anyone traveling Route 209 through the park are counted towards this visitation number. In fact, one car with one person in it making a round trip on River Road from Fernwood to I-80 each day can count for as many as 13 visits to the park. An investigative report explaining how the NPS arrives at these numbers can be read HERE.
“Equity”
The creators of the proposal stress that the people of the NY metropolitan area deserve to have a National Park.
The people whom this park services already have a National Park Service unit in DEWA. The Recreation Area is a protected National Park Service unit. People are currently free to come here and enjoy the Recreation Area. What people deserve to have is a National Park Service unit that is equipped to accommodate their visit - something achieved through lobbying for funding, not a designation change to a National Park and Preserve.
Additionally, there are over 4,200 municipal, state and township parks and other recreation areas within New York, New Jersey, Connecticut and Pennsylvania where residents and visitors have the opportunity to recreate. DEWA is not the only destination for these activities.
The proposal states that “Creating the park and preserve…will fulfill the original intention of Congress to create equity in nature-based recreational opportunities for the now 60 million people living nearby.” According to the legislature, the original intent of congress was for DEWA to serve as a Recreation Area. Read that legislation here.
Recreation Areas are among the most DEIJ (Diversity, Equity, Inclusion, & Justice) positive units in the National Park Service system. DEWA hosts an incredibly diverse array of visitors and recreation activities including hiking, boating, kayaking, canoeing, horseback riding, bicycle riding, forest bathing, etc—most of which are entirely free of cost, making its activities extremely equitable—and includes as many recreational opportunities as possible. A change to a National Park can only REDUCE this diversity, equity, and inclusiveness. The variety of activities would be reduced, as there are more restrictions on activities permitted and barriers to access in a National Park and Preserve.
“Protection”
The proponents argue that redesignating the Recreation Area to a National Park and Preserve will provide it additional “Protection.” DEWA, as a National Recreation Area, currently enjoys one of the highest levels of protection of any National Park Service unit. When pressed, Mr. Donohue, the author of the proposal, admitted that the only additional level of “protection" would be the loss of hunting within the National Park area.
National Parks, National Preserves, and National Recreation Areas are all open to natural resource extraction including water, timber, and land for energy farming. Changing the designation of the Recreation Area to a National Park and Preserve would not increase DEWA’s protection from natural resource extraction.
Newly included in the revised proposal (Sept 2023) is Forest to Field Conversion. What is Forest to Field conversion? From Client Earth:
“Forest to Field conversion is the clearing of natural forests (deforestation) to use the land for another purpose, often agricultural (growing crops like palm oil or creating pasture for cattle), but also for mines, infrastructure, or urbanization. Forest conversion is the largest cause of global deforestation today. It is being done by businesses and individuals, for economic reasons, or simply for survival. Forest conversion has complicated roots, but one emerging global trend is that big, commercial investments are increasing, and with them, rates of deforestation.”
The proposal states that there will be ”No Forest to Field Conversion except in the Preserve” . The preserve is slated to be over 56,000 acres, the MAJORITY of the park unit. Why would the “Alliance” be supporting Forest to Field conversion on the majority of land in DEWA? It goes against their stated values of protection and conservation. This is highly concerning.
“Honoring the First Nations People”
The NJ State recognized Ramapough-Lenape who currently reside in this area have pointed out that because they are not a federally recognized tribe, their heritage and history would not be recognized or honored with the creation of a Lenape Preserve in the (Federal) National Park System. Mr. Donohue has only recently met with representatives from these local tribes, and says that he came away with “great insight”, yet fails to mention that they are adamantly opposed to a re-designation. An article reporting on the issue can be read HERE. A .pdf of the Ramapough-Lenape’s official statement opposing the redesignation is available HERE.
From the Delaware Riverkeeper Network: “We are concerned that while Lenape representatives living in the Midwest have been included in the planning process, the Lenape Nation and the tribes of our region, those that have an intimate, personal, and enduring relationship with our River and watershed have not. The perspective of the local Lenape tribes and people is essential and must be honored. Failure to include them in the planning seems a dramatic oversight of high concern.”
Other Concerns
Loss of Private Property
The proposal states that Eminent Domain will not be used and that “The National Park and Preserve is authorized to accept or acquire additional lands from willing sellers and donors to enhance large landscape scale connectivity, to address climate adaptation, to create wildlife corridors, and watershed protection, and to provide recreational equity for the millions of Americans living in urban and suburban areas within a day’s travel.“ (Emphasis added).
This does not inspire confidence if you’re familiar with the Tocks Island Dam project. Many people in this area remember how “willing sellers” were created by the government.
In his classic study, “Preservationist Agencies and the Myth of the “Willing” Seller - Willing Seller, Willing Buyer - A Survey of the No So “Willing” Sellers,” Bo W. Thott of the Washington County Alliance in Maine shows how the Federal Government essentially forces property owners to become “willing sellers”. He explains:
“[The] problem arises when Park Service officials are using their jargon term SELLER outside their circle, understood by the public in the generally accepted meaning of a free agent conducting business. A clever Park promoter even coined the slogan WILLING SELLER/WILLING BUYER, falsely implying that the two parties are on an equal footing. This slogan has developed into a mantra recited at hearings and discussions on Park expansion for the deception of legislators and the general public.”
He continues, “The “sellers” are as willing as robbery victims handing over their wallets when under the gun. The reason for their willingness to sign — going to court over a small piece of land generally means a further loss — is not explained by the land agencies. Instead they are trumpeting throughout the nation that their acquisition is not through eminent domain but through sales.”
To illustrate this point, below are just a small sample of quotes from people across the country who sold their land to the Federal Government, without the government having to use eminent domain. They are ALL considered “willing sellers”:
“We did not want to sell...but were told...it would make no difference - the government would get the land, and at the value that they had decided”
“The price was set by the buyer and we were told it was not negotiable! We learned of people...who did hire lawyers...they lost and were paid 1/2....and were really big big losers. We could not afford such a loss.”
“There was no negotiation with the Park Service...if you don't accept it we will force you to accept it in court, I could not afford to fight them.”
“....They sent me a contract with a set price and the only way to get any more out of them was to take them to court. Naturally I could not bear the expense of fighting the Federal Government & their multitude of experienced lawyers, knowing in the end I would lose out.”
Erich Veyhl, of Washington County, Maine, summarizes, “private landowners ostensibly selling their properties to the National Park Service as allegedly willing sellers are in fact not bona fide “willing” sellers but instead give up their title to escape the futility of legal expenses against a foredoomed condemnation that cannot be legally stopped. Government agencies and their apologists then disingenuously publicly proclaim that the acquisitions are from “willing” sellers because the victims were not legally condemned in court.”
In addition to the tragedy of displaced families, the loss of private property results in the loss of taxes collected on those properties, decreasing available tax money for our education systems. Impact Aid, a government program created with the intention to offset this loss, must be re-applied for each year, and funding allocated by the program has been significantly decreasing every year. Any loss of tax base in our communities puts an increased burden on those remaining.
Strain on local Emergency Medical Services:
Currently, our local EMS responds to emergency calls from within DEWA. The National Park Service emergency response services are severely lacking, and the NPS depends on local EMS, who in turn receive no funding from the Park Service. More visitors to the park will lead to more emergency calls in the park, further straining the resources of these services and limiting their availability to our communities. See this article for an example on how this can impact a community.
Lack of Details:
There is no clear plan disclosed to the public. The proposal lacks any detail as to permitted uses, fees, and visitation, as well as impacts on local environment, economy, and infrastructure. There are no economic or environmental impact statements. No entities should be supporting any proposal without this detailed information.
Ultimately, neither Mr. Donohue nor the PA Sierra Club, the author and proponents of this proposal, has jurisdiction on how a National Park Service Unit is developed, managed, or expanded upon. This all falls under the authority of the Department of the Interior and the National Park Service.
Conclusion
While we recognize the need for increased funding for DEWA, a designation change is not the answer. It will attract more visitors to the area by virtue of name only, without the necessary infrastructure to support the increased visitation numbers. Our EMS system will be put under further strain, with no additional funding from the federal government. We ask that you join the 20+ townships, boroughs, and counties in New Jersey and Pennsylvania who have passed resolutions to oppose this re-designation until we have more funding and more information available for public review and comment.
For a complete list of those who oppose, including members of the NJ and PA State Senates, as well as local and Congressional representatives, please visit the homepage of our website, nonationalpark.org
For more information, you can follow us on facebook “No National Park” or find us online at nonationalpark.org. Please send questions and comments to nonationalpark2030@gmail.com
