America’s national parks are icons of the county’s natural and cultural history and are often described in superlatives such as our “crown jewels” and “America’s best idea.”
But the national parks are more than the physical, biological and historical objects of which they are composed. In a more sociological sense, they are “social constructions” borne out of the evolving values and norms of society and reflect historical and contemporary thinking about the appropriate relationship between humans and nature.
Management of America’s national parks should be informed by science — this includes both the natural and social sciences.
Social science can contribute to park management in many ways. Why do nearly 300 million visitors travel to the national parks each year? How many visitors can be accommodated in national parks without unacceptable crowding and associated impacts? Why are racial and ethnic minorities historically underrepresented in the national parks? Are younger generations of Americans disaffected from national parks and nature more broadly? And there are dozens of other questions and issues on which the voices of park visitors and other stakeholders should be heard.
But the pursuit of social science in the national parks is being thwarted by unreasonable administration of the federal Paperwork Reduction Act by the Office of Management and Budget, turning the PRA into one of the great oxymorons of government.
As the name suggests, the PRA was designed to reduce the burden placed on the public by data-collection activities of federal agencies. Approval is required from the OMB for federally funded data collection from 10 or more respondents. Under this definition, surveys of national park visitors and other stakeholders must receive OMB approval, and this approval has become harder and more time-consuming (creating even more paperwork) over the past several years.
In fiscal 2008, the OMB instituted a process in which only one National Park Service survey at a time is considered. This has substantially limited social science research. While the approval process calls for the OMB to act on a survey submission within two weeks, this is often ignored; one survey was held at the OMB for 185 days while all other proposed studies waited in a growing queue. Since the one-at-a-time procedure was instituted in fiscal 2008, the number of surveys administered in the national parks has fallen by half and many planned surveys have been postponed or canceled.
There are many other problems associated with the OMB review process. Review criteria are applied inconsistently and in an arbitrary and autocratic manner. Refusal to make changes required by the OMB results in rejection of the submission. Survey approaches that reflect the peer-reviewed literature and that constitute received practice are sometimes rejected without explanation. There is no provision for discussion or appeal.
National Park Service Director Jonathan Jarvis recently submitted comments to the OMB, stating that “The National Park Service has experienced lengthy and debilitating delays of a year or more waiting for OMB clearance of survey requests” and that “This has impacted the ability of National Park Service to be responsive to the American public.”
The problems experienced by the National Park Service are accompanied by related issues in the academy. Researchers are unable to plan and conduct studies in efficient and effective ways. The arbitrary and authoritarian way in which the OMB approval process is administered squelches innovation and application of research to contentious and pressing issues. These problems affect the ability of graduate students to meet their research requirements in a timely way.
Comments on these problems have been submitted to the OMB multiple times by the park service, university scientists, and scientific and professional organizations. Yet the problems have grown worse.
Several reasonable solutions have been suggested to the OMB. For example, the PRA allows for delegation of approval authority to the National Park Service, which has a Social Science Program Office that is qualified and willing to accept this responsibility.
It’s unlikely that Congress intended the PRA to limit the application of social science in the national parks. These surveys result in a relatively small number of “burden hours” on the public. Moreover, the typically high response rates to these voluntary surveys (often exceeding 80 percent) suggest that most park visitors and other stakeholders are eager to have their voices considered in park management.
A substantial body of scientific and professional literature has evolved from these studies, enhancing our understanding of human-nature relationships and many other topics. And this program of research is educating the next generation of park managers and scientists.
Yet the OMB has continued to make social science research in the national parks more difficult. If these types of restrictions were placed on natural science in national parks, there would be a widespread and well-deserved outcry from the scientific community.
But social science can be just as important as natural science to park management. National park managers need to know more about park visitors, other stakeholders and the society at large to develop informed management plans, and social science can contribute in important and meaningful ways. The scientific and professional communities and the general public should not stand for the current unreasonable bureaucratic intrusion on social science in the national parks.
Robert E. Manning is professor of natural resources and director of the Park Studies Laboratory in the Rubenstein School of Environment and Natural Resources at the University of Vermont.