Editor's note: The public comment period on the Interior Department's proposal to allow national park visitors to carry concealed weapons runs through June. If you haven't already commented, please consider doing so at this site before the deadline. This is a high profile, emotionally and politically charged issue, one that figures to affect all visitors to our national parks. Don't let it be decided without your voice. What follows is the Traveler's position on this proposal.

Dear Secretary Kempthorne,

There are many fine centennial projects under way, and proposed, to help the National Park Service prepare itself and the 391 units of the National Park System for the agency's centennial in 2016. Hopefully there will be many more in place before that celebration arrives.

While there are many concerns about the risks of commercializing the parks along the way to 2016, so far things seem to be under control. Except, that is, for one glaring example that could bring the likes of Smith & Wesson, Glock, SIG and other brands of handguns into our National Park System.

Mr. Secretary, forgive those of us who might think the National Rifle Association's full-court press to see the National Park Service's gun regulations tossed out the window is its version of a centennial project. I'm sure it's merely a timing thing -- the NRA's election-year gambit pitted against your Centennial Initiative.

National Parks Do Not Have a Crime Problem

Joking aside, Mr. Secretary, there simply is no need to change the current gun regulations for our national parks. The National Park System is not crime-ridden. Far and away, the majority of the hundreds of millions of visitors who entered some unit of the National Park System last year did not place their lives in danger from other park visitors nor from wild animals when they did so. You can look it up. I did. This is what I found:

While even one murder is too many, the crime statistics for a park system that attracts more visitors than Major League Baseball, the National Football League, professional basketball, soccer
and NASCAR combined would seem to indicate that parks are relatively safe havens from violent crime.

During 2006, when 273 million park visits were tallied, there were 11 criminal deaths across the system. Two involved women who were pushed off cliffs (one at Pictured Rocks National Lakeshore and one at Lake Mead National Recreation Area), one was a suicide (at Golden Gate National Recreation Area), and one was the victim of a DUI accident (in Yellowstone National Park).

National Park Service records also show that one of the 11 deaths, reported in Great Smoky Mountains National Park, involved a stabbing that was spawned by an alcohol-fueled altercation. Great Smoky also was the setting of a fatal shooting of another woman; three people were arrested for this crime.

The suicide at Golden Gate involved a man who "began shooting at hang gliders. He did not hit any of the hang gliders, but then he shot a stranger. Then he turned the gun on himself."

At the Blue Ridge Parkway, a woman parked at an overlook and wearing headphones while studying for final exams "was killed by a handgun by a suspect on a killing spree," the Park Service said. In another case involving the parkway, the body of an individual shot and killed outside the parkway was dumped there.

At Amistad National Recreation Area, a woman was found floating in a reservoir in about 5 feet of water. "She appeared to have blunt force trauma to the head and was possibly stabbed," the agency said.

The last two murders were reported in Washington, D.C., area park units. In one case a victim died from a gunshot wound to the head, in the other, U.S. Park Police found a partial human skull, with an apparent gunshot wound, on the shoreline of the Anacostia River. This crime didn't necessarily occur in the park system.

Most folks, I think, would agree that the suicide, two pushing victims, and the DUI victim couldn't have been prevented if guns were allowed to be carried in the national parks. And, of course, there was the victim who was murdered outside the Blue Ridge Parkway. That lowers to six the number of violent deaths investigated in the parks, one of which involved a stabbing in a drunken brawl, an outcome that could have turned out just the same -- or worse-- if either individual was carrying a gun.

During 2006 there also were 320 assaults without weapons, 1,950 weapons offenses, 843 public intoxication cases, and 5,752 liquor law violations. How many of those might have turned deadly were concealed carry allowed in the park system?

Last year, 2007, the numbers fell lower. There were nine criminal deaths across the park system, 1,495 weapons offenses, and 974 public intoxication cases.

Mr. Secretary, before you opt to change the current restrictions, consider the input from your National Park Service professionals, both those in Washington and those spread across the National Park System. After all, the agency is not calling for this change that would allow visitors to carry concealed weapons at the ready, nor is the Ranger Lodge of the Fraternal Order of Police, nor is the Association of National Park Rangers.

More so, all seven living former National Park Service directors (appointed, by the way, by presidents of both parties) are on record saying this proposed change is unnecessary (see attachment).

Why is the NRA Pushing For Armed Visitors in the Parks?

So why is it necessary to rewrite regulations that already allow gun owners to transport their weapons through our parks? True, those regulations require that the weapons be unloaded, broken down, and stored out of easy reach, but is that unreasonable? From here it seems as if only the self-righteous NRA, ever anxious to boost its membership, feels that the only safe national park is one where the visitors are armed and ready.

So anxious is the NRA to see this change that it changes its stance when the circumstances dictate. For instance, the NRA freely admits that it "initiated and worked closely" with U.S. Sen. Mike Crapo, R-Idaho, on a letter the senator sent to you asking for concealed carry to be the lay of the federal landscape. A portion of that letter claims that inconsistencies between state and federal gun laws are "confusing, burdensome, and unnecessary." And yet, NRA spokeswoman Ashley Varner, told the Smoky Mountain News that rangers in parks that touch multiple states shouldn't have trouble keeping track of varying laws.

“I think that’s a bogus argument,” she told the newspaper. “Our park rangers know the laws. They are fully capable of understanding where they are within the forest.” (Judging from Ms. Varner's choice of words, could it be that the NRA doesn’t know the difference between the national forests and the national parks?)

So, on one hand the NRA says those who are permitted to carry concealed weapons are confused by the current laws, and yet if rangers are required to memorize more than one set of gun laws and all their intricacies and nuances that's not a problem.

Is the NRA implying that gun owners aren't capable of understanding when they leave state lands and enter national parks?

Allowed Concealed Carry in the Parks Will Complicate, Not Simplify, Matters

Mr. Secretary, since at least 1936 (earlier gun prohibitions were instituted at many individual parks, as the attached file shows) it's been clear that visitors are not allowed to carry weapons in national parks, unless that park allows hunting, of which there are relatively few. But under the proposal you are endorsing, concealed carry in the parks would depend on myriad state laws, some of which carry quite a few nuances. Scan the laws out there and you can certainly see where your proposal would make for a much, much more confusing landscape than currently exists in the National Park System.

Jim Burnett, a commissioned law enforcement officer during much of his 30-year Park Service career, discovered the significant challenge that exists for sorting out all of those conflicting regulations. Here's a sampling of his findings:

The State of Wyoming Attorney General's website sums up this problem: "It is extremely important for all concealed firearm permit holders to be aware of the requirements and laws of all reciprocating states. The permit issued by your state does not supersede any other state’s laws or regulations. Legal conduct in your state may not be legal in the state you are visiting."

The State of Florida website on concealed weapons permits notes, "The Division of Licensing constantly monitors changing gun laws in other states and attempts to negotiate agreements as the laws in those states allow." Even if someone took time to sort out the concealed weapons laws of all the states he'd be visiting, some of those laws may have changed recently, so the process has to be repeated before every trip.

Here's only one example of the problem: Florida has reciprocal agreements to honor concealed weapons permits with only 32 of the 50 states. Visit the other 18 and you're out of luck, so don't forget to lock up your gun when you cross the state line. To make matters worse, Florida's official website notes seven different exceptions to those agreements, so even among the 32 states with agreements, guidelines vary. Are you a resident or non-resident? Are you over the age of 18 but under 21? Are you from Vermont, which doesn't even require a concealed weapons permit? (Sorry, you can't "carry" in Florida under the reciprocal agreement guidelines, since Florida can't "reciprocate" if a permit doesn't exist in the first place.) The list of exceptions goes on.

So, Mr. Secretary, not only will rangers have to be knowledgeable about federal laws, but also the laws of the states that their parks fall within. And then, of course, there are the parks -- Yellowstone, Great Smoky, Death Valley, and the Blue Ridge Parkway just for example, as there are several more -- that span more than one state. As a result, rangers will not only have to be schooled on those states' gun laws but also, presumably, carry a GPS unit so they know in which state they're in when they're in the backcountry so they'll know which set of laws to apply to armed backcountry travelers.

Professional law enforcement rangers, at least, are trained to pay attention to jurisdiction and legal authorities; can we reasonably expect the average visitor to do the same?

2nd Amendment Rights Are Not in Jeopardy Under the Existing Guidelines

Mr. Secretary, in arguing for this change of regulations, the NRA and more than a few of its members would have you believe that their 2nd Amendment rights are being trampled by the national park regulations. Really, Mr. Secretary, this isn't a 2nd Amendment issue. No one is trying to deny folks the right to carry arms, although you couldn't tell that by listening to the NRA. Nor are you denying that weapons can be prohibited in federal buildings, or that states – if they choose – can decide to prohibit them in the national parks within their states.

So this isn’t a 2nd amendment issue. If it’s anything, it’s a states rights issue. But where in federal law does it say that the states should make decisions about how national parks are managed? In fact, the law says quite the opposite:

16 US Code 1-1a says that the National Park Service (not the states) “shall promote and regulate the use of the Federal areas known as national parks.”

Why did this issue crop up now, 2008? Could it be because this is an election year, one that not only has members of Congress up for re-election but also the president's office? Could it be that the NRA is trying to use guns in the parks as a wedge issue, to force politicians to kowtow to the almighty weapon to be re-elected?

What should be at issue here is some sanity and reasonableness. Just as the 1st Amendment carries restrictions concerning where you can voice your right to free speech -- after all, there are prohibitions against inciting violence and yelling "Fire!!" in a crowded theater -- there are and should be reasonable restrictions as to where you can carry your gun, if you choose to carry one at all.

Statistics Show More Guns Are Not the Answer

Mr. Secretary, more and more it seems that as gun violence escalates the NRA believes the only answer is to respond with more guns. Seemingly, we live in a gun-crazed society. If the NRA isn't evidence of that, just look at the publicity surrounding the release of Grand Theft Auto IV, one of the more controversial video games that actually awards points for murder.

Or, look at the statistics. According to a 1994 study performed for the Centers for Disease Control and Prevention, the United States "has by far the highest rate of gun deaths -- murders, suicides and accidents -- among the world's 36 richest nations ... The U.S. rate for gun deaths in 1994 was 14.24 per 100,000 people. Japan had the lowest rate, at .05 per 100,000."

In response to those statistics a Johns Hopkins University researcher who specialized in gun violence remarked that, "If you have a country saturated with guns -- available to people when they are intoxicated, angry or depressed -- it's not unusual guns will be used more often. ... This has to be treated as a public health emergency.''

The statistics point to just such an emergency, Mr. Secretary. Here are some sobering numbers, from the Brady Campaign to Prevent Gun Violence:

Gun Deaths and Injury - The United States Leads the World in Firearm Violence

• In 2004, 29,569 people in the United States died from firearm-related deaths – 11,624
(39%) of those were murdered; 16,750 (57%) were suicides; 649 (2.2%) were accidents;
and in 235 (.8%) the intent was unknown. In comparison, 33,651 Americans were
killed in the Korean War and 58,193 Americans were killed in the Vietnam War.

• For every firearm fatality in the United States in 2005, there were estimated to be more
than two non-fatal firearm injuries.

• In 2004, firearms were used to murder 56 people in Australia, 184 people in Canada, 73
people in England and Wales, 5 people in New Zealand, and 37 people in Sweden. In
comparison, firearms were used to murder 11,624 people in the United States.

• In 2005, there were only 143 justifiable homicides by private citizens using handguns in
the United States.

Mr. Secretary, as you well know national parks are widely popular backdrops for family vacations. During the summer vacation months the sounds of laughing and giggling children can be heard throughout the park system as they run and play. Do you also know that more children and teens died died as the result of gun violence in the United States in 2003 than all the U.S. military deaths in Iraq from 2003 to 2006? If we can’t prevent such tragedies in America, can we not at least try to keep the national parks as sanctuaries from such violence to the degree possible?

Mr. Secretary, it seems you want to make it even easier to carry guns in America in general and our national parks specifically.

Here are some more statistics compiled by the Brady Campaign that point to the flawed logic that an armed America is a safer America. In fact, looking at these numbers, an argument could be made that arming more Americans with more weapons isn't decreasing murders but is leading to more suicides, accidental deaths, and accidental shootings. Plus, as the Brady Campaign points out, more and more youth are being killed because of our gun culture:

Gun Violence - Young Lives Cut Short

• In 2004, nearly 8 children and teenagers, ages 19 and under, were killed with guns
every day. (My emphasis)

• In 2004, firearm homicide was the second-leading cause of injury death for men and
women 10-24 years of age - second only to motor vehicle crashes.

* In 2004, firearm homicide was the leading cause of death for black males ages 15-34.

• From 1999 through 2004, an average of 916 children and teenagers took their own lives
with guns each year.

* Each year during 1993 through 1997, an average of 1,621 murderers who had not
reached their 18th birthdays took someone's life with a gun.

Mr. Secretary, you claim that, “The safety and protection of park and refuge visitors remains a top priority for the Department of the Interior,” and that the proposed revisions are intended to make gun regulations in the parks more consistent with state laws. On that second point, about making the national parks more consistent with state laws, should we also make them more consistent in terms of logging, and mining, and hunting? Why have a national park system if the goal is to diminish the parks distinctiveness from other places? That too, seems to violate Congress’ clear intent, codified again in 16 US Code 1a-1:

Congress declares that the national park system, which began with establishment of Yellowstone National Park in 1872, has since grown to include superlative natural, historic, and recreation areas in every major region of the United States, its territories and island possessions; that these areas, though distinct in character, are united through their inter-related purposes and resources into one national park system as cumulative expressions of a single national heritage; that, individually and collectively, these areas derive increased national dignity and recognition of their superb environmental quality through their inclusion jointly with each other in one national park system preserved and managed for the benefit and inspiration of all the people of the United States…

Will More Guns Really Make the National Parks Safer?

Mr. Secretary, will allowing concealed carry in the parks give parents peace of mind when they put their children down for the night in campgrounds where those in the next site might have a weapon? Will it make it safer for visitors riding on shuttle buses if many of their fellow riders are armed? Will it make it safer for rangers responding to drunken fights in campgrounds? Will you require concessionaires to install gun lockers in their lodges? Will restaurant and convenience store patrons have to check their weapons at the door? Will it be OK to knock down a couple shots of Jack Daniels and chase it with a beer at the Bear Pit Lounge in the Old Faithful Inn while you're packing?

Mr. Secretary, many gun owners are quick to proclaim that they are as skilled and tested as Park Service law enforcement rangers when it comes to handling guns. Is that so?

As I understand it, the intensive training program for law enforcement rangers is 18 weeks long. Then, once the ranger completes their basic law enforcement training at the Federal Law Enforcement Training Center their next stop, after a short break at their home park, is to report to a field training park for an additional 10 weeks of mentored, hands-on experience. The Field Training Officers are experienced rangers who are specifically trained to provide field training. They are with the trainees in the field, but the trainees make all the law enforcement contacts while the training officers serve as observers, back-up, and evaluators.

Mr. Secretary, if violence breaks out in a national park, whether in the backcountry or the front country, are you comfortable with the possibility that some park visitor, armed with a Smith & Wesson or a Glock, will either try to bring things under control on their own or rush to the aid of a ranger, who then will be in the uncomfortable position of having to decide in an eye-blink who can be trusted with a firearm and who can't be?

What, Mr. Secretary, would you tell international visitors, many whose home countries have extremely stringent gun laws, to make them feel safe in our parks if concealed carry is permitted? Should you sign off on this change, how would you explain it to visitors to Waterton/Glacier International Peace Park?

Mr. Secretary, don't you think that as we move towards the National Park Service’s centennial in 2016 one thing we should strive to do is use the national parks to instill in visitors not just a feeling of safety, that they’ve entered sanctuaries, but to convince tomorrow’s generations that they don’t need to arm themselves to feel safe?

Mr. Secretary, can you honestly say, after considering all the facts and after closing your eyes and ears to all the political pandering, that increasing the number of loaded weapons in our parks is a good idea? I urge you to reconsider. Stand up to the NRA and for the national parks.