June 9, 2017
President Donald J. Trump
The White House
1600 Pennsylvania Avenue
Washington, DC 20500
Subject: Executive Order on a Comprehensive Plan for Reorganizing the Executive Branch
Dear President Trump:
I am writing to you on behalf of the Coalition to Protect America’s National Parks (Coalition) in response to the White House request for comments on “Executive Order on a Comprehensive Plan for Reorganizing the Executive Branch,” which was issued on March 13, 2017. The Coalition is composed over 1200 retired, former, or current salaried employees of the National Park Service (NPS). Collectively we represent more than 30,000 years of national park management experience. As a national parks advocacy group, we will focus our comments on executive branch reforms needed to ensure the long term success and viability of the NPS in managing the many units of America’s National Park System.
A brief reflection on the history of national parks is necessary to put the importance of taking good care of America’s National Park System in proper perspective.
In March 1872, President Ulysses S. Grant signed the Yellowstone National Park Protection Act, thereby establishing the world’s first national park dedicated for “the benefit and enjoyment of the people.” Today Yellowstone’s incredible geothermal features and magnificent wildlife remain unimpaired and more than 4 million people visited the park in 2016. Decades after the establishment of Yellowstone, in January 1908 President Theodore Roosevelt exercised his authority under the Antiquities Act of 1906 to designate more than 800,000 acres of the Grand Canyon area as a national monument. In doing so, he declared, “Let this great wonder of nature remain as it now is. You cannot improve on it. But what you can do is keep it for your children, your children’s children, and all who come after you, as the one great sight which every American should see.” In 1919, Congress passed and President Woodrow Wilson signed the Grand Canyon National Park Act, re-designating Grand Canyon as a National Park. Today the Grand Canyon remains one of the most remarkable natural wonders of the world and was visited by 5.9 million people in 2016.
The ideal expressed in these acts of conserving America’s cultural and natural treasures for generations to come is strongly reflected in the NPS Organic Act, signed into law by President Woodrow Wilson on August 25, 1916. The Act created the National Park Service and defined the fundamental purpose of the parks, monuments and reservations, which is
“to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”
In essence, more than any other Federal agency, the NPS is responsible for taking care of America’s most treasured natural, cultural, and scenic heirlooms, its “scenery and the natural and historic objects and wildlife” and to manage those resource in such manner as will leave them “unimpaired for the enjoyment of future generations.”
Americans love their national parks; and so does the rest of the world! America’s National Park System, which has grown to 417 units, celebrated its 100th anniversary in 2016 when it welcomed over 330 million visitors, who spent an estimated $18.4 billion in local gateway regions (defined as communities within 60 miles of a park), supporting 318,000 jobs and contributing $34.9 billion in economic output to the national economy. In practical terms, the current NPS annual budget of around $3 billion produces slightly more than a 10:1 return on investment in terms of contribution to the national economy. Few, if any, other Federal agencies can make that claim!
Yet, the NPS has struggled in recent years with a variety of fundamental issues and is more challenged than ever before to continue its decades long traditions of excellence. For example, the National Park System is struggling with aging infrastructure, with estimated deferred maintenance repair costs of over $12 billion. Substantial investments are needed in park roads and trails, visitor centers, transportation, public water systems, and telecommunications to keep such facilities open to the public. The NPS needs to reinvigorate its leadership and pay close attention to work force development. Sufficient numbers of well trained staff are needed in parks to address issues of public safety, overcrowding, and facility maintenance. Finally, the NPS serves as an important partner to both states and local communities that provide information and services to park visitors. As a result, parks provide important economic opportunities for the outdoor recreation and tourism industries, activities that support sustainable economies throughout our nation.
The current situation is not sustainable. It is time to make America’s national parks great again! A number of government reforms are, in fact, necessary for the NPS to successfully and sustainably accomplish its important mission for the benefit and enjoyment of the American people. Toward that end, we make the following recommendations:
I. REFORMS NEEDED TO ENSURE EFFECTIVE LEADERSHIP AND WORKFORCE
As the NPS enters its second century, significant human resource and training/development changes need to be instituted to meet future needs and to ensure NPS continues to accomplish its important mission. These reforms include:
A. Start at the Top: Ensure NPS Senior Leaders Understand Expectations and Are Held Accountable
Senior leadership, including the NPS Director, Associate Directors and Regional Directors, must set a good example of strong leadership, personal integrity, and individual accountability. Commitment to the NPS mission is paramount! Park resources must be protected. Laws must be followed. These expectations must be reinforced and fully incorporated into the agency’s leadership culture. Individuals who violate the law or otherwise abuse their roles as government employees must be held accountable!
B. Ensure Mid-level Managers and Supervisors Receive Necessary Training and Development
Some supervisors, mid-level managers, and even some park superintendents have been promoted without effective supervisory or leadership skills, and without basic knowledge of applicable NPS laws, regulations, and policies or other environmental laws. Training in these topics is essential to effective leadership and decision making, and should be provided early in one’s supervisory career, continued as one progresses within the agency, and considered “required” training for supervisory and leadership positions.
C. Ensure a Well-trained and Competent Workforce
All NPS employees should have a fundamental understanding of the NPS mission, as well as being trained to competently and safely perform their assigned duties. Informal on-the-job skills training by a work unit supervisor is the norm in the NPS; however, certain training topics, such as orientation to the NPS mission or technical safety training, are best provided in a more formal training environment. Lastly, the NPS has made great strides in its employee safety program over the past 10-15 years and in many parks a strong commitment to employee safety has become an important part of the work culture. However, given the inherent risks involved with many NPS jobs (e.g., often working short-handed or alone in remote locations or in challenging weather), NPS leadership agency must continue to make employee safety a high priority.
D. Hire and Develop a Workforce Reflective of the Strength and Diversity of America
Much lip service has been given over the years to improving the diversity of the NPS workforce so that it reflects the diversity of park visitors and of our nation. While progress has been made within the NPS, it is not enough. We doubt the agency can fix this on its own. An independent review is needed to analyze the current workforce and devise methods for transitioning to a workforce reflective of the country’s diversity.
E. Conduct a Thorough Review of the NPS Organizational Structure BUT Put the NPS Mission First
In our decades of experience, the NPS has suffered from a history of new Administrations making bold organizational changes in the name of “streamlining government.” But, invariably, the results have not lived up to the goals of change. Such changes have included consolidating and reducing the number of regional offices, removing administrative support staff and scientists from parks and consolidating them in “service centers” or in other DOI agencies, with the promise that those employees would still serve the park(s) from which they were taken away. From the perspective of getting the job done more effectively in those parks, such moves have rarely succeeded. Other changes have included “stove-piping” certain technical or support functions, such as criminal investigators or contracting specialists, removing those employees from the parks they served and stationing them as a shared resource in central offices under the control of central office supervisors. Such consolidation has almost always been detrimental to the parks that lost the specialized staff. In our opinion, the primary evaluation factor in considering any changes to the NPS organizational structure should be “will the reorganization improve the delivery of cost-effective, efficient services needed to accomplish the NPS mission (including staffing, programs, and support functions).” Such decisions should be mission driven and results oriented. Otherwise, if it ain’t broke, don’t fix it!
We do believe there is room for improved communications and coordination and perhaps resource sharing (e.g., of specialized or technical staff) between Department of Interior agencies at the regional level. However, given the very different missions, regulations and policies of the respective DOI land management agencies, consolidating the respective agencies’ chains-of-command at the regional level makes no sense at all. It is a recipe for ineffective decision making, with likely errors in the application of agency laws and policies, creating an open invitation to increased litigation.
F. Zero Tolerance Means Zero Tolerance
Every Federal employee deserves to come to workplace that is free from discrimination and harassment. Clearly, this has not always been the case within the NPS. We completely support Secretary Zinke’s zero tolerance policy and encourage him to ensure that any such allegations are investigated in a timely and objective manner, and all proven violators are held accountable. All supervisors and managers need to receive training/ development to equip them to address and correct employee misconduct/poor performance.
II. ADDRESS PARK INFRASTRUCTURE NEEDS
The NPS has an extensive inventory of 86,000 facility assets, many of them irreplaceable national treasures, and manages over 84 million acres of America’s most scenic landscapes. Much of the existing park infrastructure is over fifty years old, since the last major infusion of funding for park facilities occurred during the 10-year “Mission 66” initiative that occurred from the mid-1950’s to the mid-1960’s. The cost of rehabilitating or replacing visitor facilities, water systems, roadways and bridges, and restoring historic properties is staggering and currently estimated at over $12 billions of dollars. The fact is funding for the parks has not kept pace with the growth in the Gross Domestic Product (GDP), the expansion of the park system (now numbering 417 park units), and the increases in park visitation.
Significant reforms, not just funding, are needed to address NPS infrastructure needs. There are opportunities to develop innovative funding approaches including public/private partnerships, skilled job training programs, and leveraging funding from the philanthropic sector. However, public investment is an essential part of rebuilding the infrastructure of our parks. Such an investment would provide multiple benefits: supporting the tourism industry that is lifeblood of many states and local communities, providing jobs in both the construction and specialized crafts sector, and leaving a tangible legacy for future generations. Reforms include:
A. Develop a 15-year Plan to Address the $12 Billion Infrastructure Backlog
The math is staggering! To reduce the $12 billion backlog would require an infusion of $800 million per year for 15 years. A good start would be to address non-transportation infrastructure needs by supporting S. 751, the National Park Service Legacy Act. Address road and bridge infrastructure needs by reauthorizing the Highway Trust Fund and raising the portion provided to the NPS consistent with a 15-year project schedule. Take advantage of public private partnerships opportunities presented by the historic leasing program as a way to rehabilitate historic buildings that are a significant portion of the park system’s deferred maintenance inventory.
B. Address the Root Cause of the Backlog
It is rarely discussed why the size/cost of the infrastructure backlog continues to grow year after year despite considerable NPS investment in major renovations and repairs over the past few decades. The fundamental issue is that NPS has a massive inventory of facility assets, most are aging and heavily used by the public; yet NPS has been chronically underfunded and understaffed for conducting preventive and recurring (AKA “cyclic”) maintenance. Parks with inadequate maintenance staffs necessarily focus on “operating” NPS facilities, such as keeping the lights on, emptying the trash, and cleaning the bathrooms; not on “maintaining” them. Many parks are rarely able to consistently perform the necessary maintenance to keep small problems from becoming big problems. Eventually, those problems become so large that the facility requires an expensive major repair or renovation and at some point the “project” competes well for major construction funding because the need has become so great. Once the major renovation occurs, the cycle of deterioration begins again – facility is “good” for a few decades and but the continued lack of preventive and recurring maintenance leads to a premature decline in the facility’s condition. The solution is simple but requires commitment. Ensure the NPS has adequate funding and is committed to implementing a systematic preventive and recurring maintenance program. Major investment in park infrastructure (from the major renovations) must be protected by doubling the NPS budget for repair, rehabilitation and cyclic maintenance from $ 200 million to $400 million annually. Every park should have a line item in its budget for this purpose that is proportional to the overall value of its asset inventory.
III. PROVIDE ADEQUATE STAFFING TO PROTECT AND MAINTAIN OUR PARKS
As the popularity of the parks as a tourism destination rises, NPS must respond to challenges beyond just investing in infrastructure. More national park rangers are required to serve the needs of visitor use and resource protection as well as to respond to emergencies and a prolonged fire season. As described above, additional maintenance staff is needed to prevent future deterioration of park facilities and to care for any new investments. The staffing and funding to meet these needs have declined in all areas of park operation – maintenance, interpretation, resources management, and visitor protection. Since 2001 the NPS operating budget has been reduced by approximately $500 million dollars. At the park level this translates into a loss of approximately 1,500 full-time employees. We recommend restoring staff levels to FY2010 levels, more than 10% above 2015 staffing levels.
While we understand it is unlikely that NPS would receive increased appropriations to restore staffing to FY2010 levels, there are opportunities for alternative funding that are currently underutilized. For example, the Federal Lands Recreation Enhancement Act allows agencies to collect certain user fees (e.g., entrance fees and campground fees) and allows the agencies to use those fees for certain purposes. Such fees are used to pay for staffing for fee collection and for a limited variety of fee-raising programs (such as special interpretive programs), or for facility repair projects. However, because the Act has a relatively short sunset period and needs to be regularly reauthorized by Congress, NPS has a self-imposed policy to not use fee money to pay for permanent staffing, such as for preventive and recurring maintenance, since the fund source is not guaranteed beyond the sunset date. The Act should be permanently reauthorized or at least reauthorized for an extended period (such as 10-20 years). The reauthorization legislation should include a clause that explicitly authorizes the use of fee revenue to support preventive and recurring maintenance programs.
IV. UTILIZE PARTNERSHIPS TO ACHIEVE NPS GOALS
Over the past 10-15 years, the NPS has become much more effective in using partnerships, typically with non-profit organizations set up to support the NPS in accomplishing its mission goals. Many parks have “cooperating associations” or “Friends groups” that raise funds and provide other support to the park operation. Despite this progress, more could be done. Every park should have a fundraising partner. Looking outside the parks, NPS has the opportunity to leverage the park experience by effectively using its long standing programs that support the work of its state partners as well as private landowners and community conservation organizations. The NPS can use its iconic brand, its powerful interpretive messages, and its many well-regarded partnership programs to offer healthy outdoor recreation, tell America’s stories, and enhance economic vitality in states and local communities. Funding for these programs has been inconsistent in recent years. Even though a reliable source of funding exists, it requires Congress to reauthorize the use of such funds. We recommend the following reforms:
A. Fully Fund the Land and Water Conservation Fund
Funded from off shore oil and gas receipts, non-taxpayer dollars, this program assists in the conservation of critical federal lands for resource conservation and supports state partners in the planning and development of parks and other recreational assets. In our national parks these funds can be used to acquire inholdings and fill in mandated park boundaries to protect resources and benefit the visiting public. At the state level, the fund has leveraged millions of dollars, created thousands of local parks, and conserved land for outdoor sports and public recreation.
B. Fully and Permanently Fund the National Historic Preservation Fund
The Historic Preservation Fund also uses receipts from off shore oil and gas receipts, non-tax payer dollars, to partner with States and Tribes to provide cost effective preservation strategies. This includes the Historic Tax Credit, which over the past three decades has created 2.3 million jobs, leveraged $117 billion in investment, and rehabilitated more than 41,250 buildings. Investments in historic preservation help conserve historic properties and revitalize both our urban and rural communities.
C. Enact Program Legislation to Permanently Authorize and Fund the National Heritage Areas
The National Heritage Area approach has a thirty-year track record of developing strong regional partnerships for resource conservation and community prosperity. Today there are 49 National Heritage Areas from Alabama to Alaska. Program legislation has been introduced with bi-partisan support for over a decade and now is the time to make a push for its passage.
D. Support Strategic Partnerships Centered Around Recreation and Trails
The NPS does more than just manage parks. Programs like the National Scenic and Historic Trails, and the Rivers, Trails, and Conservation Assistance (RTCA) program enable NPS to reach out to and connect with state and local partners across the country centered around the idea of recreational access and resource conservation. NPS should continue to target the benefits of this program to work with partners at Federal, state and local levels to improve community recreation and resource conservation.
In closing, we reflect on the words of Pulitzer Prize winning author Wallace Stegner, “The Dean of Western Writers,” who said in 1983: “National parks are the best idea we ever had. Absolutely American, absolutely democratic, they reflect us at our best rather than our worst.” We believe that is true today. And it is time to make America’s National Parks great again!
Thank you for the opportunity to comment on this important topic.
Maureen Finnerty, Chair
Coalition to Protect America’s National Parks
cc: Ryan Zinke, Secretary of the Interior