September 4, 2019

Honorable Raul Grijalva
Committee on Natural Resources
House of Representatives
Washington, D.C. 20510

Dear Mr. Chairman:

On behalf of the Coalition to Protect America’s National Parks, I am writing concerning the September 10, 2019, hearing about the proposed reorganization of the Bureau of Land Management (BLM) and its effect on the National Park Service (NPS) and our nation’s treasured national parks.  The Coalition is largely comprised of retired National Park Service employees with over 1,700 members and roughly 40,000 years of experience leading and working in the National Park Service. The Coalition studies, educates, speaks, and acts for the preservation and protection of the National Park System and mission-related programs of the National Park Service.

This administration seems to think that the bureaus within the Department of the Interior exist in a vacuum.  Nothing could be further from the reality found in the day-to-day management of the department.  Numerous BLM lands surround or are neighbors to national parks.  Our national parks depend on compatible land management to retain ecosystem, cultural, and historical integrity. There were numerous times in past administrations that the director of the National Park Service and the director of the Bureau of Land Management, or their senior staffs, met to resolve conflicts between the bureaus in order to be good stewards of the land.

In the past administration this included issues involving uranium mining, solar arrays, wildlife corridors, science, Grand Canyon water, law enforcement matters, fire management, budget priorities, and many others.  The Park Service and the BLM did not always agree; however, many conflicts were resolved and those conflicts were kept within the department.  In a similar manner, the NPS also had to work with other federal agencies including the U.S. Forest Service, the National Oceanic and Atmospheric Administration, and the U.S. Army Corps of Engineers.  Moving the head of BLM and its senior staff to various locations within the western United States will only result in greater and unresolved conflict between the missions of the agencies.  Such failures of collaboration more likely will become publicized and lead to congressional hearings, and expensive and time-consuming litigation.

The current structure of our land management agencies, which has worked for decades, has the senior leadership based in Washington, D.C., in order to respond personally to Congress and the White House and to collaborate with the leadership of other agencies.  This location enables them to be available to meet with members of Congress and their staffs, to discuss issues face to face with fellow agency leadership, and to effect change and institute policy on regional and national levels.

The proposed DOI reorganization is not being done to create a more efficient decision-making process, but rather, as Secretary David Bernhardt admitted before a recent audience at the Heritage Foundation, to have these federal employees be subject to the pressure of the states and local individuals when it comes to the management of our public lands. Secretary Bernhardt contends that Department of the Interior (DOI) employees have been acting “arbitrarily based on policy preferences” in making federal lands decisions without offering any evidence to back up his statement.

Not only are Secretary Bernhardt’s comments insulting to DOI employees, but as with many statements out of the department, the real purpose or this reorganization and many other policy changes is to hide from the American public the reasons for its actions.  The secretary is merely continuing the pattern he followed in his work during the administration of former President George H. Bush where he advocated for allowing individuals and corporations to exploit federal lands while circumventing laws, rules, and regulations.  Many examples of similar results have been widely documented in the last two plus years where individuals and corporations previously represented by now-Secretary Bernhardt and other political appointees within the department have been able to have rules withdrawn or changed, and policies revised, to benefit them. Unfortunately, our parks, public lands, and the American public suffer the consequences of these unwise actions.

The alleged goal to have agency staff closer to the resource is contradicted by a review of existing staff assignments.  Most agency staff and leadership are already in the field.  They are already close to the resources they are managing and in position to respond quickly to needs of their local communities.  For example, the NPS 2019 budget submitted to Congress showed that with 19,668 full-time staff, only 285 were in Washington, with the rest in the field.  And as the Washington Post recently pointed out in the article of July 15, there are only 360 BLM employees in Washington while 9,260 are in the field.

The specious arguments offered by the department about the reasons for the reorganization are undermined by facts and the recent comments by Acting White House Chief of Staff Mick Mulvaney who asserted that the recent push to relocate federal workers from the Washington, D.C. area is all about “draining the swamp.”  As Mulvaney revealed, the proposed move of BLM and other agency leadership is not to fix a problem of organization, but to break a system that works.

This result was confirmed by Secretary Bernhardt’s August 9, 2019, memorandum to all DOI employees where he assigned the responsibility of the twelve newly appointed Field Special Assistants who report directly to the secretary to “provide a clear and distinct point of contact for stakeholders to elevate, and seek prompt resolution on, issues that involve multiple Bureaus.”  This structure totally bypasses the NPS and BLM regional directors as well as the Office of the Directors in Washington, D.C.  Any conflicts between the NPS and the BLM in the future will be resolved by, in many regions, individuals who have no experience or expertise in the two bureaus, their missions, or the laws that guide their mission.  And with these assignments lasting “typically” one year, the rotation of individuals into these positions will prevent the development of any expertise or continuity and keep the decision-making authority squarely within the secretary of the interior’s office.

We urge the committee to examine the facts of the proposed reorganization and its effect not only on the BLM, but also on the NPS and other bureaus within the department and on other federal agencies that work with the BLM on a regular basis.  Your first commitment by law is to the protection of our national parks and public lands and not catering to the desires of states, corporations, or individuals that want to exploit them for their own profit and purposes.

Finally, as taxpayers, we oppose the proposed reorganization because it is a colossal waste of federal funds badly needed for countless projects to preserve landscapes and the wildlife they support. This cost will only be exacerbated when the next administration recognizes the futility of this reorganization and decides to move the BLM staff back to Washington, D.C. in order to have them effectively carry out their mission by being responsive to Congress and the American public without undue pressure from those seeking to profit off the public lands.

We are committed to our mission to support the NPS in the protection and preservation of America’s national parks. And we are concerned that reorganization, relocation, and smear campaigns targeted at the very people who protect our national treasures will have devastating results for our public lands.





Phil Francis
Chair, Coalition to Protect America’s National Parks