2/14/20
Mr. David Vela
Acting Director
National Park Service
1849 C Street NW
Washington, DC 20240
Dear Acting Director Vela:
I am writing to you on behalf of the Coalition to Protect America’s National Parks (the Coalition) and in partnership with the Association of National Park Rangers, to express our grave concern over the initiative that will convert all National Park Protection Rangers from the current Park Ranger (0025) series to the Inspection, Enforcement, and Compliance (1801) series.
As you know, the Coalition is a non-profit organization composed of over 1,700 retired, former, or current employees of the National Park Service (NPS). As a group we collectively represent over 40,000 years of experience managing and protecting America’s most precious and important natural and historic resources. Many of our members have decades of experience as protection rangers and have been involved with this issue.
The Coalition is aware that you have met with the Association of National Park Rangers to discuss this issue, but we feel it is important to add our voice to this discussion. We have several concerns.
We believe that converting protection rangers to the more generic 1801 series would clearly violate the intent of Congress, as articulated in the House Report on the 1976 Authorities Act, which stated that law enforcement was to be but one of a broad suite of resource and protection duties, performed by protection rangers. The 1801 series is strictly a law enforcement/inspector series and is not appropriate for National Park Rangers, who need to continue to perform a broad spectrum of resource and visitor protection duties.
The 1801 Benchmark Position Descriptions developed by OPM would increase the percentage of law enforcement duties from 51% (under the current 0025 Benchmark Position Descriptions) to 65-70%, moving law enforcement from a “primary” duty under the current PDs to an almost exclusive duty. This is an inappropriate and unnecessary standard that will be virtually impossible for some protection rangers who are working in less active parks to meet, perhaps putting their 6c retirement at risk.
The 1801 Position Descriptions would also fundamentally change the nature of the protection ranger job, significantly reducing the current emphasis on resource knowledge, resource education, emergency medical services, search and rescue, and firefighting. In fact, OPM’s own guidance on the use of the 1801 series states that it “may not be used for those involved with the conservation of resources on federal park lands,” as these unique duties were best described under the Park Ranger 0025 series.
When we met with you in January and raised a question about this issue, you stated “we just have to do it.” We respectfully disagree and urge you to do everything you can to protect the history and integrity of the National Park Ranger job. We respect and fully support the fact that law enforcement commissioned rangers must perform at the highest possible level of competence and professionalism, and that law enforcement should remain a “primary” duty of these positions.
However, we believe that virtually every National Park Superintendent would tell you that Protection Rangers need to continue to serve as a multi-skilled specialist, with duties to include law enforcement, emergency medical services, search and rescue, and firefighting. This is what has made the National Park Ranger job distinctive and iconic. While a conversion to a generic job series and PD might seem like a benign administrative change, we strongly believe that over time, it will erode the foundation of what has made this profession unique and will do a great disservice to the profession, the parks, and the visiting public.
Thank you for your continued attention to this matter. The Coalition stands ready to work with you in any way we can to preserve the integrity of these unique and special positions within the National Parks.
Sincerely,
Phil Francis
Chair, Coalition to Protect America’s National Parks