August 26, 2021

Honorable Deb Haaland
Secretary
U.S. Department of the Interior
1849 C Street, N.W.
Washington, D.C. 20240

Dear Secretary Haaland:

Our organizations1 The Coalition to Protect America’s National Parks (Coalition) represents over 1,900 retired, former, or current National Park Service (NPS) employees as well as NPS volunteers and supporters. As a group, we collectively represent over 40,000 years of experience managing and protecting America’s most precious and important natural and cultural resources. Established in 1919 and currently with more than 1.6 million members and supporters, the National Parks Conservation Association (NPCA) is an important voice for America’s national parks, working to protect and preserve our nation’s most iconic and inspirational places for present and future generations. NPCA celebrates the parks — and works tirelessly to defend them — whether on the ground, in the courtroom, or on Capitol Hill. are writing to express our deep concern about the need to make funding from the Great American Outdoors Act (GAOA) available to more units across the National Park System. There are many park units in dire need of repairs, but funding has been limited to a few dozen parks and we believe there is no plan to more equitably obligate the Legacy Restoration Funds (LRF) through GAOA. Providing funding for deferred maintenance (DM) needs at more park units would be a tangible commitment to the administration’s whole-of-government approach to racial justice, and the NPS goals of diversity, relevancy, and inclusion. We are disappointed the National Park Service (NPS) has not yet incorporated these principles in the administration of the LRF.

The FY 21-22 LRF allocations for NPS are heavily focused on the DM needs of primarily large parks with the highest visitation numbers. While we recognize these parks have long-standing needs, we fear this is happening at the expense of the DM needs of small and medium-sized parks and that these parks are receiving disproportionately less than their combined high-priority DM needs warrant. We urge you to increase funds for these other NPS units in FY 23-25.

We maintain that the focus mainly on high visitation—as well as shovel-ready projects—goes against the intent of Congress. In drafting GAOA, Congress intended that DM funds be distributed widely throughout the park system based on the highest-priority needs. This was made clear in committee hearings and markups, as well as floor speeches. Yet, NPS’ focus remains on the more well-known parks. For example, of the 36 major projects proposed for LRF funding listed in the FY 22 president’s budget, only five have had average visitation over the decade of less than a half million visitors. Yet, more than half of NPS units receive less than a half million visitors annually.

It is unfortunate that we hear the NPS will continue on this path of focusing overwhelmingly on larger parks for future years of the LRF and by increasing the dollar threshold for project consideration in FY 23-25. We ask that the department reconsider this approach to LRF distribution by dedicating a greater percentage of annual funding for small and medium-sized parks and by publishing a list of these park projects in the annual NPS budget.

The list of smaller projects not specified in the budget but funded through the Maintenance Action Teams (MATs) is telling of the many smaller projects that can be addressed for a relatively small amount. Yet, our understanding is that list, which comprises approximately $14 million over FY 21-22 combined, is a mere half a percent annually of LRF funds. The needs of smaller parks are taking a back seat to the large parks, and our smaller parks deserve better.  Their needs also deserve the same level of transparency as the larger parks are receiving.

Our collective members spent considerable time educating members of Congress about the DM needs of our national parks and requesting their support for the GAOA legislation.  These education efforts were reflected in hundreds of news articles that appeared on a regular basis with many of the articles focusing locally on the potential benefit of GAOA to a nearby unit of the National Park System while mentioning the specific amount of DM at that unit. With 423 units of the system, it was clear to members of Congress that parks across the country would benefit from these funds, including parks in their states and congressional districts.

However, once GAOA was signed into law, the last administration placed its emphasis on getting funds distributed quickly and focused funding on parks with the highest amount of DM and projects that were shovel-ready. This decision left out small and medium-sized parks that rely on the regional offices, the Denver Service Center, or other central historic and cultural resource assistance offices to help with contracting and project management. Additionally, we understand in conversations with park staff that a number of small and medium-sized parks were not even asked to submit projects for GAOA funding consideration under the past administration and several of them believe this is continuing under the Biden administration.

Even more embarrassing were the comments we heard from some park staff who shared they have no idea how to respond when members of their congressional delegation ask how much their park received from the GAOA funding and what DM it is addressing, when the response is “nothing.”  It will be difficult, if not impossible, to secure broad congressional support for LRF reauthorization without the recognition that parks in hundreds of congressional districts are benefiting from the law.

We have been told by NPS that by focusing the GAOA funding on larger parks, it will free up other sources of funding, such as the annual repair/rehab and cyclic maintenance appropriations that can benefit the smaller and medium-sized parks. Since the NPS’ DM is more than double what GAOA will provide, we doubt projects from small and medium-sized parks will be able to compete any better with the larger parks for these other amounts of annual appropriations.  Additionally, GAOA projects identified in annual appropriations bills have the force of law unless the NPS asks for a reprogramming, while the NPS has wide discretion in how it allocates repair/rehab and cyclic maintenance funding. The small and medium-sized parks need just as much certainty to plan and help manage its projects as the larger parks do with their GAOA funding.

We ask that you work with the NPS to reconsider its project lists for FY 23 and future years by providing specific project funding for small and medium-sized parks with identified projects submitted to Congress for the FY 23 budget that actually reflect the percentage of the overall high-priority DM needs these parks comprise. We expect this would be considerably more than what has been provided in FY 21-22.  We also ask that the NPS be directed to work diligently to establish the internal capacity at the regional and project assistance office level to help small and medium-sized parks become full partners in the GAOA implementation, as we fear this may be a reason these parks have received disproportionately little attention.

Additionally, we request that NPS become more creative in how funding is allocated among smaller parks by allowing them to group projects among parks for GAOA funding. For example, we heard from some park staff that many parks in their region had a need for replacement windows in several buildings. If the NPS selected as a GAOA priority the replacement of windows at multiple parks in a geographic area, one contract could provide efficiencies in scale and costs that would spread the benefits of GAOA more widely and benefit both the parks and park visitors at one time.  We believe there are other similar opportunities that the NPS should explore and prioritize for future GAOA funding.

We know it will require great effort by NPS to achieve the goals of GAOA, but NPS has shown in the past through its implementation of the American Recovery and Reinvestment Act at the beginning of the Obama administration that it could spend those funds in a timely manner, and with the same professionalism and level of service the agency has always shown. We are confident NPS can do similar things with the implementation of the GAOA funding, while ensuring that a wider and more diverse group of parks benefit from its funding.

Thank you for your consideration of our request. We stand ready to continue to work with you to achieve the goals of this law.

Sincerely,

 

 

Theresa Pierno, President and CEO
National Parks Conservation Association
777 6th St NW Ste. 700
Washington, DC 20001

Phil Francis Signature

 

 

Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
1346 4th Street SE #908,
Washington, DC 20003

CC:
Shannon Estenoz, Assistant Secretary for Fish, Wildlife, and Parks, DOI
Shawn Benge, Acting Director, NPS