July 28, 2020
United States Department of the Interior
Office of the Secretary
Law Enforcement Task Force
1849 C Street NW
Washington DC 20240
Dear Members of the Secretary’s Law Enforcement Task Force:
I am writing on behalf of the Coalition to Protect America’s National Parks, a non-profit organization comprised of more than 2,200 retired, former, and current employees of the National Park Service (NPS) who collectively have over 40,000 years of experience managing and protecting our national parks. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System.
First, we applaud the Department for undertaking a series of listening sessions to gather public input designed to strengthen public trust in the Department’s various law enforcement programs. Public trust is clearly imperative to a successful law enforcement program at any level. In addition to participating in one of the listening sessions, we offer these additional written comments.
Many of our members have decades of experience performing, supervising, and leading the law enforcement function in a wide variety of units of the National Park System, including some of the busiest in the system. Many of our members also have extensive experience working with the U.S. Park Police and law enforcement officers from the other Interior bureaus. While some of our comments may have application to the other bureaus within the Department of the Interior, our comments are mostly focused on the work of National Park Rangers.
Our experience is that most National Park Rangers are highly professional and are very dedicated to their work and the mission of the NPS. At a time when public trust of government in general is at a very low level, National Park Rangers are still held in very high regard by the public. This is not an accident and is testimony to the quality of the work performed by National Park Rangers.
The Coalition strongly supports improved recruitment to further diversify the ranks of National Park Rangers and all officers within the Department. The recently implemented centralized hiring system for protection rangers within the NPS is a step in the right direction to achieve this goal. Efforts to improve recruitment should continue to ensure highly qualified candidates who are prepared for the unique challenges of working in national parks (often remote, at isolated duty stations) and the rigors of multi-disciplinary work (see paragraph below). A more diversified law enforcement work force will contribute to increased professionalism and greater public trust.
The Coalition feels very strongly about maintaining the historical integrity of the National Park Ranger profession, as a multi-disciplinary profession that includes not just law enforcement, but also resource protection, emergency medical services, search and rescue, structural and wildland firefighting, and more. These are disciplines that every park superintendent needs available for both resource and visitor protection. Recent efforts by the Department to move all National Park Rangers in to the 1801 (law enforcement) job series, as opposed to the traditional multi-specialist 025 (Park Ranger) series, was misguided and will continue to be opposed by the Coalition. One of the reasons that the public has such high regard for national park rangers in general is because of their reputation as multi-skilled specialists that can assist in a wide variety of circumstances and solve a wide variety of problems.
On a similar note, the Coalition will strongly oppose any efforts to “stove-pipe” supervision of the law enforcement function outside of a park’s normal chain of command, which is typically led by the park superintendent. Individual park superintendents and Chief Rangers (Senior Law Enforcement officers within each park) understand that they are responsible for managing their respective park law enforcement programs in full compliance with Departmental and agency policy and practice. Leadership, management, and supervision of these programs should remain at the local park level to ensure continuity of responsibility and accountability, similar to how law enforcement programs are managed in many other jurisdictions, such as towns, cities, and counties. Public trust is enhanced with excellent recruitment and training, strong Department and agency policies to ensure professionalism, and local supervision and accountability.
The Coalition supports recent efforts within the NPS to ensure that the Type II Law Enforcement Commission (used by temporary and seasonal employees with more limited law enforcement training and authority) is being used properly in all parks and that such employees are not being asked to perform tasks better suited by permanent, year-round employees with more advanced law enforcement training.
The Coalition is gravely concerned about the erosion of the number law enforcement commissioned rangers within many parks. By some accounts, the number of permanent full-time rangers is down by over 15% since 2005, with a decline in seasonal rangers of over 30% in that same time period. This is occurring at a time when Congress has added additional parks to the system and visitation to many parks has exploded. We are aware of parks that clearly are not meeting widely accepted minimum staffing levels for both officer and public safety. This is a serious problem that has not only resulted in a decline in public service, but will clearly result in a loss of confidence in the NPS law enforcement program over time.
The Coalition strongly supports the mandatory use of both in-car and body camera systems by all Department of Interior law enforcement officers. National Park Rangers have used in-car systems for many years, and we understand are near 100% implementation of body cameras Service wide. The U.S. Park Police and other Department bureaus need to follow suit. These systems alone, along with professional review or investigation, when appropriate, of and accountability for officer’s decisions and actions will do a great deal to increase public trust.
We are very concerned about the all-to-frequent situation involving National Park Rangers working in areas with totally inadequate radio communication systems to support them in the field. This is not only an officer safety issue, it can also negatively impact the effectiveness of emergency responses as well as public safety. There have been a number of high profile emergency response incidents in the U.S. in recent years being poorly managed, in part, due to inadequate radio communications between officers and/or other first responders from different departments and agencies. The lack of interoperability between various responders’ communications systems and devices resulted in significant breakdowns in communications at the incident scene and in some cases contributed to poor outcomes such as increased loss of life. To address the concerns of unreliable communications in remote locations, as well as ensuring interoperability of communications during multi-agency incidents, it is imperative that the Department give its employees the communications equipment they need to perform well.
The Coalition strongly supports recent and on-going efforts to improve the mental health screening of officers as part of the selection process.We also encourage the Department and the bureaus to develop effective programs to support both the mental and physical health of all its law enforcement officers throughout each employee’s career. Few people outside the profession understand the mental health pressures put on officers, and the number of suicides among law enforcement officers, including National Park Rangers, is alarming. It is a complex issue that should not be ignored. On-the-job stress can negatively impact an officer’s home life; off -duty stressors can negatively an officer’s job performance and decision making. Ensuring that all of your officers feel supported by their employer and receive the support they need to remain mentally and physically healthy, from recruitment until retirement, will also build public trust.
Finally, we encourage the Department to study and consider systems being used in some police departments now to allow the public to provide timely feedback to supervisors and managers about the professionalism of individual officers during law enforcement related public contacts. We are aware of one Department that requires every officer to give to individuals they contact for a law enforcement contact a business card with their officer number and a QR code. The QR code allows that citizen access to a portal where they can provide feedback on how professional the officer was during the contact. Used in conjunction with in-car and body camera systems, this not only promotes professionalism and policy compliance among officers, but also builds public trust.
In closing, we greatly appreciate this opportunity to comment on this important topic.
Michael B. Murray
Chair of the Executive Council