June 2, 2025
Charles Ezell
Acting Director, Office of Personnel Management
1900 E Street, N.W.
Washington, DC 20415
Re: “Improving Performance, Accountability and Responsiveness in the Civil Service,” Proposed Rule, 90 Fed. Reg. 17182, Docket ID: OPM-2025-0004
Dear Acting Director Ezell,
The National Parks Conservation Association (NPCA), Association of National Park Rangers (ANPR) and Coalition to Protect America’s National Parks (CPANP) submit these comments in strong opposition to the Office of Personnel Management’s (OPM) Proposed Rule “Improving Performance, Accountability and Responsiveness in the Civil Service,” 90 Fed. Reg. 17182 (April 23, 2025). This rule deeply troubles us, and we oppose it in the strongest possible terms. It would significantly undermine 140 years of career civil service protections including the Pendleton Act of 1883 and Civil Service Reform Act of 1978. It threatens to politicize and lead to the dismissal of potentially thousands of National Park Service (NPS) employees, putting at risk the management of the National Park System that belongs to all Americans, thereby hurting the public at large.
Founded in 1919, NPCA is the leading national, independent voice for protecting and enhancing America’s National Park System for present and future generations. Protecting our national parks requires sufficient staffing to protect the world-class resources for which they were designated and to ensure adequate interpretation for public enjoyment, as required by the Organic Act of 1916 that created the National Park System and Service and by numerous ensuing laws and regulations.
The Coalition to Protect America’s National Parks is comprised of over 4,100 members, all of whom are current, former, and retired employees or volunteers of the National Park Service. Together, they have accumulated over 50,000 years of experience caring for America’s most valuable natural and cultural resources. Their members include former NPS directors, deputy and regional directors, superintendents, park rangers (both law enforcement and interpretive), maintenance and administrative professionals, and many other dedicated career professionals.
The Association of National Park Rangers was formed in 1978 and currently has nearly 800 members, both NPS retirees and current employees. Its purpose is to educate and support employees of the NPS and support the purposes of the NPS and the National Park System. The Association of National Park Rangers was formed in 1978 and currently has nearly 800 members, both NPS retirees and current employees. Its purpose is to educate and support employees of the NPS and support the purposes of the NPS and the National Park System.
Creating a new civil service category, Schedule Policy/Career (Schedule P/C), undermines decades of protection for federal career staff, and places national park personnel at risk of being terminated if they do not cater to the political whims of an administration. We fear that this Rule threatens to reduce both the number of staff and their ability to focus on meeting park missions with objective, science-based management rather than pressure to cater to the political preferences of an administration.
Cumulatively, NPCA, CPANP, and ANPR have more than 1.9 million members and supporters throughout the country in all fifty states, plus Puerto Rico, Guam and the Virgin Islands who care deeply about our national parks and want them well cared for and to ensure a safe and quality visiting experience. These supporters, and Americans across the country, are likely to see the resources of their national parks threatened and the visitor experience diminished if the Schedule P/C proposed in the Rule led to staff reductions and/or political oversight that dilutes or undermines staff capacity to objectively implement the mission of the National Park Service.
Federal civil servants have long been hired, retained, and promoted based on their expertise and performance rather than political loyalty. Long-standing civil service law and policy allows these experts to exercise objective judgment without fear of retaliation by political leaders. This applies to the National Park Service. We oppose this proposed new—and dangerous—civil service category because we value NPS personnel and know how important unbiased, experienced, professional career employees are in implementing the agency’s mission to protect park resources. We also know that the administration’s ongoing effort to create a Schedule P/C is having a chilling effect on NPS personnel. Park superintendents, regional directors, Washington Office personnel, scientists, and other employees must make difficult decisions about protecting park resources, and sometimes this is in the midst of pressure from political figures or others who seek certain outcomes. It is critical that these employees feel empowered to make these hard decisions in accordance with agency management policies and legal mandates and in the best interest of our national parks and the public. Fear of retribution would not only further challenge employee morale but also pressure employees to make decisions that may not be in the best interest of the National Park Service and System and instead serve the political interests of the administration in office, its partisan allies, or others. The NPS is already struggling with recruiting and retaining employees, and the risk of political retribution or misguided, politically driven decisions would only create further challenges.
Qualified career staff at NPS and other Department of the Interior (DOI) agencies who are protected from the pressure of a political spoils system ensure that decisions can be made in the public interest and consistent with a series of interacting laws and the intention of Congress. Changes such as the creation of a Schedule P/C threaten to degrade both the public trust and the efficacy of these decisions. NPS and other DOI agency personnel must be free of political interference in part to retain and build expertise. Protecting these civil servants from political decisions ensures the experience necessary to protect resources and navigate laws mandating protection of natural and cultural resources. This also reassures our membership base that national parks can have the career staff they need to make thoughtful and legal decisions to protect parks for current and future generations. The implications of this proposed Rule threaten NPS experts at many levels, from superintendents to historians, air and water quality specialists, staff working on implementing the Endangered Species Act, and many more who must be able to make science-based decisions. Under this new career schedule, they could face the potential—if not the likelihood—of political retribution for making objective management decisions.
Federal civil service cuts and staff losses due to coerced, deferred resignations—specifically those made to the National Park Service—have already caused significant harm to park operations and to our members who want our parks well cared for. We’ve seen resource protection compromised, threats to visitor safety, reductions in visitor access, and a compromised visiting experience in many parks. For our members and all those who value their visit to national parks, this diminishes their experience.
If the proposed Schedule Policy/Career is created, it would decimate recruitment and retention. It’s clear that this “at will” policy is not intended to guarantee a federal workplace free of discrimination based on race, national origin, religion, retaliation, race, disability or anything else. In fact, if this is allowed, fear of reporting any type of perceived or actual discrimination will permeate the workforce. Individuals who are perceived as not agreeing with the current administration would be targeted. The Spoils System will be reenacted and jobs would be at threat of going to political supporters and friends as a reward for their loyalty and efforts. Diversity could be rooted out because the current administration finds it resentful—if not abhorrent. The Equal Pay Act of 1963, Title VII of the Civil Rights Act of 1964, Pregnancy Discrimination Act of 1978, Age Discrimination in Employment Act of 1967, and Sections 501 and 505 of the Rehabilitation Act (Section 501 and Section 505) of 1973 could all be undermined.
Reenacting a Spoils System would send a strong message to National Park Service staff who do not conform to either get on board, get out, or be left behind. The Civil Service Reform Act insisted on fair treatment, due process, and performance-based accountability. But this Schedule P/C would undermine employees’ protections against adverse actions; it would give carte blanche permission to negatively impact employees who will have no way to challenge or appeal such actions. There would be no recourse.
We appreciate the opportunity to comment and urge you to consider our opposition for the sake of the National Park Service, the National Park System, and the heritage of the American people who collectively own these irreplaceable representatives of our nation’s patrimony.
Sincerely,
John Garder
Senior Director of Budget and Appropriations
National Parks Conservation Association
Phil Francis
Chair
Coalition to Protect America’s National Parks
Bill Wade
Executive Director
Association of National Park Rangers