ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW
Submitted online via: https://www.regulations.gov/commenton/OPM-2025-0273-0001
Subject: Performance Appraisal for General Schedule, Prevailing Rate, and Certain Other Employees (3206-AP06)
March 20, 2026
Dear Noah Peters,
I am writing on behalf of the Coalition to Protect America’s National Parks (Coalition), which represents nearly 5,000 current, former, and retired employees and volunteers of the National Park Service.
Collectively, our membership represents over 50,000 years of national park management and stewardship experience. Our members include former National Park Service directors, deputy directors, regional directors, and park superintendents, as well as a variety of program specialists and field staff. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service (NPS).
If the proposed Final Rule of the Employee Performance Management Appraisal System is allowed, it will cause discord and cost the American people an insurmountable amount of personal, psychological and inhuman damages. It is clear that this Standard Performance System proposed by the Office of Personnel Management (OPM), that states “it will strengthen the agencies’ ability to evaluate performance accurately and fairly, ensure that high performance is recognized and rewarded, and align workforce management with mission accomplishment,” is politically driven to align employees with the ongoing political agenda and weed out those who are not perceived as “loyal.”
The final rule states that OPM aims to promote a culture of accountability and excellence across the Federal workforce – one that reflects both the government’s “evolving operational demands and its longstanding commitment to merit-based service.” The proposed Standardized distribution to assign individual ranks to employees or categorize them into groups, such as top performers, average performers, and low performers is no more than cloaked profiling. If this is allowed, perceived or actual discrimination will permeate the workforce. Individuals who are thought not to be politically correct, or in agreement with the current administration, will be targeted.
The Civil Service Reform Act of 1978 includes the Merit System Principles, and states:
“…all employees and applicants for employment should receive fair and equitable treatment in all aspects of personnel management without regard to political affiliation, race, color, religion, national origin, sex, marital status, age, or handicapping condition, and with proper regard for their privacy and constitutional rights.
Employees should be provided with effective education and training in cases in which such education and training would result in better organizational and individual performance
Employees should be protected against arbitrary action, personal favoritism, or coercion for partisan political purposes, and employees should be protected against arbitrary action, personal favoritism, or coercion for partisan political purposes.”
The Final Rule proposes a standard distribution of evaluating performance, categorizing employees, establishing quotas to determine who will receive 2’s and 3’s, and limiting who receives 4’s and 5’s on the Employee Performance Appraisal Evaluations, eliminating employees with performance evaluations at the level below fully successful rather than utilizing the Performance Improvement Plan to educate and provide additional training as outlined in the Merit System Principles. Contrary to the proposed standardized rating system, this would deny employees fair or equitable treatment and subject them to arbitrary action. Employee performance ratings would not be based on individual merit and individual performance but on factors like race, color, political affiliation, religion and gender. This system would generate conflict with the principle of fair and equitable treatment without regard to prohibited factors.
If the Final Rule is established employees will face significantly reduced options to challenge unfavorable performance evaluations, forcing disputes through channels such as the Equal Employment Opportunity Commission, overwhelming this system and resulting in abuse.
This Final Rule permits agencies to implement forced distribution (quotas) among SES and non-SES employees for performance ratings that undermines merit-based evaluations and creates significant workforce morale issues. By capping the number of employees who can receive high ratings. It also prioritizes subjective management preferences over actual performance and creates incentives for unfair evaluations.
The National Park Service has enjoyed and benefited from large numbers of highly dedicated and professional employees who are well trained to accomplish the mission, uphold various legal mandates, and provide excellent public service. And many of these employees are currently taking on additional work and responsibility to protect irreplaceable resources and ensure parks are open and operational. We strongly believe that OPM should not force performance appraisals to fit a bell curve but should allow supervisors to give the ratings that outstanding employees deserve.
Sincerely,
Cheryl A. Schreier, Chair
Executive Council
Coalition to Protect America’s National Parks
Email: Ed****@********ps.org
Mail: 2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Web: www.protectnps.org
Phone: (202) 819-8622