ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW
Submitted online via: https://www.regulations.gov/commenton/OPM-2025-0107-0001
Subject: Reduction in Force
May 4, 2026
We are writing on behalf of the Coalition to Protect America’s National Parks (Coalition), an organization which represents over 5,000 current, former, and retired employees and volunteers of the National Park Service, and the National Parks Conservation Association (NPCA), the leading national, independent voice for protecting and enhancing America’s National Park System for present and future generations.
The Coalition to Protect America’s National Parks represents over 50,000 years of collective national park management and stewardship experience. Our members include former National Park Service (NPS) 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.
The National Parks Conservation Association was founded in 1919 and has over two million members and supporters who care deeply about national parks and the NPS staff who steward and interpret them. We and our supporters have a vested interest in NPS employees who are the people who tirelessly work to protect and interpret our national treasures.
Congress has historically recognized Federal agencies’ authority to engage in a Reduction in Force (RIF). It was determined that veterans would receive a preference over other employees and agencies were precluded from discharging or reducing the rate or salary of honorably discharged veterans. In 1921, a system was created to place employees into classes to determine which position would be eliminated in a RIF. It has been the practice of the Federal Government to exercise a RIF for the permanent elimination of positions due to restructuring, budget constraints, or lack of work, rather than performance issues. We do not necessarily question this practice when there is justification that the results would create efficiencies that lead agencies to perform better. These decisions should be made very carefully. Our comments in regard to this rule, however, raise deep concern and questions about the use of a RIF for performance issues and its implications for the NPS workforce, particularly in the context of the recent Office of Personnel Management (OPM) rule, “Performance Appraisal for General Schedule, Prevailing Rate, and Certain Other Employees” (RIN 3206-AP06).
The OPM Rule applies statute (5 U.S.C 3502) and directs it to prescribe regulations “for the release of competing employees in a reduction in force” that give “due effect” to four factors; tenure of employment, military preference, length of service; and efficiency or performance rating.
The proposed Final Rule of the Employee Performance Management Appraisal System to standardize distribution and assign individual ranks to employees or categorize them into groups, (as the proposed RIF does), including “top performers,” “average performers,” and “low performers” would deny employees fair or equitable treatment and subject them to arbitrary action. One of our primary concerns is that employee performance ratings would not be based on individual merit and individual performance but on factors like race, color, political affiliation, religion and gender, and preferential treatment. This is a particular concern when the Merit Systems Protection Board has been stripped of jurisdiction over RIF appeals (as per “Reduction in Force Appeals,” RIN 3206-AO99).
Past presidents, agency directors, and OPM have understood the consequential implications of requesting a RIF – not just the reduction of the workforce, but the negative impact on the lives of federal workers and their families and those remaining in the workplace.
OPM states it is proposing these changes to improve the efficiency of the RIF process to effect better outcomes with less burden on agencies invoking these rules, and to increase the focus on “merit” in determining retention standards. However, the proposed RIF authority is absent of a plan that truly considers merit and has not, to our knowledge, surveyed agencies such as NPS in the development of the proposed authority.
We are deeply concerned that if this RIF authority is allowed, OPM and agencies will read this guidance as giving them complete freedom, absolute authority, and full discretionary power to act as they wish, particularly regarding decision-making related to employees who are not given the performance rating they deserve because of arbitrarily – and legally dubious – assigned quotas. There is potential for individuals who are thought not to be “in agreement” with the current administration to be targeted.
We were deeply concerned by the Rule “Performance Appraisal for General Schedule, Prevailing Rate, and Certain Other Employees” (RIN 3206-AP06), which has implications for this proposed Rule. At NPS, it led to arbitrary downgrading of employee appraisals at the direction of the Department of the Interior (DOI), which has consistently undermined NPS employees, creating fear of job security and undermining morale among its staff. This climate of fear—in addition to a misguided, chaotic and counterproductive consolidation effort—led to more than 4,000 NPS staff being transferred or pressured to leave in 2025. This has led to parks and supporting programs and offices scrambling to meet basic needs for visitor services, and resource protection, maintenance, visitor safety and enjoyment significantly compromised.
RIN 3206-AP06 only heightened NPS employees’ fear for their job security and further led to plummeting morale for the people who tirelessly serve in the interest of our national treasures and the public to whom they belong. Some employees were told that their performance appraisals were being withdrawn and downgraded due to an arbitrary ceiling of 3 as the highest acceptable rating.
As noted earlier, DOI has been relentless in undermining NPS employees, and we fear a RIF could still take place despite the decimation of the agency over the course of one year alone. The forced downgrading of performance ratings in RIN 3206-AP06 will make it more difficult for NPS managers to emphasize merit. This, in turn, would threaten to make them subject to a RIF under this proposed Rule. Combined with the aforementioned attack on the Merit Systems Protection Board (MSPB), we are alarmed at the potential for NPS employees to be arbitrarily fired. This threatens to give a clearly politicized DOI—or DOI under any future administration— sweeping discretion over who is fired and who can remain at NPS, paving the way for politically motivated layoffs under the guise of “performance-based decisions.”
NPS employees serve the agency’s mission and the American people who collectively own our national parks, not merely the political whims of any administration, irrespective of its approach to land management. Administration policy guides agency decisions, but it is a frightening prospect that career staff could be arbitrarily fired in a RIF if they make decisions that foremost adhere to the NPS mission and the many statutes that guide protection of park resources rather than those that may align with decisions that are inappropriately swayed by political appointees and perspectives that could contradict the NPS mission to protect irreplaceable natural and cultural treasures for the enjoyment of present and future generations.
The rigging of the performance system by RIN 3206-AP06, combined with this proposed Rule and the undermining of the MSPB, threatens to upend the current system that protects employees from arbitrary, politically motivated decisions that could lead to their dismissal despite good performance. This is a dangerous concept.
OPM repeatedly states the changes are proposed to create “a more efficient and merit-based set of RIF rules that agencies can use in conjunction with other modern downsizing tools, such as Voluntary Early Retirement Authority (VERA) and Voluntary Separation Incentive Payments (VSIP) to address needs. The proposed revisions make the RIF process more clearly focused on merit by giving performance ratings a much more central role in determining retention in a RIF.” This proposal is said to better assist agencies in retaining their top performers.”
However, the Reduction in Force (RIF) authority was established primarily in the 1940s and was solidified by the Veterans’ Preference Act of 1944 to provide an orderly, fair process for agencies to release employees due to lack of work, budget cuts, or reorganization. RIF rules were developed to ensure that factors like seniority and veterans’ preference determine staffing cuts, rather than arbitrary decisions. This Rule, coupled with “Performance Appraisal for General Schedule, Prevailing Rate, and Certain Other Employees,” threatens to foster the very arbitrary decisions the current civil service protections are intended to prevent.
If RIFs are proposed for the permanent elimination of positions due to restructuring, budget constraints, or lack of work, rather than performance issues, performance should not be considered, especially where performance quotas are being required.
On behalf of our public-interest nonprofits and our members and supporters, we strongly oppose this proposed Rule. These proposed changes to RIF authority should not be allowed.
Sincerely,
Cheryl A. Schreier
Chair, Executive Council | Coalition to Protect America’s National Parks
(202) 819-8622 | Ed****@********PS.org | ProtectNPS.org
John Garder
Senior Director, Budget & Appropriations | National Parks Conservation Association
(202) 604-7386 | jg*****@**ca.org | npca.org
Your parks. Your turn.