December 5, 2023
Associate Director, Park Planning, Facilities, and Lands
National Park Service
1849 C Street, N.W.
Washington, D.C. 20240
Subject: Comments on Director’s Order #36: Housing Management (D.O. 36)
Dear Associate Director Caldwell:
I write to you on behalf of more than 2,500 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former National Park Service (NPS) directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
We appreciate the NPS Park Planning, Facilities, and Lands directorate undertaking the revision of D.O. 36 to create greater efficiencies and best practices in developing, providing, and establishing sustainable management of park staff and essential cooperator housing. This is a progressive step forward in addressing the ever-present critical NPS housing shortages. We are certainly aware of the impacts to the administration, preservation of resources, and protection of many parks created by staffing shortages that are the direct result of the lack of adequate housing, both in-park and in gateway communities. Lack of staff housing has become an increasing threat both to NPS employee morale, as well as to the agency’s ability to accomplish its essential mission under the NPS Organic Act.
Overall, the revised D.O. 36 comprehensively addresses important needed improvements in park and regional management of Government-furnished housing (GFH). We offer the following comments regarding specific sections of the revised D.O. 36:
- Sec. 3.2, lines 131-132: We propose that the definition of “unaffordable” as it is applied to seasonal employees is inappropriate. A permanent employee, depending on their grade, may be able to afford 30% of their gross salary on housing, depending on the local market, but we believe it is too high for low-graded seasonal employees. This certainly will impact individual park’s ability to meet seasonal hiring needs if affordable housing is unavailable in nearby gateway communities. We understand and applaud that the NPS Washington Administrative Support Office (WASO) has established a program to support leasing seasonal housing within the gateway communities to increase the availability of affordable housing for seasonal park staff. This funding has been established to help cover the gap between the lease cost and the employee’s salary. However, adequacy and reliability of this funding is a concern. Assuming this funding is provided on an appropriations year-to-year basis, more must be done to provide for certainty of the funding in other ways.
- Sec 3.2, lines 141-145: We are encouraged and enthusiastically support the provision that directs superintendents to first explore and do sufficient due diligence on public-private partnerships for either leasing or new housing development projects. Additionally, we would recommend more explicit language in this provision that clearly directs superintendents to document their efforts, due diligence, findings, and decisions in their park’s efforts to explore local leasing and public-private housing development partnerships. It also would be beneficial to include language that articulates that Regional Housing Coordinators, WASO Housing Program Support Office, and solicitors will work with the regions/parks in exploring and developing potential public-private partnerships. Through these collaborative efforts the needed acumen, resources, tools, and skills will be developed and lessons learned will be a long-term benefit service-wide.
- Sec 3.4, line 210: A 5-year requirement to fully update a park’s housing management plan (HMP) is very useful and sorely needed. As with so many other park administration needs, due to funding and staffing issues, HMPs often gets put on the back burner. We trust that your office has an inventory of parks with current HMPs and have identified the parks with the most critical need for updated HMPs. We also would suggest a practical flexibility would be achieved by revising the provision language to state something like “An HMP must be updated every five years or revised by the superintendent earlier if significant changes warrant, like market conditions, housing availability in gateway communities, public-private partnership opportunities, etc.”An option to revise vs. completely update an HMP may facilitate strategic housing actions; and it would frame the HMP as a fluid, on-going housing management strategy and tool.
- Sec 3.7, lines 284-294: We support the proposed requirements that: superintendents will maintain GFH in good condition and no worse than fair condition; units in fair condition must be brought into good condition within two years; units in poor condition must be brought into good condition within 3 years; and obsolete units cannot be used but must be brought into good condition through renovation or replacement. It seems that these requirements necessitate a special account to provide funding that small parks could draw from to meet critical housing needs vs. losing GFH units due to deferred maintenance. Without additional funding, this requirement cannot be met by most park units, (DM). We have observed occasional use of Great American Outdoors Act funding to address housing DM in a few parks. Could it be used more often or extensively to support park housing needs, especially in smaller parks that often do not compete well for DM funding? Could a special category or prioritization be established to identify critical housing needs and priorities that is separate from the NPS 5-year construction budget cycle?
- Sec. 3.7, line 295-303: We recommend adding language to this provision that each superintendent is to provide a summary of annual housing condition inspections to their Regional Housing Coordinator. This would help ensure inspections are done and such information should also be part of the park’s due diligence package.
In closing, we appreciate the opportunity to comment on this important policy revision. We would be glad to respond to any questions you might have and look forward to continuing to work with the National Park Service to help address the housing needs of permanent and seasonal park employees.
Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013