NPCA submitted the following position to members of the House Natural Resources Committee Subcommittee on Oversight and Investigations ahead of a hearing scheduled for September 10, 2019.
NPCA is deeply concerned about the relocation and reorganization of the Bureau of Land Management (BLM) and the broader Department of the Interior (DOI) reorganization of which it is a part.
We commend the committee for holding this important hearing. As we have stated in numerous letters, including in one we requested be submitted for the record for this committee’s April 30th 2019 hearing on the reorganization, we are deeply concerned that the reorganization threatens the management of our national parks, the stewardship of their resources, and the employees of the National Park Service (NPS). DOI’s effort has consistently lacked transparency and has been accompanied largely by insufficient documentation and vague outlines as to the purpose, scope, and timeline of the reorganization, justification for the expenses, and any cost/benefit analysis. Staff have been confused, some being given vague directives with instructions to flesh out the details, occupying much staff time. Most have been entirely in the dark. The proposal has created uncertainty among NPS and other DOI staff and has further reduced morale at a time when NPS staff are already disheartened by understaffing and underfunding, a lack of an NPS director, and government shutdowns.
On the broader reorganization, we are concerned about the assignment of Field Special Assistants, as their roles remain unclear, and there remains potential for political appointees, as well as Senior Executive Service (SES) career staff, in these roles to inappropriately overrule NPS regional directors with political priorities and decisions that run counter to conservation. There is no clear justification for these assistants, and no discernable agenda for the interagency teams they are tasked with facilitating. A major question remains as the reorganization moves forward: why? What precisely is broken to justify an effort of this magnitude, particularly given its implications for our national parks and other public lands?
We have concerns as well about the BLM move, more specifically. BLM lands have connectivity with treasured NPS landscapes, and decisions at BLM can affect the protection of resources on NPS lands. We fear that moving BLM staff west will lead to inappropriate influence from stakeholders, and that a disconnect between NPS leadership and lawmakers in DC could yield decisions that marginalize NPS’ conservation mandate and the protection of the lands they manage. Moving BLM west will undermine the importance of BLM and NPS leadership sitting down together in Washington to resolve conflicts and make decisions that protect our public lands. A failure to collaborate could lead not only to decisions contrary to conservation but also litigation and congressional hearings as a result of poor decision-making. The move reduces accountability to Congress; perhaps that is part of the intent.
We fear that this move is part of an effort to reduce staffing in federal agencies. We were disheartened to hear that White House Acting Chief of Staff Mick Mulvaney recently commented that a benefit of moving federal agencies out of Washington, DC is that it causes federal employees to quit their jobs. Given these comments and OMB’s effort under the management of Mr. Mulvaney to reduce the size of the federal workforce, we are concerned this BLM move is not about fixing a poorly defined problem but is instead intended to reduce BLM’s capacity. The new structure threatens to bypass NPS and BLM regional directors and threatens land management decisions that are not informed by science and are made by staff who lack necessary expertise and backgrounds in resource management.
The BLM move and broader reorganization are a distraction for staff. They are an irresponsible use of taxpayer funds for poorly justified reasons with insufficient research and documentation, threatening the integrity of our national parks and other public lands and the agencies that steward them. As stated before, NPCA’s view is that absent any clear, justifiable demonstration of the reasons for the reorganization, benchmarks, a timeline and realistic roadmap, and assurances that the effort would ultimately benefit our public lands, the Americans who own them, and the federal employees who steward them, we urge Congress to take appropriate and immediate measures to prevent DOI from engaging in this risky and dangerous effort.
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Senior Director of Budget & Appropriations, Government Affairs