NPCA sent the following position to leaders of the House and Senate Appropriations Committees ahead of negotiations on final FY20 funding bills.
NPCA commends appropriators on their work on FY20 Interior appropriations bills and their support for our national parks and respectfully ask that a final bill include as much an increase as possible for the underfunded National Park Service (NPS). We also wish to share our views on the House and Senate bills’ and reports’ provisions relevant to our national parks, their personnel, and their ecosystems and cultural landscapes.
Funding for the National Park Service and EPA clean water programs: We commend the bills’ increases and, while recognizing the constraints of the 302(b) suballocation that make targeted investments challenging, we ask that you provide as high a funding level as possible for our parks in a final bill. Specifically we 1) appreciate the continued funding for the Centennial Challenge program; 2) request the higher House level of $2.65 billion for park operations—which among other needs would help bring park rangers back after years of declines as noted in report language; 3) support the higher House levels for the National Recreation and Preservation and Historic Preservation Fund accounts; 4) recognize the improvements that the higher Senate Construction level would provide for park infrastructure and related needs; and 5) request that a final bill include the higher House amount for NPS’ Federal Land and Water Conservation Fund (LWCF) program, which would better support needed land protections. We also appreciate the investments in new park service designations as well as funding levels for the Great Lakes Restoration Initiative and other Environmental Protection Agency (EPA) clean water programs that protect aquatic ecosystems important for national park and visitor health.
Heritage Partnership Program: NPCA commends the House and Senate bills’ $1.6 million funding increase for the Heritage Partnership Program (National Heritage Areas), which provides the basic funding required to support the six new National Heritage Areas designated by Congress earlier this year. We are very concerned, however, that Congress has not yet chosen to reauthorize the eligibility of Oil Region National Heritage Area and Aviation Heritage National Heritage Area to receive federal funding. Both face a looming deadline of December 8, 2019, and a loss of eligibility to receive federal funding will have dire impacts for both programs.
Department of the Interior (DOI) Reorganization: NPCA has expressed to the committees numerous times our deep concern with this proposal, which threatens the integrity of NPS and the ability of park personnel to make science-based decisions rooted in NPS’ conservation mission and free of political influence. The proposal lacks both justification and transparency, is accompanied by no cost benefit analysis justifying the use of taxpayer dollars and threatens to undermine staff morale as well as coordination and implementation of cooperative agreements, project funding, deferred maintenance, staff and materials coordination and more due to unnecessary realignment to unified DOI regions. The moving of BLM west threatens coordination with NPS and the stewardship of resources important to park ecosystems. DOI’s reported intent to scatter BLM’s FOIA offices only heightens our concerns about the intent and threats of the reorganization.
Accordingly, we are relieved that neither the House nor Senate bill fund the reorganization. However, DOI reportedly intends to use unobligated balances to fund the initiative and has a deeply problematic history of sidestepping appropriators by reprogramming funds. Therefore, we urge final bill language that specifies that no reprogramming can be done—nor can any unobligated balances be used—without the express written approval of appropriators. While report language is very helpful, NPCA is concerned that statutory language may be needed to ensure DOI’s compliance.
Federal Lands Recreation Enhancement Act (FLREA) Reauthorization and Use of Fee Dollars: NPCA appreciates reauthorization of FLREA until October 2021 to allow for parks and other public lands to continue to collect needed entrance and recreation fees to enhance visitor experiences. We also commend the language in the House bill providing oversight on reprogramming of funds and language in the Senate bill to provide more transparency of the projects paid for with fee dollars.
NPCA continues to be concerned with the administration’s use of park fee dollars during a government shutdown, for general park operations and for special events like Salute to America. We are also concerned about the Administration’s use of Centennial Challenge dollars for special events. The fee and Centennial Challenge dollars were intended to enhance visitor experiences including addressing deferred maintenance and educational programs, not to replace annual appropriations.
We commend the work to date appropriators have done to demonstrate oversight on this important issue. Because DOI appears intent on continuing these practices, we respectfully request clarity on this subject in a final FY20 Interior bill. We urge you to include statutory language specifying that recreation fees cannot be used 1) when there are lapses in appropriations, 2) for general operations or permanent staff beyond positions that collect and process fees, or 3) for special events of the nature of the Salute to America. Further, we ask you to legislatively clarify that valuable Centennial Challenge dollars are not intended for special events such as the Salute to America.
Chaco Canyon protections: Chaco Culture National Historic Park is a unique landscape that tells the story of one of North America’s oldest and most sophisticated cultures. NPCA strongly supports actions to withdraw BLM lands around the historical park from further oil and gas development. Withdrawal will preserve scared sites of great significance to human history, help address some of the public health concerns of neighboring communities and tribes and ensure the park’s exceptional resources are protected. Therefore, we commend the Senate report’s direction to suspend leasing activities in the withdrawal area. We request that the final conferenced bill include the House language, which goes further by directing not only the suspension of leasing but also to prioritization of planning updates, increased cultural resource inventories in coordination with tribes, and consultation with tribes as well as regional ethnographic studies.
Pebble Mine: The language in the Senate bill regarding Pebble Mine correctly focuses on the lack of scientific substance in the draft Environmental Impact Statement (EIS) prepared by the Army Corps of Engineers, which fails to meet basic standards of scientific rigor. It must be revised so that the proposed mine’s risks and impacts to the communities of the region, Lake Clark and Katmai National Parks’ world-famous bears, and the salmon run that supports them all are fully explored. NPCA also supports the language included in the House Energy and Water Appropriations bill prohibiting the use of funds on the Pebble Project.
Badger Two-Medicine area: We are pleased the Senate report recognizes the importance of protecting this cultural and natural landscape in the Crown of the Continent. We support the language directing DOI to continue working with the Blackfeet Nation to protect the Badger-Two Medicine area, including but not limited to continued legal defense of oil and gas lease cancellations and consideration of protected status, and ask that a final report retain this provision.
Transboundary Rivers: We commend the Senate report language restoring the Kootenai Watershed, which is critical for the protection of the Crown of the Continent ecosystem that includes Glacier National Park and other protected areas. This effort is important to delineate the federal role in this transboundary watershed region. We also appreciate and ask for retention of the Senate’s $1.5 million directed towards river data collection. We support this appropriation to the four US states that border British Columbia to facilitate water quality data gathering in transboundary watersheds affected by existing or proposed Canadian mining.
Everglades Restoration: NPCA appreciates the Committees’ continued support for Everglades restoration and acknowledgment that several key infrastructure projects are in the final phases and will enhance water deliveries throughout the ecosystem. Among these projects are Tamiami Trail Next Steps Final Phase and the Central Everglades Plan, which will improve hydrology specifically for the southern Everglades and Florida Bay. While we continue to advance restoration, it is critical to remain vigilant to the threat of invasive species to the health of the Everglades. NPCA appreciates the committees’ prioritization of funding to combat Old World Climbing Fern and other invasive plants at the Loxahatchee National Wildlife Refuge and recognition that the Burmese Python is a significant threat to both Everglades and Big Cypress habitat. Strong data is the cornerstone of restoration success. NPCA greatly appreciates increased funding of the South Florida EPA program, including funds specifically to monitor coral reef health, enhance seagrass monitoring in the northern estuaries, and enhance water quality monitoring in Florida Bay and Biscayne Bay.
Freedom of Information Act (FOIA): NPCA is pleased the Senate report language addresses FOIA; we urge retention of this language in a final report, as well as continuing oversight of the administration’s actions regarding the release of information to both Congress and the public. We are alarmed at DOI’s effort to limit FOIA requests and fear that a rule change could restrict public access and delay requests, so appreciate the committee’s attention to those concerns. As you know, FOIA is a critical tool for public access, transparency and accountability, so we hope a final report and continuing oversight will demonstrate Congress’ commendably bipartisan commitment to this critical law.
Grant Reviews: We commend the House report language expressing concern with the delays in funding agreements due to DOI review of all agreements above $50,000. As noted in the report language, the reviews have been causing undue challenges to recipients who operate with scarce funds to assist the park service and help steward our public lands and provide a more quality visiting experience. We appreciate your effort to ensure oversight and transparency on this important issue.
LWCF: NPCA appreciates that both bill reports address the administration’s lack of funding for LWCF projects and their effort to ensure that the administration meet Congress’ bipartisan desire to fund this important program by submitting project lists.
Deferred Maintenance: We appreciate the bills’ attention to the park service’s $12 billion backlog of projects. We also commend the report language directing updated 5-year plans that include a list of the outstanding projects. Transparency with these needs will help the Congress and public have a fuller understanding of the parks repair challenge.
Rainy River Watershed: NPCA shares the House report’s expression of deep concern over the health of Voyageurs National Park, the Boundary Waters Canoe Area and the broader ecosystem that would be threatened by sulfide-ore mining. We commend the extensive report language directing the review that is needed for such a proposal and the protective measures needed for this critical landscape. We ask that final report language include this provision.
Cooperative Management: NPCA is pleased to see that the Committee supports the Cooperative Management Agreement approach at Chesapeake and Ohio Canal National Historic Park and encourages this model elsewhere as an alternative to the GSA leasing process. NPCA concurs this is especially important for the Mississippi National River and Recreation Area as this model will allow the national park the ability to pursue the opportunity to relocate its headquarters along the St. Paul riverfront.
Legacy Riders: We commend the House bill’s removal of legacy riders that threaten the environment and are disappointed the Senate bill retains provisions that threaten wildlife, clean air and progress on climate change. The Senate bill’s defunding regulations on lead ammunition is particularly concerning given the common lead poisoning of wildlife that scavenge on carcasses that contain lead fragments. Lead poisoning is the number one threat to the endangered California Condor, and annual blood testing finds dangerous lead levels in 20 percent of wild condors. These majestic birds are found in national parks including Zion and Pinnacles National Parks. NPS recognizes that lead poisoning also threatens bald and golden eagles, hawks, ravens, turkey vultures, and grizzly bears. We also note the contribution of livestock to climate change that threatens many of our national parks and are disappointed relevant provisions remain in the Senate bill. We request that these riders do not appear in a conferenced FY20 bill and any future appropriations bills.
Thank you again for your support for our national parks, their ecosystems, cultural landscapes and personnel, and for your attention to our views. We invite you to reach out to us if we can be of assistance with the FY20 appropriations process, as we recognize the importance of an adequate allocation, passage of a final bill and the avoidance of a year-long continuing resolution.