NPCA, along with partners, submitted the following letter to congressional leadership in response to OMB circular M-20-34 and an Executive Order dated September 22, 2020.
Dear Senators and Representatives:
On behalf of our millions of members and supporters across the country, we write with deep concern about – and strong opposition to – the September 4th 2020 OMB circular M-20-34, “Training in the Federal Government,” and the related September 22nd 2020 Executive Order on Combating Race and Sex Stereotyping. These directives are beginning to have a damaging and chilling impact on agency efforts to address prejudice, workplace harassment, discrimination, and related challenges. Among other impacts, the cancelation of trainings threatens to interfere with remediation of pending Equal Employment Opportunity (EEO) claims and to make some employees who have experienced workplace discrimination feel less capable of getting needed support. Unfortunately, the initiative to stifle trainings is now going far beyond federal agencies themselves.
For the reasons outlined below, we urge that a final FY21 appropriations vehicle or any other moving vehicle in the remainder of this Congress prevent any federal funding from being used to implement these directives, which threaten to have a crippling effect on agencies including those that steward public health and our environment, as well as the contractors who coordinate with them and grant recipients who support their missions to serve the public.
There are many challenges that workplace trainings seek to address. Many of the agencies that protect public health and our land, air, water, wildlife and cultural resources lack diversity, particularly at the managerial level. Recruitment and retention efforts that may help shift this dynamic can benefit from employees across the agencies being educated on the societal challenges, human behaviors and intentional or unintentional discriminatory practices that contribute to these patterns. This includes but is not limited to EEO training. One need look no further than the high-profile cases of sexual harassment and discrimination at the National Park Service to recognize the importance of managers having the discretion to pursue these trainings.
Environmental agencies also face relevant challenges not just within their workforce but in their missions and the impacts the agencies have on communities. This includes, for example, the disproportionate impact of polluting industries on communities of color, with profound public health impacts now exacerbated by the covid-19 pandemic. Visitation to our national parks lacks the diversity that reflects the American public, with numerous barriers to access. Low income communities and communities of color also face disproportionate challenges in access to community parks and other environmental amenities.
The circular and EO have already led to interagency memos that are creating employee and manager confusion. In particular, the National Park Service has indefinitely stopped EEO, sexual harassment, tribal consultation, and disability discrimination training to ensure it is in compliance with the OMB circular. This is having a chilling effect on efforts to train employees on a diversity of issues not necessarily limited to race or privilege. Also put on hold are different workforce development leadership trainings such as those addressing conflict resolution and discriminatory structures in the workplace. The orders’ directives do not only apply to federal agencies, but to contractors and grant recipients, many of whom are proactively seeking to address these workplace issues. Contracts can be denied and grants rescinded if the applicable nongovernmental organizations engage in training.
Federal agencies, contractors and grant recipients, including but not limited to those that regulate and oversee public health and environmental protections, deserve better. We respectfully call on you to support these entities’ engagement in training they deem appropriate and necessary to try to enhance awareness of diversity, harassment and discrimination challenges, employee morale, opportunities for advancement, workplace culture and more.
The civil service and its contractors and grant recipients should have the opportunity to pursue the management and training excellence that is available in the private sector. We ask you to include a provision in a final FY21 appropriations omnibus or other moving vehicle in the remainder of this Congress a provision halting implementation of this regressive OMB circular and EO.
Thank you for considering our views.
Alaska Wilderness League Action | Alliance for the Great Lakes | American Hiking Society | American Littoral Society | American Rivers | American Society of Landscape Architects | Appalachian Mountain Club | Appalachian Trail Conservancy | Archaeology Southwest | Arizona Trail Association | Association for Experiential Education | Association of Nature Center Administrators | Avid4 Adventure | Berks Nature | Brown People Camping | Bucks County Audubon Society | Business for Montana’s Outdoors | Capital Region Land Conservancy | Chispa Arizona, League of Conservation Voters | Clark Fork Coalition | Clean Water Action | Clean Wisconsin | Coalición de Derechos Humanos | Coalition for Sonoran Desert Protection | Coalition for the Delaware River Watershed | Coalition to Protect America’s National Parks | Confluence (confluenceproject.org) | Conservancy for Cuyahoga Valley National Park | Conservation Minnesota | Continental Divide Trail Coalition | Defenders of Wildlife | Defensores de la Cuenca | Delaware Highlands Conservancy | Delaware Nature Society | Dogwood Alliance | Earthjustice | Endangered Species Coalition | Environmental Defense Fund | Environmental Justice Center of Chestnut Hill United Church | Environmental Law & Policy Center | Fairbanks Climate Action Coalition | For Love of Water (FLOW) | FracTracker Alliance | Friends of Fort McHenry | Friends of Hopewell Valley Open Space | Glen Canyon Conservancy | Greater Yellowstone Coalition | Greenpeace USA | Green-Rock Audubon Society | Illinois Environmental Council | Indiana Wildlife Federation | Interfaith Partners for the Chesapeake | International Fund for Animal Welfare | IslandWood | Izaak Walton League, Public Lands Committee | John Burroughs Association, Inc. | John Muir Project | Lakeshore Natural Resource Partnership | Latino Outdoors | League of Conservation Voters | Maine Environmental Education Association | Michigan League of Conservation Voters | Mid-Atlantic Youth Anglers & Outdoors Partners | Milwaukee Riverkeeper | Milwaukee Water Commons | Mississippi Park Connection | Montana Wilderness Association | Mount Rushmore Society | MountainTrue | National Aquarium | National Audubon Society | National Parks Conservation Association | National Recreation and Park Association | National Wildlife Federation | Natural History Institute | Natural Resources Defense Council | New Jersey Audubon | New Jersey Environmental Lobby | New Jersey Highlands Coalition | New Mexico Wildlife Federation | NJ Sustainable Business Council | North American Association for Environmental Education | North Cascades Institute | NW Energy Coalition | Olympic Park Associates | Onondaga Audubon | Oregon Wild | Otsego County Conservation Association | PennFuture | Pinelands Preservation Alliance | Religious Coalition for the Great Lakes | River Alliance of Wisconsin | Rockland Conservation & Service Corps | Rocky Mountain Conservancy | San Juan Citizens Alliance | Save Our Canyons | Save Our wild Salmon Coalition | Sierra Club | Sky Island Alliance | SOS Outreach | St. Croix River Association | The Corps Network | The Mission Continues | The Mountaineers | The Wilderness Society | Tip of the Mitt Watershed Council | United States Tour Operators Association | Upper Gila Watershed Alliance | Utah Clean Energy | Valley Forge Park Alliance | Voyageurs National Park Association | Washington Conservation Voters | Washington Environmental Council | Washington Trails Association | Washington Wild | WaterNow Alliance | Western Colorado Alliance | Western Resource Advocates | Western Slope Conservation Center | Western Watersheds Project | Winter Wildlands Alliance
For More Information
Senior Director of Budget & Appropriations, Government Affairs