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Former National Park Service Director Jonathan Jarvis, in response to an order that the agency prepare a reduction-in-force plan, argues that all NPS employees provide direct services to visitors and are essential/NPS file
Adding insult to injury, the Office of Management and Budget (OMB) issued a memo on February 26, 2025, directing all federal agencies to submit their plans for a systematic Reduction in Force (RIF) by March 13. This lands with a thud on the National Park Service after it has already had over 1,000 probationary employees fired*, an unknown number taking the deferred resignation, and a start-stop-start again on seasonal hiring.
This is no way to run the National Park Service and I know, because I did from 2009-2016. Every one of those years, I advocated to the administration and Congress to increase the parks budget as they are and have been chronically underfunded and understaffed. Now, with these proposed reductions, they will drop below critical life support that impacts visitation, resources, and gateway economies.
The American public, who visited the national parks at the level of 320 million in 2023, should be outraged. The communities and businesses who rely on these parks should be calling their representatives and demanding the NPS be left whole.
The latest barrage from the Trump administration indicates that the government should be reduced to only those functions that specifically provide services to the public and are required by statute. To accomplish this, the February 26, 2025 OMB memo directs the agencies to identify for continuation (among other things):
- A list of agency subcomponents or offices that provide direct services to citizens.
- Any statutes that establish the agency, or subcomponents of the agency, as statutorily required entities.
I would assert the National Park Service and all its “subcomponents or offices” provide direct services to citizens. I would argue that the NPS is the perfect example of an agency providing
direct services to the public through its operation of 433 park units, its conservation of natural and cultural resources, its programs, and the delivery of high quality visitor experiences. A
backcountry ranger who encounters a hiker in stress is providing direct services to the public. An interpretive ranger who swears in a junior ranger is providing direct services to the public. A park archaeologist who recommends a trail be rerouted to protect an important site is providing direct services to the public. A park historian’s research that is used in interpretative park programs is providing direct service to the public.
In response to the February 26, 2025 OMB memo, the National Park Service, is a “statutorily required entity” established as an agency by the Organic Act of 1916: “(The National Park Service) shall promote and regulate the use of Federal areas known as national parks, monuments, and reservations by such means and measures…..to conserve the scenery and natural and historical objects and the wild life therein and to provide for enjoyment of same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”
I would argue that the lines “promote and regulate, by such means and measures, and to conserve” are statutory mandates for the agency to carry out its public services through park and
central office employees.
In addition, all 433 units of the National Park System are “statutorily required entities" established individually by an act of Congress or a Presidential Proclamation.
Congress has reaffirmed the statutory requirements of the National Park System in both the General Authorities Act of 1970 and the Redwoods Amendment of 1978. In particular, the Redwoods Amendment states “Congress further reaffirms, declares, and directs that the promotion and regulation of the various areas of the National Park System, as defined in section 1c of this title, shall be consistent with and founded in the purpose established by section 1 of this title [the Organic Act provision quoted above], to the common benefit of all the people of the United States. The authorization of activities shall be construed and the protection, management, and administration of these areas shall be conducted in light of the high public value and integrity of the National Park System.”
I would argue that the lines “to the common benefit of all the people of the United States” and “the protection, management, and administration” clearly states that the NPS is delivering direct
services to the public.
And, even more importantly, the Redwood Amendment states that “National Park System….shall not be exercised in derogation of the values and purposes for which these various areas have been established, except as may have been or shall be directly and specifically provided by Congress.”
In plain language, and how this has been interpreted by the courts, is that the Executive Branch of the government does not have the authority to derogate (significantly harm) the resources of the parks without direct and specific authority of the Congress. This would include, in my opinion, neglect of the parks through its effort to reduce the National Park Service workforce.
The February 26, 2025 OMB memo directs “All agency components and employees performing functions not mandated by statute or regulation who are not typically designated as essential during a lapse in appropriations.” Based on the NPS experiences with the December 2018 35-day government shutdown, parks experienced resource damage, vandalism, accumulated trash, filthy restrooms and closed facilities. Leaving the parks open with only those designated as “essential” during a shutdown would be clearly a “derogation of the values and purposes” by the
Trump administration without the direction of Congress.
I would argue that the National Park Service, rather than being caught up in this torrent of government slash and burn, should be held as an exemplar of government service for the people and ultimately be provided additional funding and staff. If the administration does just the opposite, continuing to decimate the National Park Service workforce, then their stated goal of providing better service to the public is just a smoke screen.
*Note: on February 27, Federal District Judge William Alsup ruled that these firings were illegal and directed the agencies to rehire their probationary employees, specifically calling out the National Park Service.