A Report by a Panel of the

 

NATIONAL ACADEMY OF

PUBLIC ADMINISTRATION

 

for the United States Congress and the National Park Service

 

 

February 2004

 

 

 

 

IMPLEMENTATION OF RECOMMENDATIONS

 

ACADEMY PANEL 2001 REPORT

ON THE U.S. PARK POLICE

 

 

 

 

 

PANEL

 

Royce  Hanson, Chair

Frank J. Chellino

Ben R. Click

Thomas C. Frazier

Kristine M. Marcy

 


 

 

 

 


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ABOUT THE ACADEMY

 

The National Academy of Public Administration is an independent, nonprofit organization chartered by Congress to improve governance at all levels:  local, regional, state, national, and international.  The Academy’s membership of more than 500 Fellows includes public managers and scholars, business executives and labor leaders, current and former cabinet officers, members of Congress, governors, mayors, state legislators, and diplomats.  Since its establishment in 1967, the Academy has assisted hundreds of federal agencies, congressional committees, state and local governments, civic organizations, and institutions overseas through problem solving, objective research, rigorous analysis, information sharing, developing strategies for change, and connecting people and ideas.

 

Most reports and papers issued by Academy panels respond to specific requests and needs of public agencies.  Projects also address government-wide and broader societal topics identified by the Academy.  In addition to government institutions, businesses, foundations, and nonprofit organizations support the Academy.  


A Report by a Panel of the

 

NATIONAL ACADEMY OF

PUBLIC ADMINISTRATION

 

for the United States Congress and the National Park Service

 

 

February 2004

 

 

 

 

IMPLEMENTATION OF RECOMMENDATIONS

 

ACADEMY PANEL 2001 REPORT

ON THE U.S. PARK POLICE

 

 

 

 

 

 

 

 

 

 

PANEL

 

Royce  Hanson, Chair

Frank J. Chellino

Ben R. Click

Thomas C. Frazier

Kristine M. Marcy


 

 

 

 

Officers of the Academy

 

Carl W. Stenberg, III, Chair of the Board

C. Morgan Kinghorn, Jr., President

Valerie Lemmie, Vice Chair

Jonathan D. Breul, Secretary

Howard M. Messner, Treasurer

 

 

Project Staff

 

J. William Gadsby, Responsible Staff Officer

Kenneth Ryder, Project Director.  (KRyder@napawash.org)

Arnold E. Donahue, Senior Consultant.  (ADonahue@napawash.org)

Elaine L. Orr, SeniorAnalyst.  (EOrr@napawash.org)

Harry G. Meyers, Senior Consultant. (HMeyers@napawash.org)

Christine A. Mooney, Research Assistant. (CMooney@napawash.org)

Martha S. Ditmeyer, Project Associate

 

 

 

 

 

 

 

 

The views expressed in this document are those of the Panel. 

They do not necessarily reflect the views of the Academy as an institution.

 

National Academy of Public Administration

1100 New York Avenue, N.W.

Suite 1090 East

Washington, DC 20005

(202) 347-3190

http://www.napawash.org/

 

First published February 2004

 

Printed in the United States of America

 

 

Academy Project Number: 2029-001


LIST OF ACRONYMS

 

 

DAS                            Deputy Assistant Secretary

DHS                            U.S. Department of Homeland Security

DOI                             United States Department of the Interior

ELO                             Emergency Law and Order [funds]

FLETC                        Federal Law Enforcement Training Center

FOIA                           Freedom of Information Act

FY                               Fiscal Year

GGNRA                      Golden Gate National Recreation Area

GNRA                         Gateway National Recreation Area

GSA                            General Services Administration

HRED                          Human Resources and Employee Development

IACP                           International Association of Chief’s of Police

IG                                Inspector General

LENA                          Law Enforcement Needs Assessment

LETF                           Law Enforcement Task Force

MPD                            [Washington, DC] Metropolitan Police Department

NCR                            National Capital Region

NLC                            National Leadership Council

NPS                             National Park Service

OFS                             Operating Formulation System

OLES                          Office of Law Enforcement and Security (departmental office)

USPP                           United States Park Police

VRAP                          Visitor Management Resource Protection Assessment Program


 

IMPLEMENTATION OF RECOMMENDATIONS

ACADEMY PANEL 2001 REPORT

ON THE U.S. PARK POLICE

 

 

In the conference report on the Department of the Interior’s Fiscal Year (FY) 2001 Appropriations Act, Congress directed the National Park Service (NPS) to contract with the National Academy of Public Administration (the Academy) to conduct an independent review of the United States Park Police’s (USPP’s) structure and financial plan.  NPS contracted with the Academy in January 2001 to conduct this study, which addressed four principal areas:

 

·        Whether USPP’s goals and missions are in accordance with statutory and regulatory requirements

 

·        Current USPP functions or activities that may go beyond NPS’ mission or support the functions of other federal, state, or local law enforcement agencies, including USPP costs associated with such activities

 

·        Current and projected USPP staffing needs, including the methodology used to develop them

 

·        Actual USPP spending over the last three years relative to planned spending, with a focus on specific items including overtime and special deployments, new personnel activities, helicopter operating costs, and equipment replacement

 

In August 2001, an Academy Panel issued its report, The U.S. Park Police: Focusing Priorities, Capabilities, and Resources for the Future, which contained 20 recommendations geared to clarifying the mission, developing and executing an integrated and comprehensive USPP budget, and conducting a thorough assessment of staffing needs as they relate to mission.

 

After the August 2001 report was issued, a number of major changes occurred.  First were the 9/11 terrorist attacks, which have led NPS and USPP to place increased emphasis on the protection of park monuments in the Washington, DC area and at the Statue of Liberty.  NPS appointed a new USPP Chief, Teresa C. Chambers, who took office in February 2002.  The establishment of the U.S. Department of Homeland Security (DHS), increased local, state, and federal counterterrorism activities, and improved law enforcement cooperation and coordination may also be affecting USPP’s roles, functions, and organizational structure.  In addition to these developments, there continue to be questions about the increasing USPP budget and implementation of the Academy Panel’s 2001 recommendations. Congress, in the conference report on the FY 2004 Interior Appropriation bill, directed NPS to contract with the Academy to do a follow-up study on the recommendations made in its 2001 report.

 

 

 

 

The Academy’s study is being conducted in two phases that include the following areas:

 

 

 

Ø      Examine whether roles and functions have changed since 9/11 in terms of their relationship to mission, needs and priorities.

Ø      Identify budget resources used to fulfill specific functions, USPP priorities assigned to each function, and assess the feasibility of adjusting currently performed functions assuming constrained budgets in the next few years.

 

There have also been a number of significant changes at the Department of Interior (DOI), NPS, and USPP that affected the actions taken on those 20 recommendations in the August 2001 report.  DOI has undertaken a number of law enforcement reforms in response to changing security needs in the wake of the 9/11 terrorist attacks and recommendations from some internal DOI reports.  Newly appointed managers at DOI, NPS, and USPP have attempted to define their roles in setting law enforcement policy and determining law enforcement resource requirements.  Recent trends in USPP budget and personnel resources have also reinforced the importance of implementing many of the August 2001 recommendations.

This report will summarize these major changes before assessing the implementation status of the 20 recommendations.

 

 

LAW ENFORCEMENT REFORMS AT INTERIOR

 

Interior Secretary Gale Norton requested that the Inspector General (IG) assess the actions needed for effective departmental law enforcement, and the IG staff reviewed the seven distinct organization units in five DOI bureaus, which contain nearly 4,400 law enforcement officers.  This IG study, published in January 2002, led the Secretary to establish a special review panel to improve law enforcement throughout the department.  The Secretary approved more than 20 measures this special review panel proposed, including the appointment of a Deputy Assistant Secretary (DAS) for law enforcement and security.  The measures, which were largely consistent with the IG recommendations,[1] were designed to improve training, supervision, oversight and coordination among the five Interior bureaus with law enforcement personnel: National Park Service, Bureau of Land Management, U.S. Fish and Wildlife Service, Bureau of Indian Affairs, and Bureau of Reclamation.

 

 

 

 

Among the recommendations the Secretary approved are:

 

 

In August 2003, the IG issued a progress report on the Secretary’s directives on law enforcement reform.[2]  It found that OLES and the bureaus had made efforts to improve law enforcement, but that the pace was initially slow moving because of early resistance.  One that was proceeding well was Directive 5, ordering the coordination and review responsibility for law enforcement and security budgets be formally shared between the DAS for OLES and the DAS for budget and finance.  NPS created the position of Associate Director for Resource and Visitor Protection to respond to this reform effort.

 

 

OVERVIEW OF LEADERSHIP CHANGES

IN NPS AND USPP SINCE AUGUST 2001

 

In July 2001, as work on the first project was completed, Fran P. Mainella became the NPS Director, having previously served as Director of Florida’s Division of Recreation and Parks.  She appointed Teresa C. Chambers, then Chief of Police in Durham, NC and formerly with the Prince George’s County Police Department in Maryland, to become USPP Chief; Chambers was sworn in February 2002.  She reports to Deputy NPS Director Donald W. Murphy, who joined NPS in the fall of 2001 from the California Department of Parks and Recreation.

 

The post-9/11 security environment supported DOI and NPS efforts to improve the structure and operations of their law enforcement organizations.  For example, all NPS law enforcement activities, except for USPP, were consolidated under one office and, along with USPP, report to Deputy Director Donald Murphy.  Karen Taylor-Goodrich, former Director of NPS Park Operations, was appointed to the newly created position of Associate Director for Resource and Visitor Protection.  Taylor-Goodrich has line authority over NPS’ 60 Special Agents, who primarily investigate crime in national parks, and oversight of the 1,400 Law Enforcement Rangers (also called Protection Rangers) who work in the 384 parks and report directly to park Superintendents.  Under Taylor-Goodrich is the Office of Law Enforcement and Emergency Services, headed by Don Coehlo, former Chief Law Enforcement Ranger at Yosemite.  This office has coordinated preparation of the Law Enforcement Needs Assessments (LENAs) that each park prepared according to a template Taylor-Goodrich issued.

 

Taylor-Goodrich does not have authority over USPP.  She and the USPP Chief are organizational equals and both serve as members of the NPS National Leadership Council (NLC). 

 

DOI created the position of DAS for Law Enforcement and Security, which oversees all DOI law enforcement activities and is headed by Larry Parkinson, formerly a prosecutor with Washington, DC Superior Court, and FBI General Counsel.  Under him is the Director of Law Enforcement and Security, Steve Calvery.  When Secretary Norton established Parkinson’s office (which reports to Lynn Scarlett, Assistant Secretary for Policy, Management and Budget) she described it as having “broad responsibilities, including developing law enforcement staffing models, establishing consistent departmental training requirements and monitoring their implementation, overseeing the hiring of key law enforcement and security personnel, establishing updated emergency procedures, and overseeing and reviewing bureau law enforcement and security budgets.”[3]  At the Secretary's discretion, the DAS can also be given direct authority in times of emergency to oversee the deployment of all departmental law enforcement officers.

 

Within USPP, Chief Chambers made a number of leadership changes.  She elevated former Deputy Chief Benjamin J. Holmes Jr. to Assistant Chief and brought in several others for top positions.  They are: Dwight E. Pettiford, Deputy Chief for Operations and formerly with the Durham, NC Police Department; Barry S. Beam, Deputy Chief for Field Offices and formerly with the Prince George’s County Police; and Pamela L. Blyth, the Civilian Manager for Organizational Development and Fiscal Management.  The Deputy Chief positions were announced competitively, and Academy staff have been told that several USPP majors applied for the positions. 

 

 

BRIEF OVERVIEW OF CHANGES IN CRIME OR INCIDENT DATA

 

Academy staff have compiled statistical data on crime trends and enforcement patterns for 2001, 2002, and the first six months of 2003 to update the summary of incidents in the USPP jurisdictions shown in the August 2001 report.  These data are presented to document overall trends and major changes in crime trends.   

 

In general, the data confirm that the nationwide downturn in urban crime continued and applied to USPP venues.  The incident closure rates have generally improved, and the percentage of incidents outside of NPS jurisdiction has declined marginally.  For example, USPP incidents involving violent crimes in the Washington, DC area decreased between 2000 and 2002 from 265 to 189, and property crimes decreased similarly from 409 to 275, with the downtrends continuing into 2003.  Traffic incidents, including citations and warnings, increased marginally (from 4,813 to 4,919) between 2000 and 2002, but were off markedly in the first six months of 2003.  Vehicle accidents increased from 3,197 to 3,413 between 2000 and 2003, but decreased sharply in the first half of 2003.  

 

In New York, violent and property crimes, lesser crimes, and traffic incidents and accidents are down markedly.  In San Francisco, violent crime increased, but there was reduced property crime.  Traffic incidents there rose sharply from 1,317 to 2,593 between 2000 and 2002, and vehicle accidents also increased from 149 to 168.

 

 

 

 

BRIEF OVERVIEW OF USPP SINCE 2001

 

Staffing Levels

 

Looking at absolute staffing numbers between 2001 and 2003 would indicate a relatively stable state for sworn officers, but this belies a great deal of fluctuation.  Table 1 contains data on aggregate staffing levels for officers, civilians, and civil-service guards.

 

Table 1

USPP Staffing Levels

2001-03

 

Position

12/31/01

12/31/02

1/21/04*

Chief/Asst/Dep

3

4

4

Major

10

8

8

Captain

25

19

17

Lieutenant

39

43

40

Sergeant

125

118

107

Detective

16

15

16

Privates

407

395

423

Total Sworn

625

602

615

Civilian

91

99

108

Guards (CS)

25

27

25

All staff

741

728

748

 

* 1/21/04 data are from a staffing list and are not likely to be the

exact staffing numbers that will be in the 2003 USPP Annual Report;

the 2001 and 2002 data are from previous USPP Annual Reports.

These “end strength” data reflect filled positions at a given date and are not FTEs.

 

Table 1 shows a net loss of ten officers between 2001 and 2003, with a gain of seventeen civilians.  In calendar year 2002, USPP had 44 graduates in its recruit classes and in calendar year 2003 there were 70.  However, there were substantial retirements during that time (26 in 2002 and 18 in 2003), and a larger number of resignations (52 and 28, respectively).   USPP staff indicated that many of the resignations were officers who left to go to the Department of Homeland Security.

 

Spending Levels

 

USPP operational costs have increased substantially over the last few years.  From FY 2000 to FY 2003, the USPP appropriation for operations – the major source of USPP operational funds – increased from $54.4 million to $77.9 million.  This 43.2% increase substantially exceeded the 22% increase in the overall NPS operations appropriation. 

 

In addition, the appropriation was augmented by funds from the Emergency Supplemental for Terrorism ($1.4 million in FY 2001 and $25.3 million in FY 2002). These no-year funds helped sustain higher USPP spending levels in FYs 2001, 2002, and 2003.  However, once these supplemental funds were exhausted, a significant “funding gap” emerged in FY 2004 between the enacted appropriations and previous levels of USPP operation.  This situation resurrected many of the same concerns that led to the 2001 Academy study.

 

 

IMPLEMENTATION OF AUGUST 2001 RECOMMENDATIONS 

 

The Academy Panel’s August 2001 report was issued when USPP still reported to NPS’ National Capital Region (NCR).  Initially, the NCR Regional Director established and led a study group of USPP and NCR staff to develop steps for implementation.  This group discussed the recommendations and initially developed a strategy for when actions could be taken and who would review proposals.  When USPP began to report directly to the NPS Director, it assumed direct responsibility for most of the recommendations.

 

The Conference Report (H.R. 107-234) accompanying the Interior FY 2002 Interior Appropriations bill noted that the department, in cooperation with NPS, should develop a detailed plan to implement Academy Panel’s recommendations and forward that plan to the House and Senate Committees on Appropriations.  The Assistant Secretary of Interior for Policy, Management, and Budget sent a letter (April 14, 2003) to the Chairman of the House Appropriations Subcommittee on Interior and Related Agencies describing progress achieved on the 20 Academy Panel recommendations.  In a September 24, 2003 memorandum to NPS Deputy Director Murphy, Chief Chambers updated progress.

 

To prepare this report, the Panel reviewed each of the 20 recommendations and the extent to which either DOI, NPS, or USPP had implemented them.  In some cases, more than one organization had a role.  The Panel divided implementation achievement into five categories:

 

·        Fully implemented

·        Moderate progress

·        Limited progress

·        No progress

·        Rejected

 

The following section of this report provides the Panel’s views about the implementation status of each recommendation, a brief paragraph providing an explanation or the rationale for that assessment, and a section providing more complete details documenting specific actions taken.  The recommendations are organized in the three functional categories used in the first report: roles and missions, budgeting, and staffing.

 

The Panel found substantial variation in the progress made to implement the August 2001 recommendations.  In sum, four were fully implemented and two were rejected.  For the others, there had been limited progress made for the vast majority (ten), moderate progress for three, and no progress for one.

 

 

I.        Roles and Missions

 

1.  The Secretary of the Interior, in conjunction with the Director of the National Park Service, clarify the mission, responsibilities, and priorities of the U.S. Park Police.

 

Status: Limited Progress

 

Explanation or Rationale for Current Status

 

A new mission statement, revised responsibilities, and clear priorities for USPP have yet to be developed.  The department has made some priorities explicit, such as icon security, but most other activities, such as parking enforcement, escort duties, and drug enforcement, continue largely on the basis of historical precedent, mutual accommodation, or other factors without explicit prioritization.  Since mid-summer 2003, a departmental level committee with NPS and USPP participation has been intensively reviewing USPP activities and functions with a view to clarify the mission and elaborate on priorities by the end of February 2004.

 

Discussion Documenting Actions Taken

 

Existing, long-standing statutory guidance and more recent internal statements on USPP mission, responsibilities, and priorities have not changed.  These include:

 

·        The NPS Organic Act, 16 U.S.C. 1, as amended, which directs the protection of the park system’s natural and cultural resources and the safety and security of visitors, employees, and concessionaires 

·        A 1882 statute that extends the duties of the USPP, originally park watchmen established by President Washington, to include the same powers and duties as the Metropolitan [Washington, DC] Police

·        A variety of statutes between 1928 and 1948 expanding USPP’s jurisdiction beyond Washington, DC to nearby roads, parkways, and Virginia and Maryland counties

 

In the Spring 2002, NPS formed a Law Enforcement Task Force (LETF) to address the findings and recommendations of several studies[4] of law enforcement in DOI, including those of the Academy Panel. The LETF adopted the following mission statement covering NPS rangers and USPP officers:

 

“In support of the National Park Service mission, law enforcement serves the public interest to protect resources and people, prevent crime, conduct investigations, apprehend criminals, and serve the needs of visitors.”

 

In March 2002, this LETF also assigned actions to implement various recommendations in these reports to working groups and individuals.  These included tasking the new USPP Chief to develop a new staffing needs analysis system similar to a revised visitor management and resource protection assessment program (VRAP), which was to be adopted service-wide.  Both had a scheduled due date of June 1, 2002.  The Chief was also to provide a comprehensive staffing needs assessment using either VRAP or a better methodology by that date.  According to the Deputy Director, this assessment was to include a review of USPP’s mission that took account of the Academy Panel’s recommendations.[5]  The revised VRAP analysis and associated LENA were delayed until June 2003, and the new USPP staffing analysis system has yet to be defined. 

 

In the interim, several actions reflecting priority decisions, primarily associated with icon protection, were reflected in funding for the USPP.  Post-9/11 supplemental funds of $25.3 million for the USPP were used in 2002 and 2003 to provide for additional patrols and overtime in Washington, DC and New York, upgrades to security equipment, and a third recruit class in 2002 to maintain adequate force levels.  The FY 2003 budget, largely prepared by USPP and reviewed by regional and NPS headquarters in late 2001 after the Academy report, provided an additional $12.6 million for USPP for contract guards, pay increases, and 48 additional personnel workyears.

 

In April 2003, OLES provided guidance for a budget review by a high-level committee composed of OLES, the department’s budget office, and the NPS Deputy Director.  The focus was on the FY 2005 budget, but the review included consideration of mission, programs, and priorities for all DOI law enforcement activities.  Guidance for the review indicated that requests for increased resources should emphasize:

 

·        Infrastructure protection, to include symbolically important national monuments, key dams, and resources

·        Implementation of reforms approved by the Secretary that resulted from the January 2002 IG study of departmental law enforcement

·        Border protection and control

·        Law enforcement officer safety

 

Just prior to this committee’s July 16, 2003 meeting on the USPP budget, the USPP Chief submitted electronically a draft staffing study, which stated that it did not address priorities because USPP lacked the authority to judge priorities.  The report provided a listing of significant areas, organizational components, patrol beats, and fixed posts, but did not articulate a force-sizing rationale.

 

This draft staffing study, which called for an increase of 900 to 1,075 sworn officers relative to the current level of 620,[6] led NPS to conclude that it could not successfully delegate to USPP the task of clarifying its mission and setting priorities within currently available resources. After this mid-summer budget review was completed, the committee decided to explore USPP’s mission, responsibilities, and priorities more thoroughly through a series of weekly meetings with USPP components.  This process is ongoing, and expected to be completed by the end of February 2004.   

 

 

2.  The U.S. Park Police mission increasingly focus on Washington, DC, as the nation’s capital, and on its surrounding areas.  Priority should be given to the safety and assistance of park visitors, the protection of resources, particularly monuments, memorials, and other national treasures from damage and terrorism, and the management of special events and demonstrations.

 

Status: Limited Progress

 

Explanation or Rationale for Current Status

 

NPS indicated support for better focusing USPP’s mission, while recognizing that certain USPP activities extended beyond NPS’ mission.  NPS rejected, however, the recommendation to transfer USPP responsibilities in the New York area and some in the San Francisco area to park rangers (see # 3 below).   NPS icons were afforded increased priority after 9/11, but the priorities associated with core, specialized, and urban policing functions discussed in the Academy report have not been addressed more specifically or in terms that would better focus USPP activities.

 

Discussion Documenting Actions Taken

 

After 9/11, USPP identified security improvements, including higher staffing levels based on the homeland security alert condition, for the Washington, DC Mall icons, as well as the Statue of Liberty.   These were reviewed by the Secret Service and, after some modifications, accepted by NPS, OLES, and the Secretary of Interior.  Current priorities do not specifically address the management of special events and demonstrations.  When NPS issues permits for Washington, DC Mall activities, USPP is heavily engaged in these events, such as the 40th anniversary of Martin Luther King’s speech and NFL kick-off week, and demonstrations, such as World Bank/International Monetary Fund and anti-war protests.

 

The 2001 Academy report identified functions that the Panel believed were not directly related to the USPP and/or the NPS mission.  Between 10% and 15% of the incidents USPP were involved in occurred outside NPS jurisdiction.[7]  Some specialized functions such as presidential and foreign dignitary escorts, urban functions like drug enforcement, and even some core functions such as parking and traffic control were not directly related to the NPS mission, and the priority assigned to these activities needed to be reexamined.  USPP clearly believes these functions are part of its core mission and are related to visitor safety. The Academy Panel had also suggested using reimbursements to determine the value of continuing to assign ten high-ranking USPP officers as law enforcement specialists to the NPS regions.   NPS formed another group to examine the regional law enforcement specialist, but reached no resolution.  NPS concluded that providing presidential and dignitary escorts “on and through parklands” was “appropriate” and agreed to provide similar vice-presidential escorts after 9/11.  NPS also noted that combating drugs in parks extended “of necessity” beyond parklands. 

 

 

3.  The National Park Service work with its park superintendents in New York and San Francisco to transfer the U.S. Park Police’s current responsibilities in these locations to park rangers.  These should include Park Police activities at the Statue of Liberty and Ellis Island, Gateway National Recreation Area (GNRA), and Golden Gate National Recreation Area (GGNRA), except for the Presidio Trust.

 

Status:  Rejected

 

Explanation or Rationale for Current Status

 

As noted above, NPS did not concur with this recommendation, concluding “it would be inappropriate, especially at this time, to withdraw the Park Police from their mission to provide visitor and resource protection to national Parks in New York and California.”   NPS recently said that it is readdressing USPP’s roles in San Francisco and New York within the context of the on-going OLES/NPS review of USPP activities.

 

Discussion Documenting Actions Taken

 

There have been no specific actions taken to transfer responsibilities for New York or San Francisco to park rangers.  Neither NPS nor USPP explored the pros and cons of this recommendation, or explored more limited adjustments between USPP and park rangers in the Presidio and at the Statue of Liberty, prior to rejecting the recommendation.  NPS cited the increased priority associated with urban policing in the aftermath of 9/11, the increased security required at the Statue of Liberty, as well as the increased need to protect the park-based approaches to the Verrazano and Golden Gate bridges in New York and San Francisco.  USPP argues that urban coverage has become increasingly important and that transition to rangers would disrupt coverage and promote undesirable retirements within USPP.  Park rangers maintain they don’t have the personnel to handle these additional assignments, and NPS is concerned that numerous USPP officers would leave rather than transfer to the park ranger force.  Recently, NPS indicated that the current OLES/NPS review was readdressing possible field office adjustments, particularly in San Francisco.

 

 

4. The U.S. Park Police and the National Park Service work toward joint operations and involving state and local police forces in patrolling major commuter parkways, investigating accidents, controlling traffic and parking enforcement, and providing neighborhood policing services.  The long-term goal should be to transfer or contract out these activities, whenever possible, to state and local jurisdictions.

 

Status: Limited Progress

 

 

Explanation or Rationale for Current Status

 

There were early unsuccessful attempts by USPP to engage other jurisdictions in a transfer of responsibilities, and USPP did not renew a Memorandum of Understanding to provide services to the Washington, DC juvenile detention facility in Maryland.  The new USPP Chief seemed more willing than her predecessors to explore using other law enforcement forces, including park rangers, to fulfill the USPP mission.  In addition, USPP no longer supports active-duty participation in grade and high school anti-drug education programs.

 

Discussion Documenting Actions Taken

 

In early 2002, the then-acting Chief of USPP (sent letters to local Washington, DC area jurisdictions (primarily counties) seeking their participation in discussing the concept of transferring responsibilities, rather than working toward joint operations.  USPP staff said that only one jurisdiction (Montgomery County, Maryland) replied, and it raised the question of reimbursement.  Separately, USPP terminated a police support agreement it had with a Washington, DC government children’s correctional facility in Maryland.  The District’s Metropolitan Police Department (MPD) picked up this responsibility.  In addition, USPP curtailed active-duty officer participation in community drug education activities in local area grade and high schools. 

 

Also, rangers took the lead in establishing a Potomac River fisheries task force, in which both USPP and MPD actively participated.  The rangers and USPP are also in the process of formally adopting a cooperative policing arrangement along the C&O Canal to provide better coverage.  USPP also increasingly relied on and reimbursed police from local jurisdictions during special events and demonstrations on the Washington, DC Mall.   

 

 

5.   The U.S. Park Police Chief be subordinated to the Director of the National Park Service, rather than the Director of the National Capital Region.

 

Status: Fully Implemented

 

 

Explanation or Rationale for Current Status

 

By NPS memorandum of January 2002, the USPP Chief was directed to report to the Director through the Deputy Director of NPS rather than to the NCR Director under the previous arrangement. This change recognized the multi-regional responsibilities of USPP and that some responsibilities, such as personal protection, escorts and demonstrations, transcend park and regional interests, and were national in scope.  The USPP Chief was also added to NPS’ National Leadership Council comprised of NPS regional directors and senior NPS staff.

 

 

6. Executive search firms, such as Police Executive Research Forum and the International Association of Chiefs of Police,  be used to identify candidates for Park Police Chief who not only have law enforcement credentials and experience, but also a strong managerial background and demonstrated leadership capabilities.

 

Status: Fully Implemented

 

Explanation or Rationale for Current Status

 

Chief Chambers’ selection and appointment resulted from a national search, and wide-ranging solicitation produced 26 outside and six inside candidates. Though executive search firms were not involved in the process, NPS used the bulletin boards of national law enforcement organizations to solicit candidates.  The NPS Director believed the applicants were well-qualified and represented a good cross section of candidates.  Chambers rose through the ranks to major and served as a District Commander in Prince Georges County and was serving as the Chief of the Durham, N.C. police force immediately prior to her appointment as USPP Chief.

 

II. Budgeting

 

 

7. The U.S. Park Police, in conjunction with the National Park Service and within its current appropriation account structure, develop a unified, integrated, and comprehensive Park Police budget.  It should include estimates for all costs, both operating and construction or rehabilitation, and funding from all sources, whether appropriations, user fees, other reimbursements, or emergency law and order funds.  This budget should be provided to and monitored by the Park Police Chief, the Park Service, Interior, and Congress.

 

Status:  Limited Progress

 

Explanation or Rationale for Current Status

 

The creation of a separate line item appropriation for USPP operations in the FY 2001 Interior Appropriations bill has consolidated most Washington, DC, New York and San Francisco operating costs into one aggregate operating budget. But, the appropriation does not account for planned reimbursable activity, some capital spending, or  USPP’s total annual use of emergency law and order (ELO) funds and other special event reimbursements (e.g. from unplanned, special events such as the NFL’s kick-off week).  A comprehensive USPP budget reflecting total resources used annually would include these additional funds in addition to the annual appropriation for operations.

 

 

 

Discussion Documenting Actions Taken

 

The creation of a separate line item appropriation for USPP operations in the FY 2001 Interior Appropriations bill was an important first step in developing a comprehensive USPP budget. It consolidated most, but not all, USPP operating costs for San Francisco, New York, and Washington, DC into a single, highly visible, annual appropriation. But the appropriation does not account for planned reimbursable activity funded by other governmental (e.g. Presidio Trust, Federal Law Enforcement Training Center (FLETC)[8]) or private (e.g. Fort Wadsworth, scheduled event sponsors) entities.  In addition, the USPP appropriation also excludes contingency funds used by USPP (ELO funds, special event reimbursements) and some USPP capital spending. For example, funding for some USPP capital equipment and maintenance costs (e.g. buildings or telecommunications, such as narrowband conversion) continues to come from NPS appropriations for construction and major maintenance—the same as it does for all other NPS parks.

 

In the April 14, 2003 DOI letter to the House Interior Appropriations Subcommittee (the “April 2003 memorandum”), NPS concurred with the recommendation and noted that “all funds being obligated by the Force, regardless of fund source, have been included in the U.S. Park Police Financial Plan.”  However, the FY 2003 USPP financial plan still contained only appropriated operating funds.  The FY 2004 financial plan is not yet completed. In addition, other published budget documents, including the NPS “green book” and the President’s budget appendix, do not add reimbursements, building repair and maintenance, and contingency budget spending to the annual USPP operations appropriation to present a comprehensive USPP budget. USPP staff note that, given the uncertainty surrounding the timing and size of specific special events, the amount of contingency funds USPP uses in any year varies significantly and is therefore difficult to project and include in a proposed financial plan. 

 

The annual “financial advice” provided by the NPS Comptroller contains the USPP enacted operations appropriation, with separate amounts established for Washington, DC, San Francisco and New York.  Previously, USPP had received separate allotments from NCR, as well as the east and west regions for Washington, DC, New York, and San Francisco, respectively.   The Chief did not necessarily receive the New York and San Francisco allotments. USPP staff indicate that they are now starting to develop a comprehensive budget to include major reimbursements (e.g. the Presidio Trust reimbursement for San Francisco) and the FY 2004 financial plan should confirm this.

 

USPP and NPS staff also acknowledge that the creation of a separate appropriation for USPP operations – which enhances visibility of USPP operating costs and the ability of the USPP Chief to present, justify and implement a unified USPP budget – has produced some disadvantages.  The principal one is the limited ability of the much larger NPS budget to provide emergency relief to high priority USPP law enforcement spending needs without additional appropriations action. Current legislative language limits the transfer authority between the NPS and USPP operations appropriation to $10,000 per transaction.  While NPS and USPP staff initially agreed to this limit, its size may be inhibiting USPP’s ability to obtain reimbursement for some services provided to other NPS parks.  (See recommendation # 10 below.)

 

Both USPP and NPS recognize the need for a comprehensive USPP budget and have taken steps to develop one.  However, current budget documents do not yet provide a readily available summary of USPP’s total resource use annually.

  

 

8.      The U.S. Park Police components, in conjunction with the superintendents of the parks they service, develop and submit their budgets to the Park Police Chief.  In turn, the Chief should submit a unified budget proposal to the Director of the National Park Service.

 

Status:  Limited Progress

 

Explanation or Rationale for Current Status

 

USPP uses NPS’s Operating Formulation System (OFS) to develop and submit recommended budget initiatives to augment its currently enacted, baseline, operating budget.  The USPP Chief ranked each of the proposed initiatives, but they do not appear to arise from the detailed, joint NPS/ USPP review of park level law enforcement needs (at least in the Washington, DC area) called for by the Academy’s recommendation. The process for developing budget initiatives and the role of major commanders within USPP are also not clearly established.

 

Discussion Documenting Actions Taken

 

NPS concurred with this recommendation and noted in the April 2003 memorandum that “procedures are currently being developed to facilitate this recommendation and will be fully implemented with the formulation of the FY 2004 budget.”  The development, review, and final formulation of the annual USPP budget has evolved as newly appointed DOI, NPS and USPP managers became more familiar with the DOI budget system and their roles in it.

 

To start its budget formulation process, DOI issues a budget call to each of its bureaus (e.g., NPS) providing policy guidance and other information to develop the department’s annual budget.  Each bureau, in turn, uses its own internal system to develop the bureau budget.  The NPS budget development process (the OFS system) now used by USPP does not require a formal  bottoms-up  review of law enforcement services required from USPP by individual parks.  Instead, OFS seeks budget initiatives from the regions and USPP to add to the baseline operating budgets currently in effect.  This system is similar to other incremental budget processes that seek to determine the costs of maintaining current services and then identify additional resources needed to meet new requirements.

 

Prior to the FY 2004 budget, the USPP budget had been developed by the administrative staff of NCR. They helped USPP develop the budget for the Washington, DC area, and received the USPP budget components from San Francisco and New York that was developed by the parks served by the USPP in those two regions.  Because the new USPP leadership was not familiar with the OFS system, much of the FY 2004 USPP budget development was done by the NPS Comptroller’s office.[9]  USPP staff supplied the data requested, but there did not appear to be any formal meetings with the Chief to review that budget.

 

In contrast, the FY 2005 budget process involved a series of meetings for all DOI law enforcement entities with DOI’s newly created OLES.  These meetings occurred during late Spring and Summer of 2003 and involved a review of each law enforcement agency’s FY 2004 and FY 2005 budgets with the agency head.  This process was intended to implement the Secretary’s law enforcement directives and ensure greater consistency among all DOI law enforcement budgets.  The review of the USPP budget for FY 2004 and FY 2005 during this process identified a significant shortfall if the USPP were to meet icon protection requirements, maintain its existing park patrols, continue to respond to other planned law enforcement needs (e.g. escort duties, medivac operations, drug enforcement, etc.) and support sufficient new officer training to meet overall USPP staffing targets.   

 

Academy staff interviews revealed that there was little formal interaction between park superintendents and USPP management in developing USPP budget initiatives or reviewing ongoing USPP activities for either the FY 2004 or FY 2005 budgets.  While the OFS system may not require the type of bottoms-up budget development contemplated in the Academy Panel recommendation, it does not preclude USPP from pursuing such a process.  That has not yet been done, in part because communications between the Chief and senior NPS management in NCR has deteriorated for a number of reasons.  However, day-to-day activities continue to be coordinated effectively between the park superintendents and the USPP district commanders servicing individual parks.[10]

 

 

 

 

9.      The Park Police Chief, early in the fiscal year, provide separate budget allotments to major commanders in its field offices and major components that include appropriated funds allotted by the park service, as well as anticipated reimbursements.  Major Park Police commanders, like park superintendents, should be expected to operate their commands during the year within the budget allocations.  The Chief should work with the commanders and park service staff to develop appropriately detailed financial plans to accompany these allocations, including restrictions on the use of selected resources where appropriate and desired.

 

Status: Limited Progress

 

Explanation or Rationale for Current Status

 

USPP budget staff did provide spending allotments for the major Washington, DC commanders, through the Deputy Chief for Operations, for a number of non-personnel expenditures in FY 2003.  However, personnel resources in Washington, DC were controlled centrally.  Moreover, commanders were not able to reallocate the allotments among spending categories (e.g. shifting funds from supplies to travel) without headquarters approval. As of February 2004, USPP budget problems precluded similar allotments for the FY 2004 budget. 

 

Discussion Documenting Actions Taken

 

NPS concurred with this recommendation and USPP staff in Washington, DC initiated a budget delegation process with the FY 2003 budget.  Although the San Francisco and New York commanders had always exercised control over their entire budget, including personnel, major commanders in Washington, DC had not. 

 

Personnel resources are managed centrally in Washington, DC for a number of reasons.  Individual commanders have less control over the timing of promotions, reassignments, losses and new accessions than USPP headquarters.  Such personnel decisions affect personnel costs and the resources needed to maintain staffing levels. Therefore, retaining central control over these personnel resources provides a better alignment between cost accountability and decision authority.  In addition, USPP has continued to maintain central control over recruit training and this is the principal source of new accessions.  Finally, the USPP budget office has traditionally used the projected resource savings from the delay associated with replacing personnel losses during the year to help fund other USPP spending needs.  Allocating personnel resources to individual commanders would jeopardize this practice.

 

 

 

 

 

 

 

10.  The U.S. Park Police, the National Park Service, and Interior continue to use the current Emergency Law and Order transfer process to help fund the special deployment and other costs associated with major unplanned special events.  For smaller, unplanned, park-sponsored special events, the Park Police should seek reimbursement from the sponsoring parks for the additional costs of special deployments supporting the events.

 

Status:  Moderate Progress

 

Explanation or Rationale for Current Status

 

The ELO transfer process remains an efficient means of funding unexpected contingencies and the USPP continues to use it effectively.  For smaller events, there appears to be little use of reimbursements from sponsoring parks to fund additional law enforcement costs associated with these and  other unplanned activities.  

 

Discussion Documenting Actions Taken

 

NPS concurred with this recommendation in the April 2003 memorandum, noting that “the parks should be responsible for funding law enforcement support for special events, which are not part of their routine operation.  Therefore, parks will be directed to provide funding for law enforcement for new, planned events such as the park co-sponsored Washington Area Bike Ride.”  NPS and USPP made little use of this reimbursement policy during FY 2002 and FY 2003.  There appear to be several reasons for this.

 

First, USPP was able to meet most of its unexpected or increased operational funding requirements during these two years with the $25 million no-year supplemental for terrorism operations it received in FY 2002.  Second, funding for NPS operations has increased modestly during FY 2002 and FY 2003; individual parks did not have substantially more resources to help fund additional planned or unplanned activities. Finally, appropriations language currently limits any park reimbursements for USPP law enforcement services to $10,000 per event – and this may have reduced the use of reimbursements between NPS and USPP.  While that limit was initially agreed to by both USPP and NPS, USPP staff now believe it is too low in a post-9/11 environment.

 

USPP has been using ELO funds to meet the additional protection costs incurred when the terrorist threat level shifts from Code Yellow (the USPP baseline funding level) to Code Orange.  These funds, however, can only be used for limited emergencies. When the heightened threat level exceeds 28 days, the ELO mechanism can no longer be used.

 

 

 

 

  

 

11.  The U.S. Park Police budget for services that extend beyond the park service mission, such as personnel protection, escort duties, and services provided to other federal, state, and local agencies, based on prior experience.  The Park Police should provide additional services that go beyond budgeted levels on a reimbursable basis.  The law enforcement advisory services provided to the park service regions by the Park Police, if continued, should be funded by reimbursements.

 

Status:  Rejected

 

 

Explanation or Rationale for Current Status

 

The USPP has not sought additional reimbursements for additional escort, medivac rescue, or other services that extend beyond the park service mission.  The regional law enforcement specialist positions are still filled (about half are currently vacant) and funded by the USPP budget.

 

Discussion Documenting Actions Taken

 

In the April 2003 memorandum, NPS acknowledged the appropriateness of continuing some USPP activities such as presidential and dignitary protection and anti-drug activities even when those activities extend by necessity beyond parklands.  However, NPS noted that “these activities were addressed in the FY 03 appropriation for the USPP.  Any activity not funded by the FY 03 appropriation will be performed on a reimbursable basis.”  Since six of the regional law enforcement specialist positions have been funded within the USPP baseline budget,[11] NPS believes that adopting a reimbursement policy for these positions is redundant and would unnecessarily transfer NPS resources to USPP. Neither NPS nor USPP has sought reimbursement from the U.S. Secret Service for the additional escort duty now provided to the Vice President.

 

USPP disagrees with this general approach and continues to believe that the value of services it receives from the U.S. Secret Service and other state and local law enforcement entities (such as fire and ambulance service) adequately compensates for the unreimbursed services USPP supplies to them.  The value of these “quid pro quo” transactions continues to be very difficult to measure.  But, since USPP has reimbursed local law enforcement entities for their assistance in providing law enforcement services for special events on the Washington, DC Mall, NPS management believes that the trade-offs may not be as balanced as USPP believes.

 

 

 

 

 

 

12.  The U.S. Park Police develop a multi-year replacement plan for cruisers and other major equipment for the Washington area.  This plan should be the basis for developing annual equipment funding requests and allocating approved budgetary resources consistent with overall Park Police budget limits and spending priorities.

 

Status:  No Progress

 

Explanation or Rationale for Current Status

 

USPP was able to use some of the funds from the FY 2002 terrorism supplemental and its FY 2003 appropriation to meet its immediate equipment replacement needs.  USPP indicates they are still developing a vehicle and equipment replacement plan for the Washington, DC area, and the Deputy Chief for Operations has moved responsibility for this activity to his immediate office to stress its priority.

 

Discussion Documenting Actions Taken

 

NPS concurred with this recommendation indicating that USPP had developed a multi-year, annual equipment replacement plan.  USPP staff noted that the FY 2002 supplemental and the FY 2003 appropriation provided sufficient funds to complete the planned equipment replacement, but those funds were placed in reserve to meet other higher priority spending needs in FY 2004.

 

Academy staff requested copies of the replacement plan, but have been told that USPP is still developing that plan for the Washington, DC area.   In New York and San Francisco, USPP uses a lease agreement to obtain vehicles and these lease costs are included in the annual operations appropriation.[12] 

 

13.  The U.S. Park Police and National Park Service work with Congress to reform the funding by shifting it to a permanent indefinite appropriation similar to the current Secret Service’s and Treasury’s current annual payments.

 

Status:  Fully Implemented

 

Explanation or Rationale for Current Status

 

Language in the FY 2002 appropriations bill created a permanent and mandatory funding source for this retirement benefit.

 

 

 

 

 

14.  Congress and the legislatures of Maryland, Virginia, and the District of Columbia establish a legal framework for police units in the Washington area that provides for mutual aid in case of emergencies and alleviates the burden caused by indemnification.

 

Status:  Fully Implemented

 

Explanation or Rationale for Current Status

 

NPS concurred and indicated that the enactment of PL 106-437 addressed any outstanding indemnification issues that existed in some USPP mutual aid agreements with local law enforcement entities within the Washington, DC metropolitan area.  USPP also noted that the departmental Solicitor’s Office had also concurred with this view.

 

 

 

III.  Staffing

 

15.  A thorough staffing needs assessment based on the U.S. Park Police mission, as clarified, be performed.  It should examine the balance among patrol activities, specialized units, and administrative assignments.  The assessment should use primarily external expertise to ensure its objectivity and credibility, and the results should be addressed through the budget process recommended in Chapter 3.

 

Status: Limited Progress

 

Explanation or Rationale for Current Status

 

The USPP did not hire external experts to conduct such a staffing needs assessment.  The Chief’s senior staff said this is mostly because the mission had not been clarified beyond adding security to the icon areas, and the Chief did not want to bring in outsiders until the work could be defined.  With input from staff in her immediate office, the Chief prepared her own staffing needs analysis in July 2003 and submitted it to NPS and DOI.  This analysis, including its underlying assumptions, is not available and is described as a set of notes and calculations. This needs analysis did call for more than doubling the current USPP sworn officer force.

 

 

Discussion Documenting Actions Taken

 

NPS concurred with the need for such a study and said that a staffing needs assessment “will be conducted based on the conclusions reached in the review of USPP mission and priorities.  USPP officials in concert with park managers are conducting preliminary work on this analysis.  Their recommendations will be evaluated and validated by external law enforcement professionals.”   While there are more regular interactions with some park managers and the lieutenants assigned to their parks, there has been no coordinated effort with Washington, DC superintendents to assess USPP staffing needs relative to park law enforcement needs; Academy staff have not spoken with superintendents or USPP managers in New York or San Francisco.

 

The current USPP assumptions have them continuing to perform all duties previously performed, and absorbing some new ones since 9/11, such as escorting the Vice President and expanding icon security coverage.  NPS and DOI did not issue guidance on mission clarification because they believed that such mission clarification should be part of a comprehensive internal review by the USPP as they analyzed their staffing needs.  USPP staff said they were waiting for mission clarification from NPS and DOI before doing their staffing needs analysis.  Therefore, it appears that there were communication breakdowns on this point.  The Chief prepared an estimate of additional resources required to better protect the icons at Code Yellow and submitted them to NPS; Academy staff were told that she expected to receive some additional funds for this but was told to absorb the costs.

 

At the request of the Interior Secretary, the Department of Homeland Security reviewed Washington, DC Mall security (using the Secret Service) and suggested specific staffing patterns for the major icons.  DOI (including NPS and the Chief) received these recommendations in March 2003.  Since the nation went to a Code Orange alert shortly after that, NPS and USPP decided this was not the time to question the Secret Service recommendations. Consequently, the DHS report was accepted as the standard for Washington, DC Mall area staffing.  But, as the IG’s Icon Security Report indicated, it was not fully implemented until late 2003.  While this increased staffing requirements,[13] the specific information contained in the DHS report is classified.

 

In July 2003, the Chief transmitted to the NPS Director and Deputy Director a “Draft Staffing Study” of sworn officers. This was a listing by USPP districts of the significant areas within each district, beats that cover them, and estimated staff per district.   The timing of its completion related to one of the meetings with DOI’s OLES staff, because the transmittal refers to a staff member from the DOI Division of Budget Administration expecting them.  In the transmittal, the Chief says she feels “awkward” presenting them to NPS senior staff via email, but “it’s clear that [the DOI Budget] office wants some idea of how far off of our staffing needs we are.  [The DOI Budget office] would also like us to prioritize the beats and areas we patrol, another area I would rather not tread.  This is a lose-lose conversation, especially when I don’t have the authority to say that one patrol area is less significant than another.” 

 

USPP staff indicated that the Chief’s file had handwritten notes and figures, and that she had considered recommendations such as the Academy Panel’s and Booz-Allen’s.  The Chief’s email said she believes her numbers are in line with Booz-Allen recommendations.  The Chief estimated a need for 921 USPP officer positions or assignments.  At the end of the Chief’s July 2003 estimate are sample “relief factors” that are to account for scheduled days off, leave, illness, court time, military duty, etc.  The factors are 1.65 to 1.84, meaning the total number of officers needed to fill 921 assignments would be 1,520 to 1,695.  USPP staff said that these relief factors were those used by organizations such as IACP.

 

Because of on-going personnel matters, the Chief remains unavailable at this time to clarify her methodology.  Consequently, Academy staff are unable to examine the assumptions behind the Chief’s estimates.[14]  The USPP’s 1993 beat analysis indicated they needed 749.8 officers and had 632 on board (as of February 1, 1993), for a deficit of 128.2.  This was a more detailed presentation that included specific assumptions for each beat (hours per day, days of the week covered, type of beat, priority).  However, a beat analysis starts with the assumption that an area needs to be patrolled, and the written document does not reflect why a given staffing level is needed per beat.  In developing the 2001 report, Academy staff discussions with senior staff in the Central District (which covers the monuments), revealed their rationale for the current beat assignments (such as crime levels, importance of the property).  However, while unit commanders can articulate a rationale for their officer deployment, there is no documentation of the rationale.  In part because of the need to better understand this, the DOI Deputy Assistant Secretary for OLES has discussed the relation between work and staffing with USPP senior staff at their now-regular meetings, which are often attended by senior NPS staff.

 

There have been some efforts to relate staffing to duties and staffing costs.  USPP prepared an assessment of staffing levels at Code Yellow and the additional staffing and associated costs needed for Code Orange.  It was presented at a meeting that the DAS for OLES called of all DOI law enforcement units, and he found it so useful that he asked the other units to use it as a model.

 

The NPS Deputy Director and the Chief have discussed staffing issues, including deployment.  The Chief has changed some shifts to reduce overtime use, and these efforts have continued to help address the FY 2004 budget shortfalls. 

 

 

16.  The U.S. Park Police administratively earmark and separately control an entry training budget.  To facilitate more frequent graduations, Park Police recruit training should be accelerated to the first available FLETC class and/or trained in conjunction with law enforcement rangers, when possible.

 

Status:  Limited Progress

 

Explanation or Rationale for Current Status

 

During fiscal years 2002 and 2003, when USPP had funds from the terrorism supplemental, they earmarked funds for recruit classes.  There were three in FY 2002 and four in FY 2003.  There were literally no more FLETC slots available to USPP during FY 2003 because so many other agencies’ programs were also adding classes.  There have been no classes yet in 2004, and although one is scheduled for April, some USPP interviewees question whether there will be funds for this.  

 

USPP staff believe that training with rangers would not be appropriate.  Ranger training is shorter and focuses relatively little on urban crime.  The April 2003 memorandum noted, “While it is difficult to quantify its benefit, we believe that training our recruits as a U.S. Park Police class establishes an esprit de corps that serves to inspire our officers throughout their careers.  Nevertheless, we will review other agency programs to identify regimens that are similar to and meet the standards established for our officers.”  The Chief reported in September 2003 on the results of this examination and said that if USPP recruits were to train with rangers, USPP would have to extend its overall training time so that its officers could be trained to handle situations in an urban environment.

 

Discussion Documenting Actions Taken

 

Classes held in FYs 2002 and 2003 were:

 

Class Date                  Number Entered                    Number Graduated

 

10/7/01                                    24                                            22

12/30/01                                  21                                            19

9/22/02                                    24                                            24

11/03/02                                  24                                            20

01/12/03                                  24                                            22

04/06/03                                  24                                            23

07/20/03                                  18                                            15

 

Totals                                      159                                          145

 

The September 2002 class was a “lateral” class comprised of people with officer experience in other federal agencies.  That class was taught at USPP rather than FLETC. Because of their accelerated training, that class became functioning officers faster than other recruit classes.

 

The size of the USPP officer force has not increased commensurate with the number of new graduates over the past few years.  Although the graduates total 145 officers, USPP lost 121 officers during this time, 81 in FY 2002 and 40 in FY 2003; resignations accounted for 75 of these officer losses, with many going to other federal agencies, largely because of hiring at DHS.

 

The costs of hiring new recruits are more than those associated with FLETC training.  The direct costs include salaries, equipment, background checks, and medical and fitness physicals.  The average annual cost of a class ranges from $1.2 - 1.8 million, depending on the time of year the class begins and how much of annual salaries need to be paid in the fiscal year in which the class is hired.  About $500,000 of the cost is for the FLETC training.  USPP loans staff to FLETC to serve as instructors (currently seven, down from twelve in 2001), as do most other agencies that send recruits to FLETC.  Tuition is reduced for USPP classes based on the number of loaned instructors.

 

 

17.  The U.S. Park Police reduce its ratio of supervisor to non-supervisory positions to a level approximating that of other local area police entities.

 

Status:  Limited Progress

 

Explanation or Rationale for Current Status

 

The overall ratio of the number of privates to higher-level officers has remained essentially the same, going from 2.1 to 2.2 privates for each officer above that level, with substantial variation by unit.  USPP has reduced its use of some higher-level positions.  For example, lieutenants instead of captains currently head districts in Washington, DC.  Also a captain, rather than a major, heads the New York field office.  Five of the ten captain positions in NPS regions are vacant, though this is in large part because NPS and USPP are exploring issues related to these positions. However, it is not clear how many of these reductions are temporary rather than permanent. 

 

Discussion Documenting Actions Taken

 

The April 2003 memorandum said that NPS concurred with the need to reduce the ratio and this was “being addressed as part of the Force staffing needs assessment.”

 

USPP took exception to the Academy’s use of the term “supervisor” in the recommendation because not all people above the private level have supervisor duties.  For example, sergeants on the Secretary’s Protection Detail and in the Internal Affairs unit do not serve as supervisors.  The language in the main body of the report uses the terms “ratio of privates to higher-ranking officers,” which is more appropriate than the language in the recommendation, and will be used in all future discussions. 

 

The USPP Chief noted in her September 2003 memorandum to NPS’ Deputy Director that the Academy Panel did not “consider the vacant officer positions in determining this ratio, which drove up the ratio.”  USPP noted that, “short of firing supervisors and commanders, when officers [privates] leave in great numbers, as they did for the previous two fiscal years, the ratio of supervisors to officers is currently greater than it would normally be.  This situation will self-correct over the next several years as we continue to work toward achieving previous and adequate officer staffing levels.”  In examining hiring and attrition data (which is not complete), it appears that, as more privates were hired, there was not an increase in officers above private level. Therefore, absent a substantial attrition of privates, the ratio of privates to higher-ranking officers should increase. 

 

This picture changes when the number of guards is considered.  There are currently 34 contract guards and 24 civilian guard employees now on staff.  These guards are supervised by two lieutenants (as collateral duty assignments, not as separate positions) in the Operations Division.  If it were assumed that these 54 contract and civilian guards conduct work that privates would otherwise do, the ratio in the Operations Division changes from 1.5 privates to higher-level officers to 4.0, and the overall ratio grows from 2.1 privates for each officer above that level to 2.4.  Part of the work in Phase II of this study will be to examine the attrition rates of privates hired since 2001, a number of whom have been hired by other federal agencies.   

 

Ratios vary among individual USPP offices and districts.  For example, in the Central District (where patrol areas include the Washington, DC Mall, most monuments, and Rock Creek Parkway) there are 4.5 privates for every officer above that rank, in the East District (which includes Anacostia and the Suitland Parkway in Maryland) the ratio is 3.6 to 1, in the West District (which includes the George Washington Parkway, Great Falls and Wolf Trap) the ratio is 3.6 to 1, and at the Statue of Liberty it is 4.9 to 1.  In specialized units, the ratios vary from 1.7 to 1 in Special Forces (which includes aviation, motorcycle officers, and K-9) to .7 to 1 in the Criminal Investigations Branch, where the work generally requires experience above the level of a private. 

 

 

18.  The U.S. Park Police civilianize positions currently occupied by officers when law enforcement training and experience are not required.  This should be done as the positions turn over, and the staffing needs assessment can be a vehicle to define specific civilianization goals.

 

Status: Moderate Progress

 

Explanation or Rationale for Current Status

 

USPP has made the commitment to assess all positions, (a few before they have become vacant) has civilianized a number of positions, and continues to do so.

 

Eleven positions were converted as of January 9, 2004 and decisions were pending on the two positions shown below:

 

Former Position                      Converted to civilian post as:

Captain                                    Human Resources Officer

Major                                       Civilian Financial Officer

Private                                      Applicant Background Investigator

Sergeant                                   Civilian Security Specialist

Sergeant                                   Freedom of Information Act (FOIA) Officer

Sergeant                                   Police Planner

Private (5)                                Firearms or Physical Skills Instructors (5)

 

Pending

Sworn dispatchers                    Civilian dispatchers

Captain                                    Facility Management

 

USPP has yet to review all of their positions to identify those positions that could potentially be civilianized and has not established a long-term plan to accomplish those reviews.

 

 

 

 

 

 

 

 

 

19.  The U.S. Park Police change its law enforcement staffing mix to include an armed security patrols with duties that are more limited than those of sworn officers to the current mix. This professional security patrol force, composed of government employees, possibly under contract with GSA (General Services Administration), should provide full-time security services at critical park facilities, including historic national memorials, monuments, and other treasures.

 

Status:  Moderate Progress

 

Explanation or Rationale for Current Status

 

There are now 34 unarmed contract guards, primarily at the Washington, DC Mall monuments, and 24 civilian guards (down one from 25 in 2001) who have fixed posts, but are generally not at the Washington, DC Mall monuments.  USPP assessed the costs of recruiting and hiring employees rather than contractors as guards and decided it was faster and less expensive to hire guards under contract.  Guard staff at the Washington, DC Mall monuments perform traditional fixed-post duties, but are always assisted by at least one USPP officer.  If the guards were not in place, the positions would have to be filled by the more highly paid (and trained) officers.  In addition to the reduced costs of using guards at these posts, a number of sworn officers have told Academy staff that they became police officers to perform more than guard duties.  Therefore, it could be difficult to retain officers for this duty 

 

Discussion Documenting Actions Taken

 

Initially, DOI noted in the April 2003 memorandum that use of unarmed guards had increased “at our monuments and memorials in response to heightened security in the Nation’s Capital.”  However, NPS does not concur with the use of armed guards in any circumstance.  Armed guards were employed until the mid-1980s when the decline in the quality of candidates reached the point where NPS management believed the public’s safety would be compromised if use of armed guards was continued.  It is the position of NPS management that in situations where an armed employee is warranted, that the employee should have the full knowledge, skills and abilities required of a sworn police officer.  The increased risk to public safety of appointing a class of employees with lesser training far outweighs the minor immediate cost savings.”

 

Since that time, NPS’ view on the use of armed guards appears to have changed somewhat, since it issued a contract to Wackenhut Security to provide armed guards at Independence Hall in Philadelphia.  These armed guards are now in place and NPS’ initial assessment is favorable.  The OLES staff also believe that armed guards are a less costly alternative to expanding on-board officer staffing for meeting fixed post security requirements. 

 

allH

 

20.  The U.S. Park Police establish a workforce planning and management system that addresses all aspects of human resources management, including attrition, recruitment, and training of officers and civilians.

 

Status: Limited Progress

 

Explanation or Rationale for Current Status

 

The Chief said, in September 2003, that the establishment of a workforce planning and management system was a work-in-progress, and began with the hiring of a Civilian Manager who oversees Organizational Development and Fiscal Management, and the consolidation of all Human Resources and Employee Development (HRED) needs under one command officer.  The Chief instituted bi-weekly reports on activities and accomplishments from command officers, and the HRED report includes reporting on civilian and sworn officer training and related issues.  The report also contains lists of goals in HRED for 2004, including engaging in DOI and NPS workforce planning strategies and aligning USPP with the NPS goal of continuous learning for all employees.  While these types of activities are basic components of human resources management, this broad perspective was not clearly in evidence in 2001. 

 

Discussion Documenting Actions Taken

 

The USPP Command Officer who oversees HRED sits on the NPS Administrative Advisory Council. This group helped develop the formal NPS workforce plan, issued in October 2003.  USPP will align its plan with the NPS plan, and USPP staff have obtained information on how to develop a plan and are accumulating some of the data on which a plan will be based.  In addition, a USPP staff member sits on an NPS committee that is developing competencies for law enforcement staff, and this will be applied to development of USPP competencies. 

 

In conjunction with the NPS workforce plan, USPP prepared a two-page statement of “Workforce Key Issues,” per an NPS request for input to the overall plan.[15]  USPP did not receive a request to do this until August, and the plan is dated September 30, 2003.  Thus, only top USPP management (Assistant and Deputy Chiefs, Chief, and Civilian Manager of Organizational Development and Fiscal Management) were involved in preparing the input.

 

One of the HRED goals is to, “Establish competencies for each job title (career field) at USPP, in order to design training opportunities for our employees that are essential for employees to perform effectively at respective levels within the Force, as set for by the National Leadership Council-approved NPS Employee Training and Development Strategy.”  Another goal is to “Revamp the Force’s Performance Management System, tailoring it to the specific needs and central goals of the agency.”  There were no such clearly articulated goals in 2001.

 



[1] U.S. Department of the Interior, Office of Inspector General, Disquieting State of Disorder: an Assessment of Department of the Interior Law Enforcement, January 2002, No. 2002-I-0014.

[2] U.S. Department of the Interior, Office of Inspector General, Progress Report:  Secretary’s Directives for Implementing Law Enforcement Reform in the Department of the Interior, August 2003, No. 2003-I-0062.

[3] Press release from the Office of the Secretary of Interior, July 19, 2002.

[4] In addition to the Academy Panel report, these included separate NPS studies in 2000 of the U.S. Park Rangers and the U.S. Park Police, an October 2000 International Association of Chiefs of Police (IACP) study on Policing the National Parks, a January 2002 IG assessment of Interior Law Enforcement, and an NPS task force report on women in law enforcement.   The LETF was chaired by the NPS deputy director and included the new USPP Chief, as well as other USPP and park ranger members.

[5] USPP staff indicted they were waiting for mission guidance from NPS; there is no indication that NPS had any review underway at that time to produce revised mission guidance. 

[6] The aggregate numbers in this draft July staffing study are discussed more fully on pages 20 and 21 of this report.

[7] Some of these result from USPP concurrent jurisdiction responsibilities.  For example, if a USPP officer is driving from one park to another and sees a possible drunk driver, the officer must take action.

[8] The annual FLETC reimbursement for instructional services provided by USPP officers at the Glynco, Ga. training site is small, amounting to only $347,762 in FY 2003.  In FY 2004, FLETC will reimburse USPP only for overtime costs – estimated to be only $25,000.

[9]For example, the appointment of new senior managers in NPS (Deputy Director Murphy, Associate Director Taylor-Goodrich) and USPP (Chief Chambers, her two new Deputy Chiefs and the new Civilian Manager of Organizational Development and Fiscal Management) was not completed until the spring and early summer of 2002.  These new senior managers had critical roles in the USPP and NPS law enforcement budget formulation, (except for Deputy Director Murphy, who was appointed in the fall of 2001) but were still learning about the DOI budget process during the formulation of the FY 2004 budget.

[10] This pertains to Washington, DC only, since Academy staff have not yet had an opportunity to do follow-up interviews with USPP and NPS staff at either the New York or San Francisco parks.

 

[11] USPP staff believe that when these positions were transferred to the separate USPP operations appropriations, the transferred funds only covered a portion of their actual FY 2001 costs.

[12] Academy staff have not contacted these field offices to determine whether they have developed equipment replacement plans for USPP owned equipment (e.g., marine equipment in New York.)

 

[13]  USPP has recently signed a contract to use unarmed guards to meet some of this requirement.

[14]  Since this July 2003 staffing needs study was not shared with USPP staff below the Deputy Chief level, USPP staff could not provide any additional information on the Chief’s methodology or assumptions.

[15] USPP was not sure this was sent to Interior; transmittal note not in file.  Could only be 2 pages, and was a standard format.