TABLE OF CONTENTS

FOREWORD........................................................................................................................... iii

ACRONYMS........................................................................................................................... ix

EXECUTIVE SUMMARY..................................................................................................... xi

CHAPTER 1:1INTRODUCTION........................................................................................... 1

The U.S. Park Police: A Brief History.......................................................................................... 2

NPS and USPP Missions............................................................................................................ 3

Key Changes Since the August 2001 Academy Report................................................................ 4

Law Enforcement Reforms at the Department of the Interior................................................... 4

NPS and USPP Leadership Changes..................................................................................... 5

USPP Organizational, Spending, and Staffing Changes Since 2001............................................... 6

USPP Organizational and Structural Changes......................................................................... 6

Spending Trends.................................................................................................................... 9

Staffing Trends...................................................................................................................... 9

Crime or Incident Data Changes.......................................................................................... 10

Implementation of the 2001 Recommendations........................................................................... 10

Subsequent USPP Actions................................................................................................... 13

Study Methodology................................................................................................................... 14

Road Map to the Report............................................................................................................ 16

CHAPTER 2: LAW ENFORCEMENT IN URBAN PARKS

AND USPP MISSION..................................................................................................... 17

Differences Between the Work of Protection Rangers and USPP Officers................................... 17

USPP’S Evolution and Expanded Mission.................................................................................. 20

Previous Efforts to Narrow the USPP Mission..................................................................... 22

Increased Involvement in Fighting Crime in DC and Throughout the Country......................... 23

Conclusions and Recommendations: USPP’s Evolution and Expanded Mission.................... 24

Setting Priorities in the Post-9/11 World..................................................................................... 26

USPP Responses to Increased Counterterrorism Requirements............................................ 27

USPP Priority Setting Processes.......................................................................................... 28

NPS Law Enforcement Needs Assessments......................................................................... 29

Conclusions and Recommendations: Setting Priorities in the Post-9/11 World...................... 31

USPP Activities Beyond NPS Law Enforcement Needs............................................................. 32

Conclusions and Recommendations: USPP Activity Beyond NPS

Law Enforcement Needs..................................................................................................... 34

CHAPTER 3: METHODOLOGY FOR SETTING USPP PRIORITIES.......................... 35

USPP Functions and Activities................................................................................................... 35

Priority-Setting Criteria.............................................................................................................. 38

Ranking and Applying the Criteria........................................................................................ 41

The Ranking Matrix............................................................................................................. 41

Distinguishing Higher and Lower-Priority Functions.............................................................. 42

Potential High-Priority Functions.......................................................................................... 43

Potential Low Priority Functions........................................................................................... 44

Conclusions and Recommendations—Priority Setting Criteria............................................... 47

Alternatives for Lower Priority Functions: ~~................................................................................. 48~~

The Role of the Budget Process................................................................................................. 48

Conclusion and Recommendations—the Role of the Budget Process.................................... 48

CHAPTER 4: CREATING A CONSOLIDATED BUDGET AND FINANCIAL REPORTING SYSTEM 55

Expenditures From Appropriations for Operations...................................................................... 56

Expenditures From All Sources of Funds.................................................................................... 58

Spending Growth Over the Past Six Years................................................................................. 61

Overtime Spending.................................................................................................................... 62

Reimbursements and Transfers................................................................................................... 65

Conclusion and Recommendations............................................................................................. 66

CHAPTER 5: REFLECTING USPP’S MISSION IN ITS WORKFORCE...................... 69

Changes in Allocation of Officers............................................................................................... 69

Growth in Non-Patrol Forces.............................................................................................. 71

Recruiting Thwarted by Turnover............................................................................................... 73

Training in Other Organizations............................................................................................ 74

Turnover Results in No Growth Among Sworn Officer Force............................................... 74

Conclusions and Recommendations: Recruiting Thwarted by Turnover................................. 76

Changes in Staff Mix Since 2001............................................................................................... 77

Less Change in Ratio of Privates to Officers Above that Level.............................................. 77

Comparison of Privates to Sergeants.................................................................................... 78

Conclusions and Recommendations: Changes to Staff Mix Since 2001................................. 80

Adding Flexibility to Staffing Patterns......................................................................................... 81

Potential to Refocus Resources from Regional Captain Positions........................................... 82

Conclusions and Recommendations: Adding Flexibility to Staffing Patterns........................... 82

Developing Staff Throughout Their Careers................................................................................ 84

Conclusions and Recommendations: Developing Staff Throughout Their Careers.................. 84

Relationships With and Reliance on Other Law Enforcement Agencies........................................ 85

How Police Departments Estimate and Deploy Officers........................................................ 86

Estimating Staffing Needs........................................................................................................... 87

How NPS and USPP Estimate Staffing Needs..................................................................... 88

USPP Beat Analyses........................................................................................................... 88

Other Options to Estimate Required Officer Strength............................................................ 89

Conclusions and Recommendations: Estimating Staffing Needs............................................ 90

APPENDICES

Appendix A: Project Panel and Staff List................................................................................ 93

Appendix B: Individuals Interviewed or Contacted................................................................. 95

Appendix C: Selected Bibliography ~~(Not~~ ~~Included)~~................................................................. 99

Appendix D: Crime Trends Data.......................................................................................... 101

Appendix E: Evolution of USPP Responsibilities................................................................... 107

Appendix F: NPS Law Enforcement Needs Assessment Template....................................... 115

Appendix G: Park Protection and Response Plan for Gateway National

Recreation Area................................................................................................................ 121

Appendix H: Pairwise Comparison Methodology.................................................................. 137

Appendix I: USPP Appropriations Changes FY 1997-FY 2003......................................... 141

Appendix J: Detailed USPP Attrition Data........................................................................... 145

Appendix K: USPP Radios of Number of Privates for Each Sworn Officer

Above that Level......................................................................................................... 147

Appendix L: Summary of Changes in USPP Beat Analysis 1884-2004................................. 149

Appendix M How NPS Estimates Law Enforcement Staffing Needs..................................... 153

Appendix N: VRAP Factors as They Apply to the U.S. Park Police

with Additional Factors Suggested............................................................................... 157

TABLES AND FIGURES

Figure 1-1: 2001 United States Park Police Organizational Structure .......................................... 7

Figure 1-2: 2004 United States Park Police Organizational Structure .......................................... 7

Table 1-1: Park Police Sworn Officers: 1986-2004 .................................................................. 10

Table 1-2: Status of the Twenty 2001 Recommendations ........................................................... 11

Table 3-2: USPP Functions and Application of Priority Assessment .......................................... 50

Table 4-1: Relative Size of USPP’s Budget and Employment, FY 2005 .................................... 56

Table 4-2: USPP Appropriated Fund Spending by Organization, FY 2001-2003...................... 56

Table 4-3: Appropriated Funds Spending Change, FY 2001-2003 ........................................... 57

Table 4-4: Appropriated Funds Spending Change in the New York Field

Office, FY 2001 and 2003 ................................................................................................. 57

Table 4-5: Spending by all Funding Sources, FY 2001-2003 .................................................... 60

Table 4–6: Actual Spending from all Sources of Funding, by Fiscal Year ................................... 62

Table 4–7: Overtime Spending, FY 1998–2003 ....................................................................... 63

Figure 4-1 Concentration in Use of Overtime and Compensatory Time Payments........................ 64

Table 4-8: Appropriated and Non-Appropriated Spending, FY 2001–2003 ............................. 65

Table 5-1: Civilian and Officer Staff: March 2001 and March 2004 .......................................... 70

Table 5-2: Comparison of Specialized Units ............................................................................. 72

Table 5-3: Recruit Classes in FYs 2002-2003 .......................................................................... 73

Table 5-4: Calendar Year Attrition Data for Sworn and Civilian Positions: 1998-2004 .............. 75

Table 5-5: Separation Rates for 13 DC Area Uniformed Federal Police Departments ............... 76

Table 5-6: Comparison of Ranks: 2001 and 2004 ................................................................... 77

Table 5-7: Ratio of Privates to Sergeants: 2001 and 2004 ........................................................ 79

ACRONYMS

BWP	Baltimore Washington Parkway
C&O	Chesapeake and Ohio
CFO	Chief Financial Officer
CY	Calendar Year
CIB	Criminal Investigations Branch
DARE	Drug Abuse Resistance Education
DAS	Deputy Assistant Secretary
DC	District of Columbia
DEA	Drug Enforcement Agency
DHS	U.S. Department of Homeland Security
DOI	United States Department of the Interior
ELO	Emergency Law and Order [funds]
FBI	Federal Bureau of Investigation
FFS	Federal Financial System
FLETC	Federal Law Enforcement Training Center
FOIA	Freedom of Information Act
FTE	Full time Equivalent
FY	Fiscal Year
GAO	General Accounting Office
GGNRA	Golden Gate National Recreation Area (in San Francisco)
GNRA	Gateway National Recreation Area (in New York)
GSA	General Services Administration
GWP	George Washington Memorial Parkway
HMP	Horse Mounted Patrol
HR	Human Resources
HRED	Human Resources and Employee Development
HUD	United States Department of Housing and Urban Development
IACP	International Association of Chiefs of Police
IG	Inspector General
IMF	International Monetary Fund
LE	Law Enforcement
LENA	Law Enforcement Needs Assessment
LETF	Law Enforcement Task Force
MNCPP	Maryland National Capital Park Police
MOA	Memorandum of Agreement
MOU	Memoranda of Understanding
MTP	Metropolitan Transit Police
MPD	[Washington, DC] Metropolitan Police Department
NCR	National Capital Region
NLC	National Leadership Council
NPS	National Park Service
NYPD	New York Police Department
NYFO	New York Field Office (USPP)
OFS	Operations Formulation System
OIG	Office of Inspector General
OJT	On-the-job Training
OLES	Office of Law Enforcement and Security (departmental office)
OPM	Office of Personnel Management
OMB	Office of Management and Budget
PD	Police Department
PG	Prince George’s
PSA	Police Service Area
READI	[The George Washington University’s] Response to Emergencies
	and Disasters Institute
RLES	Regional Law Enforcement Specialist
SFB	Special Forces Branch
SFFO	San Francisco Field Office
SP	Suitland Parkway
SWAT	Special Weapons and Tactics Teams
TSA	Transportation Security Administration
PMIS	Personnel Management Information System
USDA	United States Department of Agriculture
USPP	United States Park Police
USSS	United States Secret Service
VAPD	Virginia Police Department
VRAP	Visitor Management Resource Protection Assessment Program
WASO	Washington [DC] Service Office

EXECUTIVE SUMMARY

The U.S. Park Police (USPP), the nation’s oldest uniformed federal law enforcement agency, has a long and distinguished history of protecting federal parklands in the nation’s capital. It has been a separate entity within the National Park Service (NPS) since the 1930s. With about 615 sworn officers and an operating appropriation of $81 million for Fiscal Year (FY) 2004, USPP is relatively small, but has unusually high visibility.

As NPS’ law enforcement arm for urban parks in Washington, DC, New York and San Francisco, USPP officers protect such unique national treasures as the monuments on the National Mall and the Statue of Liberty, and ensure the safety of visitors and other park users. Because the Mall area frequently hosts major events, demonstrations, and marches, sometimes involving hundreds of thousands of individuals, USPP also must manage large crowds to ensure the safety of demonstrators and visitors alike. Consequently, USPP has acquired a well-earned reputation as an exemplary preserver and protector of First Amendment rights of peaceful assembly.

Given USPP’s high visibility and several budget and management issues, the House Appropriations Subcommittee on Interior and Related Agencies in 2000 asked the National Academy of Public Administration (the Academy) to review and evaluate USPP’s mission, its priority-setting process for law enforcement functions, and the adequacy of its systems for developing and controlling its budget and other resources. In its August 2001 report—The U.S. Park Police: Focusing Priorities, Capabilities, and Resources for the Future—an Academy Panel made 20 recommendations designed to clarify USPP’s mission, set priorities for its diverse law enforcement functions and work activities, strengthen leadership and accountability, and improve financial and workforce management.

In light of renewed USPP budget and financial problems in FY 2004 and other concerns, the subcommittee asked the Academy to follow up on the 2001 recommendations. This follow-up study was conducted in two phases:

— Phase I: Review the implementation status of each recommendation from the August 2001 report, assess the rationale for non-concurrence where applicable, and identify possible options to adjust the pace of implementation.

— Phase II: Evaluate USPP’s mission, roles, and functions, the resources allocated to them, and their relative priorities; identify major changes in them since the 9/11 terrorist attacks; and assess the feasibility of adjusting current functions, assuming constrained budgets for the next few years.

In a February 2004 Phase I report, this Panel found that four of the 20 recommendations had been fully implemented and two had been rejected. As for the others, limited progress had been made for ten of them, moderate progress for three, and no progress for one. Only limited progress was made in implementing the five recommendations considered most crucial to refocus USPP resources and their use on NPS’ most critical law enforcement needs.

This report completes Phase II of the follow-up study.

LEADERSHIP, DIRECTION, ACCOUNTABILITY, AND RESPONSIBILITY

Although the terrorist attacks have made protection of our national treasures a top law enforcement priority, neither the Department of the Interior (DOI) nor NPS has established explicit, clear priorities for the range of USPP’s other law enforcement functions and work activities. To address this fundamental problem now, the Panel reaffirms, with a modification (in italics) the central recommendation of its 2001 report that:

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

Although high-level meetings have taken place during the ensuing three years at both NPS and DOI, agreement has not been reached on a new mission statement for the USPP that distinguishes it from other federal and local law enforcement agencies. The current mission statement is very general and could apply equally to almost any police organization. Without clarity of mission and established priorities, issues of structure, function, and resource allocation cannot be effectively resolved, and managers cannot be held accountable for the proper discharge of their responsibilities.

The Panel found NPS and USPP have sharply divergent views regarding the latter’s role. USPP views itself as a full-service urban police force, principally focused on NPS parklands. NPS, on the other hand, views USPP as a more specialized police force principally focused on urban national parks. There also appears to have been disagreement about who had primary responsibility for mission definition.

9/11 Changes Reinforce Need to Clarify Mission and Set Priorities

The increased law enforcement and security requirements resulting from the 9/11 attacks reinforce the need to resolve these different views, clarify USPP’s mission, and set priorities among USPP’s diverse law enforcement functions. Enhanced requirements also emphasize that none of the three organizations–DOI, NPS, or USPP–can act alone.

Failure to implement this 2001 recommendation has strengthened the Panel’s conviction that specifically defining the mission of the Park Police remains a critical and urgent joint management issue for DOI, NPS, and USPP. In an era of heightened risk to the national treasures, visiting public, and First Amendment exercises that the Park Police secure, this task is too important to be assigned to USPP management without either the necessary guidance or authority to make many changes, or to be imposed from above. It is essential that the Chief and executive staff of USPP and the policy leadership of NPS and DOI be engaged together in defining the mission of the Force and establishing priorities.[1] Once the mission has been defined, DOI and NPS must provide strong leadership and active support to USPP in defending this redefined mission within the administration, before Congress, and among the agencies with which USPP traditionally works. NPS superintendents and USPP leadership and officers must fully understand and support the reasons for any change, which should be reinforced through training, budgeting, and day-to-day management.

EXPANSION OF USPP’S ROLE AND NPS LAW ENFORCEMENT NEEDS

USPP’s broad role and diverse law enforcement functions reflect its long, evolving statutory history, much of which took place apart from NPS. Since USPP’s creation, Congress has viewed it as an integral component of the overall law enforcement protection and security functions for the District of Columbia (DC). Even after USPP was placed within NPS, its role continued to expand as its assumed law enforcement responsibilities for new national park sites outside DC, specifically the Presidio and other parts of the Golden Gate National Recreation Area (GGNRA) in San Francisco and the Statue of Liberty and parts of Gateway National Recreation Area (GNRA) in New York. Within DC, its responsibilities have recently expanded to protect new monuments and their visitors, including the Franklin Delano Roosevelt, Vietnam Veterans, Korean Veterans, and World War II Memorials. The USPP’s geographic focus on “the environs of the District of Columbia” has expanded as new parklands have been added within DC and the surrounding Maryland and Virginia suburbs.

NPS Urban Park Law Enforcement Needs

The nation’s 385 national park sites require some level of law enforcement services to protect visitors and natural, cultural, or historical assets, yet urban national park needs differ substantially from those of most large, isolated rural parks. Different uses of urban national parks pose different risks for visitors, such as fewer wildlife encounters and more person-on-person criminal activity. Natural resource and environmental preservation requirements are more prevalent at rural parks given their greater geographic size and diversity.

NPS relies on protection rangers and USPP to meet its law enforcement needs. The former focus primarily on law enforcement for the vast majority of non-urban parks, though they do serve several urban ones as well, Independence National Historic Park in Philadelphia and the Boston National Historical Park being examples. However, protection rangers and USPP officers approach NPS’ urban park law enforcement needs quite differently. Some variations reflect different law enforcement requirements at specific parks, but most appear to reflect differences in leadership, perceptions of respective roles, training, performance, and career expectations.

In general, protection rangers want and expect to work primarily in a park setting, protect natural and physical park assets, and serve visitors. USPP officers view themselves as police officers focused on visitor safety and property protection by preventing criminal activities or investigating those that occur on or near NPS parklands. Separate organizational structures reinforce these perceptions, as rangers are accountable directly to park superintendents and USPP officers are accountable to their own district commanders.

All of USPP’s diverse law enforcement functions fit within its broad statutory assignments, yet some extend beyond explicit NPS law enforcement needs, specifically requests from the U.S. Secret Service to help with presidential, vice presidential and foreign dignitary escorts within DC and various NPS parklands in the DC metropolitan area. In addition, USPP continues to provide protection for the Secretary of the Department of the Interior.

Changes Since the 9/11 Terrorist Attacks

The 9/11 terrorist attacks brought substantial changes in NPS’ protection, security and law enforcement needs. Throughout NPS, the threat of a terrorist attack on a “national Icon” and the impact on visitors and the national heritage became a law enforcement priority. NPS identified critical national Icons within its park sites that could be targeted for attack, assessed vulnerabilities, and developed security plans for addressing them. This increased emphasis on security significantly affected USPP activities. Major changes included:

— Increased coverage at the Washington Monument and Lincoln and Jefferson Memorials in DC.

— Expanded coverage at the Statue of Liberty and Ellis Island in New York and the Golden Gate Bridge in San Francisco.

— Cooperation with the Department of Homeland Security (DHS) on issues related to general and specific threats. For example, much of the land along the Ronald Reagan National Airport flight path is on USPP property, while many of the flight path approaches for JFK airport cross Jamaica Bay, part of GNRA in New York.

— Escort service, at U.S. Secret Service request, for the Vice President as he travels from his residence to work.

These changes not only required additional resources, but different approaches for using those resources. Prior to 9/11 for example, tourists were screened as they entered the Statue of Liberty. They now are screened twice: once in Battery Park prior to boarding the ferry to Liberty Island, and again on the island, outside the statue.[2]

USPP received a $25 million anti-terrorism supplemental appropriation in FY 2002. It tried to use the funds to bolster its officer strength to address additional law enforcement needs; yet substantial officer attrition in 2002 and 2003 offset hiring increases. Consequently, USPP met these increased counterterrorism requirements by increasing its use of overtime, reallocating officers through scheduling changes (including 12 hour shifts in several areas), reducing training and drug interdiction activities, and expanding the use of contract guards. These responses created major stresses and conflicts within USPP once the supplemental funds were expended, since subsequent resource limitations precluded continuing all of its previous functions while increasing anti-terrorism activities.

SETTING LAW ENFORCEMENT PRIORITIES

Most federal, state, and local law enforcement agencies use their annual budget process to align their needs with resources. The process can address trade-offs among law enforcement activities and available resources only if there is a clearly defined mission, explicit, agreed-upon needs, and a process to establish priorities for those needs.

Defining Law Enforcement Needs

In 2003, NPS required each park to define its own law enforcement and security requirements through an internal planning process that involved the park superintendent, chief ranger, and other appropriate staff. All parks developed Law Enforcement Needs Assessments (LENAs), except for most served by USPP. Those in the National Capital Region did not develop LENAs because they believed that the assessments were only for parks served by protection rangers. USPP did not develop park-oriented protection and law enforcement plans.

Better progress was made in New York. Gateway’s acting superintendent prepared, in conjunction with USPP’s New York Field Office (NYFO), a “Park Protection and Response Plan” that defined park management goals and established law enforcement needs, supported by data and other information describing the surrounding park environment. The acting superintendent noted that this joint process allowed NPS supervisors and USPP commanders to better understand each other’s needs and limitations. In San Francisco, rangers created a LENA for GGNRA. However, this plan was developed with no input from or consultation with USPP.

The lack of clear law enforcement needs assessments for most USPP-served parks is a critical problem. Priorities cannot be established for USPP law enforcement functions and associated work activities if NPS’ law enforcement, protection, and security needs are not clearly defined and understood. The New York process had two distinct advantages: It was undertaken outside the annual budget development process, and cognizant USPP commanders were directly involved in the plan’s development. This enhanced communication and understanding can only help both groups when making difficult trade-offs in setting priorities. Therefore, the Panel recommends that:

Park superintendents and the U.S. Park Police district commanders in the National Capital Region and the Golden Gate National Recreation Area should jointly develop law enforcement needs assessments for their parks that identify their law enforcement, protection, and security needs.

A formal joint planning process to identify and define law enforcement needs should take place outside the often contentious budget process to facilitate better communication and a more complete understanding of NPS and USPP needs, capabilities, and limitations. This is critical for resolving the fundamentally different views that now exist about USPP’s role.

The Panel’s most important message to all who make decisions about Park Police resource needs—including Congress—is that you can’t have it both ways.

USPP cannot be expected to function as a full-service urban police department and guardian of national parks at current resource levels. If it is to continue to fulfill its current broad roles, it needs additional resources. If resources are not available, its mission must be clarified and priorities established for its diverse law enforcement functions.

PRIORITY-SETTING CRITERIA

A priority-setting process for USPP law enforcement functions must have explicit criteria to assess the relative importance of each function and associated work activities. These criteria should be clearly defined and independent of each other, capable of being weighed or ranked relative to each other, and limited and manageable.

The priority-setting process should include a clearly defined set of law enforcement functions and the work activities that flow from them, as well as the resources currently used for each. Although USPP functions and work activities were identified during this study, it was not possible to develop complete resource costs or staffing data on a functional basis. Neither USPP nor NPS has this type of budget categorization or system. The NPS budget is organized around individual parks by type of appropriation—operations, capital construction, and the like. The USPP budget for operations is developed and presented organizationally for its major components in DC, New York, and San Francisco.

Given these limitations, this report identified criteria to be used and how to apply them to set priorities.

Therefore, the Panel recommends that:

The Department of the Interior and National Park Service should adopt the following six criteria for setting priorities for current Park Police law enforcement functions and activities:

— Benefits Expected. Includes the threats or risks being deterred, the significance or importance of the individuals, properties, or other assets being protected, and the frequency and magnitude of the need for the activity.

— Uniqueness of Function to NPS. Distinguishes functions unique to NPS (e.g. crowd control for National Mall activities, Icon protection, and visitor service in conjunction with visitor protection) from those more common to urban policing (e.g., traffic control, parking enforcement, drug enforcement).

— Principal Beneficiaries and Relationship to NPS Mission. Identifies whether the principal beneficiary is a key NPS stakeholder. (Such stakeholders are primarily current and future generations of visitors to national parks. The Icons and irreplaceable natural or physical NPS assets are themselves stakeholders, in a sense.)

— Cost Effectiveness. Determines the relative efficiency of current USPP work activities and service delivery techniques.

— Comparative Advantage of Alternative Providers. Determines whether alternatives exist for some USPP activities or services and, if so, the legal feasibility, costs, effectiveness, timeliness, reliability, or availability of those alternatives.

— Collateral Benefits. Determines how much providing a particular law enforcement work activity also meets law enforcement needs in other areas.

All six criteria are important, yet it still may be necessary to distinguish their relative importance. Not doing so can imply that each one is equally important, an improbability. Moreover, individual decision-makers are likely to value the criteria differently. Therefore, the Panel recommends that:

The Department of the Interior, National Park Service, and Park Police officials should rank the priority-setting criteria using a standard and transparent approach.

Assessing Higher and Lower-Priority Functions

Using the Panel’s criteria to assess current USPP law enforcement functions and activities should produce a consistent outcome. Higher-priority activities should generate substantial benefits that accrue primarily to key NPS stakeholders, provide collateral benefits for other NPS law enforcement needs, address needs that are unique to NPS and provided efficiently by USPP, and have few equally effective and efficient alternatives. On the other hand, low-priority functions may produce substantial benefits, but key NPS stakeholders are not the primary beneficiaries; they do not address unique NPS needs, there are few collateral benefits for other law enforcement needs, and alternative providers can efficiently provide the service.

Icon protection is one example of a potential high-priority function using the Panel’s criteria. The expected benefits are substantial and accrue to key NPS stakeholders; the assets being protected are unique to NPS and irreplaceable; significant collateral benefits include the safety of visitors and their protection from criminal activities; less expensive contract guards, rather than armed USPP officers, appears to be

A Report by a Panel of the

August 2004