oversight

National Park Service: Employee Housing Issues

Published by the Government Accountability Office on 1997-10-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                   United States General Accounting Office

GAO                Testimony
                   Before the Subcommittee on Interior and Related
                   Agencies, Committtee on Appropriations, House of
                   Representatives


For Release
on Delivery
Expected at
                   NATIONAL PARK SERVICE
10 a.m. EST
Wednesday
October 29, 1997
                   Employee Housing Issues
                   Statement of Barry T. Hill, Associate Director,
                   Energy, Resources, and Science Issues,
                   Resources, Community, and Economic
                   Development Division




GAO/T-RCED-98-35
    Mr. Chairman and Members of the Subcommittee:

    We are pleased to be here today to summarize our past work on National
    Park Service employee housing issues. Our comments today are based on
    two reports that we issued in 1993 and 1994.1 Where possible, we have
    updated some of the information in preparation for today’s hearing. While
    these reports are now a few years old, their findings and recommendations
    are still valid.

    In summary our work has shown the following:

•   The Park Service has not clearly justified the need for all of its employee
    housing units. The agency requires parks to perform needs assessments to
    justify its housing. However, these assessments may not be in-depth,
    objective, nor performed consistently from park to park. In response to
    the Omnibus Parks and Public Lands Management Act of 1996, the agency
    is beginning the process to assess the need for its housing units; however,
    this process is not scheduled to be completed until 2002—9 years after we
    recommended such assessments.
•   The Park Service has not been able to provide detailed support for its
    backlog for repairing and replacing its housing inventory. In 1993, we
    reported that the agency estimated its housing backlog at $546 million.
    However, the Park Service could not support this figure. Today, the
    agency estimates its housing backlog to be about $300 million. However,
    the Park Service acknowledges that this figure is not based on a detailed
    assessment of its housing repair and maintenance needs but rather a gross
    estimate based on the total number of houses whose condition has been
    rated less than good.
•   Individual park managers have broad discretion in implementing park
    housing policy. This has resulted in inconsistencies in how the program is
    managed across the agency and raises questions about whether housing
    decisions are being made in the best interest of the agency. For example,
    the Department of the Interior’s Inspector General’s Office reported in
    1996 that in constructing employee housing at the Grand Canyon, a former
    park manager decided to build 59 single-family houses. At the time of the
    report, these houses were in the process of being constructed, and many
    of them had already been completed. According to the report, the decision
    to build 59 single-family houses was made despite advice from the Park
    Service regional office and others that building a mix of 114 single-family
    and multi-family units would better address that park’s housing shortage.

    1
     National Park Service: Condition of and Need for Employee Housing (GAO/RCED-93-192, Sept. 30,
    1993), and National Park Service: Reexamination of Employee Housing Program Is Needed
    (GAO/RCED-94-284, Aug. 30, 1994).



    Page 1                                                                       GAO/T-RCED-98-35
                 By building the single-family houses, the report stated that approximately
                 50 permanent and 100 seasonal employees would still be living in
                 substandard housing at the completion of the construction.2
             •   Other federal land management agencies such as the Forest Service and
                 the Bureau of Land Management (BLM) do not provide the same level of
                 housing to their employees. Because its mission emphasizes providing
                 more in-park visitor services than the other agencies, the Park Service
                 believes that it needs to provide a larger number of its employees with
                 in-park housing. For example, in 1994 we reported that the Park Service
                 had one housing unit for every 5 employees, while the Forest Service had
                 one unit for every 11 employees and the BLM had one unit for every 58
                 employees. Furthermore, when compared with the other agencies, the
                 Park Service’s mix of housing units has relatively more houses, multiplex
                 units, and apartments and relatively fewer dormitories and cabins.
                 Because of this, the Park Service’s housing inventory is more costly to
                 maintain.


                 The Park Service has about 5,200 housing units which include facilities
Background       such as detached single-family homes, multiplexes, apartments, cabins,
                 dormitories, and trailers. These housing units are located in many of the
                 370 parks throughout the country—although about 70 percent of the
                 housing inventory is located in western parks.

                 In accordance with Office of Management and Budget guidance, the Park
                 Service is authorized to provide park housing to seasonal employees in all
                 locations and to permanent employees (1) whose position description
                 requires them to live in the park to provide needed service or protection or
                 (2) when adequate housing in the local community is not available. In
                 November 1996, the Congress passed the Omnibus Parks and Public Lands
                 Management Act of 1996 (P.L. 104-333). This act required the Park Service
                 to review and revise its employee housing policy and conduct a
                 park-by-park assessment of the condition of and need for park housing
                 units. In response to the act, the agency recently modified its housing
                 policy to state that housing will be provided for those not required to live
                 in the park only when all other alternatives have been exhausted.
                 However, Park Service headquarters officials acknowledged that while the
                 agency is taking the steps needed to implement this policy, it may take a
                 few years for the field units to fully comply.


                 2
                  U.S. Department of the Interior Office of the Inspector General, Special Report: Cost of Construction
                 of Employee Housing at Grand Canyon and Yosemite National Parks, National Park Service , (Report
                 No. 97-I-224, Dec. 11, 1996).



                 Page 2                                                                           GAO/T-RCED-98-35
                      Each park that provides housing is required by the Park Service to have a
                      housing management plan. This plan is to identify the park’s need for
                      housing, the condition of housing, and an assessment of the availability
                      and affordability of housing in nearby communities. The agency requires
                      that the parks update their housing management plan every 2 years so that
                      it reflects the current need of the park. Housing management plans are
                      generally approved at the park level by the park superintendent—the
                      senior park official at any park. The plans are not required to be reviewed
                      or approved by agency regional management.


                      In 1993, we reported that the Park Service had not fully justified the need
The Need for          for all of its employee housing. Most park housing is for seasonal
Employee Housing Is   employees, employees at isolated parks such as Yellowstone and the
Not Fully Justified   Grand Canyon, and employees who are required to live in the park to
                      provide needed service or protection such as law enforcement rangers. In
                      1993, these employees accounted for about 4,570 of the agency’s 5,200
                      housing units, and the justifications for these housing units appeared
                      adequate. However, there was little if any justification for the 630
                      remaining housing units for employees located in nonisolated parks who
                      were not required occupants. Some of these housing units were being
                      provided because park managers believed that adequate housing was not
                      affordable in nearby communities. But, in 1993, we found that only 1 of 11
                      nonisolated parks we visited had prepared the required assessments to
                      show that local housing was not affordable. Furthermore, even though
                      park managers at some of these parks felt that adequate housing was not
                      affordable, the surrounding evidence suggested otherwise. Specifically,
                      about 75 percent of the permanent employees at the 11 nonisolated parks
                      were living in nearby communities.

                      In updating this information for this hearing, we found that while there has
                      been some improvement, many of the same problems we found 4 years
                      ago are still evident today. For example, at a recent sample of 15 parks, we
                      found 7 parks did not have a current assessment of the availability or
                      affordability of housing in nearby communities. Park Service headquarters
                      housing officials have raised concerns that many assessments conducted
                      at local parks are not being performed consistently across the agency. In
                      addition, these officials said that most Park Service employees are not
                      technically qualified to conduct assessments of real estate markets.
                      Furthermore, according to these officials, because of the culture, tradition,
                      and past practices of the agency, park managers may not be able to
                      provide an unbiased objective review of the housing needs at any park. As



                      Page 3                                                      GAO/T-RCED-98-35
                      a result, and in response to the requirements of the Omnibus Parks and
                      Public Lands Management Act of 1996, the agency is in the process of
                      issuing a contract to provide an assessment of housing needs within the
                      Park Service. The contractor will review the justification of those
                      considered required occupants, the availability and affordability of
                      housing in nearby communities, and the condition of existing housing
                      facilities within each park. If funding is available, Park Service officials
                      expect that the contract will be completed and implemented by 2002.

                      Once this contracted assessment is completed, the agency should have a
                      more consistent and objective assessment of its housing needs. At that
                      point, agency headquarters and regional staff can use the findings to better
                      hold park managers accountable for their management of each park’s
                      housing program.


                      Today, as in 1993, the Park Service cannot provide detailed support for its
Backlog Estimate Is   backlog of housing needs. In 1993, we reported that the Park Service
Not Based on a        estimated the backlog to be about $546 million—however, at that time, the
Facility Specific     agency was not able to provide support for this figure. The 1993 report
                      recommended that the agency develop a repair/replacement estimate that
Assessment            is supportable. Today, the agency estimates that its housing backlog is
                      about $300 million. However, a Park Service housing official
                      acknowledged that this estimate is not based on a park-by-park review of
                      the condition of housing facilities but rather a gross estimate based on the
                      total number of houses whose condition has been rated less than good.
                      (The condition of park housing units are rated either excellent, good, fair,
                      poor, or obsolete.)

                      The Park Service anticipates that it will soon make some progress towards
                      having a supportable housing backlog figure as this is one of the
                      requirements of the upcoming contracted needs/facilities assessment. In
                      response to the requirements of the Omnibus Parks and Public Lands
                      Management Act of 1996, the contractor, among the other items previously
                      discussed, will be required to provide a detailed condition assessment for
                      each housing facility within the parks reviewed. Once the contractor has
                      reviewed all parks where housing is provided, the agency will have a
                      supportable backlog estimate of its housing needs. The contractor is
                      scheduled to complete its work in 2002—9 years after we raised this
                      problem in our 1993 report.




                      Page 4                                                        GAO/T-RCED-98-35
                       As required by the Omnibus Parks and Public Lands Management Act of
Park Managers Have     1996, the Park Service has reviewed and revised its housing policy. Its new
Broad Discretion in    policy puts greater emphasis on the use of government housing as a last
Managing the Housing   resort after all other alternatives have been exhausted. However, while the
                       policy has changed, it has not yet been implemented by park managers.
Program                Until that happens, the employee housing program will continue as it
                       has—with individual park managers implementing employee housing
                       programs under broad guidelines with little oversight. As a consequence,
                       there is a wide range of employee housing conditions across the national
                       park system and no assurance that housing decisions are being made in
                       the best interests of the Park Service.

                       In the 15 park units we recently surveyed, park managers took a variety of
                       approaches to providing employee housing. Among the sample of parks,
                       we found wide disparities in the quality of the analysis of local housing
                       markets. For example, at Harpers Ferry National Historical Park, the
                       housing management plan provided no analysis of the local housing
                       market. Instead, it simply provided a description of the local situation
                       stating that: “rental units are very difficult to find . . . single income park
                       employees find it difficult to secure adequate housing.” Without
                       supporting analysis, there is no way to determine the validity of this
                       assertion. In comparison, the analysis of local housing markets that
                       accompanied the housing management plan for Santa Monica National
                       Recreation Area was an in-depth analysis prepared by a contractor and
                       exceeded 35 pages. Similarly, at Arches National Park the housing analysis
                       included an in-depth assessment of the local housing market and rental
                       rates as well as an evaluation of the population and economic base of the
                       surrounding area. Furthermore, we found that for 7 of the 15 parks we
                       sampled, assessments of local housing markets were either out of date or
                       had not been done.

                       Another indication of the broad discretion given to individual park
                       managers is how housing units are allocated to employees. Beyond those
                       employees whose position descriptions require them to live in the park,
                       park managers use a variety of methods to determine which employees are
                       provided park housing. These allocation methods include lotteries as well
                       as a variety of ranking systems that give weight to such factors as length of
                       employment, salary, size of family, and number and/or gender of children.
                       The net effect of this is that housing decisions are not made consistently
                       across the national park system.




                       Page 5                                                        GAO/T-RCED-98-35
                        The significance of the broad discretion given to individual park managers
                        is that the potential exists for housing decisions to be made that may not
                        be in the best interest of the agency. This is best illustrated by some recent
                        work done by the Department of the Interior’s Office of the Inspector
                        General at the Grand Canyon. The Interior Inspector General’s Office
                        reported in 1996 that in constructing employee housing at the Grand
                        Canyon, a park manager decided to build 59 single-family houses. At the
                        time of the report, these houses were in the process of being constructed,
                        and many of them had already been completed. According to the report,
                        the decision to build single-family houses was made despite advice from
                        the Park Service regional office and others that building a mix of 114
                        single-family and multi-family units would better address the park’s
                        overcrowded, unsafe, and substandard housing conditions. According to
                        the report, by building the single-family units, approximately 50 permanent
                        and 100 seasonal employees would still be living in substandard housing at
                        the completion of the construction. In responding to this point, the park
                        manager at the Grand Canyon stated that it was never the park’s intention
                        to only build single-family houses and that a mix of multi-family dwellings
                        would be constructed at a later time. Nonetheless, the park manager’s
                        decision has resulted in more employees living in substandard housing
                        units for a greater period of time.

                        Furthermore, in reviewing records concerning the project’s justification
                        for the high quality of materials, the Interior Inspector General reported
                        that the contracted architectural and engineering firm noted that costs
                        would drop significantly “if some of the top-of-the-line items that the Park
                        is insisting on, i.e., doors and windows, could be lowered a notch in
                        quality.” The report stated that this proposal was not studied nor taken by
                        the park. The park’s decision on these matters is difficult to understand
                        when budgets are so tight and the agency is faced with large maintenance
                        backlogs and cutbacks in park services.


                        The Park Service has taken a different approach to employee housing in
Park Service Provides   comparison to BLM and the Forest Service. While all three are responsible
Significantly More      for managing and protecting federal lands, the Park Service provides a
Housing Than the        much larger portion of its employees with housing than the other two
                        agencies. Also, the Park Service’s housing inventory contains
Forest Service or BLM   proportionately more houses, multiplex units, and apartments and fewer
                        dormitories and cabins than the other two agencies. The sheer number
                        and mix of the Park Service’s inventory combine to produce higher initial
                        construction costs and recurring maintenance costs for the agency.



                        Page 6                                                       GAO/T-RCED-98-35
Compared with the Forest Service and BLM, the Park Service mission
emphasizes providing more in-park visitor services such as law
enforcement, search and rescue and other supporting activities. As such,
the Park Service believes that it needs to provide a larger number of its
employees with in-park housing. In 1994, we reported that the Park
Service had 23,908 employees and had about 4,718 housing units or about
one housing unit for every 5 employees.3 In comparison, the Forest Service
had 50,877 employees and 4,402 housing units or about one unit for every
11 employees. BLM had 11,861 employees and 206 housing units or about
one unit for every 58 employees. Another indication of the variance in the
agencies’ housing programs is the extent to which the agencies require
their employees to live on-site. In 1994, the Park Service required about
1,400 employees (about 9 percent of its permanent employees) to live
on-site in park housing to provide necessary visitor services, protect
government property and resources, or both. In marked contrast,
according to agency officials, the Forest Service required about 70
employees—less than 1 percent of its permanent employees—to live
on-site in government housing. BLM had only two employees who were
required to live on-site.

About 75 percent of the Park Service’s housing inventory is composed of
single-family and multiplex units compared with about 50 and 26 percent,
respectively, for the Forest Service and BLM. In part, because of the Park
Service’s mix of housing types, the agency has experienced far higher
repair and rehabilitation costs. For example, in 1993, we reported that the
Park Service estimated a backlog of $546 million for repairs, rehabilitation,
and replacement of its housing inventory; whereas the Forest Service,
having about the same number of units but a different mix, had a backlog
of less than a third of the Park Service. A Park Service official had a
difficult time substantiating the difference beyond the fact that only a
portion of the difference resulted from the agency’s higher rehabilitation
and construction standards and higher costs associated with rehabilitating
units classified as historic structures.

Furthermore, in 1994 we reported that of the three agencies, only the Park
Service plans to replace and upgrade its housing. Although the Forest
Service and BLM do not plan to stop providing housing altogether, both
plan to minimize their involvement in providing housing to employees and
instead rely more upon private sector housing. Among the reasons the
Forest Service and BLM are minimizing housing is that (1) their current

3
 For each agency, the number of agency employees includes seasonal staff and the number of housing
units does not include trailers.



Page 7                                                                        GAO/T-RCED-98-35
           housing inventories were too expensive to maintain, (2) previous
           justifications for providing housing were no longer valid, (3) better roads
           have made it easier for employees to live in nearby communities, and
           (4) employees have shown a preference for living in private residences.


           In closing, the Park Service has been slow to resolve problems that we
           have identified in past reports. It has taken an act of Congress to move the
           agency to review and revise its housing policies and make arrangements to
           determine its need for and condition of its housing inventory. By taking
           these steps, the agency appears to be on the right track toward making
           progress in key areas. However, it’s clear that continued congressional
           attention is needed to ensure that the Park Service is held accountable to
           provide housing only where it is absolutely necessary and appropriately
           justified.

           Mr. Chairman, this concludes my statement. I would be happy to answer
           questions from you or any other Members of the Subcommittee.




(141126)   Page 8                                                      GAO/T-RCED-98-35
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