National Park Service: Concerns About the Implementation of Its Employee Housing Policy

Published by the Government Accountability Office on 1999-03-17.

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, Committee on Appropriations, House of

For Release
on Delivery
Expected at
                    NATIONAL PARK SERVICE
9:00 a.m. EST
March 17, 1999
                    Concerns About the
                    Implementation of Its
                    Employee Housing Policy
                    Statement of Barry T. Hill, Associate Director,
                    Energy, Resources, and Science Issues,
                    Resources, Community, and Economic
                    Development Division

    Mr. Chairman and Members of the Subcommittee:

    We are here today to discuss the National Park Service’s housing program.
    The Park Service provides housing for its employees when either
    (1) affordable housing is not generally available or (2) staff are needed so
    that they can be available to respond to after-hours incidents within the
    park. Within the agency, the housing program involves a large financial
    commitment. Over the past 10 years, the agency has spent about
    $175 million on employee housing. In addition, the agency currently has
    almost $20 million in unspent construction funding that it plans to use to
    address current housing needs. Furthermore, the Park Service estimated
    that it needs about another $300 million to repair and replace some of its
    existing housing inventory.

    In October 1997, we testified before this Subcommittee about the Park
    Service’s management of this program. At that hearing, the Park Service
    committed to improve its housing program by (1) revising its housing
    policy and (2) conducting a park-by-park assessment of its need for
    employee housing. You asked us to assess what progress the agency has
    made since that time. Our response is centered on two questions: (1) what
    did the Park Service do as a result of the Omnibus Parks and Public Lands
    Management Act of 1996—one purpose of which was to move the agency
    to eliminate unnecessary government housing and rely more on the private
    sector to supply housing for employees, and (2) what impact is that action
    likely to have?

    In summary,

•   The Park Service carried out both actions that it committed to in
    October 1997. In November 1997, it issued a revised housing policy.
    Generally, the revised policy permits the agency to provide housing under
    two situations: (1) to assure timely responses to park emergencies and
    (2) where parks are located in remote areas or in areas where affordable
    housing is not available. This policy was aimed at minimizing the amount
    of employee housing it provides—which was consistent with the goals of
    the 1996 law. In 1997, the Park Service also began a park-by-park housing
    needs assessment to determine the number of housing units needed under
    the new policy. In order to ensure that this assessment was independent
    and objective, the agency hired two contractors to perform the
•   The contractors’ park-by-park assessments found that the Park Service
    had 522 more housing units than it needed. However, in reviewing the

    Page 1                                                     GAO/T-RCED-99-119
             contractors’ assessments, park managers and regional officials disagreed
             with the contractors’ findings and concluded that 760 more units than they
             now have were needed—a difference of 1,282 units. This wide divergence
             of opinion about how much housing the agency should provide reflects
             many park managers’ fundamental disagreement with the revised housing
             policy. The disagreement with Park Service policy by park managers raises
             serious concerns about the credibility of future Park Service housing
             initiatives and any funding requests that the agency might have for
             providing employee housing.

             The Park Service provides nearly 5,300 housing units for its employees.
Background   These include such facilities as detached single-family homes, multiplexes,
             apartments, cabins, dormitories, trailers, and trailer pads. These housing
             units are located in over 200 of the 378 parks throughout the
             country—mostly in the West.

             The amount and condition of Park Service housing has been a matter of
             concern for some time. In 1993 and 1994, we reported that the Park
             Service (1) had not fully justified the need for all of its employee housing
             units and that many of its housing units were badly deteriorated and
             (2) had not developed a strategy for minimizing its housing inventory.1 It is
             important that the agency understand its need for housing so that it can
             justify requests to Congress for funding housing repairs or construction. In
             November 1996, the Congress enacted legislation, the Omnibus Parks and
             Public Lands Management Act of 1996. This law required the Park Service
             to review and revise its employee housing policy and conduct a
             park-by-park assessment of housing needs and condition. One purpose of
             the law is to move the agency to eliminate unnecessary government
             housing and rely more on the private sector to supply housing for
             employees in order to reduce the need for federal appropriations. The law
             also provided park managers with additional authorities for working with
             the private sector to help address park housing needs.

             The Park Service’s response to concerns about the amount and condition
             of Park Service housing has been slow in coming. In our October 1997
             testimony before this Subcommittee, we reported that the Park Service’s
             assessment of housing needs was not scheduled to be completed until

               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 2                                                                      GAO/T-RCED-99-119
                     2002—9 years after we first recommended such assessments.2 In response
                     to concerns raised by this Subcommittee in October 1997, the Park Service
                     Director committed to (1) finalizing a revised housing policy and
                     (2) completing a housing needs assessment by October 1998.

                     The Park Service has met both of its commitments that it made to the
Housing Policy Has   Subcommittee in October 1997. In November 1997, the Park Service issued
Been Revised and     a revised housing policy. This policy’s stated goal is for parks to have the
Housing Needs Have   minimum number of housing units they need to meet their mission, which
                     is consistent with the goals of the 1996 legislation. The new policy calls for
Been Assessed        the Park Service to rely on the private sector to provide housing for its
                     employees to the maximum extent practical and for government housing
                     to be provided only after all other alternatives have been exhausted.
                     Generally, the policy permits the agency to provide in-park housing under
                     two situations: (1) to assure timely responses to park emergencies and
                     (2) where parks are located in remote areas or in areas where affordable
                     housing is not available. In addition, housing can be provided under
                     certain other circumstances. For example, parks may house volunteers
                     and other unpaid staff when excess housing units are available.

                     Also in November 1997, the Park Service awarded contracts for a total
                     cost of about $1.9 million to two firms to conduct park-by-park
                     assessments of the need for housing. Park Service officials said that they
                     used contractors rather than conducting their own internal analysis
                     because the agency wanted to obtain a consistent and objective review of
                     housing needs, and because park staff generally do not have the expertise
                     needed to properly analyze local real estate markets. Park Service officials
                     were concerned that the culture, traditions, and past practices of on-site
                     park managers would affect their ability to perform an objective analysis
                     of their parks’ employee housing needs. In addition, the Park Service
                     officials believed that the contractors would add to the process their
                     expertise in assessing the availability and affordability of housing in areas
                     surrounding parks.

                     The contractors’ assessments were conducted by applying the agency’s
                     housing policy to individual parks. Specifically, the contractor determined
                     how many housing units a park needed (1) to assure timely responses to
                     park emergencies and/or (2) because the park was located in remote area
                     or in an area where affordable housing was not available. The two
                     contractors conducted 145 park assessments—primarily at parks with 5 or

                      National Park Service: Employee Housing Issues (GAO/T-RCED-98-35, Oct. 29, 1997).

                     Page 3                                                                      GAO/T-RCED-99-119
                     more housing units.3 The contractors did not include trailers, trailer pads,
                     tents, and temporary housing in their assessment because the agency is
                     trying to minimize putting employees in these types of units. The agency
                     currently has about 900 of these types of units. The 145 parks assessed by
                     the contractors contained about 4,250 of the agency’s 4,400 housing units,
                     or about 97 percent. The contractors completed their assessments in
                     November 1998.

                     The contractors’ assessments included recommendations to the agency for
                     the minimum number of housing units needed at each park. After the
                     assessments were completed, the agency permitted individual park
                     managers to review the contractors’ work and determine their own
                     minimum number of housing units needed for their parks. According to
                     Park Service officials, because park managers are responsible and
                     accountable for the areas they manage, they were allowed to make
                     changes to the number of minimum housing units needed at their parks.
                     Once park managers determined their parks’ housing needs, their revised
                     numbers were reviewed by the agency’s regional directors.

                     While the Park Service has followed through in its commitment to revise
Implementation of    its housing policy and assess its need for park employee housing, its
New Housing Policy   implementation of these initiatives may not lead the agency to effectively
May Not Lead to      achieving the purposes of the 1996 law. In fact, after spending about
                     $1.9 million for getting an independent assessment of its housing needs,
Intended Reforms     the agency may be in no better position to justify its housing inventory
                     than before the recent initiatives began. Our concerns about the
                     implementation of the agency’s initiatives focus on two areas:
                     (1) significant differences between the contractors’ assessment of the
                     amount of housing needed under the agency’s new policy, and what park
                     managers believe they need, and (2) little response to pursuing and
                     implementing alternatives to in-park housing. The financial impact of not
                     implementing the agency’s housing policy are significant as the agency
                     estimated in 1998 that about $300 million was needed to address deferred
                     maintenance and replacement of its housing inventory.4

                      A few of the contractors’ needs assessments included more than one park. This was done where park
                     units were either jointly managed or located in close proximity to each other. As a result, the 145 park
                     assessments included 152 parks.
                      The Park Service reported these estimates in February 1998—before the contractors had completed
                     the housing needs assessments.

                     Page 4                                                                           GAO/T-RCED-99-119
Contractors’assessments   The contractors’ assessments showed that under the housing policy, the
Show Too Much Housing;    Park Service had 522 more housing units that it needs. At nearly
Park Managers Believe     three-fourths of the parks assessed (106 of 145), the contractor found the
                          parks had too much housing with the excess totaling 1,072 housing units.
More Housing Is Needed    Twenty-eight parks were assessed as having too little housing, with a total
                          shortage of 550 units. The remaining 11 parks had the proper amount of

                          After park managers were permitted to determine their own parks’
                          minimum housing needs, a much different picture emerged. Instead of
                          having too much housing, park managers indicated that the agency needs
                          760 more housing units than it currently has—about 18 percent of the
                          assessed parks’ housing inventory. Specifically, these managers believe
                          that 37 parks have too much housing, 64 parks need more housing, and 44
                          parks had the proper amount of housing. According to revisions made by
                          park managers and reviewed by regional directors, the number of excess
                          housing units dropped from 1,072 to 165, and the number of units needed
                          at parks with housing shortages rose from 550 to 925. In all, the total
                          difference between the contractors’ assessments and the park managers’
                          revisions amounted to 1,282 units—about 30 percent of the assessed parks’
                          inventories. Figure 1 summarizes the differences.

                          In commenting on a draft of this testimony, Park Service officials indicated
                          that much of the difference between the contractors’ numbers and the
                          park managers’ numbers was due to the number of historic structures
                          currently used as housing units. In their view, many of these historic
                          structures may not be needed as housing, but they nonetheless must be
                          preserved and maintained by the parks. According to these officials, using
                          them to house employees is in many cases the best option available to
                          park managers. While the use of historic structures does account for some
                          of the difference between the numbers of the contractors and park
                          managers, agency data indicates it likely accounts for less than 20 percent
                          of this difference.

                          Page 5                                                     GAO/T-RCED-99-119
Figure 1. Contractors’ Assessments of
Housing Units Needed Under the New
Housing Policy Versus Park Managers’
Assessments of Housing Needs

                                            Our analysis showed that the major difference between the two
                                            assessments was that the park managers did not assess their housing
                                            needs consistent with the Park Service’s housing policy. As part of our
                                            work, we visited 10 parks to discuss the results of their housing needs
                                            assessments. (App. I lists the park units we visited.) Most of the reasons
                                            given by the park managers for the disparity between their analysis and
                                            the contractors’ assessments were not consistent with the agency’s
                                            housing policy. Most of the reasons given by park managers for the need
                                            to provide more housing fell into the following three categories:

                                        •   providing housing to volunteers or other unpaid staff,
                                        •   providing housing to deter crimes against park visitors or park resources,
                                        •   more than doubling the number of housing units needed for staff
                                            designated to respond to after-hours incidents.

                                            Page 6                                                     GAO/T-RCED-99-119
The following examples demonstrate what we found.

Housing for volunteers or unpaid staff. The current housing policy allows
volunteers or other unpaid staff working in a park to occupy in-park
housing as long as the housing is not needed for park employees.
However, many park managers were providing housing to volunteers and
unpaid staff even though the housing was not considered excess.
Furthermore, many park managers told us that while providing this
amount of housing may not be consistent with the agency’s housing policy,
they believed that the significant contributions made by volunteers and
other unpaid staff justified the costs of providing them with housing. At
the 145 parks assessed, about 830 housing units—or about 20 percent of
these parks’ inventories—are currently occupied by volunteers and other
unpaid staff.

For example, in Rocky Mountain National Park in Colorado, the
contractor’s assessment indicated that under the current housing policy,
the park had an excess of 18 housing units. However, park officials
disagreed with this assessment. Officials at the park believe that they need
to increase their housing by 22 units in order to, among other things, retain
20 housing units for volunteers and other unpaid staff. Park officials also
indicated that they would like to provide housing for more volunteers.

Deterring crime. The Park Service’s housing policy does not recognize
deterrence as a reason to provide in-park housing where it is otherwise
available. Nonetheless, several parks we visited justified additional
housing beyond the contractors’ assessments on the basis of providing a
deterrence to crimes against park resources. For example, at Prince
William Forest Park in Virginia, the contractor’s assessment indicated that
the park did not need to provide any housing to its staff. However, the
park manager decided to retain three park rangers in park housing in
order to provide a deterrent to crimes against park facilities or resources.

Increasing the number of housing units for staff needed to respond to
after-hours incidents. The revised housing policy states that providing
housing for staff needed to respond to emergencies is a criterion that can
be used to justify housing. Accordingly, in performing the needs
assessments, the contractors determined the number of housing units
needed for staff at each park to respond to after-hours incidents. The
methodology used by the contractors in doing these assessments were
approved by the Park Service and based on a review of the frequency and

Page 7                                                     GAO/T-RCED-99-119
nature of after-hours incidents, as well as individual circumstances that
could affect needs at each park. For example, some parks maintain their
own fire departments while others do not. However, some parks managers
increased the number of housing units needed for staff to address
after-hours incidents—far beyond the number of units suggested in the
contractors’ assessments.

For example, at Yosemite National Park, the contractor determined that,
based on agency criteria, the park needed 69 units for staff to respond to
after-hours incidents. However, in revising the results of the contractor’s
assessment, park managers more than doubled this number to 175 housing
units. They did this in order to have what they thought was an acceptable
number of employees who could be called back to duty during the middle
of the night, when there are typically no staff on duty, or during unusually
busy periods of the day. The park managers indicated that the park needed
the additional 100-plus housing units because it was difficult to get staff to
respond to after-hours incidents. These managers said that the park
normally must call about four off-duty law enforcement staff or other staff
in order to get one to respond to an after-hours incident. The Yosemite
park managers’ views are not consistent with the direction of the Park
Service’s policy that encourages parks to minimize its employee housing.
In this case, there may be other options for the agency to address its
after-hours needs other than providing this amount of housing—for
example through using shift work to cover the off-duty period.

These factors help explain much of the disparity between the results of the
contractors’ assessments and the views of park managers. Moreover, there
is some evidence to suggest that park managers have not accepted the new
housing policy or the need to minimize the agency’s housing inventory. A
recent study by senior park managers provides evidence of this. At the
request of the Director of the Park Service, several of the agency’s most
senior park managers formed a task force to review key issues associated
with the contracted needs assessment. In October 1998, the task force
presented an internal report to the Director of the Park Service.5 The first
issue discussed in that report was whether the housing needs assessment
was trying to “address a problem that does not exist.” The report stated
that “We have seen no accurate description of the problem that the
Service set out to address through the contractor’s process.” It also states
that by assessing the housing needs of the parks, “we could be needlessly
and unnecessarily going about a mission that does not need to be done.”

 This report is the final reporting document from the task force reviewing the housing needs
assessment process. This report has been marked “draft” for the agency’s continued internal review.

Page 8                                                                         GAO/T-RCED-99-119
                          This report indicates that senior park managers were not aware or
                          convinced of the agency’s objectives in performing the housing needs

                          Overall, the wide disparity between the contractors’ assessments and the
                          views of park managers raises questions about how much housing the
                          agency really needs including whether the agency needs all of the
                          $300 million it has identified for repairing and replacing it’s current
                          housing inventory. For example, in February 1998, the agency estimated
                          that part of the $300 million in housing needs was $180 million to replace
                          about 460 trailers used for employee housing with newly constructed
                          housing units.6 Based on our work, we question the agency’s ability to
                          justify construction of new employee housing until it fully implements its
                          new housing policy.

Parks Have Not Pursued    Another way to help accomplish the Park Service’s policy of minimizing its
Alternatives That Would   employee housing inventory is to pursue other options to in-park housing
Reduce Housing Needs      such as (1) moving administrative functions outside of parks to nearby
                          communities which have affordable housing, (2) leasing or purchasing
                          private residences in communities and renting them to employees at rates
                          similar to in-park housing, or (3) working with private developers to build
                          apartments or other dwellings. Consideration of these and other
                          alternatives is required by current policy and consistent with the purposes
                          of the Omnibus Parks and Public Lands Management Act of 1996.7
                          Pursuing these kind of housing alternatives would not only be consistent
                          with the agency’s housing policy, it could also help preserve park
                          resources as fewer facilities would need to be located inside parks.
                          However, none of the parks we visited could provide us examples where
                          they had pursued and implemented alternatives to in-park housing. In
                          addition, only one example of a park implementing an alternative to
                          in-park housing was provided by officials at the 2 regional offices we
                          visited. (These two regions contained over half of the agency’s housing
                          inventory.) Furthermore, agency headquarters housing officials were
                          aware of less than 5 examples where parks that had implemented some
                          alternatives to in-park housing—although they acknowledged that parks
                          would not necessarily alert headquarters staff on the details of their
                          pursuit of alternatives.

                           In commenting on a draft of this testimony, Park Service officials indicated that they now have 367
                          trailers. Agency officials indicated that not all of these trailers will be replaced. However, they could
                          not provide details on the locations of the trailers that would be replaced or at what cost.
                           P.L. 104-333.

                          Page 9                                                                              GAO/T-RCED-99-119
                  While agency officials acknowledge that more could be done to reduce the
                  amount of housing provided through implementing alternatives, they also
                  indicated that there is frequently no incentive for park managers to pursue
                  alternatives to in-park housing. Frequently there is a disincentive to
                  implementing alternatives, as the funding for many alternatives would
                  come from park operating budgets. Thus, under current circumstances,
                  alternatives to park housing compete for funding against all other park
                  operating needs. For example, the cost to lease administrative space in a
                  nearby community that has affordable housing would come from park
                  operating budgets. In contrast, funding for the construction of in-park
                  housing does not come out of park operating funds but rather the agency’s
                  construction program. As such, the funds for the construction of park
                  housing are a supplement to the funds parks receive for operating needs.
                  This is important because some alternatives may actually be less
                  expensive to the agency than constructing and maintaining in-park
                  housing. However, because they would use operating funds, there is no
                  incentive for park managers to pursue alternatives that could result in cost

                  We provided copies of a draft of this testimony to Park Service and
Agency Comments   Department of the Interior officials for their review and comment.

                  The Director of the Park Service commented that while he agrees with
                  some of the points in our testimony, he disagrees with our conclusion that
                  the employee housing policy is not being implemented. He commented
                  that the agency still needs time to work through the differences between
                  the contractors’ findings and the determinations made by park managers
                  to decide whether they need to modify their housing policy. In our view,
                  while the agency is still in the process of implementing its employee
                  housing policy, we are concerned that the approach being used by the
                  agency in determining its actual housing needs may result in a larger
                  housing inventory than suggested by its policy. Furthermore, to the extent
                  any revisions to the current housing policy are made, they need to be
                  consistent with the purposes of the Omnibus Parks and Public Lands
                  Management Act of 1996. The Park Service also provided us with technical
                  and clarifying comments, which have been incorporated into this
                  testimony as appropriate.

                  We also discussed the draft with the Housing Officer for the Department of
                  the Interior. The Department monitors and oversees the employee housing
                  programs of all Interior agencies including the Park Service. He agreed

                  Page 10                                                    GAO/T-RCED-99-119
with the thrust and findings of our analysis, and said that the
implementation of the Park Service’s housing policy would result in a
smaller housing inventory and, accordingly, reduced costs over the

In closing, Mr. Chairman, it has taken an Act of Congress to move the
agency to revise its housing policies and make arrangements to determine
its need for its housing inventory. However, while the Park Service has
taken these steps, many park managers appear to be resisting the agency’s
new housing policy. In addition, the agency may be compromising the
benefits it obtained from its contractors’ needs assessments if it permits
park managers to determine their own parks’ needs for housing. These
factors, combined with the absence of park managers’ initiatives in
pursuing alternatives to in-park housing, raise questions to us about
whether the agency is positioning itself to meet its housing needs in the
most efficient and effective way. If the agency implements its policy, then
its housing inventory will be reduced and the costs associated with
providing housing will decrease. If, on the other hand, the agency does not
implement its policy, then the number of housing units and the costs
associated with the agency’s housing program are likely to increase.
Furthermore, until this situation is resolved, any future funding request to
Congress for additional in-park housing would be questionable.

Page 11                                                    GAO/T-RCED-99-119
Appendix I

Park Units Visited by GAO

               Park unit                                        Location
               Gettysburg National Military Park                Pennsylvania
               Golden Gate National Recreation Area             California
                                                                West Virginia, Maryland and Virginia
               Harpers Ferry National Historical Park
               Mount Rainier National Park                      Washington
               Olympic National Park                            Washington
               Prince William Forest Park                       Virginia
               Rocky Mountain National Park                     Colorado
               Sequoia and Kings Canyon National Parks          California
                                                                Wyoming, Montana, and Idaho
               Yellowstone National Park
               Yosemite National Park                           California
               Note: Sequoia National Park and Kings Canyon National Parks are jointly managed by the same
               superintendent and for the purposes of our work were considered one park unit.

(141255)       Page 12                                                                   GAO/T-RCED-99-119
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