National Park Service: Concerns About the Implementation of Its Employee
Housing Policy (Testimony, 03/17/99, GAO/T-RCED-99-119).

The Park Service provides housing for its employees when either
affordable housing is not generally available or staff must be available
to respond to after-hours incidents within a park. The Park Service's
housing program entails a significant financial commitment. During the
past 10 years, the agency has spent about $175 million on employee
housing. In addition, the agency now has almost $20 million in unspent
construction funding that it plans to use for current housing needs. The
Park Service estimates that it needs about another $300 million to
repair and replace some of its existing housing inventory. This
testimony discusses (1) what the Park Service did in response to 1996
legislation directing the agency to eliminate unnecessary government
housing and rely more on the private sector to supply housing and (2)
the likely impact of that action.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-RCED-99-119
     TITLE:  National Park Service: Concerns About the Implementation
	     of Its Employee Housing Policy
      DATE:  03/17/99
   SUBJECT:  National parks
	     Federal employees
	     Housing programs
	     Cost control
	     Housing
IDENTIFIER:  NPS Housing Plan

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Cover
================================================================ COVER

Before the Subcommittee on Interior and Related Agencies, Committee
on Appropriations, House of Representatives

For Release
on Delivery
Expected at
9:00 a.m.  EST
Wednesday
March 17, 1999

NATIONAL PARK SERVICE - 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

GAO/T-RCED-99-119

GAO/RCED-00-119T

(141255)

Abbreviations
=============================================================== ABBREV

============================================================ Chapter 0

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 providesï¿½which 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 assessment. 

  -- The contractors' park-by-park assessments found that the Park
     Service had 522 more housing units than it needed.  However, in
     reviewing the contractors' assessments, park managers and
     regional officials disagreed with the contractors' findings and
     concluded that 760 more units than they now have were neededï¿½a
     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. 

   BACKGROUND
---------------------------------------------------------- Chapter 0:1

The Park Service provides nearly 5,300 housing units for its
employees.  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 countryï¿½mostly 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 2002ï¿½9 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. 

--------------------
\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). 

\2 National Park Service:  Employee Housing Issues (GAO/T-RCED-98-35,
Oct.  29, 1997). 

   HOUSING POLICY HAS BEEN REVISED
   AND HOUSING NEEDS HAVE BEEN
   ASSESSED
---------------------------------------------------------- Chapter 0:2

The Park Service has met both of its commitments that it made to the
Subcommittee in October 1997.  In November 1997, the Park Service
issued a revised housing policy.  This policy's stated goal is for
parks to have the 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 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
assessmentsï¿½primarily at parks with 5 or 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. 

--------------------
\3 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. 

   IMPLEMENTATION OF NEW HOUSING
   POLICY MAY NOT LEAD TO INTENDED
   REFORMS
---------------------------------------------------------- Chapter 0:3

While the Park Service has followed through in its commitment to
revise its housing policy and assess its need for park employee
housing, its implementation of these initiatives may not lead the
agency to effectively achieving the purposes of the 1996 law.  In
fact, after spending about $1.9 million for getting an independent
assessment of its housing needs, 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

--------------------
\4 The Park Service reported these estimates in February 1998ï¿½before
the contractors had completed the housing needs assessments. 

      CONTRACTORS'ASSESSMENTS SHOW
      TOO MUCH HOUSING; PARK
      MANAGERS BELIEVE MORE
      HOUSING IS NEEDED
-------------------------------------------------------- Chapter 0:3.1

The contractors' assessments showed that under the housing policy,
the Park Service had 522 more housing units that it needs.  At nearly
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.  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 housing. 

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 hasï¿½about 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 unitsï¿½about 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. 

   Figure 1.  Contractors'
   Assessments of Housing Units
   Needed Under the New Housing
   Policy Versus Park Managers'
   Assessments of Housing Needs

   (See figure in printed
   edition.)

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, or

  -- more than doubling the number of housing units needed for staff
     designated to respond to after-hours incidents. 

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 unitsï¿½or about 20 percent of these parks'
inventoriesï¿½are 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 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
incidentsï¿½far 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 housingï¿½for 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 ï¿½address a problem that does not
exist.ï¿½ The report stated that ï¿½We have seen no accurate description
of the problem that the Service set out to address through the
contractor's process.ï¿½ It also states that by assessing the housing
needs of the parks, ï¿½we could be needlessly and unnecessarily going
about a mission that does not need to be done.ï¿½ This report indicates
that senior park managers were not aware or convinced of the agency's
objectives in performing the housing needs assessment. 

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. 

--------------------
\5 This report is the final reporting document from the task force
reviewing the housing needs assessment process.  This report has been
marked ï¿½draftï¿½ for the agency's continued internal review. 

\6 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. 

      PARKS HAVE NOT PURSUED
      ALTERNATIVES THAT WOULD
      REDUCE HOUSING NEEDS
-------------------------------------------------------- Chapter 0:3.2

Another way to help accomplish the Park Service's policy of
minimizing its employee housing inventory is to pursue other options
to in-park housing 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 housingï¿½although they
acknowledged that parks would not necessarily alert headquarters
staff on the details of their pursuit of alternatives. 

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 savings. 

--------------------
\7 P.L.  104-333. 

   AGENCY COMMENTS
---------------------------------------------------------- Chapter 0:4

We provided copies of a draft of this testimony to Park Service and
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 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 long-term. 

-------------------------------------------------------- Chapter 0:4.1

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. 

PARK UNITS VISITED BY GAO
=========================================================== Appendix I

Park unit                                 Location
----------------------------------------  ----------------------------
Gettysburg National Military Park         Pennsylvania

Golden Gate National Recreation Area      California

                                          West Virginia, Maryland and
Harpers Ferry National Historical Park    Virginia

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. 

*** End of document. ***