August 24, 2009

Dear Lodge Members,

By now, you have been made aware of a recent DOI proposal for moving all field law enforcement officers of the BLM, FWS and NPS into an 1801 series position description (PD) under the title of Land Management Officer. At immediate face value, one would be very optimistic at such a change. Over the past two years, the Lodge and NPS WASO have worked together on the best solution for ensuring 6C retirement coverage for law enforcement rangers. A great deal of work has been done by a dedicated WASO staff to provide the law enforcement park ranger staff with position descriptions that are written correctly in respect to actual work duties and are free of conflicting elements which would otherwise prevent park rangers from meeting the 6C standard.

This spring the Lodge testified at a congressional hearing on employee morale, and addressed the issues of recruitment and retention of law enforcement rangers. The lack of a definitive 20-year retirement standard throughout the NPS was cited as a significant factor in poor employee morale. A second contributing factor was haphazard communication with the field about important issues such as changes to RM-9, medical standards, retirement and other matters. The memo posted on InsideNPS, Saturday August 22, 2009, by acting director Wenk shows the lack of coordination and supportive actions between DOI and NPS management. The fact that the acting Director was not briefed prior to the release of the new draft PD covering over 1,700 employees is troublesome to the Lodge board.   A review of the certification shows that key management officials, who hold positions of approval authority, may not have been available at the time that a more thorough review would have been warranted. Sound good judgment might have prevailed especially for the sake of the NPS where the largest number of employees would be affected.

Review of the draft memo is quite alarming.  The law enforcement park ranger staff should be concerned about this document, especially when the main contact person is Michael Gilmore who led FLERT in the denial of more then one third of the Ranger rank’s retirement benefits.  We also find it unsettling that the draft policy states in its purpose that the PD will assist in the recruitment, training, development, and retention of land management law enforcement personnel, but yet no where in the draft memo or PD’s does it state how it will do this.    In the past the Lodge has advocated transferring law Enforcement Park rangers into the 1800 series, as it is a professional series and more geared to the law enforcement and investigation work we do, than the 025 series. The choice of the 1801 series is a curious one, as the majority of agencies utilizing the 1801 series, place non-6C covered Inspectors in the 1801 series. The new PD is certified as meeting 6C coverage, but there is nothing that addresses what happens to a ranger’s prior 6C coverage under the 0025 series PD, which is rescinded when a ranger is placed in a new PD.  This may lead to yet another battle with FLERT involving the approval of our coverage under the 025 series since 1994.   The Lodge has always advocated that our prior coverage under the 025 PD be guaranteed should we be moved to another series.

It is still too early for the Lodge board to make or issue a definitive statement about the PD change nor do we have enough information to make an informed recommendation to our membership at this time.   The Lodge board is still taking comments, concerns, and questions about the new PD’s. We encourage members to contact rangers in other DOI bureaus to see if those bureaus have additional information, and forward it to the Lodge.  In the meantime, the Lodge will continue to attempt to make further contacts with DOI and gain more information before we come to any decisive conclusions.  

The 6C issue is the number one priority of the Lodge, and we will continue to work on a legislative solution to guarantee 6C coverage for law enforcement positions. We will continue to work with NPS WASO on solutions for this and other matters.  I encourage all of our Lodge members to continue to send your emails of concerns and questions to me and to check in at the Lodge Website for any updates.

 Fraternally,

 John T. Waterman

 President