National Park Service's Draft Shutdown Contingency Plan

In this draft guidance, sent to National Park Service officials across the U.S. Wednesday, Interior outlined how they could maintain significant public access to parks even during a lapse in appropriations. Access should continue unless it "presents a serious and imminent threat to human life, safety or health, or a serious and imminent threat to the condition of a sensitive natural or cultural resource.

Updated 01.17.17

DRAFT
Pre?decisional Internal Discussion Only

NATIONAL PARK SERVICE CONTINGENCY PLAN
January 2018

As stated in its original authorizing legislation, the purpose of the National Park Service is to
?conserve the scenery and the natural and historic objects and the wild life therein and to provide
for the enjoyment of the same in such manner and by such means as will leave them unimpaired
for the enjoyment of future generations.?

Effective immediately upon a lapse in appropriations, the National Park Service will take all
necessary steps to close and secure nationalpark facilities in order to suspend all activities
except for those that are essential to respond to emergencies involving the safety of human life or
the protection of property. Upon receiving the closure order, parks must notify visitors that the
NPS will cease providing visitor services, including restrooms, trash collection, facilities and
roads maintenance (including plowing), campground reservation and
services, backcountry and other permits, and public information. Visitors utilizing NPS-operated
campgrounds should be cautioned that no services will be available should they wish to remain
in their campsites. National and regional of?ces and support centers will be closed and secured,
except where they are needed to support excepted personnel. These steps will be enacted as
quickly as possible while still ensuring visitor and employee safety as well as the integrity of
park resources. .

Once the shutdown is initiated employees should proceed with shutdown activities, including
notifying the public of the cessation of operations and securing government records and property.
Non-excepted employees will generally have 4 hours to complete their shutdown activities
before entering furlough status. The entire closure process will be completed as expeditiously as
possible: operations and staffmg numbers are expected to be at the minimum levels defined
below within two days. I

Part 1: Designation of Essential and Continuing Programs/Activities

The Emergency Response Of?cial designation on a Federal ID card is not necessarily a factor in
determining excepted personnel. Rather, as de?ned by the Department of the Interior, essential
activities and activities that will continue during a lapse in appropriations are:

0 Providing for ?nance and contracting activities such as bene?t payments and actions
necessary to suspend or step work on projects currently underway that require oversight
or support from employees ?mded from lapsed appropriations. That is, contracting and
?nance personnel necessary to perform these duties should remain until the activities can
be suspended.

0 Direct management of projects obligated from ?nds that are not subject to lapse, such as
multi-year appropriations from prior ?scal years. People not DIRECTLY involved in

Updated 01.17.17

project management or necessary contracting actions and payments for these projects will
not be considered excepted or continue to work.

- Protecting life and property, including;

0 Law enforcement and Emergency Response (commensurate with a reactive rather
than proactive posture see Visitor Services section of this plan for further
information);

0 Border and coastal protection and surveillance;

0 Protection of federal lands, buildings waterways, equipment and other property
within the National Park System;

0 Activities essential to. ensure continued public health and safety, including safe
use of food and drugs and safe use of hazardous materials, drinking water, and
sewage treatment operation,

Activities that ensure production of power and maintenance of the power
distribution system;

Activities necessary to maintain protection of research property;

Essential or time-sensitive support services for employees;

Uninterrupted command, control, and policy leadership;

Maintenance of IT systems critical to activities being carried out by excepted
personnel radio communication, e-mail, accounting systems, etc.); and
0 Communication with employees and the public.

0000

NOTE: Staf?ng will be held to the very minimum to perform essential functions. This will
ordinarily be only law enforcement personnel, at a staf?ng level that allows for reactive
emergency response commensurate with levels of park Operations under the shutdown. Staf?ng
levels will be based on the assumption that no visitor services will be provided. While parks
may still be accessible to visitors, parks may not use the presence of visitors in the park to justify
higher staf?ng numbers than approved during previous shutdowns. However, in certain instances
maintenance and IT personnel may be required for systems that normally require 24 hour
monitoring or periodic maintenance, without which the system would shut down. Emergency
responders, including Fire Management, EMS, and Law Enforcement personnel, not required for
essential activities will'be placed on furlough but may be called back to duty if an emergency
situation arises.

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Headquarters

In order to complete the required, essential activities de?ned above, the NPS Washington
Support Of?ce (N PS Headquarters) will retain key NPS leaders, as well as a bare minimum
number of employees in policy coordination, comrriunication, human resources, contracting,
?nance, and budget roles. NPS leaders remaining on duty will include the Director, Deputy
Director for Operations, Deputy Director for Management and Administration, and the

Comptroller. Total excepted and continuing staff is estimated to be no more than 50 full-time
employees.

Regional Of?ces

Updated 01.17.17

The National Park Service?s seven regional of?ces play key roles in policy direction and
coordination between the Washington of?ce and individual national park sites. During the
shutdown process, the regional leaders of law enforcement, administration, budget, contracting,
public affairs, and concessions management will remain on duty to implement the closure
guidance. Once the shutdown is complete, each region will retain approximately three full?time
staff members to conduct essential activities, disseminate information, both internally and

externally, and ensure continued shutdown coordination and communication between
Washington and the ?eld.

National Park Sites

Due to the dramatic differences in Operations, size, visitation, location, and infrastructure
represented in national park sites, the number of employees required to carry out the essential
activities de?ned above will vary greatly from site to site. As a rule, staf?ng will be held to the
very minimum for the protection of life, property, and public health and safety. Staf?ng levels
will be based on the assumption that the NPS is conducting no park operations and providing no
visitor services. While parks may still be accessible to visitors, parks may not use the presence
of visitors in the park to justify higher staf?ng numbers than approved during previous
shutdowns. Only personnel absolutely required to support the essential activities listed above
will remain on duty. Wildland ?re personnel required for active ?res or for monitoring areas
currently under a ?re watch will remain on duty. All other personnel, including maintenance,
law enforcement, EMS, and Fire Management not deemed excepted will be furloughed, but will
be subject to being called back in the case of an emergency. Parks may not exceed the staf?ng
number approved during the October 2013 shutdown unless a partner is willing to provide
payment in advance (as a donation) to support additional staff. See below for employee counts
by region.

Other Of?ces

The NPS maintains?two project management support centers for large?scale projects one in
Harper?s Ferry, WV and one in Denver, CO. Many of the projects managed through these
centers are funded through multi-year appropriations. However, even if an employee?s salary is

funded from carryover or a multi-year appropriation, they are not automatically excepted from a

furlough. Only employees conducting essential activities as de?ned above will be deemed
?excepted.? Employees funded from multi-year appropriations typically rely on facilities and
support staff who are funded by expiring appropriations, and thus managers will designate
exceptions and furloughs based solely on whether an employees? activities are essential or not.
Employees at these locations necessary for DIRECT project management of ongoing projects
funded by multi-year appropriations will remain on duty.

Visitor Services

- Park roads, lookouts, trails and open-air memorials will generally remain accessible to
visitors, but there will be no NPS?provided visitor services, including restrooms, trash
collection, facilities and roads maintenance (including plowing), and public information.

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Updated 01.17.17

- All NPS-managed property and facilities that can be locked or secured will be closed,
including visitor contact stations, restrooms and comfort stations, and fee collection
facilities.

- As a general rule, if a facility or area is locked or secured during non-business hours
(buildings, gated parking lots, etc.) it should be locked or secured for the duration of the
shutdown.

The NPS will not operate parks during the shutdown no visitor services will be
provided. The NPS will not issue permits, conduct interpretive or educational programs,
collect trash, operate or provide restrooms, maintain roads or walkways (including
plowing and ice melting), or provide visitor information.

If visitor access becomes a safety, health or resource protection issue (weather, road
conditions, resource damage, garbage build-up to the extent that it endangers human
health or wildlife, etc.), the area must be closed. Parks may not bring on additional staff
to accommodate visitor access.

- The NPS will cease providing'services for NPS-operated campgrounds, including
maintenance, janitorial, bathrooms, showers, check-in/check-out and reservations.
Visitors in campgounds will not be asked to leave but should be advised that no services
will be available. In addition, visitors holding campground reservations for a later date
will be advised that the NPS is not operating campgrounds, including providing check-
in/check-out services during a shutdown. There is no guarantee their reserved campsite
will be ready and available should they arrive during a government shutdown.

Park websites and social media will not be maintained. Parks will not provide regular
road or trail condition updates. Signs will be posted that no visitor services, maintenance
or other management activities will be conducted, and emergency and rescue services I
will be limited.

At the superintendent?s discretion, parks may close grounds/areas with sensitive natural,
cultural, historic or archaeological resources vulnerable to destruction, looting or other
damage that cannot be adequately protected by the excepted law enforcement staff that
remain on duty to conduct essential activities.

At the superintendent?s discretion, parks may enter into arrangements with local
governments, cooperating associations, concessioners and/or other third parties for trash
collection and other visitor services. The NPS will not reimburse third parties (through
payments, franchise fee relief or any other consideration) who provide such visitor
services. If NPS staff will be conducting the work using funds from a third party,
payment must be received in advance. The Washington Of?ce will provide template
agreements.

- In general, enforcement actions should be reactive rather than proactive. Parks should
not take measures to keep visitors out of an area unless access presents a serious and
imminent threat to human life, safety, or health, or a seriOus and imminent threat to the
condition of a sensitive natural or cultural resource.

Updated 01.17.17

Concession and CUA Operations, Partner Operations, and Leased Facilities

Access to leased facilities is permitted.

- Visitors on out?tter or guided trips that have already commenced at the start of the
shutdown will be allowed to complete their trip.

The park superintendent will make a determination, on a case-by-case basis using the
criteria below, whether a commercial, concession, and /or partnership facility may remain
open or its operations continued during a lapse in appropriations. With the permission of
the park superintendent, operations meeting the following criteria may generally remain
open:

0 The concessioner, commercial use authorization (CUA) holder, or partner can
Operate during the shutdown without the park exceeding the staf?ng number
approved to support essential activities or otherwise incurring expenditures or
obligations in violation of the Antide?ciency Act.

0 The concessioner, CUA holder, or partner operation does not require access to a
closed NPS facility.

0 The concessioner, CUA holder, or partner operation does not require NPS
monitoring and regulatory oversight in the short term.

0 The operator con?rms in writing that its existing agreement requires it to
indemnify NPS and the United States for any liabilities that may be incurred as a
result of its operations during the government shutdown.

The operator acknowledges in writing that NPS-provided visitor services will be
unavailable, and emergency and rescue services will be limited.

- If over the course of the shutdown, NPS expenditures or obligations become necessary to
support commercial, concession or partner operations, the park superintendent mug;
require a suspension in those operations. Park superintendents may not bring on
additional staff in excess of numbers approved to support essential activities in order to
provide for commercial, concession or partner operations.

- Commercial, concession or partner operators may work with parks to fund park
operations during a shutdown if doing so will allow them to remain open.

0 Commercial, concession or partner operators must provide payment in advance
equal to the estimated cost to the park of providing required services
(maintenance, waste removal, utilities, etc.) for one week. The NPS will refund
remaining funds should the shutdown end before one week. Additional advance

payments may be necessary should the shutdown continue for more than one
week.

0 If the NPS provides utilities without reimbursement, the partner must provide
payment in advance equal to the estimated cost of providing those utilities for one
week if they wish to remain open during the shutdown. The NPS will refund
remaining funds should the shutdown end before one week. Additional advance
payments may be necessary should the shutdown continue for more than one
week. If the Operator already reimburses NPS for utilities on a or annual
basis, no advance payment is necessary.

Updated 01.17.17

Special Events

Park superintendents may allow special events and activities authorized by special use or ?rst
amendment permit to continue if they meet the following criteria:

- The activity does not require park service personnel to provide monitoring for protection
of resources or government property or monitoring for public health and safety protection
such as crowd control.

- The activity does not require access to a closed NPS facility.

All other special events or permitted special use or ?rst amendment activities will be cancelled,
postponed or suspended. In addition, the NPS will issue no new permits during a shutdown.

As always, law enforcement action may be taken in cases where there is a violation
regulations, including if it reasonably appears that the special event or demonstration presents a
clear and present danger to the public safety, good order, or health. This includes demonstrations
that either qualify under the NPS small-group permit exception or demonstrations that have
submitted an application, either before or after the shutdown that were not denied.

Updated 01.17.17

Part 2: Designation of Excepted Personnel

The following estimate of personnel required to carry out the essential activities defined re?ects

current estimates of excepted employees. Please note that this remains an estimate, as the
number of excepted employees will continue to ?uctuate throughout the shutdown period.
Please also note that this list re?ects positions, though duties may be shared by one or more
employees. Employees who report for a very limited number of hours per week such as a
maintenance employee who must conduct a safety check on a facility system are still

considered ?furloughed,? though they will maintain a log of hours conducting essential activities

during the shutdown period.

Total Employees Essential v. Furlough

NPS Employees 24,681
NPS Employees deemed essential* 3,298
NPS Essential for Visitor Protection (LE, EMS, Fire, USPP) 111]
NPS Employees to be urloughed 21,383
Exception Summary by Organization

WASO Leadership 10
WASO Support Staff 40
Denver Service Center 21
Harper?s Ferry Center 7
US. Park Police 652
Alaska Region 41
lntermountain Region 777
Midwest Region 234
National Capital Region 122
Northeast Region 364
Paci?c West Region 694
Southeast Region 326

TOTAL NPS EXCEPTIONS 3,298

*Inclusive of employees paid by non?expiring fund sources