On April 30, 2019, Jamie Rappaport Clark, president and CEO of Defenders of Wildlife, testified before the Subcommittee on Oversight and Investigations of the Committee on Natural Resources at a hearing on the implementation and impacts of the Trump administration’s proposed reorganization of the Department of the Interior.
The proposed reorganization of the Department of the Interior raises profound and troubling questions. Its purposes and goals remain unclear, as does its actual scope. What does seem clear, however, is that it is likely to be a wasteful and disruptive distraction to Interior’s bureaus and agencies and their dedicated employees, some of whom will face years of uncertainty about their professional careers and their personal lives. The nation’s lands, waters, and wildlife will be better served by focusing on the critical conservation and natural resource management challenges Interior faces today. We respectfully urge Congress to suspend this damaging effort.
The agencies, bureaus, and programs administered by the Interior Department are profoundly important to conserving and managing the natural resources that define our nation and the values we share. Three Interior agencies, the U.S Fish and Wildlife Service, National Park Service, and Bureau of Land Management steward vast areas of public lands and waters and manage fish, wildlife and plant species that touch the lives of every American and are an indispensable part of our nation’s natural heritage. Other bureaus bear vital responsibilities for water management, scientific programs, management of the nation’s minerals, and upholding trust responsibilities to Tribes.
Improving the effectiveness, efficiency of operations and public responsiveness of federal departments and agencies is always an appropriate goal for government. Defenders of Wildlife itself maintains a Center for Conservation Innovation whose mission is to identify and develop innovative ways to improve the performance of the Endangered Species Act and other conservation programs.
But restructuring federal departments and processes is a daunting challenge that can pose serious risks of disruption to the ongoing and vital responsibilities of the government. To succeed, there must be clarity on not only the problems posed by the existing structure, but also how proposed reorganization will measurably improve performance. Problems and solutions must be evaluated in the light of the specific legal obligations and missions of the various affected bureaus and agencies. Impacts to personnel and operations must be explicitly considered. A realistic appraisal of benefits and costs, including unintended consequences, must be carefully evaluated prior to initiating action. Transparency and public engagement across all affected sectors are vitally important.
In the absence of clear information on the nature and purposes of reorganization, many critical questions remain. Will the Department involve the public, Congress and stakeholders in its reorganization effort? Will reorganization undermine the authority and missions of Interior bureaus, agencies and officials? Is reorganization a vehicle to deliver the administration’s controversial policy agenda? Will it impede Interior bureaus and agencies from achieving outcomes in accordance with their missions and responsibilities that may not be a priority for this administration? Will reorganization displace or reduce staff and distract Department employees from their mission critical duties? Will reorganization siphon critical resources needed to fulfill essential responsibilities for natural resource management and protection?
The recent change in leadership at the Secretarial level has only further muddled the goals and rationale for reorganization. This administration has never described a compelling need for reorganization, even as the current process continues to interfere with Interior bureaus and agencies achieving their missions and disrupt staff responsible for managing and conserving our natural resources. Pushing forward with this ill-considered, poorly communicated proposal will continue to interfere with Interior’s ability to engage with critical management challenges to the detriment of the Department, our natural resources and the nation. It will take decades and require fiscal resources the federal budget is likely ill-prepared to support, to recover from the dislocation and disruption caused by this proposed reorganization.
The Department of the Interior doesn’t need reorganizing; it needs leadership. After more than two years in office, the administration should focus instead on filling the vacant high-level positions, including the Directors of the Fish and Wildlife Service, National Park Service and Bureau of Land Management and the Assistant Secretary for Fish and Wildlife and Parks, with qualified professionals and addressing the critical conservation and resource management challenges Interior faces today.