THE WOMEN IN LAW ENFORCEMENT TASK FORCE REPORT The Women in Law Enforcement Task Force (WLET) was appointed by Director Stanton in November 1999 for the purpose of looking into issues concerning women with law enforcement commissions in the 025 park ranger series, the 1811 cn'nuna/ investigator series, and the 053 park police officer series. This report relates to our findings. specifically the problem issues identified and the action items developed to Mitigate or correct them These action items are recommended for implementation Via a five--year action plan deSIgned to counter current and past effects of gender bias, sexual harassment. and hostile work environment within the NPS law enforcement program The target completion date (or the action plan is October 1. 2005. The WLET has met twice The first meeting was in Phoenix, AZ for three days during the week of March 13, 2000. and the second meeting was in Washington, Dolor an additional three days during the week of June 3, 2000 During the time we have been a task force, we have rewewed a great deal of pertinent information Some of this information originated from within the NPS Through surveys of commissioned National Park Sewice (NPS) and S. Park Police (USPP) women, Superintendents, and Chief Rangers, the WLET was able to assess how these employees viewed the role of women in our law enforcement programs Other information was proVIded by outside sources such as the National Center for Women and Policing and the Massachusetts Institute of Technology (refer to the attached bibliography), A presentation on the class action lawsuit and resulting consent decree against the Department of Agriculture, Forest Sen/ice (USDA FS), Southwest Region was an additional, key component of this latter aspect of our review. 9F FINDINGS Federal Law Enforcement Training Center (FLETC) records indicate 469 women completed the NPS basic law enforcement tor land management program between 1977 and 1999. This is 20% of the total NPS trainees (does not include USPP trainee date but does include NPS women now in speCial agent positions), The current percentage for NPS women in law enforcement park ranger and special agent positions combined is 163%. Not only does this show little change in twenty years, it indicates an inability to retain women in these positions. The International Association of Chiefs of Police (IACP) identities organizational culture as a significant obstacle in the retention of women and minorities that is not readily overcome in organizations where they have been lradltionelly absent Their related course presentations state Regim- Fir-ll om Ana-m I7, nu Page of I. organizational culture is difficult to change until underrepresanted groups achieve representation in the 207257.: range. Similarly, the NPS Strategic Plan (goal calls for a 25% increase in nine targeted series by 2005 so as to increase the sewioewide representation of underrepresented groups The 025 park ranger and 053 police officer series are among these targeted occupations The consulting firm Lighthouse Associates conducted the surveys and focus groups studies for the NPS and USPP. Per industry standards regarding such research, negative responses from 25% or more of the respondents indicate an organization In crisis Notable on its face was the dramatic difference in responses from employees v. Superintendents and Chief Rangers, an indicator that NPS managers lack understanding of the concerns of women working in the law enforcement programs under their supervision, The five most negative categories of response by NPS women (and all well in excess of the 25% standard) were: recruitment, retaliation, timely resolution of complaints, promotions, and training in EEO type matters such as sexual harassment and diversity Survey results by USFP women were also generally unfavorable and Indicate the USPP work environment needs significant improvement as well Together, these responses are alarming indicators that systemic disparate treatment of women, including sexual harassment, does exist in both the NPS and USPP law enforcement programs While there is no comparable study on the numbers of women working as Federal law enforcement officers, the WLET did review the 1999 study of state, county. and local agencies by the National Center For Women In Policing which showed women represented 14% of sworn officers. The NPS is above this average in the number of women in law enforcement park ranger positions However. we were well below average in the representation of women in park police officer and speclal agent positions, Additionally. when we reviewed law enforcement program data available at the park level, we found that women were often found only in the lower grades or absent altogether. improvement is needed Given our reputation for excellence and innovation in visitor and resource protection, we believe strongly that the NPS should lead in career opportunities for women and not settle for the unimpressive record of more traditional (law enforcement) organizations. THE 1 2 Hostile Work Envtronment 3 v4.51 - Flu-l om Angina 11, mo rape or II 4. EEO Complaint Processing/Program 5 Data Collection/Monitoring. FIVE-YEAB Ag I ION 1. ACCOUNTABILITY: Issue a memorandum from the Director to retain the delegation tor processing informal complaints with the NPS EEO Program Manager in WASO tor a period of two years. [maement immediatele effective dates 10- 91-00 through 09-30-02 The NPS EEO Program Manager is the rayontiue ofiiciel for grefinng the memorandum for the Directafs signature and for del'SP I'nhiti met NPS law Inlorcement park rangers, special agents and USPP officers and in stigators trained in EEO investigations and determine their current availability tor conducting such Investigations in a structured internal affairs program in cooperation with the NPS EEO Program Office. The EEO rem Maria er is he res nsibl llici'al [or akin rtai'ri thatinve assi rim avoid an earanca nflicts {interest The Su rill nt NPS-FLET he Ca rain and in NPS EE Pro ram Mana erare here risible oh'i rdetermiriin rainin etus and mnguctim EEO lnvesfn' ah'ons coqu :9 that a minimum a! 24 EEO lnveflgg' 335 are available for case fig nmeizt oz the EEO Program anger nal EEO ers. These in st' ators should be avail le Jan 31 2002 with new inmhg' ators reenlited and trained as needed so the number a_vaflable remains congan! at a minimum 9! 24 (the size 9! the gmgrarn when ong' inallz establiLhed) The Director isthe We official lor fundinq training an rises associ withan i' in i ati 5, Issue a memorandum from the Director announcing an independent review at all NPS and USPP gender and sexual harassment cases (Including lntemal Attairs cases) from 1993 1999. The review will document (1) the number and time frame of cases pending Investigation, (2) the number and time trains of investigated cases pending disciplinary action, (3) a summary, including time frame. of any actions taken to "make a person whole", and (4) the basrs for anylall final decisions not to investigate or take action in a timely manner. The review will begin with cases that were on record es of 1993 so that recent history Is addressed Since the enhanced annuity retirement (6c) coverage was implemented in 1994, this time period simplifies the Identifimtion of cases involving law enlorcement park rangers. Lama/1mm mac later than 11-30--00 The NPS EEO Manager is the WLEY Report Final Draft August i7, mo Page in res ans/hie official for ti with an inde ntinvestr at obe the team lea rtor the review. The Dire us the res nsible land si na authon' for all disc I The NPS Human Re ram 3 er is the res nsible I ht for all also I actions as a riate ss and to insure actions ag serviceme. A (sanitizte summea o! the is review the EEO web site no later than 06--3001 Implement all pending strategies to "Ensure Accountability at the Secretarial and Bureau Levels for improving Diversity" as described in the 1998 NPS Diversity Action Plan. In: angels are the D'er My Directors and the NPS EEO Program Manager. A status report on the achievemen these strata ies hem): Post the WLET final report and related NPS and USFP gender studies on the cmmaii Learning Place Bulletin Board Announce the web site posting through electronic mail to all employees. Post other documents (or their intemet addresses if already posted elsewhere) lIsted in the bibliography or attached as appendices such as the Haskell Diversity Document, NPS Diversity Action Plan, etc, To be accomglishgg no later than 05-21520. The WLETco--chairs are the mango/e officials for preparing the "ell emqums" mmrandum for the Directors gig mm and coordinating the gusting with the NFS-WA Leami Place Bulletin one er. Assign one or the WLET co~choir8 as a monitor to track implementation oi the five-year action plan and make written progress reports to the Director at six month Intervals. be effective upon the are ctor's approval a! the five- mar action glen through its completion date (taggeted gr 10--01705), The Director will be the resmnsible official for funding exgnses associated with We JUSTIFICATION: A lack of accogntabilig has been Identified repeatedly by departmental and agency animals. in regard to a variety of agency projects and programs. as the most significant problem facing the NPS today. The WLET also Identified the accountability problem as the most sIgniiIcant obstacle In the way of accomplishing recommendations made. Directors Order #54 defines management accountability as "the expectation that managers are responsible for the quality and timeliness of program performance, increasing productivity, controlling costs and mitigating adverse aspects, and assuring that programs are managed with integrity and in compliance with applicable law." We think accountability needs to be greater than an VILET WI 7 Final Drill mm Page om "expectation"; it needs to be a requirement. Accountability has proven particularly elusive as it relates to a stated policy of zero tolerance of sexual harassment. This remains so in spite of the statement made by the Director and the NLC In the April 1999 NPS Haskell Diversity Document (in their response to question 54) that "we do not tolerate sexual harassment when we are made aware of its existence." The NPS EEO Program Manager told the WLET that "disciplinary action was taken in less than 10% of the cases" (cases where there was a finding of harassment and/or discrimination subsequent to an investigation). In the NFS Women in Law Enforcement Study, 68% of the NPS female officer respondents said the NPS was either poor or so-so at enforcing its zero tolerance policy. In the USPP Gender Equity Study, 86% of the female officers responding said the USPP was either poor or so~so at enforcing its zero tolerance policy In narrative remarks, these NPS and USPP study respondents also stated they teared reporting incidents of harassment and/or discrimination because when the offending employee is in a higher graded position, the official is, at best. moved and more often promoted. In contrast. they believed the complainant would be labeled a "trouble-maker" and their career ruined. 78% of the NFS officers responding rated the NPS as poor or 50-50 in its effectiveness on no rate 'figion because of oomplainls. 91% of the USPP officers responding rated the USPP as poor or so-so in its attentiveness on no reg ration because of complaints. It is necessary to take the responsibility and authority for disciplinary actions pursuant to EEG and related Inlemal Affairs investigations away from NPS and USFP Regional and command officials to send a strong message to all employees that there will be discipline of consequence for employees who commit discriminatory andlor harassing acts, Doing so Will also assure fairness and consistency In the administration of discipline. We believe by acting now on cases already investigated. and where there are no statutory or regulatory constraints that prohibit doing so. NPS and USPF managers demonstrate that their zero tolerance policies apply equally to all employees The WLET supports the strategies described in the 1996 NPS Diversity Action Plan to "Ensure Accountability at the Secretarial and Bureau Levels for Improving Diversity" (Goal 3) SES Managers' success In achieving this goal will be measured based on their actual record it their opportunities to hire, promote, retain, train, and develop diverse applicants or employees. For a positive contribution to the recruitment. retention, and promotion of women in law enforcement to actually result, the NPS needs to make certain such opportunities exist. Implementation of recruitment and mentoring programs to create better opportunities for women and other underrepresented groups in our wLEr Report - Flul can we i1, use no. or 1! agency's law entoroement programs are critical if this measurement of success is to have any impact in actually addressing the lack of diversity in our law enforcement occupations. With regard to displaying EEO information on a web site. posted statistics and sanitized case studies will help restore our employees "good faith" in the EEO process This restoration of faith is needed both lrom the perspective of those who fear being unfairly disciplined as wall as from the perspective of those who believe there are no consequences for bad behavior (particularly at the higher grde levels). EEO web site data will prowde all employees with factual inlormation on the outcomes of complaints in terms of the process (requirements and time frames], actions taken or not taken based on completed Investigations, and the grade/organizational status of disciplined or exonerated employees, The WLET believes that a data based approach can protect confidentiality and still lift the veil Covering the agency's problems and progress in addressing this most critical issue. 2. HOSTILE WORK ENVIRONMENT: Install an EEO hotllne for reporting unlawful harassment for employees The purpose of the hotline is to provide a means of immediately reporting incidents when the complainant has concerns about initiating the EEO process at the local level, Sexual harassment and creating a hostile work environment due to gender/sex are employee misconduct. Consideration should be given to responding to hotline reports as matters of misconducl, so such reports can be investigated Iminediately whether or not a complaint is tiled, USDA FS EEO hotline personnel should be used as a resource in designing the NPSIUSPP system. The EEO Pmram Manager is the resmnsible official to be am! no later than 10-01-00 Investigations within 10 days from the daiul the hotling mntag with all expenses borne I: the nefitin a n! i laftheR rtofln ation NPS EEO Pr Man or will chair within a do 5 a I'ew Pane to examine the re rt an alt recdm ations for a tloh to the Director 'hiri two ks of their review [he Review--Papal will conga giihe EEO Program Manager In ha ment 0 at the rial level and anoth bureau office within the De rtmen 1117' ex n'l career of th cam ain Ii. A all atlons al miscand lvi NPS or USPPI men office st be re ed immedl 5 re uir the DI ctar's Orders/ I Orders 1' their law enlarcemen rams Issue a memorandum from the Director requiring agency (park. Regional, WASO) EEO Managers to strictly adhere to EEOC guidelines regarding complaint processing. The NFS EEO Pmram Manager is the remnsible official for angering the memmndum for the 0m Dr's signature to be WLET - Dun Militant 2000 Page .n distn'guted to all emplomas a9 lag, than 10-31-00 Issue a memorandum from the Director requiring the NPS EEO Program Manager to notify the Director within 30 days when corrective action is not implemented within two weeks after issuance of finding and when discipline does not occur within 45 days after corrective action is ordered. me NPS EEO Erograrn Managils the official for the memoraggum gr the Director's signatug to be distributed to all employees no later than 10-31-00. Issue a memorandum from the Director requiring the NPS EEO Program Manager to inform the Director within 30 days at the ending of the 130 day period following the filing ot a lormal complaint when an Investigation has not been initiated or completed. This notice should be in writing and explain why the investigation has not been conducted according to EEOC guidelines Lite NPS EEO Emram Manaaer Is the rewnsible officval locprepefina the memorandum for the Director's sig' natgre to be distributed to all emploEe? no later than 10731-09 JUSTIFICATION: A hostile work environment is the worst presentation of an organizational culture The April 1999 NPS Haskell Diversity Document In response to the question (155) about why the NPS is having a harder time with diversity than other federal agencies and private corporations, states "Diversity requires a change In our culture and many ot our employees appear reluctant to change." The response to the question (161) asking NPS leaders what they believe are the root causes for the NPS: lack ol diversity states "Reluctance to changing the way we do our recruitment. hiring, and development of employees. A reluctance to change our culture and become a catalyst for change." The correlation of organizational culture and diversity IS undeniable and described in presentations by the IACP in their courses on "Mentoring tor the Retention of Women and Minority Public Safety Personnel" and "Harassment, Discrimination, and Liabilitf developed for their law enforcement agency membership In the responses to the NPS Women In Law Enforcement Study and the USPP Gender Equity Study, It is evident that many of our women are working in such an environment 52% of the NPS women and 76% of the USPP woman stated they had personally experienced sexual harassment while an employee at the NPS. 63% of the NPS women and 71 of the USPP women stated they had personally experienced gander discrimination while an NPS employee. 77% of the NPS women and 83% at the USPP women said they knew of other people who had experienced sexual harassment or gender discrimination while an NPS WLET RM - Final Drift Aug-a 11. mo pm om employee. Comperatively. the study conducted by the MSPB in 1994 reported that 44% of women In the federal government believe they had experienced some tom of unwanted sexual attention. We are greatly concerned that the findings in the NPS and USPP studies are lar above this national average Narrative comments related to the issue of hostile work environment varied most among the NPS respondents USPP respondents) The mixed positive and negative experiences of NPS women seem directly related to the particular park and supervisory settings at their assignments as well as the greater number at possible locations for these assignments. As a smaller workforce with lewer geographic locations, the negative aspects ol the USPF organizational culture were oenemlly unavoidable for their lemale officers The WLET believes it is critical tor the NPS to show a sense ol urgency in ensuring that all employees are working in an environment free from unlawful harassment. Currently, there is a class action complaint, filed in Federal District Court, which is on behall of women in NPS and USPP law anloroement poSitions, As a result, the pradices and procedures of the NPS are being closely examined. The law is clear in cases of sexual harassment in stating that an organization must investigate allegations and take immediate action to stop such harassment when it is found. As stated in the 1998 NPS Diversity Action Plan (Goal 5. Objective the NPS needs to loilow the legal requirements for implementing corrective actions swiftly when lindings ol discrimination occur and for disciplining perpetrators of discrimination in accordance with applicable regulations Policy statements zero tolerance, etc.) are required to demonstrate that employees have been notified that unlawful harassment will not be tolerated Within the organization. However, policy statements by themselves do not show urgency in addressing problems identified The establishment of a hotline combined with an independent reView of all NPS and USPP gender discrimination and sexual harassment cases is necessary to restore confidence in the agency's ability to respond expediently and consistently to reports of harassment and hostile work environment within the NPS. 3. Implement all pending USPP Women's Task Force recommendations as stated In the February 2000 Gender Study Matrlx. Particularly important are the recommendations that support achievmg gender balance (Within the ranks and specialized assignments) and establish (fund) the Office of Prolessional Integrity (OPI), The shall be lunded and anemtional no later than 10-30-00. The resmsib/e official for fundina is the 009MB official for is the Chief of Police QSPP. The will coordinate mm the ma m- Film one win 11. no me am WLET co-chair monitor topregana mm the Dimctor a: six month Intemals We me of the in aohiewnqpendingJecommendaiions Th1 meniafinurogram [Lama] should submm' ed to the BMW no later than 12-31 -01 and be operafionaM/aier' than 1231-02. The en/isor descn in (h SPF rider ud irix rdiriate 'h the CPI de recm' ent i'es. rider resen tI'on ol women In all ranks and specialized Is to be eliminated by 10-017 05. L/ndelementalion will be measured per the criteria used in the NPS and Divemt' 1 Action Hans and as established b1 EEOQ Management 2E nth/es. Contract with an outside consultant to prepare an NPS Retention and Employee Satisfaction Study tor law enforcement park ranger and special agent positions to complement research done on behall oi the USPP In December 1998 The NPS EEO In Maria I is th res OfilCIE/i Si be com eted later than 09-30-01 Explore Implementation 0' llnancial and workplace incentives to encourage recruitment and retention ol NPS and USFP women and other underrepresented employees In the 025 law enforcement park ranger, 1811 crimlnal investigator. amt DB: park police officer job series. A reVIew of requirements and/or reshictions for implementing incentives such as quality step increases (QSI), "enlistment bonuses". job sharing. NPS subsidized daycare lor remote areas, retention allowances, and alternative work schedules is necessary so that recruitment or retention plans developed offer new Ideas for Improving the diversity of the NPS law enioreement workforce. The NPS Human Resources ram na ell he res ible [for ari a "n a smenl" areas wide I1 for IetI'n a corn reh nsive re I1 that i'de since sl all avail Ia and re ulat' ns verm'n Im nlation The NP Human source Ia Mana er is {he re neihle all! liar su mm in rtlo th Direct no la han 107 1471. The ori res I official iundin incentives rm lamented. The nee semen ould an he Iemeri al law enforcement 33mm marks and field offices can support ngn>>traditignal ules Iorl enforcement alfi havln ate! res nsIbIlili'es in child an glfir care compromising the safety of officers or menu! patrol ang in alive ms. Fund/Hire a full time NPS law enforcement recruiter, who is a current, active NPS law enforcement officer The position will require a commission. and the recruiter selected must have significant experience as a NPS law enforcement park ranger. This should be a new/additional position, which be responsible for the development and coordination of a national recruitment program. T_he_ Dlnectaris the sible Iior la hi 'ii'on a 've 10--0100. The Superintendent NPS--FLETC is the official fizr recmitIMln'ng mm- rum our: human 11mm Page the goslgg' no later than 12-31-00. Implement national recruitment and hiring program ("front door") for NPS law enforcement park ranger and special agent positions. The law enfo men i a rib rein in NPS an source Maria er and the NPS EEO Program Manager are the oflici'als, Recruitment grogram grows submim to the Director no later than 12-31--01 [assuming Ingumbent EQQ is no lat?r than 12-31-09. ngram should ianalnolater han 12-31-01 Underre resen of men in the law enfommegt park ranggr and sm' 1 agent msitions in all grades and 'allzed nment be elim ted [7 10--01-05 nderre same 'on Will be measured gel the criteria gse_d in NPS Slratggfi and Div/gng Agag' 17 Plan; and as emblished 21 EEOC Management Directive; Issue a memorandum truth the Director requiring all law enforcement series vacancies to be tilled competitively tor a period of two years, Require vacancies be announced in an upward mobility or career ladder format at at least a two grade intervals v. 68712 only). Require review at promotions resulting from reclassification of positions due to an "accretion of duties" before such actions are Implemented non-competitively. The revtew team will consist at the Regional NPS EEO Program Manager and a second classifier not directly associated With the selection. The immediate supervisor will submit a written justification tor the accretion of duties to the review team that explains why competitive recruitment should not be done. This revtew is needed to assure consistency in promotions achieved by poSItIon re- classriication and to guard against this promotion practice becoming a barrier to advancement per the 1998 NPS Diversity Action Plan (Goal 2. Objective AA). ULNPS Human Resources Program Manager is the msze Mae! lor gregaan the memorandum for the Director's sg' nature no later than 1001-00 Develop and implement a national mentoring program tor women and other underrepresented groups In the NPS and USPP law enforcement programs. He Superintendent, NPS--FLETC and chiel USFP are the responsible mats lor dove/own for law enforcem ark ran 9 'al a and ollce cers, tori rain ls should 0 omitted Direct no later 12-3 1 be 0 rational later than 1 431702. Un rr resen ion Will measu er the used in the Strata it: Diversit cfion Fla 5 and as established oz EEQC Management Directives. Develop and implement an agency-wide "scholarship" program tor NPS and USPP tamale officers to regularly attend national conferences of organizations that bring together women in law enforcement and support the role women play In the protession. Such organizations include the National Center for Women and Policing. the National Association of Women WLEY upon - Final nun Augul 17' not: oi Io Law Enforcement Executives. the International Association of Women Police, and Women in Federal Law Enforcement (WIFLE). Funding should support annual attendance at these conferences by no less than two women trom each NPS Region and USPP Field Office, Director he res nsibla 'allor fu The NP Human uroes ram Ma er is th res offigial [or announcing the Logan! publishing informgm on umrniflg owls/ems grid selem' new; Both the NES Morning Regan and the Pa Bul 'n Board uld be to no a atta once at upcoming conferences. The man is to be onjine no later than 1241--00. Develop and implement a placement program for women in NPS and USFF law entoroemont positions. The program should be modeled after Operation Opportunity which was used to assist employees relocate when central oflice stath were "down-sized." It should not exclude new external hires (areas at consideration could be "all sources. govemment-wtde, and/or demonstration project"), Women with Federal employee status could apply specifically to the program. and the program would provide lists to hiring officials, allowing the hiring official to bypass the usual certification process or use both processes The purpose is to organize a defined pool or women candidates expressing a particular interest or badground in a law enforcement wreer The MP3 Chief of Human Resources is the official developing the pmgram and evaluating it over time The (Lograrn to be on-ling gg later than 10-01-91, Fund a mandatory program so that all NPS and USPP law enforcement officers, supervisors, superintendents. and regional directors trend the IACP courses "Harassment. and Liability" and "Mentoring tor the Retention of Women and Mlnority Public Safety Personnel." Other courses on these topics identified by the Superintendent, as similarly targeting the law enforcement workforce may be substituted. The the rgsponsible official for funding the training annually g: the! all current and managers of law entorgment ram com traini' -30-04and hatallfi --timesu rvisors and managers attend it ugh/n two years QtMelr EOD date. The Sugen'ntenfiut --F sthe res ni eoflicielfor lnatin th rain/n on re arm a memorandum for the Diem srg' nature as to the mandatgcy attendanfi muiremenl lmplemont an Exit |ntorview Program for separating USPP and NPS law enforcement officers. The program should include employees who remain in the NPS in non-commissioned positions Regardless of gender. employees leaving law enforcement positions should be asked to complete a survey form (from the Gender Equity Study or the NPS Women in Law Enforcement Study as appropriate) as part ot this program. The tone at the interVIew should be constructive with a stated purpose of improving law enforcement recruitment and retention, improving the efteotiveness oi the EEO Program. and supporting Report - mi Dull Most 11. mt rag-nits the 1998 NPS Diversity Action Plan strategy to conduct retention analysas (Goal 2, 5.1) The NPS Human Resourgs Program Manageris the responsible official fouivirmfige to the NPS 559 Program Manager of se ns or rits I law a men ositnsible a] de i an mordinating Vietnam/n to be imflernenfied no later than 12-31-01, The agency recruiters descfibem the {gr condmging he inte w' in their res 've enizations. JUSTIFICATION: The WLET believes the issues of recmi nt rat tion ro tions are inseparable, The April 1999 NPS Haskell Diversity Document states in response to the question (32) concerning the agency's commitment to recruitment vi retention that "we are doing a fairjob of hiring women and minorities but we are not doing a good job in our employees" It also refers to a 1983 survey which is to be the foundation tor the development of "a new survey instrument to ascertain why employees, especially minorities and women are leaving at such a high rate." The law enforcement recruiters described herein should be part of the team working With Dr. Gary Machlis and the Equal Opportunity Program Manager to develop, implement, and respond to the survey, In the response to NPS Haskell Diversity Document questions (151and 136) about which occupations lack diversity. the 025 park ranger and 083 park police series are identified as two oi the nine occupations within the NPS needing greatest improvement in diversity The response to a related question (206) states "when we look at the occupations that lead to 68--12 and above, we find that women of all colors are the most underrepresented in the NPS workforce" Amt most sin nlfigantly, the response to question 218 states "The 025-Park Ranger occupational series has the highest rate or any occupational series In the Department a! the Interior. The 1998 NPS Diversity Action Plan direms EEO and Human Resource Managers to design action items to decrease voluntary separations of diverse groups (Goal 2. Objective 2) Recruitment and retention incentives should be used by NPS rid USPP managers and supervisors as a means to accomplish this goal. The NPS Retention and Employee Satisfaction Study recommended herein wiil help determine which incentives are most likely to have positive results in the recrintment and retention of women and other underrepresented groups by assisting them in overcoming barriers to having a law eniorcement career in the NPS. Incentives need to be creative and visionary it we are to achieve a diverse workforce. Specifically. the agency needs to demonstrate a Willingness to recognize the value of women and other underrepresented groups Final om W112th up ol'll with pay incentives as traditional methods are not succeeding. Future training programs for managers and supervisors should include information on incentives available, the Implementation process, and their value In improving recruitment and retention in the NPS law enforcement occupations. 4. EEO COMPLAINT Implement an automated tracking system to monitor the timeliness of complaints processing. Expedite complaints processing to meet the 180 day regulatory tlme frame. Ber the 199g NPS Dignity Acma' Plan the responsible officials are the Baggy Deg dz Dimis and the EEO Fmram Manager. Tracking system is to be orHine oz 19-31700. Establish an NPS-EEO web site that is linked with the site. The site will display EEO accountability series report intormation. complaint statistics, and sanitized EEO case summaries. The purpose of the site is to allow NPS employees to see factual information on the workings of the EEO process as well as the status of diversity within the law niorcement workforce The NPS EEO ngram Manager is the Eggnsibla officialon-line no later than {23-30--01 Fund/Hire one full time Computer for the NPS EEO Program Cities The position is critical to develop and maintain the above described web site and implement the data collection and monitoring system described below. the Director the responsible official for the ggsition' the NPS EEO Program Manager mg official for hiring m'th inggt from the WASQ computer support office, To be logged no later than 10-01-00 and EOD no later than 12-31fl, FundIHire one full time EEO Counselor in each Region Issue updated technical guidance to Regional EEO Managers. The Qirectori? the responsible olficial for funding the positions The NPS EEO Pmram Manager is the official for nmag' and and Main; updates, To be funded no later than 10-01-01 and E00 up later than 1231-01 Prepare position papers on the merits of each case progressing to the EEOC or Federal District Court. Position papers include a determination on "entitlement of relief (as dismissed in USPP Women's Task Force recommendations) for the complainant and a recommendation tor NPS action The NPS EEO Pmram Manager Ls the responsiglg official fir comp/align the Wind submitting it to the Direcmr within 45 dag of the date the comgiainant informs the NES that has @uesteg an EEOC hegnng or filgg in court. WLET nap-m - Finll nun Am i1, 2m M. at io JUSTIFICATION: NPS employees have lost faith in the ability of the EEO gomgleint Prague/Progfim to resolve complaints In the NPS Women in Law Enforcement Study, 81% of the NPS respondents rated the effectiveness of the NPS on timely resolution of sexual harassment/discrimination complaints as either poor or so-so In the USPP Gender Equity Study, 97% of the USPP female officers responding rated the effectiveness of the USPP as either poor or 50--50 With regard to EEO investigations. 5% of the NPS respondents mted the effectiveness of the NPS on prompt investigation of sexual harassment andlor discrimination complaints as poor or so