GAME COMMISSION CALLS MERGER REPORT INCOMPLETE

http://www.pgc.state.pa.us/press/2003/november/nr110-03.asp

HARRISBURG - Calling the report incomplete and lacking in many areas, Pennsylvania Game Commission officials today challenged assertions and assumptions made in the Legislative Budget and Finance Committee's (LBFC) report on the feasibility of merging the Game Commission with the Pennsylvania Fish and Boat Commission.

"This report confirms our worst fears about the impacts a merger would have on the wildlife resources and the Game Commission's ability to deliver services to the public," said Vern Ross, agency executive director.  "We are extremely disappointed with the study as it lacks thoroughness and depth in its evaluation of a proposed merger and would lead to a loss of essential services currently provided.  There are many major flaws within the report that inflate savings, fail to identify costs and ignore additional operating expenses.

"The bottom line is that this report has many failures and shortcomings.  As such, there is nothing in it that should lead anyone to the conclusion that there are significant cost savings in combining the two agencies, and even more disturbing is the report's failure to identify the many costs of combining the agencies."

In his prepared response to the report, Ross noted five areas in which the report demonstrated systematic failures of the LBFC's research:

No Costs Identified to Merge the Agencies:
The first major issue is that there is no analysis of the cost to merge the agencies. In some areas there is a mention that there would be costs, such as in automation and uniforms. But those costs, or even a model to determine those costs, are not provided. In some cases, the report fails to address costs such as construction of facilities for a combined agency.  Some remodeling is mentioned, but the report does not address major changes, such as HVAC, when remodeling is done. The question is, how can the agencies be merged when there is no identification of costs? It would be like buying a car and not knowing the price until you start making payments. There can be
no rational debate for merger without knowing the total costs involved.

No Organizational Structure Analysis:
During the initial discussions for this study, the Game Commission asked the LBFC to use a model of a similar-sized agency, such as the Department of Conservation and Natural Resources (DCNR), to build the correct organizational structure for the theoretically merged agencies. Unfortunately, this report provides no detailed organizational structure analysis. All that was portrayed was the combining of two agencies and assuming there would be savings because certain positions would be eliminated due to the merged functions. However, there was no consideration given to the structure or grading of positions to determine what the real savings might be, if any.

For example, the Human Resource Director of DCNR is a pay grade 11 and has 22 people in the Human Resources Bureau supporting a permanent employee base of 1,300. The created merged organization has a Human Resource Director who is now a Division Director at grade 9 and 17 people after the cuts supporting approximately 1,100 employees. The model the LBFC used was an average of the Fish and Game Commissions' current coverage with vacancies. The LBFC should have used a standard model across State Government. At least the LBFC should have used a ratio of a similar-sized organization such as DCNR, which has 22 human resource personnel supporting 1,300 employees. That ratio is one human resource person for every 59 employees.  Using that ratio, the newly merged organization would have 19 human resource people
instead of 17. Therefore positions would increase. The combining of Human Resource divisions could, in reality, cost more because there would be positions at a higher pay scale and a structural level that currently is not in the organization.

Another suspect area is the Press Secretary position. By combining the agencies, it was determined the merged organization will need only one press secretary, and the report compared it to DCNR, which has only one press secretary. However, the study failed to mention that DCNR has a deputy press secretary and an assistant press secretary to handle the larger organization's workload.

Salaries at the Bureau and Division levels would increase, consistent with the Commonwealth's pay scales for larger agencies. No analysis was made of the organizational structure and related increased costs.

No Workload Analysis:
Another major shortcoming with the study is that there is no workload analysis. This is true throughout the study. It is suggested that by combining bureaus and regions manpower needs would be reduced. However, there was no workload analysis to measure whether the job structure is similar or the magnitude of work retains the previous manning levels. An example of this is maintaining the number of dispatchers at the same level. The workload will increase considerably as all calls are coming to the same
location and need to be fielded not only in a wider variety of subjects, but also at an increased magnitude. There would be a need to increase the number of dispatchers, as well as the number of phone lines, to handle the increased workload.

A major flaw in the analysis is the complete elimination of the Information and Education Program from the regions. The Information and Education program is a core functional area that was completely disregarded. The Regional Information and Education effort is critical to wildlife management's future because it coordinates recruitment and retention programs; hunter/trapper education programs; youth hunts and field days; exhibits; presentations at sports clubs; and the school programs. According to LBFC figures on the WCO model, the Wildlife Conservation Officers and the Waterways Conservation Officers spent 11.4 percent and 4.7 percent of their time conducting information and education programs. This equates to 20 person years of work using their model. No one picks up that work in the LBFC proposed agency. To achieve 20 work years of work you will need about 23 people to accomplish it, based on available hours. This effort is completely disregarded and needs to be reinstated. Additionally, all the Information and Education Supervisors were removed from the regional office to manage this core program. Returning this core program, at the appropriate manning levels, into the agency reduces savings by $1,194,380. Stated savings are further reduced by the fact that these individuals will need vehicles to perform their duties. This would require an additional 29 vehicles, and thereby reduces vehicle savings by $241,681.

As John Rowe, LBFC chief analyst, stated in the 1989 testimony before the LBFC: "There's also potential in other position classifications but the unknown there is what form, what organizational structure, the merged agency would take. And a lot of the actual determination of the number of positions that could be eliminated would involve actual examination of the positions and almost a work study type analysis." In order to determine actual structure and manning requirements, a work study analysis needs to be done. The Game Commission completely agrees with Mr. Rowe. It held true in 1989 and holds true today.

WCO Work Model:
The WCO work model is severely flawed. First, leave time is nonproductive time and should not be included in actual work time. The "other" time was included in law enforcement time, but some of those activities support all the activities of the WCO and should be prorated across all the activities. The model's definition of those activities that constitute law enforcement is misleading.

The study includes in the law enforcement activities such duties as animal damage complaints, road-killed deer pick-up, crop damage wildlife removal, special permits and it appears to also include wildlife nuisance calls. What laws are being enforced with these activities? The "other" category includes land management activities such as public access programs, game lands construction and maintenance, and shooting range construction and maintenance. How are these law enforcement activities?

The model is obviously skewed, which increases the percentage of time that WCOs spend on law enforcement in order to achieve a high enough percentage to not cut the work force too much. We do not agree with the study's definition of law enforcement activities. However, if a model of law enforcement activities was used that included the LBFC model's generous definition of law enforcement, plus 50 percent of the other time, and even recalculating the leave time across all categories, the result would be only
67.1 percent of Wildlife Conservation Officer's and 78.4 percent of Waterways Conservation Officer's time is law enforcement. Using the same model, the merged agency would need only 153 FWOs in the merged organization; thereby reducing the law enforcement component by 62 WCOs or 29 percent of the workforce. This would be very difficult to accept from a labor representation point of view. Consequently, the model appears to have been inflated to get to an acceptable level. Another area of the model's
failure is what happens to the programs the WCOs used to perform? For example, the Information and Education Program, using the LBFC's model those activities account for 11.4 percent of the Wildlife Conservation Officer's and 4.7 percent of Waterways Conservation Officer's time that equates to 23 person years of work. This also holds true for the functional support role. Who in the merged organization is going to pick up that workload?

Salary Scale Skewed:
Using an average salary inflates financial savings. Personnel procedures generally follow the last in, first out rule. You will lose the lowest salaried personnel, not the senior. Therefore an average salary between the two, skews the savings to be greater than they really are. For example, the most recent graduating WCOs earn $34,905 a year. This is basically $8,727 less than the average salary presented. This adjusted rate times 24 WCOs decrease the savings by  $163,968 in the Game Commission part alone.  If the
same difference can be inferred for the Fish Commission, the savings are inflated by $310,752. Another example is salary costs in the areas of regional directors and law enforcement supervisors. Those individuals will not leave but have return rights to a lower position. They will retain their salaries and bump the lower salaried person out. For regional directors alone the reduced savings is approximately $183,600. The salary savings discrepancy is true for all the positions that are identified to be eliminated.

Additionally, other agency officials voiced concern about the potential impacts on wildlife management caused by increased competition for limited financial resources of a merged agency.

"I have a major concern that the progress we are making in deer management could be jeopardized by fewer resources being available for deer research due to a merger," said Dr. Gary Alt, Game Commission Deer Management Section supervisor.  "For example, the deer conception study would not have been possible if it were not for the dedicated work of our Wildlife Conservation Officers, who collected the data."

Other Game Commission biologists voiced similar concerns.

"If it were not for the wildlife management work conducted by our Wildlife Conservation Officers, we would not be able to tag and collect data about as many black bears as we do right now," said Mark Ternent, Game Commission bear biologist.  "Pennsylvania is the envy of many of other states because of our ability to collect this data, which provides the information we need to monitor our annual bear harvests and estimate the statewide bear population."

In conclusion, Ross noted that there are many other individual items that are in error, but they are too numerous to address in his response.

"In the past, Legislative Budget and Finance Committee reports have been thorough and professional and very informative," Ross said.  "It is unfortunate that this report does not stand up to the previous studies by the Committee staff."

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