2-25-16 Jarvis reprimanded, ignored ethics rules

NPS Director Jon Jarvis has been reprimanded for ignoring Interior Department ethics rules/NPS
An investigation has found that National Park Service Director Jon Jarvis intentionally skirted the Interior Department’s Ethics Office to write a book, a Guidebook to American Values and Our National Parks, for a cooperating association contractually tied to the Park Service, an action that brought the director an official reprimand from top Interior Department officials, who also removed him from any dealings with the Park Service’s ethics office for the rest of his career as director.
Furthermore, Deputy Interior Secretary Michael Connor ordered Director Jarvis to receive monthly ethics training for the rest of his tenure. 
“I am also concerned about the attitude the (investigation) demonstrates Director Jarvis exhibited toward important Departmental institutions such as the Ethics Office, the Office of the Solicitor, and the Office of the Secretary,” Deputy Secretary Connor wrote in a letter (attached below) to Mary L. Kendall, deputy inspector general for the department.
 
DOI OIG
 
Investigative Report of Jonathan Jarvis
Create Date:  Thursday, February 25, 2016
Report Date: Thursday, February 25, 2016
 
We investigated potential ethical concerns surrounding a book that Jonathan Jarvis, Director of the National Park Service (NPS), wrote and had published without consulting the Department of the Interior’s (DOI) Ethics Office. The book, titled “Guidebook to American Values and Our National Parks,” was published by Eastern National, a nonprofit that has cooperating agreements with NPS to operate stores and sell merchandise in numerous national parks. 
 
We focused our investigation on whether Jarvis used his public office for private gain by seeking a book deal with Eastern National and whether he misused any U.S. Government resources in the process. We also examined Jarvis’ involvement in Eastern National matters at NPS around the time of his book deal, and we reviewed Jarvis’ decision not to seek advice from the Ethics Office on the book.
 
We found that although Jarvis wrote in a note to DOI Secretary Sally Jewell that Eastern National had asked him to write the book, it was in fact Jarvis who contacted Eastern National’s CEO to see if he would be interested in publishing it. We found that although Eastern National did not pay Jarvis to write his book, he did ask that any “royalty” he would be due as the author go to the National Park Foundation, a nonprofit that fundraises for NPS, and that the book’s copyright be filed in his name so that he could later donate it to the Foundation. In addition, Jarvis approved Eastern National’s use of NPS’ “arrowhead” logo on the book’s cover, believing that one of the nonprofit’s two agreements with NPS allowed this; neither did, however. Jarvis stated that he purposely tried to downplay his Government position in the book by limiting the use of his title and using a photo of himself in street clothes instead of his NPS uniform. He wrote the book on his Government iPad, but we found for the most part his work on the book occurred outside office hours. 
 
While Jarvis renewed both of Eastern National’s cooperating agreements with NPS around the time he was discussing his book with Eastern National officials, NPS staff said that the book did not influence the agreements. 
 
Jarvis stated that he knew he risked “[getting] in trouble” by not seeking advice on his book from the Ethics Office. He felt, however, that if he had involved the Ethics Office and other DOI officials, the book would probably never have been published due to what he viewed as a lengthy approval process and some content that he believed was controversial.
 
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OIG: National Park Service Director Skirted Ethics Office In Writing Book, Reprimanded
By Kurt Repanshek on February 25th, 2016
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NPS Director Jon Jarvis has been reprimanded for ignoring Interior Department ethics rules/NPS
An investigation has found that National Park Service Director Jon Jarvis intentionally skirted the Interior Department’s Ethics Office to write a book, a Guidebook to American Values and Our National Parks, for a cooperating association contractually tied to the Park Service, an action that brought the director an official reprimand from top Interior Department officials, who also removed him from any dealings with the Park Service’s ethics office for the rest of his career as director.
Furthermore, Deputy Interior Secretary Michael Connor ordered Director Jarvis to receive monthly ethics training for the rest of his tenure. 
“I am also concerned about the attitude the (investigation) demonstrates Director Jarvis exhibited toward important Departmental institutions such as the Ethics Office, the Office of the Solicitor, and the Office of the Secretary,” Deputy Secretary Connor wrote in a letter (attached below) to Mary L. Kendall, deputy inspector general for the department.
In a short statement Thursday evening the director said, “I regret that I did not seek guidance on the most appropriate path forward to publish this book. I wrote the book to inspire and engage more Americans in our national parks, particularly during the National Park Service’s centennial year. I consider it a good lesson learned and will ask for guidance if and when similar situations arise in the future.”
Interior’s Office of Inspector General began looking into the matter last June after being alerted to the book published by Eastern National, a cooperating association that has been working with national parks for 50 years At issue was “whether Jarvis used his public office for private gain by seeking a book deal with Eastern National and whether he misused any U.S. Government resources in the process.”
Ethics Office guidelines specifically state that government employees who want to do outside work with any business or organization seeking to do business with the Interior Department must first gain approval from the Ethics Office, regardless of whether there’s payment involved. Additionally, an attorney in the Ethics Office said “that even if Jarvis was not personally receiving money from the sale of the book, having his name associated with it could create the appearance that he was using his official position for personal gain.”
The investigation also showed that Director Jarvis approached Eastern National with the idea, but that he had told Interior Secretary Jewell that Eastern National had asked him to write the book. It also showed that Eastern National Chief Executive Officer George Minnucci, after discussing the project on the phone with the director, later wrote him an email worded as if the idea was his. In his interview with OIG staff, Mr. Minnucci said Director Jarvis had not asked him to word his email in such a way, but rather he did so because “he wanted his staff to think the book was his idea and that it was ‘a CEO decision.’”
The OIG report (attached below) stated that Director Jarvis said he “did not consult with the Ethics Office on the book because doing so would have taken too long, and with NPS’ centennial approaching, the book would be ‘really powerful.’”
“Jarvis explained that he was frustrated with the Ethics Office for not being able to approve ‘very, very simple things,'” the report stated. “As an example, he explained that a thank-you letter to a donor from him and the Foundation took 6 weeks for the office to approve, which led him to believe that approving the book was going to be a problem.”
In one interview with investigators, Director Jarvis said he wasn’t afraid of taking chances, such as failing to clear the project with the Ethics Office.
I think I knew going into this there was a certain amount of risk. I’ve never been afraid of a risk. . . . I’ve gotten my ass in trouble many, many, many times in the Park Service by . . . not necessarily getting permission . . . I’ve always pushed the envelope. . . . And I felt that this values analysis . . . could be a very, very powerful tool to not only connect to the next generation but to resonate across political spectrums. 
“And from my view, from my experience, in the ethics world, having been an SES [Senior Executive Service employee] for almost a decade, I did not feel like I was violating any ethics issues because I set this up [with] no personal benefit, nothing gained for me personally,” he continued. “What I was trying to prevent is having it edited.”
While Director Jarvis did not seek to be paid for the book, and directed that any royalties go to the National Park Foundation, there was concern among some Interior officials that he retained the copyright to the title and allowed the use of the Park Service arrowhead logo on the cover and his title as Park Service director in places, “giving the appearance of Government endorsement.”
In the end, it doesn’t appear as if there will be any royalties for anyone. Eastern National officials told OIG investigators that while it had cost them $11,000-$12,000 to print the $7.95 book, they had only sold a little more than 200 copies and they didn’t expect to make their investment back.
The investigation determined that Director Jarvis used his government iPad to write the manuscript; while he claimed to have worked on it outside office hours, the investigation determined that “it appears” there were at least nine occasions when Director Jarvis worked on it or corresponded with Eastern National officials concerning the book “on weekdays when he was not on leave and Government offices were open.”
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