2016 CPANP Letterhead Logo

May 15, 2016

Reginald Chapple, Division Chief
Office of Partnerships & Philanthropic Stewardship
National Park Service
1849 C Street NW
Washington, DC 20240

Subject: 45-day review draft of Director’s Order #21: Philanthropic Partnerships

Dear Mr. Chapple:

I am writing to you on behalf of over 1,100 members of the Coalition to Protect America’s National Parks (Coalition).Our membership is composed entirely of retired, former, or current salaried employees of the National Park Service (NPS). As a group, we collectively represent more than 30,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. We are writing to comment on the 45-day review draft of Director’s Order #21: Philanthropic Partnerships (hereafter referred to as DO).

General Comments

  1. In general, the Coalition supports the intent of leveraging additional donations and reducing some burdensome and bureaucratic barriers to fundraising efforts, particularly at the park level. However, we are concerned the DO undermines the importance of appropriations, mandates additional duties for park staff, and begins to send parks and the NPS down a road of increased commercialization.
  1. Based on the revised DO as a whole, it is difficult for us, despite our extensive NPS experience, to understand exactly what it is that NPS is trying to accomplish with the proposed changes in policy. Is it to improve institutional controls of philanthropic partnerships, including Regional Office and Washington Office level oversight of park-based fundraising efforts? Is it intended to streamline fundraising procedures and requirements in a way that facilitates corporate fundraising at the national level (e.g., through NPF) and/or fundraising at the park level? Is it some combination of the above? To be frank, the DO appears to make it easier for high-level (e.g., NPF) fundraising but more difficult for park-level fundraising. And some aspects of the DO would allow greater corporate “presence” in parks in return for major donations, which raises obvious concerns about increasing commercialization of parks and the erosion of the public perceptions regarding the NPS’s image and integrity. While there are references to “ethics” and “integrity” dispersed throughout the document, we believe that NPS should provide a much stronger “foundation statement” at the very start of the DO to communicate its underlying fundraising goals and philosophy. Such a statement would provide a much more effective context for understanding the policy guidance that follows. See comment below about Line 11 for a specific recommendation.
  1. Based on its title, one would expect this DO to be mainly about “Philanthropic Partnerships.” Section 3.2 of the DO defines “Philanthropic Partners” as “any entity – including non-public entities (such as nonprofit organizations and friends groups), for-profit corporations, fundraising networks, crowdfunding organizations, and individuals – that has an agreement TO FUNDRAISE OR OTHERWISE GENERATE DONATIONS (emphasis added) on behalf of the NPS.” However, in reading through the DO it clearly addresses other aspects of partnering and partnerships completely unrelated to fundraising. We believe NPS should avoid “scope creep” and keep this DO focused on only the philanthropic aspects of such relationships.
  1. Reference Manual 21 (RM-21) is mentioned 26 times in the DO; generally, in the context of “RM-21 provides additional guidance (or procedures and forms) for [this activity]…” However, an updated version of RM-21 is not available for review. This makes it impossible to comment about the adequacy of the 26 sections of the DO that refer to RM-21 without knowing if RM-21 will adequately fill in gaps that exist in the DO. This comes across as NPS saying “trust us; we’ll take care of it in the RM.” Given the high profile nature of philanthropic fundraising in parks, we believe NPS needs to be more transparent and provide more information about how legitimate concerns regarding the DO will be addressed in the RM.
  1. The DO often lacks “symmetry” between “do’s and “don’ts” and between respective NPS and partner roles and responsibilities, resulting in gaps in policy that leave open to broad interpretation what would or would not be allowed (such as what types of donations would or would not be accepted). We will point out some of the former instances in our comments below. An example of the latter is that while NPS expects philanthropic partners to be accountable for appropriate use of and proper recordkeeping related to donations received, there is no clear statement regarding NPS responsibilities for ensuring that donations it (NPS) receives are likewise spent in accordance with the partner’s or donor’s wishes. In general, NPS must hold itself to similar accountability requirements as the partner; and the respective accountability standards for each should be made clear in the DO.
  1. We have some concerns about choice of words. In a number of places the DO is inconsistent in its use of possessive pronouns (“its” and “ours”) used when referring to NPS employees or partners as “its” employees or partners vs. “our” employees or partners. In general, “NPS” is used as a collective (or singular) noun throughout the document, which means that “its,” as a singular possessive pronoun, is the most appropriate form to use in the context of the DO. In our specific comments below, we have identified some locations where “ours” should be changed to “its.” However, we are not confident that we have identified ALL locations where the correction is needed; and therefore recommend that NPS carefully review the document and make all necessary corrections.
  1. The way that some sections of the DO are written implies that the NPS intends to, or foresees the possibility it would, solicit funds or conduct fundraising campaigns itself, rather than only indirectly through the partner. Does NPS intend to do so? The language regarding NPS’s role in fundraising must be clear and consistent throughout the document. See comment below at Lines 141-144.

Specific recommendations

Line 11: At the beginning of the DO, NPS needs to establish a stronger foundation statement regarding the importance of conducting philanthropic partnerships in a manner that is widely perceived as both ethical and appropriate, and in a manner that avoids fundraising situations that would appear to compromise NPS’s integrity or would otherwise reflect poorly on the NPS. In Section 1.1, we recommend inserting a new second paragraph, as shown below, which would make the current second paragraph the third paragraph, etc. The suggested new second paragraph is as follows:

In keeping with National Park Service Management Policies 2006, Section 1.10 Partnerships, the Service will embrace partnership opportunities that will help accomplish the NPS mission provided that personnel and funding requirements do not make it impractical for the Service to participate and that the partnership activity would not (1) violate legal or ethical standards, (2) otherwise reflect adversely on the NPS mission and image, or (3) imply or indicate an unwillingness by the Service to perform an inherently governmental function.

Line 20: After “agreements,” add “provide for philanthropic opportunity while exercising…”

Lines 141-144: Section 3.1.2 describes “General Prohibition on Solicitation by Employees.” While NPS employees are generally prohibited from soliciting donations, this section would exempt the Director and Deputy Directors from this general prohibition and allow them to “solicit donations, directly or indirectly from private individuals or organizations for the NPS and its programs.” Presumably, such soliciting would focus primarily on major donations; nonetheless, it is not an appropriate role for the three highest ranking NPS officials, and can create the appearance of a conflict of interest. We can envision a variety of situations in which this will be a significant concern. Although NPS employees at any level should not solicit donations, we believe it is appropriate for NPS officials, including the Director, Deputy Directors, and superintendents, to participate with philanthropic partners in “donor cultivation” meetings with prospective donors and to serve as the NPS subject-matter experts in providing helpful context and content as the partner solicits donations. (The DO describes this role for superintendents in Section 3.1.11.)

Line 200: Although donations or sponsorships by Concessioners may be entirely altruistic, it has the appearance of allowing a company to influence the NPS in their favor for consideration for a contract. This should be avoided.

Line 209: The table describes “Delegations of Authority and Thresholds…” The respective delegations of authority and thresholds are reasonable and appropriate, except that we do not think the NPS Chief Financial Officer (CFO) should have any authority whatsoever to authorize or accept donations or approve agreements given the CFO’s control responsibilities listed in lines 288-304. This is a clear conflict of interest. The CFO is a control position regarding philanthropic activity and must not mix that with authorizing and/or accepting money or other goods or services of value.

Line 209: Same table as above. In the bottom section of the table, below the “Superintendent” line, the last sentence says that if a superintendent is delegated authority following training and certification in one region the authority does not move to another region if that superintendent transfers. Elsewhere the DO stresses that the delegation of authority lies with the individual, not the position. Why then should the NPS engage in the extra bureaucracy of having to rectify if she/he changes regions? Why cannot the NPS act nationally rather than as seven separate organizations when it comes to such an important subject that must have servicewide consistency? We believe that a certification by the NPS to an individual superintendent should follow that individual no matter where he/she serves as a superintendent.

Lines 210 – 219: Section 3.1.4 describes “Philanthropic Competencies and Skills.” Lines 213-214 state that “authorized NPS employees will be REQUIRED (emphasis added) to complete a training certification program…to develop the knowledge base and skills for success in philanthropy and partnerships;” then Line 215 indicates the “training and certification program will also BE AVAILABLE (emphasis added) to key partner staff.” While the intent behind the proposed training and certification program is admirable, unless the training is regularly and readily available for the people who need it when they need – a shortcoming of many existing NPS training programs – such a requirement is not practical and will not facilitate the establishment of, or improve the efficiency of, philanthropic partnerships. It will only serve to make it more difficult for such partnerships to get off the ground. This is also a concern about “symmetry” as it is unclear if the partners will be REQUIRED to attend the training or not. We suggest that NPS provide more detailed information about the proposed training program in the pending RM-21. Ideally, it must be a more reasonable requirement than the current wording portrays.

Line 262: Should read “Coordinate philanthropic partnerships…” The DO is ONLY about philanthropy, and its language should be consistent about this throughout.

Line 309: Should read “Encourage park and program philanthropy…” Other partnership activities are not the subject of this DO.

Line 310: Should read “Coordinate philanthropic partnerships…”

Line 325-326: The sentence as written implies that ALL superintendents, whether they have philanthropic activity or not, must take the training. We suggest the wording be revised to say “All superintendents ENGAGED IN PHILANTHROPIC ACTIVITY must take the training…”

Lines 327-343: Section 3.1.11 describes “Superintendents.” As written, this section implies that ALL superintendents will engage in fundraising activities, which seems inappropriate to us. Line 328 should be revised to state: “Superintendents ENGAGED IN PHILANTHROPIC ACTIVITIES will…”

Line 340: Determination of what? Where is “determination” defined?

Line 342: Insert “philanthropic” before “partnership.”

Line 345: Quotation marks are not needed around donor cultivation. This is an accepted and common term in the field.

Line 350: After “partners” add “including philanthropic partners.” Again, this particular DO should remain focused on “philanthropic partners.”

Line 351: Revise to read “…about partnership (not partnerships) issues, including philanthropic, to the…”

Line 353: Add at the end “including philanthropic partnerships.”

Line 356: Add at the end “including philanthropic.”

Line 359: Why is the Council not named the “NPS Philanthropy and Partnerships Council” since the office is named the “Office of Philanthropy and Partnerships”?

Lines 366-388: Section 3.2 describes “Philanthropic Partners” roles and responsibilities. Whereas Line 328 states “Superintendents WILL” do the items listed in lines 329-343, Line 371 states “NPS philanthropic partners MUST” do the items listed in lines 372-375. But then line 377 states “Philanthropic partners SHOULD” do the items listed in lines 378-388. The variability in the wording is confusing and suggests intended distinctions that are not clear. Is there a difference between “NPS philanthropic partners” and “Philanthropic partners”? If so, what is the difference? If the Superintendent is required to do the items listed, why isn’t the philanthropic partner required to do their respective items?

Line 382: The word “program” at the end of the line should be deleted.

Line 395: Section 3.3 describes “Cooperating Associations.” Line 395 refers to a “Strategic Fundraising Agreement.” Are the requirements for a partner in this kind of agreement and in a Philanthropic Partnership Agreement that allows fundraising exactly the same? They must be, both for legal and equality reasons.

Line 398: Why is the term “(gifts)” added here? Are not both donations and gifts the same in this context?

Line 406: The words “helps us” at the end of the line should be “help it” since it refers to the NPS, not a plural or personal entity.

Lines 412-429: Section 4.1 describes “Types of Support Accepted by NPS.” Such a list is inherently incomplete and whatever is not listed can generate more questions than what is specifically listed. To improve clarity and provide “symmetry,” we recommend that section 4.1 be immediately followed (e.g., at Line 430) by a new Section 4.2 regarding “Types of Support Not Accepted by NPS” (then renumber subsequent sections accordingly). Although information about types of donations that would not be accepted is located at various places later in the DO, it would be much clearer to establish both sets of criteria here.

Line 419: We strongly recommend against the NPS accepting easements unless it is prepared to defend them and monitor them. Consider the Green Springs, VA example. Instead, encourage that easements be given to a local or national group that has the capacity to manage them.

Line 421: Does intellectual property include trademarks? Given the current situation regarding trademarks, would it not be appropriate to specifically settle the issue in this context here and now?

Line 425: “The NPS” should be added to the start of the line, as in “The NPS, parks, NPS programs…” This is important because the Director and Deputy Directors are neither “parks” nor “programs,” yet they are authorized to accept donations of over $5M. They are the “NPS.”

Line 427: Since donations may include property or other items of value rather than cash, add “or value” to “amount of the donation” so it reads: “amount or value of the donation.”

Line 429: Similar to the above comment, add “or value” at the end of the sentence.

Line 445: We suggest adding the following phrase after the word “procedures”: …“including those required to comply with federal law or regulation.” Doing so makes it clear that work such as preparing legally required documents such as an EIS, etc. can be paid for.

Lines 449-455: Section 4.3 describes “Fundraising Campaigns.” Despite the statement in sub-section a) that fundraising campaigns must “be consistent with NPS purpose, mission, and goals,” there is little anywhere else in the DO to indicate that NPS places high value on partnering with donors who are recognized for their environmental leadership and social responsibility. It is one thing to avoid relationships that could cast NPS in a negative light, which is the general perspective presented throughout the DO; it is equally, if not more, important to seek partnerships and donor relationships that are so completely positive that it enhances both the image of the partner or donor, as well as the NPS image. Toward the end, at line 454 (in sub-section b), we suggest NPS insert a new bullet along the lines of: “fundraising campaigns that identify NPS with healthy products and activities, environmentally and climate friendly products and service, or socially responsible corporate programs are preferred.” This will provide “symmetry” to the next bullet in that section (see next comment).

Lines 454 and 455: The bullet regarding “fundraising campaigns that identify the NPS with tobacco, and any type of illegal product will not be authorized” raises more questions and concerns than it resolves, both by what is stated and what is not stated. Does this mean that NPS would accept donations from sources that are closely identified with (or would identify NPS with) adult products and services, such as any/all kinds of alcoholic beverages, gambling, firearms, and certain pharmaceutical products? Would NPS accept donations from sources closely identified with environmentally or climate unfriendly industries, such as uranium mining or oil and gas development? Would NPS accept donations from marijuana sellers in states where it is legal? NPS, because of its environmental leadership responsibilities, should aspire to engage in highly positive relationships, rather than simply avoiding negative ones. This is why NPS needs to establish a clear list of “Types of Support Not Accepted” as suggested above in the comment about Lines 412-429.

Line 459: Add “the NPS,” before “national parks.”

Line 483: Does or will the NPS itself actually “engage” in cause-related marketing in partnership with philanthropic partners? Should this say “NPS may authorize partners to engage in cause-related marketing on behalf of the NPS as part of philanthropic partnerships”?

Line 492: Will cause-related marketing campaigns actually “be designed” (as stated on line 492) by the Office of Partnerships and Philanthropy (OPP)? Will OPP contract to design such campaigns? We doubt that will be the case and suggest that “be designed and vetted” (by OPP) be replaced by “be reviewed and approved” (or reviewed and authorized”).

Lines 496-510: Section 4.4.2 describes “Corporate Social Responsibility (CSR).” In general, we strongly support the idea of NPS associating itself with socially and environmentally responsible corporate partners and donors. As stated previously, NPS should aspire to engage in highly positive relationships, rather than simply avoiding negative ones. However, the intended purpose of this section is not clear and much of it written in an awkward “voice” making it sound as if NPS is doing prospective partners a favor by allowing them to fulfill their CSR goals at a park (e.g., Lines 499-505: “The NPS is a potential partner for companies with a commitment to CSR …the NPS can educate corporate leaders and employees about the National Park System and NPS programs…Corporate engagement [with the NPS] could lead to employee volunteer service days, donations to NPS initiatives through financial 504 contributions, employee donation matching programs, and pro bono expertise.”). Chances are that any well-regarded socially responsible company has plenty of other partnership options and could teach NPS a thing or two about effective environmental leadership (e.g., Subaru’s “zero landfill” program), encouraging healthy outdoor recreation, or improving diversity among park visitors. This entire section should be re-written in a more proactive and positive light opening with the fundamental premise that “the NPS places a high value on partnering with outstanding environmentally and socially responsible businesses whose corporate values and actions are strongly consistent with those of the NPS. In their best form, such relationships are synergistic and enhance the image and success of both the NPS and its socially responsible corporate partner.” Then get into the nuts and bolts of what the respective benefits of the relationship might be.

Line 504: Insert “corporate” before “employees” to be clear whose employees are being talked about.

Line 509: Change “should” to “will” to ensure consistent implementation of donor recognition plans by individual superintendents or program managers. Otherwise, following the plan appears to be discretionary, which could open NPS to criticism.

Line 515: Change “our” to “its.”

Line 519-521: We recommend removing the list of professionals that starts on line 519, and substituting the following: “…expertise of any appropriate profession or trade needed to effectively manage parks and programs.” Doing so prevents anyone from having angst that their profession or trade was not mentioned and makes it clear that all are equal.

Lines 531-534: The paragraph lists several potential sources of visitor names and contact information, but does not mention accommodation (i.e., lodging) registrations. Of course, names from such registrations also cannot be given out without specific permission from the visitor, but by leaving it out of this list, the NPS will immediately get many who ask if this means that information about accommodation registrants can be shared. Be specific and don’t create a make-work project for the NPS. We realize that everyone should know the answer by now, but we know board members of friends groups who will immediately start asking again if the document is not clearly explicit. They do not want to give up because this would be the best way for them to enhance solicitation lists.

Line 580-583: Section 4.6.3 describes “Checkout Counter Donation Program.” It is not clear if NPF will retain any portion of a park’s Checkout Counter Donations as “administrative costs,” “handling fees” or “overhead.” While we understand the general reasons for having NPF become the “bank” for handling and distributing such donations, the Coalition strongly believes that 100% of Checkout Counter Donations should be returned for use at the park-of-origin. Visitors making such donations do so believing their donation will be used to help the park they are visiting. To avoid the appearance that NPF is inappropriately taking a cut out of park-specific donations, we strongly recommend that wording be added to line 583, after “…checkout program.” and before “Older practices…”: (add) 100% of such donations will be returned to the respective park-of-origin for the donation(s).”

Line 592: We suggest revising the line to read “Many of these new methods mimic traditional ways of giving, including donation boxes.” We suggest this because the ways of giving continue to evolve, and tradition is not just limited to donation boxes. Be as inclusive as possible!

Lines 599 and 609: Line 599 states: “Partners may use SOME (emphasis added) of the funds…,” while line 609 states: “Partners may use AN APPROVED PORTION (emphasis added)of the funds.” We recommend using the language of line 609 in both places.

Line 621: It would be of value to add at this point that if IRS questions the value of a donation, it is an issue between the IRS and the donor, and not with the NPS.

Lines 622-634: Section 5 describes “Donor Review.” The DO states that, “The NPS will review (vet) ALL (emphasis added) proposed donations or gifts, and their circumstances, before acceptance.” As written, this statement appears to apply to ALL donations or gifts “regardless of value,” which presumably could include small, often anonymous donations. If that is the NPS intent, the policy is unrealistic. We recommend that NPS specify monetary or value thresholds for significant philanthropic donations and the respective approval authorities for vetting and approving such donations, consistent with the guidance offered elsewhere in the DO.

Lines 622-634: Related to the same section as above, it is a common perception among NPS fundraising partners that the current vetting process for medium-to-larger donations is already a problem due to the amount of time it often takes, which can keep prospective donors “on hold” for significant periods of time and thereby discourage a donation when a donor is inspired to make one. The proposed policy does nothing to improve this situation. While we completely understand the need for NPS to avoid the appearance of impropriety in the donations it accepts, for there to be an effective philanthropic fundraising program THERE NEEDS TO BE AN EFFICIENT AS WELL AS EFFECTIVE VETTING PROCESS! Unfortunately, the DO does not provide one. In addition to the delegation of approval authority and thresholds described in the table at Line 209, NPS needs to establish reasonable and reliable time frames for approval (or non-approval) decisions, especially at the Regional Office and WASO OPP levels, where the current concerns seem to lie. Absent an efficient vetting process, NPS and its philanthropic partners will continue to miss opportunities that are ripe for significant donations.

Line 626: We suggest a bullet prior to this line that reads, “Ensure that the item proposed for donation is of value to the NPS.”

Lines 635-650: Section 5.1 describes “Acceptance Considerations.” Consistent with our comments about Fundraising Campaigns (see Lines 449-455 above), a new sentence should be added at the beginning of the section (i.e., immediately before “The NPS generally will not accept a donation that…”). The suggested new sentence would be: “The NPS prefers donations from sources that would identify NPS with healthy products and activities, environmentally and climate friendly products and services, or socially responsible corporate programs.” This will improve provide clarity and context for the section that follows about what donations NPS will not accept. Aspire to engage in highly positive donor relationships, rather than simply avoiding negative ones. Also, there appears to be a formatting error and missing content in the transition from Section 5.1 to 5.1.1.

Line 638: We suggest that it be made crystal clear that “direct donations” means “direct donations to the NPS.” We realize that the context suggest this is the case, but suggest you add “to the NPS” to be fully clear.

Lines 639 – 647: Are there any circumstances under which the reasons listed for NPS declining direct donations would or could apply to NPS declining direct donations from philanthropic partners? If yes, how would NPS handle the proposed donation?

Line 643: Section 5.1 describes “Acceptance Considerations.” Are there guidelines anywhere that define or provide context for determining “sources that would generate controversy…inconsistent with NPS mission?” If not, there should be. Think, for instance, of a uranium mining company operating near a park; or an air tour company that operates close to but not over a park and is not constrained by an air management plan; or companies that sell “adult products,” such as tobacco, alcoholic beverages, firearms, and certain pharmaceuticals. Lacking clear guidelines, the incentive to “accept the money” from any “legal” source that is not outwardly “anti-park” can overwhelm thoughtful judgment about how much controversy is acceptable. Aspire to engage in highly positive donor relationships, rather than simply avoiding negative ones.

Line 644: Change “our” to “its.”

Lines 648 – 650: We understand the reasons behind the proposed change in NPS policy that would allow NPS to “permit—after thorough review—philanthropic partnerships with, and accept donations from, corporations that produce or distribute alcohol.” Basically, it is about the money; and, frankly, this strikes us as an obvious attempt to retroactively legitimize the Budweiser donation. If NPS is, in fact, going to accept donations from “from corporations that produce or distribute alcohol,” then NPS must establish a much better defined criteria for determining when to accept (or not accept) such donations AND what the donations would be used for. For example, should a high-profile liquor manufacturer’s donation be used and publicized as sponsoring a park youth program or a family-oriented special event such as an Earth Day, the 4th of July, or Founders Day celebration? What impression would such highly visible donor recognition (“this event sponsored by…”) have on the children and parents present? Is that really the image NPS wants to convey?

The NPS image matters, so please don’t dilute the positive image NPS has earned through many decades of caution regarding appropriate “sources” of donations. NPS should have higher standards (or at least some standards, since there are none in the DO) when it comes to the acceptance and use of donations from corporations that are primarily known for producing or distributing alcohol because of the potential controversy and negative publicity surrounding the acceptance of such donations (e.g., the Budweiser donation). We recommend that NPS add a new sentence (at the end of Line 650) that states: “NPS acceptance of such donations will be limited to corporations that have a demonstrated commitment to protecting the environment, promoting healthy products and activities, AND have an established corporate social responsibility (CSR) program.” Aspire to engage in highly positive donor relationships, rather than simply avoiding negative ones.

Line 790: At the end of the line, add “but not limited to.”

Line 818 – 821: Does this apply only to events raising money that comes directly to NPS or does it include money coming to NPS from a philanthropic partner? The format of this DO differentiates between the two throughout, and needs to be consistent in doing so throughout.

Line 882: Regarding the phrase “Upon termination of an agreement,” does this mean only when there is final termination of an agreement not to be renewed, or does it mean to include at the termination (or expiration) of an agreement that is going to be renewed and/or renegotiated as well? We assume it means the former, but it is not clear.

Lines 992 – 996: The $500K standard was set decades ago, when $500K had a great deal more buying power than it does today. We suggest that NPS consider a more reasonable standard, either using a fixed threshold (such as $1.0M); or an “index” standard that is revised periodically, say every five years, based on changes in construction costs.

Line 1023: Change “our” to “its.”

Lines 1176-1185: Section 8.5.2 describes “Suggestions for In-Park Recognition.” In general, we strongly support providing meaningful donor recognition, as long as it is appropriate. However, some of the DO’s donor recognition language should be clarified so that there are sufficient restrictions preventing commercialization of parks. We are specifically concerned with the NPS proposal starting on Line 1126 that would authorize “the temporary naming of rooms and interior spaces in NPS facilities…to recognize donations for the renovation of an existing facility or construction of a new facility.” While we understand the intent of providing significant donors with tangible, on-site recognition for supporting major facility improvements, we believe that “naming of interior spaces in facilities” violates the spirit and intent Section 3054(b) of the National Park System Donor Acknowledgment, which states, in part: “… donor acknowledgment will not be used to state or imply…naming rights to any unit of the National Park System or a National Park System facility (emphasis added), including a visitor center.” The significant amount of negative publicity already generated by the NPS “naming rights” proposal should tell NPS how the American public views the perceived commercialization of park facilities or portions of those facilities. NPS should avoid granting “naming rights” under any circumstances, regardless of the significance of the donation. Instead, use any (or any combination) of the other suggested methods listed in this section (e.g., donor boards and walls that are “integrated into the planning and design of any new facility or renovation of an existing facility”). For large donations that are instrumental in the development of a new facility or major renovation of an existing facility, we recommend that the donor recognition be left in place for the lifespan of the facility.

In closing, we appreciate the need to improve the NPS philanthropic partnership process; and believe that, while the draft DO is a step in the right direction, it has many significant shortcomings that need to be addressed to make it more effective for both the NPS and its philanthropic partners. Thank you for the opportunity to comment on this important policy guidance.




Maureen Finnerty, Chair
Coalition to Protect America’s National Parks