Director’s Order #21: Donations and Fundraising
Approved: Fran P. Mainella
Effective Date: May 1, 2006
Duration: Until revised or rescinded
1.0 Background and Purpose
1.3 Related Sources of Guidance
1.4 Activities not Subject to this Director’s Order
2.0 Authorities and Constraints
2.1 NPS Authority to Accept Donations
2.2 No Solicitation of Donations
2.3 Employee Representations
2.4 Congressionally Authorized Fundraising Organizations
3.0 Policies and Considerations
3.1 Ethical Considerations
3.2 Matching Funds/Challenges
3.3 Accountability for Donations
3.4 Annual Reporting Requirements
4.0 Delegations of Authority
4.1 Functional Management and Day-to-Day Implementation
4.2 Reservations and Delegations of Authority to Accept Donations
4.3 Reservations and Delegations of Authority to Authorize Fundraising and Corporate Campaigns
5.0 Roles and Responsibilities
5.1 National Park Service
5.2 Fundraising Partners
6.1 Considering Donations
6.1.1 Maintaining the Integrity and Impartiality of, and Public Confidence, in NPS and Department of the Interior
6.1.2 Reviewing Direct Donations
6.1.3 Director’s Approval
6.1.4 Acceptance of Donations from Donors Involved in Litigation
6.2 Use of Donations
6.3 In-Park Friend-raising
6.3.1 Donation Boxes
6.3.2 Displays and Fundraising Activity Information
6.3.3 In-Park Events
6.3.4 Guest Donation Program
6.4 Donations of Land
7.0 Corporate Campaigns
7.1 Corporate Campaign Agreements Undertaken in Association with the National Park Foundation
7.1.1 Proud Partner Marketing Exclusivity
7.2 Park-Based Corporate Campaigns
8.0 Fundraising by Outside Entities
8.1 Thresholds and Agreements
8.2 Contents of Fundraising Agreements
8.3 Determination of Feasibility for Fundraising Success
8.4 Fundraising Plans
8.5 Review of Contributions
8.6 Fundraising Costs
9.0 Construction – Partnership Construction Projects
10.0 Donor Recognition
10.1 Off-Site Donor Recognition
10.2 In-Park Recognition
10.2.1 Credit line including logos or name script
10.2.2 Credit line
10.2.3 Donor Board and Walls
10.2.4 Recognition of Corporate Donations
10.2.5 Recognition within Interpretive Programs
10.2.6 In-Park Displays, Name Plaques and Plates
10.3 Donor Recognition Plan
10.4 Special Events
10.4.1 NPS Sponsored and Co-Sponsored Events
10.4.2 Non-NPS Events
1.0 Background and Purpose
1.1 Background. The National Park Service (NPS) recognizes private philanthropy as both a noble tradition for national parks and a vital element of the success of today’s National Park System. Some national parks exist only because motivated citizens contributed time, talent and funds to create them. Gifts of land or easements have enlarged many parks. Donated artifacts are found in visitor centers and museums across the nation. The NPS actively engages the help of park-oriented philanthropies and supporters and enthusiastically welcomes them as partners in the stewardship of the properties entrusted to our care.
Donations come to the NPS from individuals, families, organizations, foundations, corporations, businesses, and other entities purely as expressions of support, as a result of a donor’s awareness of needs, or in response to an organized fundraising campaign by others. Donations are used to enhance NPS programs and to help achieve excellence. Donations are not to be used as offsets to appropriated funds or to meet recurring operational requirements. The NPS appreciates the generosity of those who donate directly, and those who work through authorized non-profit organizations which raise funds for the benefit of the park units and programs. For the purposes of this Director’s Order, these organizations, individuals and entities are collectively referred to as “NPS partners.”
The policies and procedures in this Director’s Order are intended to serve as the framework for NPS employees’ conduct in relation to donation activities and fundraising campaigns which benefit the NPS. Through their application, the NPS seeks to ensure the integrity and appropriateness of donations and fundraising activities. While the NPS does not regulate fundraising or the donation activities of third parties, fundraising conducted in its name is appropriate only when consistent with the mission of the NPS and the standards included in this Director’s Order.
1.2 Purpose. The purpose of this Director’s Order is to:
· Set forth the Director’s delegation of authority regarding donations and fundraising;
· Establish roles and responsibilities for NPS employees who work with donors, fundraising partners, and potential donors;
· Identify plans and agreements relating to philanthropic activities and explain when they are required to be used;
· Establish criteria for consideration in accepting of donations; and
· Provide general guidance on appropriate forms of donor recognition.
This Director’s Order is to be used by NPS employees in tandem with the Reference Guide to Donations and Fundraising (Reference Guide).
The NPS recognizes that each park and partner is unique and that a “one size fits all” approach does not work. This Director’s Order is intended to provide the needed flexibility in working with our partners from the start up organizations to those with years of demonstrated success. Any questions about the interpretation of the provisions of this Director’s Order may be addressed through the Regional Partnership Coordinators and National Partnership Office as appropriate.
This Director’s Order is intended only to improve the internal management of the NPS. It is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or equity by a party against the United States, its departments, agencies, instrumentalities or entities, its officers or employees, or any other person.
1.3 Related Sources of Guidance. Related sources of guidance are identified in the Reference Guide.
1.4 Activities Not Subject to this Director’s Order. The following activities are not subject to this Director’s Order:
(a) Services of individual volunteers or groups of volunteers, e.g., a Girl Scout troop, under the NPS Volunteer-In-Parks program, authorized by the Volunteers in the Parks Act of 1969 (16 USC 18g – 18j);
(b) A person’s or an entity’s share of costs where there is independent authority for such cost sharing, e.g., challenge cost-share programs where the partner does not engage in public fundraising;
(c) Moneys received as fees for services;
(d) Reports or analyses prepared or paid by outside parties, or funds received by the NPS for such purposes, pursuant to appropriate authorities, e.g. a NEPA analysis funded by an applicant;
(e) Donations of official travel covered by 31 U.S.C. § 1353 for attendance at a meeting or similar function;
(f) Donations associated with the exercise of NPS regulatory authorities, such as where mitigation measures involve the donation of interests in land to be used by the NPS for conservation purposes;
(g) Gifts to individual employees that are separately governed by the Government-wide Standards of Ethical Conduct at 5 CFR Part 2635; and
(h) Commercial services including sales of items inside a park.
2.0 Authorities and Constraints
2.1 NPS Authority to Accept Donations. The authority for issuing this Director’s Order is contained in the NPS Organic Act (16 U.S.C. §§1-4). General authority to accept donations is found in 16 U.S.C. § 6, which expressly authorizes NPS to accept donations for purposes of the National Park System. Various additional authorities to accept donations exist and may, for example be contained in a Park’s authorizing legislation. The Partnership Legal Primer (www.doi.gov/partnerships/partnership_legal_framework.html) identifies many of the additional NPS authorities to accept donations. For purposes of this Director’s Order, the term “donation” includes “gifts” and refers to something of value (cash or in-kind goods or services) received from an outside source without consideration or an exchange of value. Funds or other items received as a result of a competitively awarded grant from a foundation are also covered by the term “donation.”
The NPS may accept donations from individuals, families, organizations, foundations, corporations, businesses, associations and other entities. Generally, NPS may accept donations of funds, securities (common stocks, preferred stocks, bonds), real property (land and improvements), or interests in real property (easements), facilities, and in-kind goods or services. For information on whether a particular donation should be accepted or for further information on authorities and constraints see Section 6.1 of this Director’s Order and Section 1.3 of the Reference Guide.
2.2 No Solicitation of Donations. It is NPS policy that its employees not solicit donations. The term “solicit” means any request by an NPS employee to a non-federal entity, group or individual for donations to be made directly or indirectly to the NPS in support of its programs. There are, however, a broad range of appropriate activities that NPS employees may undertake in relation to authorized fundraising by park partners as well as, for example, in responding to inquiries from park visitors, see Section 5.1.
2.3 Employee Representations. Employees are not to portray Congress, the Department, or NPS as having failed to meet their responsibilities. Furthermore, consistent with anti-lobbying provisions such as 18 U.S.C. § 1913 and applicable appropriations acts, employees shall not engage in lobbying activities.
2.4 Congressionally Authorized Fundraising Organization. Congress occasionally charters non-profit partners or recognizes the role of an existing non-profit partner through legislation. In 1967, Congress, in the National Park Foundation Act, chartered the National Park Foundation as the official national, non-profit fundraising partner of the NPS to encourage private gifts for the benefit of the NPS and thereby to further the conservation of natural, scenic, historic, scientific, educational, inspirational or recreational resources for future generations. In addition to the National Park Foundation, Congress has authorized several other entities as fundraising organizations for specific units or programs of the National Park System. Unless otherwise specified herein, the provisions of this Director’s Order apply equally to NPS’ dealings with all of its partners regardless of how they were created.
3.0 Policies and Considerations
3.1 Ethical Considerations. NPS employees are also subject to ethics regulations which generally prohibit federal employees from using their official title, position, or any authority associated with their public office to endorse products, services or enterprises. However, this does not prohibit an NPS employee from expressing support for the authorized fundraising efforts of non-profit support groups, including friends groups and cooperating associations. See the Reference Guide for additional information and examples.
Unless specifically authorized by law, an NPS employee may not serve on the board, either as a voting member or non-voting member, including as an ex-officio member, or as an officer of a cooperating association, friends group, or other NPS partner organization that is authorized to raise funds for the benefit of the NPS. However, NPS employees serving as liaisons to partner organizations as part of their official duties, see Section 5.1.r. Liaisons should consult with bureau ethics officials in order to ensure compliance with ethics requirements.
The NPS will not accept funds donated from organizations in which an NPS employee is an officer, director (including ex-officio positions), or is otherwise engaged in a leadership role with the organization, unless the arrangement has been reviewed and approved by the Office of the Solicitor, including the Departmental Ethics Office.
3.2 Matching Funds/Challenges. The NPS may be able to use donated or appropriated funds, subject to conditions imposed on the use of the funds by the donor or Congress, as a match for donations from outside sources. Under written agreements approved by the Solicitor’s Office, NPS may approve the use of such funds as the basis for a “challenge” issued by a non-profit fundraising partner to its donors. All literature associated with this match must also be approved, as appropriate by the NPS Regional Director, superintendent or program manager.
The NPS will not accept donations that impose a fundraising “challenge” to the NPS to match the donation, or that would obligate donated or appropriated funds in advance of their receipt.
3.3 Accountability for Donations. All monetary donations received directly by the NPS must be deposited in a donation account and accounted for and disbursed using the same standards and procedures for appropriated funds. The individual park’s administrative officer, the regional office or NPS comptroller can provide additional guidance.
All non-monetary donations accepted by the park, unit, or program must also be accounted for under the same standards and procedures used to account for other similar government property (see Director’s Order #44 on Personal Property Management or Director’s Order #25 on Land Acquisition). The donor is generally responsible for establishing the value of the item.
3.4 Annual Reporting Requirements. Each NPS unit or program that receives donations must submit an annual report, through the appropriate Deputy, Associate or Regional Director to the National Partnership Office, detailing the cash amount or description of any in-kind donations received directly by the unit or program. At a minimum, for any donation exceeding $1,000 -- whether cash or in-kind --- such reporting must identify the source, the date and the amount of the donation. Additional details and guidance on the content, format, timing and requirements for this report will be provided by the National Partnership Office.
4.0 Delegations of Authority
4.1 Functional Management and Day-to-Day Implementation. The authority for the implementation and oversight of this Director’s Order is delegated to the Associate Director for Partnerships, Interpretation and Education, Volunteers, Outdoor Recreation who is designated as the Senior Manager for matters related to donations and fundraising in the NPS. This authority includes:
(a) Establishing and implementing necessary policies, procedures and standards as specified in this Director’s Order;
(b) Managing, on a day-to-day basis, the NPS relationship with the National Park Foundation; and
(c) Monitoring compliance with this Director’s Order.
Unless specifically addressed elsewhere in this Director’s Order, the day-to-day responsibility for implementation of the policies and standards set forth in this Director’s Order is further delegated to the Chief of the National Partnership Office.
4.2 Reservations and Delegations of Authority to Accept Donations. The following reservations and delegations relate to the acceptance of donations (See Section 6.1 and Section 4.3). For purposes of this section, these limits relate to either single donations or a series of related donations from a single entity, i.e. a pledge paid in installments. All such donations of $2,500 or more must be reviewed in accordance with Section 6.1.2 of this Director’s Order.
Director reserves the authority to accept, or authorize the acceptance of, donations
of $1 million or more offered to a park either directly, or through a park
partner when the donation is to be subsequently granted to a park by the NPS
(b) The Deputy Directors, Associate Directors, and the Comptroller are delegated the authority to accept or authorize the acceptance of donations offered directly to NPS, or offered to an authorized partner for the benefit of the NPS, that are under $1 million and are offered to NPS through its directorates (such as Cultural or Natural Resources), to program areas or offices within their organizations (such as the National Center for Cultural Resources). The above officials may re-delegate this authority to approve and accept the donation to senior program or office managers within their organization.
(c) Regional Directors are delegated the authority to accept or authorize the acceptance of donations under $1 million offered directly to the NPS, or offered to an authorized NPS partner for the benefit of NPS. The Regional Director may re-delegate this or more limited authority to accept such donations to park superintendents or regional program managers.
Subsequent references to “authorized employees” in this Director’s Order refer to those employees who have been delegated the authority to accept donations.
4.3 Reservations and Delegations of Authority to Authorize Fundraising and Corporate Campaign Activities. The following reservations and delegations relate to the authorization of fundraising and corporate campaign activities see Section 6.1 and Section 7.
(a) The Director reserves the authority to authorize agreements relating to fundraising activities by NPS partners that will benefit the NPS if the activities either:
i. Have a goal or $1 million or more;
ii. Involve national or international solicitations;
iii. Involve construction projects where costs are estimated to exceed $1 million; or
iv. Involve corporate campaigns of national or international significance.
Fundraising agreements which meet the threshold for Director’s approval must be submitted with a donor recognition plan, a feasibility study, a fundraising plan as described in Section 8 and a written description of the partner’s donation review process as described in Section 8.5 .
(b) Deputy Directors, Associate Directors and Regional Directors are delegated the authority to authorize agreements relating to fundraising activities that are expected to fall below $1 million to benefit the NPS and corporate campaigns with a partner as described in Section 7 that are below this level and not of national or international significance. If the fundraising or corporate campaign is likely to generate controversy, the delegated official shall consult with the Director prior to approving the campaign. The Regional Director may delegate the authority to authorize fundraising activities to superintendents for campaigns planned to raise $100,000 or less.
5.0 Roles and Responsibilities
Fundraising to support parks is typically undertaken by long-standing, park support groups such as friends groups. Friends groups are non-profit organizations that are generally formed under state law and must comply with state and federal requirements for charitable fundraising as well as standards of professional conduct (see Section 5.2 of the Reference Guide for additional information). Individuals, businesses, or groups such as local service organizations, clubs, and schools may also, from time to time, be authorized to undertake fundraising activities for the benefit of the NPS.
The NPS values the commitment of its non-profit partners and their many contributions to the NPS and the National Park System. NPS employees are expected to develop and maintain professional relationships with these partners based on mutual understanding of the goals and functions of both parties and, when required, appropriate written agreements. Written agreements are required prior to fundraising that explicitly states or implies that the fundraising is authorized by or for the benefit of the NPS as detailed in Section 8. Absent such an agreement, NPS will not accept any resulting donations without the approval of the Associate Director for Partnerships, Interpretation and Education, Volunteers and Outdoor Recreation.
5.1 National Park Service. In general, NPS employees who have been appropriately authorized:
(a) May identify projects, programs, or objectives that are appropriate for private sector support and may describe NPS needs or how donations will be used to potential donors and the public;
(b) May allow the non-intrusive display and distribution of materials in parks to educate visitors about an authorized fundraising partnership or activity;
(c) May provide information, where appropriate, regarding their ability to accept donations in support of their programs;
(d) May develop lists of programs or activities that the NPS could undertake with donated support, and discuss these in interactions with others;
(e) May enter into written agreements with specific NPS partners regarding fundraising for the benefit of a park or project;
(f) May work or participate with authorized nonprofit support groups to solicit to benefit the NPS (e.g. attend events and accompany a partner on visits to prospective donors) subject to any specific limitations contained in this Director’s Order;
(g) May work with organizations and local businesses in co-sponsoring events;
(h) May accept offers to support park activities through co-sponsorship of events by concessioners and others;
(i) Must recognize donors consistent with Section 10;
(j) Must respond in a timely manner to all offers of donations, either accepting or declining the donation consistent with Section 6.1;
(k) Must review and approve all informational materials relating to the partnership with the NPS prior to their distribution;
(l) Must ensure accountability for donations received by the NPS;
(m) Must ensure that fundraising proposed for construction projects is in compliance with the Partnership Construction Process (see Section 9 of the Director’s Order as well as the Reference Guide and www.nps.gov/partnerships/capital_campaigns.htm for additional information), as well as all applicable laws and regulations, such as the National Environmental Policy Act, Section 7 of the Endangered Species Act, and Section 106 of the National Historic Preservation Act;
(n) Must consider, in advance of entering into a fundraising agreement for a project or accepting a donation for a project for a particular use, the costs and any other operational implications of that project that would result;
(o) May apply for competitively awarded grants from foundations and for grants or similar assistance from non-federal governmental entities, in response to a grant application solicitation, in the regularly scheduled grant cycle, or to an organization that accepts unsolicited grant applications or proposals subject to Section 6.1.1;
(p) May support or encourage the efforts of third parties to create park support groups such as “friends” groups whose purposes include raising funds for the benefit of the NPS (see Reference Guide for additional discussion);
(q) May work with non-profit organizations and others to receive donations of in-holdings as well as or other property (e.g. artifacts);
(r) May serve as a liaison to cooperating associations, friends groups, or other partner organizations authorized to raise funds for the benefit of the NPS; and
(s) Must ensure that fundraising agreements comply with NPS goals, policies and plans.
5.2 Fundraising Partners. In general, an NPS fundraising partner:
(a) May work with a park or other organizational unit to engage the public in philanthropy to benefit NPS programs;
(b) Must ensure that fundraising for the benefit of the NPS is conducted in accordance with appropriate written fundraising agreements (see Section 8.1);
(c) May describe NPS identified needs to potential donors and the public;
(d) May hold and manage an endowment for the benefit of park programs when authorized consistent with Section 8.7 of this Director’s Order;
(e) Must send all fundraising and other informational materials referring to the NPS and or the approved fundraising project to the NPS for advance review and approval;
(f) Must work with NPS to ensure that fundraising proposed for construction projects is consistent with Section 9 of the Director’s Order. See the Reference Guide for additional information;
(g) Should work with the park unit to develop and implement an appropriate donor recognition program consistent with Section 10 of this Director’s Order.
(h) Should work with NPS to implement the requirements of Section 8.5.
6.1 Considering Donations. A donation may be offered either directly to a park, unit, or program or indirectly to the partner for the benefit of a park, unit or program. This section provides guidance on the consideration of donations offered directly to the NPS. Section 8 provides guidance for partner review of donations they receive.
Direct donations must be accepted in a legally and ethically appropriate manner. Authorized employees must consider all relevant factors when determining whether to accept a donation, including the value and purposes of the donation, and the nature and interests of the donor. The authorized employee should weigh the totality of the circumstances from the perspective of a reasonable person with knowledge of the relevant facts. Examples of relevant factors to be considered are identified in Section 6.1.1 below.
Furthermore, it is NPS policy to decline direct donations from a company which holds or is seeking a concessions contract or which would identify the NPS with alcohol or tobacco products.
6.1.1 Maintaining the Integrity and Impartiality of, and Public Confidence, in NPS and the Department of the Interior. Before accepting, utilizing or recognizing direct donations an authorized employee must determine that the totality of the circumstances surrounding the potential donation:
(a) Maintains the integrity of NPS and the Department of the Interior’s programs and operations:
i. The donation is not, or does not appear (such as by its size or circumstances) to be, an attempt to influence the exercise of any regulatory or other authority of NPS or the Department with respect to the donor.
ii. The donation meets an actual need of the NPS and would not require NPS to assume funding commitments it is unprepared or unable to accept.
iii. The donation and any conditions or restrictions on it are consistent with, and do not otherwise circumvent, law, regulation, NPS policy, authorized park purposes or applicable park plans.
iv. The NPS is able to properly and effectively utilize or manage any donated real or personal property consistent with policy, programmatic, and management goals.
v. The donation will not be used by the donor to state or imply NPS endorsement of the donor or the donor’s product, service or enterprise.
vi. If the donation involves temporary or term personnel or provides funding to hire temporary or term personnel, such personal services or funds may be accepted provided that such personnel are not responsible for permitting or other regulatory or policy decisions.
(b) Maintains the impartiality, and appearance of impartiality, of NPS, the Department of the Interior, and their employees:
i. The proposed donation is made to a program or made in an amount that would not influence or appear to influence any significant pending NPS or Departmental decision or action involving the donor’s interests.
ii. There is neither an actual nor an implied commitment to take an action favorable to the donor in exchange for the donation.
iii. The donor will not obtain or appear to obtain special treatment in dealing with the NPS, the Department, or any of its other bureaus.
(c) Maintains public confidence in the NPS, the Department and their programs and employees.
i. Acceptance would not likely result in public controversy.
ii. The donation comes only with conditions that are consistent with the NPS’ program and policy goals.
iii. The donation consists of only goods or services needed by NPS.
iv. The proposed donor has no known significant recent history of violations revealed by an Internet search as described in Section 6.1.2. Reviewing Potential Donors).
6.1.2 Reviewing Direct Donations. These minimum requirements shall be met as part of the review process to assure that donations to the NPS are properly evaluated:
(a) For any donation valued at $2,500 or more, the authorized employee must perform a thorough internet search to determine whether publicly available information exists that raises concerns about the propriety of acceptance. See the Reference Guide for additional information
(b) For donations valued at $100,000 or more, the authorized employee shall also refer the proposed donation to the National Partnership Office for coordination with the Office of the Solicitor and the review points of contact for other bureaus. The following information is collected as part of the review process:
i. Whether the donor is involved in litigation or other disputes with the NPS, the Department, or any of its other bureaus;
ii. Whether the donor is currently engaged in or seeking a business relationship with the NPS;
iii. Whether the donor has been debarred or suspended from contracting with the Federal Government;
iv. Whether the donor has a recent public history of violations, whether criminal or civil in nature, as disclosed by an Internet search, for which acceptance of the donation could lead to public controversy;
v. Whether the donor is regulated by or is seeking a permit from the NPS.
(c) For any donation valued at $250,000 or more, the National Partnership Office will also seek the assistance of the Office of Inspector General (OIG) for the purpose of review through its existing information systems.
(d) All proposed donations of land must be referred to the National Partnership Office for coordination with the Land Resources Division.
6.1.3 Director’s Approval. Additionally, the following potential donations must be reviewed by the Chief of the National Partnership Office before subsequent referral to the Director for approval:
(a) Single donations or a series of planned donations, i.e. a pledge paid in installments by the same donor, valued at over $1 million;
(b) Donations that raise significant concerns based on the criteria identified Section 6.1.1;
(c) Corporate donations that are tied to national or international marketing promotions.
The National Partnership Office will coordinate with the Office of Solicitor and NPS or Departmental ethics officials as appropriate.
6.1.4 Acceptance of Donations from Donors Involved in Litigation. The NPS generally will not accept a gift from a donor involved in litigation with the Department or its bureaus in order to avoid any appearance that the donation is intended to influence the handling or outcome of the litigation. There may be circumstances, however, in which the litigation is sufficiently removed from the context of the proposed donation as to not create the appearance of an attempt to influence the litigation. These circumstances, for example, may exist when a donor proposes a donation to the NPS that is clearly unrelated to the litigation with another bureau or in an amount that does not suggest it is intended to influence the handling of the litigation. Accordingly, all donations offered by a donor involved in litigation must also be approved by the Associate Director for Partnerships, Interpretation and Education, Volunteers, and Outdoor Recreation.
6.2 Use of Donations. Donations may be used to fund any NPS activity for which appropriated funds could normally be used, subject to the following:
(a) Donations for employee salaries may be made only directly to the NPS (not to the employee) and may only fund salaries of:
i. Term or temporary NPS employees;
ii. Permanent NPS employees who are directly engaged in a capital improvement project that is funded with donations. This applies only to employees who normally charge their time to project accounts, such as planners, architects, landscape architects, exhibit specialists, and construction supervisors; and
iii. Other permanent NPS employees when through an NPS approved project endowment from which the payment of such salaries is a stated purpose.
(b) Donations will not be used to begin construction, or a phase of construction or other projects or programs, unless there are sufficient appropriated and donated funds in hand to insure completion of the work to a degree that has independent utility. Donated funds may, however, be used to advance project design work.
(c) Donated funds and/or services may pay (or offset) the cost of NPS-conducted or authorized plans or studies provided that standard planning/study procedures, the requirements of the Partnership Construction Process (Section 9), and other applicable policies are followed. Research projects, books, mapping, exhibits, films and all other projects funded with donations must receive the same reviews and approvals do projects that use only appropriated funds.
6.3 In-Park Friend-raising. This section provides information on how the NPS may assist park visitors who seek information on how to make a donation to the park, a park partner, or the NPS. Visitors who have expressed no interest in such information must not be asked for donations by anyone. Direct personal solicitation of in-park visitors is not permitted. Unless visitors have specifically provided authorization (e.g. though an opt-in check box), visitor names from sources such as permit applications, backcountry or campground registrations may not be given to park partners nor may they be disclosed to any third party except as provided under the Freedom of Information Act and the Privacy Act.
Visitors may also specifically request the NPS to provide them with additional information about the NPS, the park, and/or its needs.
6.3.1 Donation Boxes. Donation boxes may be installed on park property by either the NPS or by an authorized NPS fundraising partner provided that 100% of the donations or collections go to the NPS.
Donation boxes must clearly advise the public how the park will use the money. Without this information, moneys collected in a donation box must be considered miscellaneous receipts to the U.S. Treasury.
NPS donation boxes may be placed only on NPS property or on property jointly administered by, or for the benefit of, the NPS. Funds received from NPS donation boxes on jointly administered property (for example, joint visitor centers, heritage areas, or leased facilities outside of parks) must be accounted for in the same manner as those located on NPS-controlled property, see Section 3.4 for additional information. The proceeds from such joint donation boxes will be allocated based on a formula agreed to by those entities in written agreements.
NPS may authorize the placement of an authorized fundraising partner’s (i.e. a friends group or other non-profit park support group) donation box within the park through a written agreement. See the Reference Guide for an example. Such donation boxes may recognize the role of an NPS partner in maintaining the box under its agreement with the park.
6.3.2 Displays and Fundraising Activity Information. Park managers may allow the non-intrusive display or distribution of materials in parks to educate visitors about an authorized fundraising partnership or activity. The material must identify the NPS fundraising partner and inform visitors how they may receive additional information. Materials may include donation envelopes, architectural drawings, models, graphics, newsletters or other similar information.
It is permissible to authorize links from park websites to partner websites that provide opportunities to make electronic donations provided that such linkages conform to Departmental information technology management and security policies, including those pertaining to websites, and are authorized by written agreement between the park and partner.
6.3.3 In-Park Events. Requests from NPS partners to use park facilities for authorized fundraising activities or donor cultivation events are subject to the same review and approval procedures applicable to any other non-NPS user as well as applicable provisions of this Director’s Order. (See also 36 CFR, 2.50-2.51, Section 10.7 of this Director’s Order, and DO #53).
6.3.4 Guest Donation Program. The Guest Donation Program initially authorized national park lodging concessioners to offer guests the opportunity to make donations through the National Park Foundation of $1 or more per day to support the national park they were visiting. The Guest Donation Program has since been expanded to non-lodging activities. Guidance on the program can be found in the Reference Guide.
6.4 Donations of Land. The NPS often receives offers of donations of interests in lands and buildings. Fundraising agreements are required where a non-profit entity, including a land trust, engages in public fundraising campaigns for the express purpose of acquiring specific properties to be donated to the NPS. Fundraising agreements are not required for the general fundraising activities of these entities or for their private fundraising activities.
7.0 Corporate Campaigns
Corporations and businesses generally offer two primary forms of donations: philanthropic donations or donations tied to advertising— the latter are referred to in this Director’s Order as corporate campaigns. The primary difference between the two forms of support is the use of advertising and marketing in corporate campaigns to promote a donation and a relationship between the business and the NPS or an NPS partner. The NPS may accept and recognize philanthropic donations from corporations and businesses under the guidelines set forth in Sections 6 and 10. The NPS may only enter into corporate campaigns under the guidelines set forth in this section.
All corporate campaigns authorized by NPS are subject to the following:
(a) The corporate campaign must generate a clear benefit for the NPS and be consistent with the purpose, mission and goals of the NPS as well as applicable laws, regulations and policies;
(b) Marketing or advertising activities associated with a corporate campaign may not state or imply an endorsement by NPS of any business, product, service or enterprise;
(c) A written agreement between the NPS, a park support organization (when applicable) and a corporate partner must be executed prior to initiation of corporate campaign activities (see the Reference Guide for additional information);
(d) All corporate campaign agreements must be reviewed by the Office of the Solicitor before execution;
(e) The authority to approve corporate campaign agreements is delegated as described in Section 4.3;
(f) Advertising or solicitation for corporate campaigns involving the promotion of specific brands, products, services or enterprises of a corporate partner or associated entity may not be conducted within national park units in order to maintain the long-standing policy of the NPS that parks not be commercialized.
(g) The NPS will not allow the Arrowhead symbol or an NPS employee or any part of the uniform to be featured in any advertisement that promotes a corporate brand, service, product, or enterprise; and
(h) NPS must review and approve all campaign related informational materials prior to their distribution (regional/national campaign material requires National Partnership Office approval; local requires Regional Office review).
Corporate campaigns must be conducted with high standards that maintain the integrity of the NPS and its partners. Corporate campaigns which identify the NPS with alcohol or tobacco products will not be authorized.
7.1 Corporate Campaign Agreements Undertaken in Association with the National Park Foundation. The Director and the National Park Foundation (Foundation) have entered into the Corporate Campaign Agreement which authorizes the Foundation to enter into corporate campaigns generally, and provides the terms and conditions that now govern the “Proud Partners of America’s National Parks” program. This agreement is included in the Reference Guide.
Proud Partners are a special category of corporate partners who have joined with the Foundation and the NPS to connect national parks to all Americans. Proud Partners have the opportunity to inform the public through national marketing activities that they are assisting the Foundation and the NPS in meeting the needs of the National Park System and to invite the public to add their support. The Foundation and NPS have developed a Proud Partner branding logo for use by Proud Partner corporations in their marketing materials.
7.1.2 Proud Partner Marketing Exclusivity. A Proud Partner agreement affords a
corporate Proud Partner industry “exclusivity” at the national marketing level
for a product or service category. This
means that once a Proud Partner agreement is executed, no other nationwide
corporate campaign agreements may be executed in the specified Proud Partner’s
product or service category. NPS only
offers exclusivity through a Proud Partner relationship.
Upon execution of a Proud Partner Agreement, the Director will notify park managers of the new Proud Partner, the purposes set forth in the Proud Partner agreement, the category for which marketing exclusivity is being granted and the effective dates of the agreement. In the event a new Proud Partner is engaged in a business, product or service category occupied by another partner under a regional or national corporate campaign agreement entered prior to the effective date of the new Proud Partner agreement, that the pre-existing corporate campaign may continue only until the end of the existing term of that agreement or as agreed to by the NPS and the President of the National Park Foundation. Local campaigns may continue unaffected.
If a corporate partner’s business involves a product or service for which exclusivity has been afforded to a Proud Partner, NPS will not execute a corporate campaign agreement authorizing national, state, or regional press events or promotions, including web-based promotions.
7.2 Park-Based Corporate Campaigns. When individual park units are approached with a corporate campaign proposal, the National Partnership Office must be contacted to determine if the proposed campaign is permissible. The Reference Guide contains a list of questions to help determine whether an offer of corporate support is philanthropy or a corporate campaign. The following guidance is used by the National Partnership Office to assess whether proposed corporate campaigns activities may be authorized:
(a) Single area marketing and advertising: Individual parks, NPS partners, and a corporate partner may enter into corporate campaigns either within or outside of the Proud Partner marketing exclusivity categories as long as all resulting marketing or advertising remains within the single local market area. Thus, web-based promotions are not allowed. A single local market is the metropolitan area immediately surrounding or adjacent to the park unit. If there is no such metropolitan area (e.g. the area surrounding the park unit is sparsely populated), the superintendent must consult further with the National Partnership Office to identify the applicable marketing area.
(b) State, Regional, or National Area Marketing and Advertising Outside Proud Partner Categories: After consultation with the President of the National Park Foundation, the Director may authorize a corporate partner to engage in the use of paid media activities directed at a state, regional, or national market to inform the public of their support of a park or program. Requests should be submitted through the National Partnership Office and contain the information identified in the Reference Guide.
Approved corporate campaign activities must be consistent with the specific requirements of Section 7.0(a-h) and other applicable provisions of this Director’s Order, such as those relating to fundraising agreements and donor recognition.
8. Fundraising by Outside Entities
While the NPS does not regulate the conduct of fundraising partners, fundraising activities that may result in donations to the NPS are only appropriate when consistent with law and the mission, goals and policies of NPS and the Department of the Interior. To ensure such consistency, in most cases NPS only accepts donations from fundraising campaigns for its benefit that have been conducted pursuant to written agreements with its fundraising partners. Where a written agreement is required but has not been executed, the NPS will not accept the donations without the approval of the Associate Director for Partnerships, Interpretation, Education and Outdoor Recreation. There are two types of agreements that are used to address partner fundraising, general agreements and fundraising agreements.
General agreements establish long-term relationships between NPS and its partners. General agreements may, in part, be used to authorize fundraising to support ongoing NPS needs. General agreements may also address many aspects of the relationship between NPS and its partner. A general agreement may address, for example, partner fundraising for educational materials, fundraising to support interpretive services provided by the partner and the partner’s use of NPS facilities.
When fundraising efforts are designed to support specific projects, e.g., the planning and implementation of a new park program, the construction of park facilities, the fabrication of park exhibits, the restoration of historic sites, etc., fundraising must be addressed in a fundraising agreement. Where a general agreement between NPS and a partner already exists, fundraising agreements may “tier off” the general agreement as frequently as is needed.
Fundraising activities are not to be authorized in other forms of NPS agreements, e.g., cooperating association agreements, cooperative agreements, or grant agreements.
8.1 Thresholds and Agreements. The goal and complexity of a fundraising effort will determine how it would be authorized:
(a) Small-scale fundraising efforts or events that raise funds for the NPS do not require written fundraising agreements. These include efforts or events that are local or community based, locally publicized and are not expected to exceed $2,500 in donations.
8.2 Contents of Fundraising Agreements. Fundraising Agreements contain appropriate provisions that identify or establish, for example:
(a) Goals and objectives associated with a fundraising effort;
(b) Prioritized project(s) or program(s) to be funded;
(c) Procedures governing construction;
(d) Terms and conditions of any endowments when applicable;
(e) Accountability requirements for all funds raised and, when appropriate, for the security of funds invested by the partner related to a fundraising campaign;
(f) The applicable review process for prospective contributions; and
(g) Requirements that fundraising partners not lobby Congress to fund elements of a project that are contemplated in the fundraising agreement to be raised through private donations.
The model Basic and Comprehensive Fundraising Agreements (see Section 8.1 of the Reference Guide) contain additional clauses and provisions to include in the Fundraising Agreement. The National Partnership Office and the Solicitor’s Office can provide additional advice and guidance on Fundraising Agreements.
8.3 Determination of Feasibility for Fundraising Success. Feasibility studies are a standard tool used by fundraising professionals for assessing the likelihood that a fundraising effort or campaign will be successful. Feasibility studies are required for projects that require the Director’s approval. The park and region may request this requirement not be applied in appropriate circumstances. The request should be submitted to the Director through the National Partnership Office. Assessment of the request will be based on the experience of the partner in fundraising efforts of the magnitude proposed and the experience of the superintendent and park staff in executing the type of project contemplated. The Reference Guide contains additional information on feasibility studies.
8.4 Fundraising Plans. All fundraising which requires a written agreement also requires a fundraising plan. While the complexity of the plan will vary according to the magnitude of the endeavor, in general the plan should detail techniques, timing, staff needs (including use of paid consultants), strategy, costs, and other components identified in the Reference Guide. Fundraising plans are reviewed by the NPS during the review of the fundraising agreement.
8.5 Review of Contributions. In many cases, donors contribute directly to a non-profit partner of the NPS, with the partner subsequently making the donation to NPS. The DOI has established departmental policy governing the review of donations both directly and indirectly to the NPS. Most non-profit partners also have their own professional standards under which donations are screened. Donor review is required of partners engaged in fundraising for the benefit of the NPS and the process and thresholds for donor review are to be set out in the fundraising agreement between the NPS and the partner. The model CFA, included in Section 8.1 of the Reference Guide provides details on the donor review requirements to be included in a Comprehensive Fundraising Agreement.
8.6 Fundraising Costs. All costs associated with a fundraising effort, including required plans and studies, are the responsibility of the fundraising partner. To maintain the integrity of fundraising efforts associated with the NPS and the interests of donors, the NPS will not authorize fundraising that anticipates fundraising costs in excess of 20%. Fundraising costs associated with a specific fundraising effort must be accounted for separately from other activities, expenses and donations. Any fundraising consultants and staff, if compensated, are to be paid a salary or flat fee. The NPS will not approve fundraising plans/agreements where payments are made as commissions or as a percentage of the funds raised.
8.7 Endowments. The establishment of an endowment should be considered for inclusion in any major fundraising campaign to provide for future operations, maintenance and repair costs associated with capital improvements. Endowments may also be used to establish or expand park programs. The NPS and its fundraising partner should agree in advance on general categories for which funds will be expended and ensure that NPS has sufficient discretion for the use of the funds to meet its day to day needs, consistent with the purposes for which the endowment was created.
Factors that should be considered in authorizing the creation of an endowment are:
(a) How and by whom the endowment will be administered;
(b) How endowment funds are to be used;
(c) Process of authorizing expenditures;
(d) Investment policy for the endowment funds;
(e) Funds accountability;
(f) Circumstances, if any under which the corpus may be used; and
(g) Contingencies for the disposition of the endowment in the event of the dissolution of the partner or the endowment.
9. Construction – Partnership Construction Projects
Construction of facilities in the National Park System is primarily accomplished with appropriated funds. However, various construction projects throughout the system have been built at least in part utilizing donated funds. Construction projects undertaken with donations are considered “Partnership Construction Projects” and are further described in Section 9 of the Reference Guide and on the NPS Partnership web site: (www.nps.gov/partnerships/capital_campaigns.htm) which reflect the generally applicable requirements for all construction within parks.
Partnership construction projects are evaluated using the same criteria as those used for appropriated funds. They must:
(a) Be for a previously identified priority, consistent with park planning documents;
(b) Be included in the NPS five-year capital plan if any appropriated funds are to be used for the project;
(c) Be sustainable over time in terms of maintenance and operations.
The Partnership Construction Process set forth in Section 9 of the Reference Guide provides valuable guidance for all partnership construction projects irrespective of their dollar value. The process is mandatory for all such projects with an estimated cost of $500,000 or more.
The Partnership Construction Process is intended to create common expectations between the NPS and its partner and ensure that projects are properly scoped, meet critical mission needs, and can be operationally sustained. Regional Directors are responsible for ensuring that partnership construction projects in their respective regions follow the phases of the Partnership Construction Process. See also, the model CFA in Section 8.1 of the Reference Guide.
10. Donor Recognition
Recognizing the support of donors is important. The NPS is appreciative of private sector contributions that aid in the accomplishment of its mission and will thank all donors in an appropriate fashion. Consistent with the policies expressed in this section, specific forms of donor recognition may include letters of acceptance and appreciation, press releases, public events, mementos, certificates, and other items that commemorate the gift. All types of recognition should be agreed to in writing with fundraising partners in advance of the acceptance of the donation.
The NPS will, at minimum, acknowledge all direct donations in writing through a letter of acceptance which will note the amount of the cash donation and will serve as a record the donor may use to verify their charitable contribution.
Most donors view a donation to a group fundraising for the benefit of the NPS as a donation to the NPS. It therefore is appropriate that both the partner and the NPS express appreciation consistent with NPS policy.
10.1 Off-Site Donor Recognition. Most donor recognition should occur outside parks, through letters of appreciation, press releases, mementos, certificates, and other items that commemorate a donation.
(a) Thank you letters – All donors should promptly receive a letter of appreciation. The thank you letter can be used as the required NPS letter of acceptance of the gift and to acknowledge or articulate any condition that might apply to, as well as to express appreciation for, the donation. It should acknowledge the gift, the donor, date of acceptance and, if cash, the dollar amount. It should also fairly describe in-kind gifts. Except in certain cases for donations of land, the letter should not attempt to value non-cash gifts.
(b) Awards – Nomination for an award may be appropriate for some donations. Parks and regions may establish and use their own appropriate awards. National award nomination calls may be publicized through InsideNPS as well as other sources. When appropriate, NPS units and programs may also consider nominating a donor for non-NPS awards.
(c) Publicity (unpaid media) – Press releases to newspapers, magazines, web, radio, and television media, articles in park and NPS newsletters, and articles in the donor’s media (e.g., corporate employee newsletter, annual report) are a few of the ways that NPS may publicly recognize donors through unpaid media.
(d) Park Newspaper – An article in the park newspaper or newsletter is another way to recognize donors as well as to highlight the contributions of a park friends group or other partners.
(e) Events – Media events, press announcements, photo opportunities, ground breakings, ribbon cuttings, meal functions or other recognition events, and other activities or forums in which the donor is involved (e.g., annual meeting/convention of non-profit organizations) can be used to provide high-profile donor recognition. Some of these events may be held on-site in accordance with NPS guidelines.
(f) Mementos – A book, park lapel pin, or other park- or project-related memento might be appropriate as an expression of appreciation. These may also be presented in conjunction with other forms of recognition depending on the nature and significance of the donation. These kinds of items might be sent to the donor, presented in a simple ceremony, or tied into media events or other activities.
(g) Park Websites – Parks may set up a page on their websites to function as a donor recognition board. See the Section 10.2.3 for additional guidance.
10.2 In-Park Recognition. In some cases a gift may warrant in-park recognition. This section describes the in-park donor recognition options available to park managers. This form of donor recognition will likely occur in the park’s visitor center or other similar facility or developed area.
Most in-park recognition is part of a credit line or statement of appreciation by a park. A credit line is a short, discrete, unobtrusive statement expressing appreciation typically found at the end of the material or item, or on a donor recognition plaque.
To maintain NPS policy that parks be free of commercialism, advertising and marketing slogans and taglines may not appear under any circumstances. Donor recognition is not allowed on motor vehicles or on bricks, benches or other park furnishings.
Donor recognition should not be proposed in park areas if it would compete for attention with, or attract attention away from, the purpose for which the park was created.
Other opportunities for donor recognition include donor books which may be kept on display, computer terminals with searchable donor lists, articles or displays of donor names in park newsletters.
Recognition for donations to the development of websites is generally permitted. The National Partnership Office and the Office of the Chief Information Officer (OCIO) will work on additional guidance as new web standards are developed. In the interim, any request for recognition on a park or program website should be submitted to the National Partnership Office to be coordinated with the OCIO for review.
Recognition on signs is described below and illustrated in the Reference Guide. Recognition would generally not be included on park regulatory or safety signs.
10.2.1 Credit line including logos or name script. Sometimes a corporate or business donor will request that its name script or logo be included as a part of its recognition. This may be appropriate when the recognition will appear as part of a credit line on printed or electronic material, audio/video/film products and temporary construction/restoration signs. The Reference Guide will include examples of each kind of recognition.
Brochure or other printed material: The credit line on a park brochure may state: “This brochure was made possible through the contribution of _<logo, name script, or name>______”.
Electronic material (video/film/etc): The donor recognition may appear either at the beginning of the presentation or at the end. However, the use of digital on-screen graphics or “bugs” are not permissible forms of donor recognition. In the case of computerized information kiosks or other electronic displays to be placed in visitor service areas, the credit line containing the donor name script or logo may appear either at the beginning of the presentation or at the end. The recognition may not appear on the kiosk casing itself.
Temporary construction/restoration signs: A temporary restoration or construction sign may recognize donors’ contributions to the project. The sign should be informational, of appropriate design and scale, and express clearly that the NPS is recognizing the donation. It should inform visitors about the nature of the project and the support of the donor. The sign may remain in place for the duration of the work and should be removed shortly after the work has been completed. The Reference Guide will include examples.
10.2.2 Credit line. Recognition for all other donated or donor funded items, including interpretive waysides, recreation equipment and other items that remain in the park, may include a short, discrete, unobtrusive credit line using the donor’s name (but not name script or logo).
Additional information about the use of corporate logos and name script can be found in Section 10.4.
10.2.3 Donor Boards and Walls. Donor recognition boards or walls may be permitted in visitor centers and other appropriate visitor facilities. These boards or walls should utilize a format that allows recognition of donors by the placement of name plates or other markers that can be added and removed with relative ease. Electronic donor recognition boards are a new trend in this area.
A park’s Donor Recognition Plan should establish criteria for any donor boards or walls, including minimum thresholds for recognition and duration. The period of recognition should be commensurate with the level of the gift and life cycle of the facility, for example short-term displays may be appropriate during the life of a fundraising effort, while longer-term displays may be appropriate for significant donations. The names of corporate or business donors will appear in the same fashion as any other names, but corporate name scripts and logos will not be used on donor boards and walls.
Donor Boards and Walls, either electronic or traditional, should be integrated into the design of facilities.
10.2.4 Recognition of Corporate Donations. Corporate donors may receive recognition on the same basis as other donors. However, government ethics regulations prevent NPS employees from using their Government positions, titles, or any associated authorities to endorse, expressly or impliedly, any products, services or enterprises except in furtherance of specific statutory authority authorizing such endorsement.
10.2.5 Recognition within Interpretive Programs. Where a donation is integrally related to the park, to the existence of the park, or to what is being interpreted, interpretive programs may identify the donor and how the donation was used.
10.2.6 In-Park Displays, Name Plaques and Plates. When in-park displays are deemed appropriate, tasteful and unobtrusive signs, plaques or other treatments may be used. The duration of this form of recognition may vary depending on the project, donation and location. See section 10.3 for additional discussion.
Plaques are not to be affixed to the “historic fabric” of structures nor should they, or any other donor recognition treatment, be placed in natural zones or cultural zones where they would intrude on the character of the area.
Plaques acknowledging the contribution of a donor to the restoration or rehabilitation of a room or facility are allowed. Such a plaque may state, for example:
“The renovation of this room (or facility) was made possible through the generous donation of (fill in the name).”
The naming of rooms, features, or park facilities will not be used to recognize monetary or in-kind donations to a park or the NPS.
10.3 Donor Recognition Plan. A Donor Recognition Plan sets out the basic philosophy to guide donor recognition activities. It provides a framework for donor recognition in a park or by a program, ensuring that recognition is commensurate with the level of the gift, while allowing a measure of flexibility to meet the needs of individual donors. The plan also helps fundraising partners understand the means and levels of recognition that the NPS can provide.
A Donor Recognition Plan is required for all parks and programs that receive or are likely to receive donations. While these plans will vary from park to park and program to program, there are several fundamental policies that control all such plans.
Donor Recognition Plans should include, at a minimum, the following elements:
(a) A statement of the basic philosophy of donor recognition opportunities consistent with park mission, purposes, and plans;
(b) Procedures for acknowledging/thanking donors;
(c) Hierarchy of donor levels and associated recognition;
(d) The range of allowable forms of in-park recognition, as well as the appropriate locations, consistent with this section;
(e) Criteria for donor boards or walls, if any, including the location, minimum thresholds for recognition and length of time the recognition is in place;
(f) Conditions under which donors/donations to partners will be recognized by NPS consistent with Section 6.1.1.
Donor Recognition Plans for parks that receive minimal donations (less than $50,000 annually) may simply be a memo stating that the park will send a thank you note in response to any donation over $100.
Donor Recognition Plans are developed and approved at the park and program level with the concurrence of the appropriate Regional or Associate Director. Consistent with this section:
· Regional Directors may establish common recognition standards that apply to multiple parks within a region;
· Associate Directors may establish common recognition standards that apply to multiple programs within a directorate.
Park partner donor recognition plans should complement a park or program plan with respect to the donor recognition provided by NPS. Park partner donor recognition plans should be reviewed and approved by the superintendent if they include in-park recognition and to generally ensure consistence with the park’s plan. This will ensure that a fundraising partner will not inadvertently lead a prospective donor to expect a level of recognition that the NPS cannot, or will not, fulfill.
The Reference Guide will include additional information as examples become available.
10.4 Special Events. The primary guidance for holding special events (or “special park uses”) is found in Director’s Order #53 on Special Park Uses and in Special Directive 95-11. Director’s Order #21 applies to NPS donor or partner recognition at such events.
Special events fall into two categories; non-NPS events allowed under special park use permit, and events wholly or partially sponsored by the NPS (see 10.7.1, below). In either case, they may recognize corporate sponsors by limited use of corporate logos and name script on event facilities, signs and literature at all such special events provided that the size, scale, scope and location of corporate logos and name script does not dominate the event facilities or area. This is intended to ensure that there is not commercialization of parks.
10.4.1. NPS Sponsored and Co-sponsored Events. For officially-sponsored NPS events, the NPS may provide appropriate recognition provided that corporate names are not used in a way that would imply or suggest NPS endorsement of a product or company, or be construed as commercial solicitation or advertising. The purpose of such recognition is simply to acknowledge the sponsor. To ensure against the appearance of endorsement, the pre-event written agreements must spell out the responsibilities of the parties and any conditions on the offering or acceptance of the gift and should include provisions specifying the amount, type, and size of sponsor recognition signs. These provisions may be included in a special park use permit, an exchange of letters or other written documentation.
On-site notices (e.g. banners) must be appropriate to the character and scale of the event. The park manager may display such notices for a period of time in advance of the event to encourage public attendance. Sponsors may be permitted to establish a temporary hospitality area for sponsored special events.
Distribution of free or sample products is permitted at events co-sponsored by NPS only if the item directly relates to the purpose of the event (e.g. plastic bags for a clean-up day) or is consumable at the event. The items may be imprinted with the name of the event and recognize sponsors by name (using name script if desired), logo and website address.
Additional requirements may exist at specific areas of the National Park System.
10.4.2 Non-NPS Events. Guidance on this topic is found in Director’s Order #53 on Special Park Uses. Notices on temporary displays directly associated with the event containing sponsors’ names or logos or name script may be placed in close proximity to the event in both time and location.
Distribution of free products or sample products is not permitted at non-NPS events.
Additional requirements may exist at specific areas of the National Park System.