Amendment to Reference Manual 32

Pursuant to authority delegated to the Associate Director, Interpretation, Education and Volunteers in Director’s Order #32, I hereby amend Reference Manual 32, as promulgated on February 10, 2017, as follows. 

Section 10, “Administrative Requirements,” in particular, the subsection on “Lobbying” (p. 80), is amended by (1) striking the last two paragraphs thereof, to-wit:

The relationship between the Service and Associations is one of support and cooperation.  Often, much of the information about individual park units and the National Park System made available to the public is produced through and by the Associations.  Additionally, Associations often share office space with NPS staff, have regular access to park managers and the two parties rely on each other for financial and programmatic support.  For these reasons, the NPS discourages Associations from publicly advocating positions on issues related to parks and to NPS [sic] except in limited circumstances and in close collaboration with the NPS.  Otherwise such activities can create an adversarial climate between an Association and the NPS that could undermine the Associations’ ability to carry out its primary mission.

Because Associations receive logistical support from the NPS and enjoy the privileged status of operating within units of the National Park System, it is important that they focus on their mission of supporting the educational, research, and interpretive activities of the NPS.  This does not prevent Associations form commenting on NPS plans or policies through the public involvement process, particularly in matters that may directly affect Association employees.  Nor does it prevent individual Association members, employees, or directors from expressing opinions regarding management actions, programs, or policies of the NPD.  However, they should do so as concerned private citizens, not through the Association. 

and (2) substituting the following text:

The relationship between the Service and Associations is one of support and cooperation.  Often, much of the information about individual park units and the National Park System made available to the public is produced through and by the Associations.  Additionally, Associations often share federally funded office space with NPS staff, have regular access to park managers, and the two parties rely on each other for financial and programmatic support including Federal funds going to Associations through cooperative agreements.

Please note that Associations are specifically prohibited from utilizing any portion of funding or supplies/services/equipment/facilities provided by the Government to attempt to influence or lobby any Member of Congress (18 U.S.C. §1913).  In short, the following parameters apply:

·         If an Association has staff that are paid through a cooperative agreement, they may not use the time paid through that agreement to lobby or attempt to influence a Member of Congress.  and

·         If an Association is provided office space, supplies, and services (such as copiers, computers, or phone lines) to conduct business, staff may not use those facilities, equipment or services to lobby or attempt to influence a Member of Congress.

If an Association is unsure if its involvement in lobbying violates its agreement, it should consult with the key official identified in the agreement.

This does not prevent Associations from commenting on NPS plans or policies through the public involvement process, particularly in matters that may directly affect Association employees.  Nor does it prevent individual Association members, employees, or directors from expressing opinions regarding management actions, programs, or policies of the NPS.  However, they should do so as concerned private citizens, not through the Association.

This amendment has immediate effect.

/s/ Thomas R. Medema

(Acting) Associate Director, Interpretation,

            Education, and Volunteers

 

September 6, 2018