Jun 2 2014
Policy Memorandum 14-04
To: All Employees
From: Director
Subject: Developing a New Framework for
National Park Service Partnerships and Philanthropic Stewardship in the 21st
Century
This Policy Memorandum does NOT
supersede Director’s
Order #21 (approved July
11, 2008), which remains in effect until it is officially superseded with
approved revisions.
Purpose
The
National Park Service (NPS) is in the process of updating Director’s Order
#21: Donations and Fundraising. The 2008 Director’s
Order provides guidance to park managers in accepting donations and working
with organizations who seek to raise money to benefit the national parks or
programs of the NPS. Our
policy ensures that the welcome support we receive from the private sector is
accepted and recognized in accordance with applicable laws, regulations and
policy. While
the current policy has served the NPS well, there is clear and growing
recognition within the NPS, and among our current and potential partners, that
the existing Director’s Order limits the consideration and role of modern,
mission-helpful, philanthropic options for NPS parks and programs.
New
policy guidance is needed to:
·
Help
the NPS connect with broader philanthropic communities;
·
Offer
updated tools to help current partners engage new and more diversified
philanthropic partners (for example, contemporary donor recognition options and
plans, and partnership agreements);
·
Support
more robust engagement of partners for the upcoming NPS Centennial in 2016; and
·
Provide
the framework and standards for testing philanthropic practices that could be implemented more broadly.
The
existing Director’s Order remains in effect and must be followed until a new,
revised edition is approved.
The revised Director’s Order is anticipated to
be completed by the end of 2014.
The
NPS Office of Partnerships and Philanthropic Stewardship is updating Director’s
Order #21. I
have asked the National Park System Advisory Board to support the NPS in its
efforts to achieve these goals. Board members have enthusiastically
responded and have selected Board member Paul Bardacke
to chair a committee on partnerships and philanthropy (the Committee). The Committee
represents a wide cross-section of corporate and nonprofit leaders, including
existing partners as well as entities we have not previously engaged or
consulted. These
individuals represent corporate America, universities,
museums, park philanthropy, foundations, youth, concessioners, and outdoor
recreation.
The
Committee began work in April and will meet monthly through September 2014. The Committee will
receive briefings on key policy issues by subject-matter experts who are
presently engaged with the NPS and with organizations with which the NPS has
not yet engaged. The Committee will use this
information, along with the personal knowledge and experience of its members,
to develop recommendations to be presented as white papers to the Board. These
recommendations, as adopted by the Board, will inform the revision of
Director’s Order #21. The
goal is to complete the revision and release it for formal review and comment
both within the Service and by the public.
The
Committee’s work will help the NPS develop a new strategic vision and practice
for partnerships and philanthropy Service-wide, and support the National Park
Foundation (NPF) and others in their work to engage new audiences and develop
new corporate and philanthropic alliances.
Background
From
the earliest days of America’s national parks, individual citizens and private
sector companies and organizations have played vital roles in their
development, support and promotion.
Director’s
Order #21 was first issued in 1998 to provide guidance to park and program
managers in accepting donations and working with organizations who seek to
raise money to benefit the national parks or NPS programs. This document was the first compilation
of a series of policies on philanthropy that had been developed over the years. The Order was
substantially revised in 2006 to give managers greater flexibility and to
encourage local stewardship and involvement. The 2008 revision incorporated procedural
changes directed by the Department of the Interior in the Departmental Manual (374 DM 6).
Philanthropic
and partnership practices and opportunities have continued to evolve over the last
decade, becoming more sophisticated and competitive. The existing NPS framework for
practices and policies on donations, fundraising, and partnerships is being
reassessed to ensure that we are in sync with the best
business practices in the philanthropic community.
Questions
and issues raised over time can be grouped into several basic categories: recognizing supporters; sharing and
protecting the NPS brand; making partnership easier; and sharing risk. Key points are found below.
1.
Recognizing
Philanthropic and Promotional Support. How can the NPS recognize the generosity
of supporters, treating them equitably and appropriately while recognizing
their contributions in ways that (1) are not seen as taking away from the
parks’ values and purposes, and (2) do not detract from the visitor experience,
create a sense of clutter, or come across as advertising in, or
commercializing, the parks?
The existing policy
favors recognition of donors outside of parks and allows a variety of in-park
recognition. However,
the Order prohibits types of donor recognition offered by many institutions,
such as recognition on benches, bins and other furnishings, on brick walkways,
and the use of corporate logos or name script on items that will remain on site. The policy also
prohibits naming park facilities to recognize donations, and is not
affirmatively supportive of other forms of naming, such as fellowships,
internships, and the development of endowed or supported positions (e.g., an
endowed chief historian).
Corporate support of nonprofits has significantly evolved in
the last 15 years and now spans a wide range of collaborations from
philanthropy to promotional partnerships. Present policy (1)
refers to information that is no longer relevant, e.g., the Proud Partner
Program, and (2) is neither detailed nor flexible enough to provide guidance on
this range of collaborations. Furthermore, the policy is not clear on the NPF’s
role in “corporate marketing” in support of the NPS or specific parks or
programs.
The NPS has a long
history of prohibiting marketing campaigns and donations that would associate
the parks, programs, or agency with alcohol or tobacco products. There has been
interest over the last few years in eliminating the prohibition on engaging in
marketing campaigns associated with alcohol products. Last year, the NPF—by means of a
policy waiver—piloted a marketing campaign associated with a winery in an
effort to evaluate how the public, our partners, and our employees would
receive such a campaign.
2. Protecting the NPS Brand.
NPS policies on accepting donations and engaging in
collaborative work with corporations are based on a
fundamental principle articulated in the 2007 DOI donations policy (374 DM 6): all partnerships should be undertaken in such
a way as to not undermine the public’s confidence in the integrity and impartiality
of NPS and DOI people and programs.
This ethical principle
forms the basis of two policy requirements that have proved to be controversial
in their implementation: (1) the
requirement to evaluate the source of donations (donor vetting), and (2) the
“default” requirement for NPS ownership of intellectual property created under
the auspices of friends group and fundraising agreements. The Committee will address these
topics as it looks at how the NPS protects and shares its brand, based on
Committee members’ expertise in fundraising and with intellectual property.
3.
Making
Partnering Easier. NPS partners
have operated in various organizational niches for much of the agency’s
history: friends groups raised funds and
advocated for parks; cooperating associations developed and sold interpretive
media, provided visitor programs, and supported the work of the interpretive
program generally; concessioners provided necessary and appropriate visitor
services. In
recent years, the lines between the groups have blurred with cooperating
associations and friends groups merging and concessioners providing programs. The NPS has also
seen the growth and development of different partnership models, such as
residential environmental education, youth employment, program-specific
philanthropic support organizations; as well as the increasing need to identify
earned-income strategies.
These trends have challenged the NPS, raising questions and
issues as the NPS attempts to fit existing policies and authorities into these
new partnership paradigms:
·
When
is a friends group agreement necessary? Is there a need to create a
partnership agreement template that authorizes fundraising within certain
parameters as a parallel to the friends group
agreement?
·
When
is a fundraising agreement necessary? At what point is a group leveraging
the NPS brand to raise funds?
·
Are
the lines between philanthropy, program support, and advocacy important?
·
How
does the NPS remain supportive of existing partners without discouraging new
partnerships with organizations that may operate in the same space?
·
What
tools are needed to make partnering easier? How do cooperative agreements fit into
the partnership world?
·
How
does the NPS choose organizations with whom to partner,
what standards should the agency have?
4. Shared Risk. Current NPS policy requires the partner to bear most of the financial and other risks in the relationship, and provisions in friends group and fundraising agreements—such as termination, insurance, indemnity, and intellectual property clauses—reflect that policy. Should NPS policy and agreements modify all or some of these requirements to reflect a partner’s experience in the work contemplated and the precise nature of that work?
Policy
The existing
Director’s Order #21 and its accompanying Reference Guide are found on the NPS
Office of Policy web site, at
http://www.nps.gov/applications/npspolicy/DOrders.cfm. Again, these will remain in place
until a revised Director’s Order #21 is approved.
Further Information
Please direct any questions to Reginald
Chapple, Program Manager for Partnerships and Philanthropic Stewardship, at
202-354-2112 or Reginald_Chapple@nps.gov.
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