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 may
serve 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.
(a) The 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 partner.
(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 consistent with Section 4.3;
(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.
6.0 Donations
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.
(b) Fundraising efforts or activities that are intended to raise
over $2,500 are to be authorized in a written agreement. The Reference
Guide contains two model fundraising
agreements: the Basic Fundraising Agreement (BFA) and Comprehensive Fundraising
Agreement (CFA). The BFA may be used to authorize relatively low dollar value
fundraising activities that are not authorized by an existing general agreement
between the partner and NPS. The CFA should be used to authorize all other
project specific fundraising efforts.
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.
In-park recognition is typically provided in the form 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. 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 to park
visitors is not permitted at non-NPS events.
Additional requirements may exist at specific areas of the
National Park System.
----------End of
Director’s Order----------