NCR DO-21 Issues: Summary November 30, 2005

NCR DO-21 Issues:  Summary

November 30, 2005

I. Overall: 

A. We think that many parks would have difficulty with the requirements for close park-level involvement with fundraising as this document describes.  

B. This DO places a brand new annual reporting requirement on parks

Section 4

A. It may be difficult to implement such changes such as NPS approvals of fundraising campaigns, park monitoring of partner fundraising activities, park “vetting” of donors, etc.

B. The authorization to solicit donations should be 5 million for the Director and 1 million for Deputies, Associates, and Regional Directors.  We believe that superintendents above GS-14 should also be allowed to solicit.

Section 5-6

A. The referenced vetting process that exists now is unclear, time consuming and somewhat cumbersome

Section 7

B. We suggest that corporate campaigns should not use the NPS arrowhead or any park logos.

Section 8

A. We suggest that the fund-raising authorizations approved by Superintendents for outside groups are too low.  

B. Standard insurance provision

C. NPS currently does not have adequate expertise to review fundraising feasibility studies provided by partner organizations

Section 9

A. Some of our park managers believe that the mandatory process for the DAB review should be raised to from $500,000 to one million dollars.

Section 10

A. We request the inclusion of the Commemorative Works Act

B. We believe that the guidance in Section 10 is ambiguous and confusing regarding the temporary vs. permanent nature of donor recognition.

C. We are concerned about use of the term “longer term”.  

D. Perhaps the most troubling portion of this section is “donor recognition through benches, bricks or paving materials, plaques maybe allowed…”  These permanent forms of recognition simply do not belong in units of the National Park System

E. While we concur with the naming of rooms in a non-historic building, we disagree with naming 

opportunities for elements in the landscape for which the park was 

established.

F. We are not comfortable with the proposal that would allow rooms within 

park facilities to be named for or by donors.