"Nothing dollarable is safe" -- John Muir

Proposed changes to the rules that govern fund-raising for the National Park Service have left the Coalition to Protect America's Parks wondering what exactly the Park Service is trying to accomplish with the changes and fears they will only lead to more commercialization within the park system.

The rules, collectively known as Director's Order 21, have drawn media attention in recent days over concern that they could open the door for corporate branding inside the National Park System. The Coalition in its comments to the proposed revisions didn't share the concern that Arches National Park might one day be "brought to you by McDonald's," but nevertheless voiced worries that "some aspects of the (Director's Order) would allow greater corporate 'presence' in parks in return for major donations, which raises obvious concerns about increasing commercialization of parks and the erosion of the public perceptions regarding the NPS’s image and integrity."

The draft document was released in late March. Some of the proposed changes included:

* Continued allowance of entering into partnerships with alcoholic beverage companies and accepting donations from them;

* Clearly defining which positions in the National Park Service (e.g., director, deputy director, regional director, superintendent) are permitted to receive donations, and in what amount;

* Allowing superintendents to "encourage online giving to their philanthropic partner and may accept direct donations via their parks’ websites. Parks with direct online donation capabilities can place notices to inform the public about these donation opportunities. ... NPS.gov websites may also link to the websites of authorized fundraising partners that are able to accept electronic donations;"

* Allowing for philanthropic partners to resort to "crowdfunding" to raise money for the parks;

* Letting individual parks decide how to recognize donations, with restrictions against no implication of NPS endorsement, official sponsorship of the park, or naming rights. Whereas the existing guidelines prohibit donor recognition on vehicles, bricks, benches, or other park furnishings or buildings, the proposed revisions would allow recognition on vehicles if the vehicle was the donation, and would allow recognition on bricks, walkways, benches, and landscaped areas.

"In general, the Coalition supports the intent of leveraging additional donations and reducing some burdensome and bureaucratic barriers to fundraising efforts, particularly at the park level," the group, which represents more than 1,100 Park Service retirees, said in comments it submitted Sunday. "However, we are concerned the (Director's Order) undermines the importance of appropriations, mandates additional duties for park staff, and begins to send parks and the NPS down a road of increased commercialization.

"Based on the revised (Director's Order) as a whole, it is difficult for us, despite our extensive NPS experience, to understand exactly what it is that NPS is trying to accomplish with the proposed changes in policy," the letter, written by Maureen Finnerty, chair of the Coalition's Executive Council, went on. "Is it to improve institutional controls of philanthropic partnerships, including Regional Office and Washington Office level oversight of park-based fundraising efforts? Is it intended to streamline fundraising procedures and requirements in a way that facilitates corporate fundraising at the national level (e.g., through NPF) and/or fundraising at the park level? Is it some combination of the above?

"To be frank, the (Director's Order) appears to make it easier for high-level (e.g., National Park Foundation) fundraising but more difficult for park-level fundraising."

Among other concerns, the Coalition's letter noted that:

* The revisions would allow the Park Service director and deputy directors to directly solicit contributions, something the Coalition said "is not an appropriate role for the three highest ranking NPS officials, and can create the appearance of a conflict of interest."

* The Coalition was concerned that the revisions don't specify what groups, organizations, and businesses the Park Service should specifically welcome support from. "...there is little anywhere else in the (Director's Order) to indicate that NPS places high value on partnering with donors who are recognized for their environmental leadership and social responsibility. It is one thing to avoid relationships that could cast NPS in a negative light, which is the general perspective presented throughout the (Director's Order); it is equally, if not more, important to seek partnerships and donor relationships that are so completely positive that it enhances both the image of the partner or donor, as well as the NPS image."

* The revisions should specifically list what businesses and organizations the Park Service would not accept donations from or enter into partnerships with. "The bullet regarding 'fundraising campaigns that identify the NPS with tobacco, and any type of illegal product will not be authorized' raises more questions and concerns than it resolves, both by what is stated and what is not stated.

"Does this mean that NPS would accept donations from sources that are closely identified with (or would identify NPS with) adult products and services, such as any/all kinds of alcoholic beverages, gambling, firearms, and certain pharmaceutical products? Would NPS accept donations from sources closely identified with environmentally or climate unfriendly industries, such as uranium mining or oil and gas development? Would NPS accept donations from marijuana sellers in states where it is legal? NPS, because of its environmental leadership responsibilities, should aspire to engage in highly positive relationships, rather than simply avoiding negative ones. This is why NPS needs to establish a clear list of 'Types of Support Not Accepted."

* The retirees worried that the Park Service would open up a Pandora's Box of donors without more stringent guidelines on what donations it would accept and from what groups. "Are there guidelines anywhere that define or provide context for determining 'sources that would generate controversy…inconsistent with NPS mission?' If not, there should be.

"Think, for instance, of a uranium mining company operating near a park; or an air tour company that operates close to but not over a park and is not constrained by an air management plan; or companies that sell 'adult products,' such as tobacco, alcoholic beverages, firearms, and certain pharmaceuticals. Lacking clear guidelines, the incentive to 'accept the money' from any 'legal' source that is not outwardly 'anti-park' can overwhelm thoughtful judgment about how much controversy is acceptable. Aspire to engage in highly positive donor relationships, rather than simply avoiding negative ones."

* On the matter of taking dollars from alcoholic beverage companies, the coalition questioned the propriety of Park Service Director Jon Jarvis's decision in January 2015 to sign a waiver to let the National Park Foundation take a $2.5 million donation from Budweiser. 

"We understand the reasons behind the proposed change in NPS policy that would allow NPS to 'permit—after thorough review—philanthropic partnerships with, and accept donations from, corporations that produce or distribute alcohol.' Basically, it is about the money; and, frankly, this strikes us as an obvious attempt to retroactively legitimize the Budweiser donation," wrote Ms. Finnerty. "If NPS is, in fact, going to accept donations from 'corporations that produce or distribute alcohol,' then NPS must establish a much better defined criteria for determining when to accept (or not accept) such donations AND what the donations would be used for. For example, should a high-profile liquor manufacturer’s donation be used and publicized as sponsoring a park youth program or a family-oriented special event such as an Earth Day, the 4th of July, or Founders Day celebration? What impression would such highly visible donor recognition ('this event sponsored by…') have on the children and parents present? Is that really the image NPS wants to convey?

"The NPS image matters, so please don’t dilute the positive image NPS has earned through many decades of caution regarding appropriate 'sources' of donations. NPS should have higher standards (or at least some standards, since there are none in the Director's Order) when it comes to the acceptance and use of donations from corporations that are primarily known for producing or distributing alcohol because of the potential controversy and negative publicity surrounding the acceptance of such donations (e.g., the Budweiser donation). We recommend that NPS add a new sentence that states: 'NPS acceptance of such donations will be limited to corporations that have a demonstrated commitment to protecting the environment, promoting healthy products and activities, AND have an established corporate social responsibility (CSR) program.' Aspire to engage in highly positive donor relationships, rather than simply avoiding negative ones."

Finally, the Coalition was adamant that naming rights for facilities and elsewhere in parks be removed from the revised document.

"The significant amount of negative publicity already generated by the NPS 'naming rights' proposal should tell NPS how the American public views the perceived commercialization of park facilities or portions of those facilities," reads the letter. "NPS should avoid granting 'naming rights' under any circumstances, regardless of the significance of the donation. Instead, use any (or any combination) of the other suggested methods listed in this section (e.g., donor boards and walls that are 'integrated into the planning and design of any new facility or renovation of an existing facility'). For large donations that are instrumental in the development of a new facility or major renovation of an existing facility, we recommend that the donor recognition be left in place for the lifespan of the facility."