Report to the Chairman, Subcommittee 

on National Parks, Forests and Public 

Lands, Committee on Natural 

Resources, House of Representatives 

GAO 

United States Government Accountability Office

NATIONAL PARK 

SERVICE 

Donations and 

Related Partnerships 

Benefit Parks, but 

Management 

Refinements Could 

Better Target Risks 

and Enhance 

Accountability 

June 2009 

GAO-09-386 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2009

NATIONAL PARK SERVICE 

Donations and Related Partnerships Benefit Parks, 

but Management Refinements Could Better Target 

Highlights of GAO-09-386, a report to the Risks and Enhance Accountability 

Chairman, Subcommittee on National 

Parks, Forests and Public Lands, 

Committee on Natural Resources, House 

of Representatives 

The National Park Service (Park 

Service) in the Department of the 

Interior (Interior) annually receives 

hundreds of millions of dollars in 

donated funds, goods, and services 

to support its 391 parks and other 

sites. But concerns have been 

raised about potential 

accompanying risks, such as undue 

donor influence, new long-term 

maintenance costs, or 

commercialization of parks. To 

address these concerns, the Park 

Service has developed and refined 

policies for managing donations, 

but questions remain about the 

agency’s ability to do so effectively. 

GAO was asked to examine 

(1) how donations and related 

partnerships have supported the 

Park Service, (2) the policies and 

processes the agency uses to 

manage donations and how well 

they are working, and (3) what the 

agency could do to enhance its 

management of donations and 

related partnerships. GAO 

reviewed applicable legal and 

policy documents, interviewed 

Interior and Park Service officials 

and partner organizations, and 

visited selected national parks. 

What GAO Recommends

GAO is recommending a number of 

actions to strengthen the Park 

Service’s management of donations 

and related partnerships, including 

tailoring agency policies to match 

the level of risk and developing a 

strategic vision for the role of 

philanthropy in parks. Interior 

generally concurred with the 

recommendations, except for the 

one on developing a strategic 

vision, which GAO clarified.

Donations from individuals, nonprofit organizations, corporations, and others 

have provided significant support to park projects and programs, and related 

partnerships have amplified the value of those donations with countless other 

benefits. The collective value of these donations is substantial—including over 

$500 million since 1986 at a single park and over $100 million for six recent 

construction projects, for example—but their total worth is difficult to 

quantify, in part because of the numerous and often indirect ways in which 

parks receive donations. Donations support park programs and projects, such 

as interpretation and education, new construction, repair of facilities, and 

cultural resource management and protection. Park partners also provide 

other benefits that go beyond dollar values or a simple tally of projects. These 

benefits include enabling projects and programs that would not otherwise 

have been possible, accomplishing projects more quickly, and expanding 

parks’ connections with their communities. 

The Park Service’s donations and fund-raising policy includes directives in 

key areas to protect the agency against risks, but their effectiveness is 

diminished because parks do not always follow these program requirements, 

and the agency has no systematic process to monitor conformance. Agency 

officials acknowledged some cases of nonconformance but believed they 

were justified because they involved parks and partners with long track 

records of success and therefore did not pose significant risks to the agency. 

While reasonable, this justification indicates that the policy’s requirements 

(and the resource investment needed to meet them) are not always 

commensurate with the level of risk to the agency. The Park Service has made 

improvements to its partnership construction process to address past 

accountability concerns, but remaining gaps leave the agency exposed to risks 

in some situations, such as when operations and maintenance costs increase 

for new construction. 

To enhance management of donations and related partnerships, GAO believes 

the Park Service could take a more strategic approach, further refine its 

information on donations, and increase employees’ knowledge and skills for 

working with nonprofit and philanthropic partners. The agency could benefit 

from a long-range vision of the desired role of donations and related 

partnerships, but despite growing indications of the need for one, the Park 

Service has neither a strategic vision nor a plan for how to achieve it. Also, by 

enhancing its information on donations, which is currently limited, the agency 

could better support such a strategic approach. For various reasons, 

agencywide information on donations from some of its partners is incomplete, 

out of date, and based on inconsistent determinations of support. Finally, by 

improving its employees’ skills in understanding the culture, policies, and 

constraints of nonprofit and philanthropic partners, the agency could better 

manage the risks that accompany donations. Park Service employees and 

partners say they face challenges and are not sufficiently skilled in this area, 

although they believe the skills are critical. 

View GAO-09-386 or key components.

For more information, contact Robin M. 

Nazzaror at (202) 512-3841 or 

nazzaror@gao.gov. 
Page i GAO-09-386 

Contents 

Letter 1

Background 3 

Donations Have Provided Significant Support to Park Programs 

and Projects, and Partnerships Amplify These Donations with 

Intangible Benefits 12 

Park Service Policies and Processes for Managing Donations 

Generally Work Well, but Some Could Be Strengthened 31 

Enhancements to Park Service Management of Donations Could 

Strengthen Accountability, Efficiency, and Partner Relations 58 

Conclusions 72 

Recommendations for Executive Action 73 

Agency Comments, Third-Party Views, and Our Evaluation 74 

Appendix I Objectives, Scope, and Methodology 78 

Appendix II Statutory Provisions Relating to Cooperating 

Associations and Friends Group Activities at 

National Parks 83 

Appendix III Comments from the Department of the Interior 85 

Appendix IV GAO Contact and Staff Acknowledgments 89 

Tables 

Table 1: Types of Projects or Programs Supported by Donations 

from 30 Cooperating Associations and Friends Groups in 

Our Sample 14 

Table 2: Corporate Donations Made Directly to Our Sample of 25 

Parks, 2006-2008 23 

Table 3: National Park Service Donations and Fund-raising Policy: 

Summary of Required Agreements and Documentation 32 

Table 4: Fulfillment of Donations and Fund-raising Requirements at 

25 Sample Parks 36 

 Donations to National Parks 
Table 5: Partnership Construction Process: Summary of Inspector 

General’s Recommendations and Park Service Actions 46 

Table 6: Examples of Risks, Potential Indicators of Risk, and 

Mitigating Factors Associated with Donations to the Park 

Service 51 

Table 7: National Park Service Cooperating Association Policy: 

Summary of Required Documents 52 

Table 8: National Park Service 2008 Centennial Challenge 

Procedures: Summary of Required Documents 55 

Table 9: Donations and Support Information Tracked by the Park 

Service 61 

Table 10: Parks and Associated Partner Organizations Visited or 

Interviewed by Telephone 78 

Figures 

Figure 1: Total Cash Donations to the National Park Service, Fiscal 

Years 1999-2008 5 

Figure 2: National Park Service Regional Offices 11 

Figure 3: Yellowstone National Park Visitor Watching a Podcast 15 

Figure 4: The Monument at Wright Brothers National Memorial 17 

Figure 5: Historic Painting Before (left) and After (right) 

Restoration 18 

Figure 6: Habitat Restoration Volunteer 19 

Figure 7: The Endangered San Francisco Garter Snake 20 

Figure 8: Heli-Rappel Tower at Yosemite National Park 22 

Figure 9: Hertz Green Fleet Promotion 26 

Figure 10: Leaflet Advertising Macy’s Campaign 27 

Figure 11: Rocky Mountain Nature Association Land Purchase 30 

Figure 12: Partnership Construction Process 45 

Page ii GAO-09-386 Donations to National Parks
Abbreviations 

APPL Association of Partners for Public Lands 

Interior Department of the Interior 

IRS Internal Revenue Service 

Foundation National Park Foundation 

Park Service National Park Service 

Partnership Office Office of Partnerships and Philanthropic 

 Stewardship 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately. 

Page iii GAO-09-386 Donations to National Parks
Page 1 GAO-09-386 

United States Government Accountability Office

Washington, DC 20548 

 

June 16, 2009 

The Honorable Raúl M. Grijalva 

Chairman 

Subcommittee on National Parks, Forests 

 and Public Lands 

Committee on Natural Resources 

House of Representatives 

Dear Mr. Chairman: 

The National Park Service (Park Service), in the Department of the 

Interior (Interior), manages 391 parks and other sites covering more than 

84 million acres and receiving millions of visitors each year. Although the 

management of the national parks is primarily a public responsibility, the 

national park system has benefited from philanthropic donations since the 

early 1900s. The Park Service annually accepts hundreds of millions of 

dollars in donated funds and in-kind goods and services from individuals, 

corporations, and nonprofit organizations. Some national parks—such as 

Grand Teton and Yosemite—would not exist as we know them today were 

it not for philanthropic donations that helped create or enlarge them. But 

the benefits may not come without risks. Members of Congress and others 

have pointed to various potential risks, such as donors’ raising funds for 

inappropriately large facilities and leaving taxpayers to absorb the costs of 

maintaining them, corporations’ unduly influencing agency policy, and 

parks’ becoming too commercialized. They have also raised concerns 

about how well the Park Service has been managing donations in light of 

these risks. Further, for the agency’s 100th anniversary in 2016, the 

previous administration proposed a Centennial Challenge calling for a 

dramatic expansion of donations—up to $1 billion over 10 years—to be 

matched by federal funds. Congress appropriated about $25 million for the 

program in 2008, but concerns remain about the Park Service’s ability to 

manage such a jump in donations. 

To manage its acceptance and use of donations—and the associated 

risks—the Park Service relies on several key policies and processes. For 

example, its donations and fund-raising policy includes requirements 

addressing ethics and accountability issues that arise when parks accept 

donations and when nonprofit organizations fund-raise on their behalf. A 

separate process includes requirements for large construction projects 

supported through donations. While these policies and processes reflect 

steps the Park Service has taken to address concerns raised by members 

 Donations to National Parks 
 

of Congress, GAO,1 the Office of Management and Budget, and others in 

the past, questions remain about the Park Service’s capacity to effectively 

manage the potential future increase in donations and reliance on related 

partnerships. In this context, this report responds to your request that we 

examine (1) how donated funds, goods, and services and related 

partnerships have supported the Park Service; (2) the policies and 

processes the agency uses to manage donations and related partnerships 

and how well they are working; and (3) what, if anything, could enhance 

the agency’s management of donations and related partnerships. 

To address these objectives, we reviewed applicable laws, policies, and 

processes; agency data on cash donations received; and agency 

information on noncash donations provided by partner organizations. We 

also interviewed Interior and Park Service officials, as well as 

representatives of partner organizations, at the national, regional, and park 

levels. We obtained information from park superintendents and other Park 

Service officials and from representatives of related partner organizations 

at a sample of 25 parks, using a structured interview with questions about 

partnerships, fund-raising, the Centennial Challenge, and data tracking. We 

visited 9 of these parks and their associated partners, and contacted the 

remaining 16 by telephone. We selected the 9 visited sites to reflect both 

diverse geographic representation and high levels of donation activity. We 

chose parks with high donation activity because we believed they would 

have the most practical experience with Park Service policies and 

procedures on donations and fund-raising and would be more likely to 

encounter the potential risks associated with accepting donations. For our 

telephone interviews, we selected another 16 parks across the Park 

Service’s seven regions, mainly using a nongeneralizable, stratified random 

sample, which reflected diversity with respect to the type of park, level of 

visitation, and number and type(s) of partner(s). We conducted this 

performance audit from December 2007 to June 2009, in accordance with 

generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our 

 

1

GAO, Park Service: Agency Needs to Better Manage the Increasing Role of Nonprofit 

Partners, GAO-03-585 (Washington, D.C.: July 18, 2003), and National Park Foundation: 

Better Communication of Roles and Responsibilities Is Needed to Strengthen Partnership 

with the National Park Service, GAO-04-541 (Washington, D.C.: May 17, 2004). 

Page 2 GAO-09-386 Donations to National Parks
 

audit objectives. (App. I discusses our scope and methodology in more 

detail.) 

Since 1872, Congress has set aside natural, cultural, and recreational park 

sites to leave them unimpaired for future generations. The national park 

system is now a network of natural, historic, and cultural treasures in 49 

states, the District of Columbia, American Samoa, Guam, Puerto Rico, 

Saipan, and the Virgin Islands. The system’s 391 parks and other sites 

include 58 national parks, such as Yellowstone in Idaho, Montana, and 

Wyoming; Yosemite in California; and Cuyahoga Valley in Ohio. The 

remaining 333 sites fall into other categories, such as national historical 

parks and national lakeshores.2

 Some of the parks, such as Yellowstone, 

cover millions of acres and employ hundreds of employees; others, such as 

Ford’s Theatre, which encompasses two historic structures, are small and 

have few employees. 

Background 

As the park system’s federal manager, the Park Service is charged with 

conserving “the scenery and the natural and historic objects and the wild 

life therein and to provide for the enjoyment of the same in such manner 

and by such means as will leave them unimpaired for the enjoyment of 

future generations.”3

 Because of the complexity of its mission, large land 

area, and the number and diversity of its park units, the agency has the 

difficult task of balancing resource protection with providing for 

appropriate public use, including meeting the needs of nearly 300 million 

park visitors each year—responsibilities that entail substantial 

management and financial challenges, particularly given current budget 

constraints. 

For financial support, the Park Service depends primarily upon federal 

funding, which totaled over $2.7 billion in fiscal year 2008.4

 As with any 

federal program, the Park Service is expected to manage within whatever 

 

2

Other categories include national military parks, national historic sites, national 

monuments, national memorials, and national recreation areas. In this report we use the 

terms parks or national parks to encompass all units of the national park system, 

regardless of designation. 

3

Act of August 25, 1916, ch. 408, § 1, 39 Stat. 535 (codified as amended at 16 U.S.C. § 1). The 

1916 legislation is commonly referred to as the National Park Service Organic Act. 

4

This funding amount includes the spending authorization for revenues from admission and 

user fees collected at parks and franchise fees paid by concessionaires. 

Page 3 GAO-09-386 Donations to National Parks
 

level of funding is provided and to allocate resources to its park units in a 

way that is both efficient and effective in delivering services. As we 

reported in 2006, however, operating costs increase each year because of 

required personnel pay increases, rising costs of benefits for federal 

employees, and rising overhead expenses such as utilities.5

 In addition, the 

park system faces a maintenance backlog of about $9 billion, according to 

Interior fiscal year 2006 estimates.6

 According to the Park Service, these 

budget realities are making it difficult to accomplish its core mission work, 

and partnerships are being strongly encouraged by the agency’s 

leadership. 

The Park Service relies on donations to supplement federal funding and 

assist the agency in better fulfilling its mission and fostering a shared 

sense of stewardship. Donations generally come in two forms—cash and 

in-kind goods and services. The Park Service reported receiving direct 

cash donations of $57.6 million in fiscal year 2008, about $30.3 million 

more than in fiscal year 2007 (see fig. 1). According to a Park Service 

official, a large part of the 2008 increase was attributable primarily to 

$15.6 million in privately donated matching funds in response to the 

$24.6 million appropriated by Congress in fiscal year 2008 for Centennial 

Challenge projects.7

 These matching funds, combined with an additional 

$11.3 million of in-kind contributions, supported 110 Centennial Challenge 

projects at 75 parks in 2008. 

 

5

GAO, National Park Service: Major Operations Funding Trends and How Selected Park 

Units Responded to Those Trends for Fiscal Years 2001 through 2005, GAO-06-431

(Washington, D.C.: Mar. 31, 2006). 

6

Congressional Research Service, National Park Management, RL33484 (Washington, D.C., 

Aug. 8, 2007). In February 2009, in the American Recovery and Reinvestment Act of 2009, 

Congress appropriated $735 million for the Park Service for deferred maintenance and 

other critical repair and rehabilitation projects, and construction for critical infrastructure 

projects. 

7

The increase also included donations from two major fund-raising efforts by nonprofit 

partners, including $8.5 million donated for a new visitor education center at Yellowstone 

National Park. 

Page 4 GAO-09-386 Donations to National Parks
 

Figure 1: Total Cash Donations to the National Park Service, Fiscal Years 1999-2008 

Dollars in millions

Fiscal year

Cash donations, nominal dollars

Cash donations, constant 2009 dollars

10-year average

Source: GAO analysis of National Park Service data.

2008 Centennial 

Challenge cash 

contributions

0

10

20

30

40

50

60

70

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Annual cash donations to individual parks nationwide ranged from less 

than $10 to more than $4.5 million, on average, over the last 10 fiscal years, 

with the great majority of parks receiving less than $50,000 a year. In 

addition to cash donations, parks receive donations in the form of in-kind 

goods and services, which, for various reasons, are difficult to value and 

track. Examples of in-kind donations include artifacts for parks’ museum 

collections and thousands of volunteers who contribute time and expertise 

through the Volunteers-in-Parks program.8

The Park Service is statutorily authorized to accept donations—both cash 

and in-kind goods and services—from various sources, including 

 

8

The Volunteers-in-Parks program was authorized by legislation enacted in 1970. The 

primary purpose of the program is to provide a vehicle through which the Park Service can 

accept and use voluntary help and services from the public. The major objective of the 

program is to use this voluntary help to mutually benefit the Park Service and volunteers. 

Volunteers in the Parks Act of 1969, Pub. L. No. 91-357, 84 Stat. 472 (codified as amended at 

16 U.S.C. § 18g through 18j). This program falls outside the scope of our review. 

Page 5 GAO-09-386 Donations to National Parks
 

individuals, corporations, and nonprofit organizations. Individuals include 

visitors who drop money in a park donation box or send a check to a park 

in appreciation for park services provided during a visit, such as a 

backcountry rescue or a ranger’s informative interpretation. Corporations 

range from small local businesses—like a lumber company—to large 

national corporations, such as Macy’s department stores. Nonprofit 

organizations, which support a specific park, group of parks, or the entire 

Park Service, also provide donations. Many parks accept donations from, 

and formally establish partnerships by entering into agreements with, such 

nonprofit organizations, including the National Park Foundation 

(Foundation), friends groups, and cooperating associations (see app. II for 

a description of the applicable authorizing statutes). Each of these types of 

organizations is described below. 

In 1967, Congress created the Foundation to encourage private 

philanthropy to the parks. The Foundation is an official national nonprofit 

partner of the Park Service; although congressionally chartered, it receives 

no annual federal appropriations. In accordance with its charter, the 

Foundation raises private donations from individuals, other foundations, 

and corporations to support the Park Service and has broad discretion in 

how it raises and distributes these donations. 

Friends groups are another type of nonprofit partner that supports the 

parks. The Park Service describes friends groups as any nonprofit 

organization established primarily to assist or benefit a specific park area, 

a series of park areas, a program, or the entire national park system. They 

are generally formed under state law and must comply with state and 

federal requirements for charitable fund-raising as well as standards of 

professional conduct. These include specific standards and philosophies 

of operation, best practices, codes of professional conduct, fiduciary 

guidelines and financial accountability requirements, independent audit 

procedures, and public disclosure requirements, among others. The Park 

Service does not require friends groups to operate as tax-exempt entities 

or to have formal partnership agreements with the agency unless they 

raise funds for the parks. Guidelines for park fund-raising activities are the 

primary source of park policy covering friends groups’ activities. The Park 

Service estimated that in 2006, there were 186 friends groups contributing 

time, expertise, and privately raised funds to support the national parks. 

The groups vary in size, organizational structure, and nonprofit 

governance and fund-raising expertise. Some, like the Frederick 

Vanderbilt Garden Association and Eugene O’Neill Tao House Foundation, 

are small volunteer organizations, while others, such as the Cuyahoga 

National Park Association and Golden Gate National Parks Conservancy, 

Page 6 GAO-09-386 Donations to National Parks
 

are large-scale fund-raising partners that also provide research, 

interpretive and conservation programming, and park tours. 

Cooperating associations—another type of nonprofit partner—support 

primarily interpretation, education, and research in the parks. The Park 

Service’s relationship with cooperating associations began in 1923 with the 

founding of the Yosemite Association, and by 2009, the number of 

cooperating associations had grown to about 70. Led by boards of 

directors and executive directors responsible for day-to-day management, 

cooperating associations provide program and financial assistance to 

national parks by producing and selling educational and interpretive 

materials in bookstores, providing information to visitors, and managing 

educational programs and field institutes; they return some portion of 

their profits from these activities to the parks to support the parks’ 

interpretive and educational mission. Many cooperating associations 

support multiple parks and other public land management units.9

 For 

example, Eastern National and Western National Parks Association—two 

of the largest cooperating associations—partner, respectively, with more 

than 130 and about 65 parks and other units. Others, such as Black Hills 

Parks and Forests Association and Great Smoky Mountains Association, 

partner with a few parks or a single park. Some cooperating associations 

use revenue-sharing models that enable them to support—at small parks, 

for instance—bookstores and other interpretive services that would not be 

profitable on their own. The Park Service requires that cooperating 

associations operate as tax-exempt organizations10 and employs a 

standardized cooperating association agreement, identifying the specific 

federal statutes and agency policies governing agency and association 

responsibilities.11 Some of the nonprofit partners acting as cooperating 

 

9

In addition to national parks, cooperating associations may also support national forests, 

national wildlife refuges, and state parks, among others. 

10Cooperating association agreements require associations to obtain tax-exempt status 

under section 501(c)(3) of the Internal Revenue Code. This section provides that 

organizations granted tax-exempt status must operate exclusively for charitable, religious, 

or educational purposes, among others. As tax-exempt organizations, associations enjoy 

certain benefits that for-profit organizations do not. In particular, tax-exempt organizations 

are required to pay federal income taxes only on unrelated business income. Under state 

laws, they may also be exempt from many state and local taxes. 

11Cooperating associations are subject to the National Park Service’s Management Policies 

and “Director’s Order #32: Cooperating Associations,” with guidance provided in Reference 

Manual 32. When cooperating associations engage in fund-raising to support education and 

interpretation, they are also governed by “Director’s Order #21: Donations and 

Fundraising.” 

Page 7 GAO-09-386 Donations to National Parks
 

associations—such as Golden Gate National Parks Conservancy, Rocky 

Mountain Nature Association, and Zion Natural History Association—also, 

like friends groups, actively raise funds to support programs and projects 

in parks. 

Partnerships and donations are a key component of the Park Service’s 

Centennial Initiative—a proposal the Park Service outlined in May 2007 for 

preparing the national parks for the agency’s 100th anniversary. The 

initiative is a 10-year plan that includes two funding components: (1) $100 

million per year for 10 years in new federal spending to complete 

operational enhancements such as repairing buildings, improving 

landscapes, hiring seasonal employees, and expanding educational 

programs; and (2) a Centennial Challenge, whereby the Park Service 

would receive up to $100 million per year in federal funding to be matched 

by an equal or greater amount of private donations toward partnership 

projects and programs. Although Congress has not passed legislation 

authorizing this multiyear proposal, it did appropriate $24.6 million for 

fiscal year 2008 Centennial Challenge projects. With this federal money, 

the Park Service obtained $26.9 million in contributions from its partners. 

In 2009, the Park Service plans to spend $4.5 million in federal funds, 

combined with $4.5 million in nonfederal donations, for eight Centennial 

Challenge projects and programs.12

These donations and partnerships have raised concerns among some 

members of Congress and the public about the potential for donors to 

have undue influence over agency priorities, for parks to become 

commercialized, and for partnership projects to create new operations and 

maintenance costs for the Park Service to absorb. For example, in 1998, 

members of Congress raised concerns about one park’s proposal for a new 

visitor center to be supported by a fund-raising partner. From 1998 to 

2002, in several hearings and letters to the Park Service about this project, 

members of Congress and others questioned whether 

 

12In January 2009, when the Park Service was operating under a continuing resolution, it 

designated these as Centennial Challenge projects and programs, but when the budget was 

finalized, the agency did not receive any congressional appropriations specifically targeted 

under this name. Consequently, according to an agency official, the agency will instead use 

other available funds. 

Page 8 GAO-09-386 Donations to National Parks
 

• the partner organization—which had ties to a construction company—

exercised undue influence over the visitor center project when it 

developed a proposal and the park selected it without first following 

agency policies to clarify the need for such a facility; 

• the project was an agency priority, given that it had never reached the 

nationwide priority list of construction projects in the agency’s budget 

request; 

• the project was excessively large and costly; 

• Congress might have to cover a funding gap if the partner fell short of its 

fund-raising goals; and 

• proposed features in the visitor center—including a retail store, café, 

restaurant, and IMAX theater—would commercialize the park. 

More generally, in 2001 and 2002, the House Appropriations Committee 

expressed concerns about large partnership construction projects—noting 

that such projects included both successes and failures—and reminded 

the agency to respect its own priority-setting process for construction 

projects, rather than going outside the process to seek congressional 

funding. The committee further reminded the Park Service to be cautious 

about partnership projects that resulted in new operations and 

maintenance costs, especially in light of the agency’s existing maintenance 

backlog. In 2002, the committee also said that the Park Service should be 

sure partnership agreements were in writing because in many instances, 

the scope of projects changed and the partners and the committee had 

different recollections of the original commitment. And in 2004 a 

conference committee reiterated past concerns of both congressional 

houses about the management of partnership construction projects, 

calling for the Park Service to carefully consider both construction and 

long-term operations costs of new facilities and to “make difficult 

decisions, where necessary, to defer or suspend a project that is not the 

right project, for the right reason, at the right size, and at the right time.” 

The public has also registered its concerns. For example, in 2005 the Park 

Service drafted a new version of its donations and fund-raising policy, 

including proposals to relax certain provisions related to corporate 

donations and advertising, but after receiving about 1,000 public 

comments—many expressing concern that the proposed changes would 

commercialize the parks—the agency removed these provisions from the 

final version. 

Page 9 GAO-09-386 Donations to National Parks
 

To manage donations and related partnerships, officials at all levels of the 

Park Service—park, region, and headquarters—are involved to varying 

degrees. The park is the basic management unit of the Park Service, and 

the agency relies heavily on the judgment of park superintendents (or park 

managers) who oversee each park unit for most decisions affecting local 

park operations. In addition to managing park operations, directing 

program activities, and overseeing administrative functions, 

superintendents are responsible for developing and fostering external 

partnerships. Depending on the park, other park staff, such as the deputy 

superintendent or the chief of interpretation, may also play a significant 

role in managing partnerships. Superintendents report to the regional 

director for their respective region (see fig. 2). The Park Service’s seven 

regional offices offer administrative or specialized support not always 

available at local parks—regional partnership coordinators who work with 

local parks on partnership matters within the region, for example. 

Regional offices are responsible for program coordination, budget 

formulation, financial management, strategic planning and direction, 

policy oversight, and assistance in public involvement and media relations 

for parks and programs within the region. Additionally, they ensure 

consistency with national policies and priorities and coordinate with 

Interior’s regional solicitors’ offices. 

Page 10 GAO-09-386 Donations to National Parks
 

Figure 2: National Park Service Regional Offices 

Source: National Park Service.

Regional office location

Regional boundaries

Kan.

Wyo.

Va.

Ga.

Pa.

Ore.

Nev.

Idaho

Mont.

Utah

Ariz. N. Mex.

Colo.

N.Dak.

S.Dak.

Nebr.

Tex.

Okla.

Minn.

Iowa

Mo.

La.

Ill.

Miss.

Ind.

Ky.

Tenn.

Ala.

Fla.

S.C.

N.C.

Ohio

N.H.

Mass.

Mich.

Calif.

Wash.

Wis. N.Y.

Maine

Vt.

W.Va.

ALASKA

Hawaii

Conn.

R.I.

N.J.

Md.

Washington, D.C.

Del.

Ark.

★

SOUTHEAST

MIDWEST

PACIFIC WEST

PACIFIC WEST

INTERMOUNTAIN

United States Territories

American Samoa

Guam

★ Anchorage

★

Denver ★

Oakland

Omaha★

★

Atlanta

Philadelphia★

NATIONAL

CAPITAL

★

SOUTHEAST United States Territories

Puerto Rico

US Virgin Islands

NORTHEAST

The Park Service’s headquarters office, located in Washington, D.C., and 

led by the agency’s Director, provides nationwide leadership and 

advocacy, policy and regulatory formulation and direction, program 

guidance, and accountability for programs and activities managed by the 

field and key program offices. It also manages Park Service-wide programs 

that can be carried out most effectively from a central location. Within the 

headquarters office, the Office of Partnerships and Philanthropic 

Stewardship (Partnership Office) oversees the Park Service’s policies on 

donations and fund-raising; assists parks, regional offices, and program 

areas by facilitating the review and approval of large-scale donations and 

fund-raising projects; reviews and coordinates marketing and donorPage 11 GAO-09-386 Donations to National Parks
 

recognition programs; delivers philanthropy and partnership training for 

the agency and its partners; and provides coordination between the agency 

and park-based friends groups and the Foundation. The Partnership Office 

also coordinates with Interior’s Washington Solicitor’s Office to review the 

legal sufficiency of agreements and other documents. Similarly, within the 

Division of Interpretation and Education, an agencywide cooperating 

association coordinator facilitates relationships between the agency and 

cooperating associations. 

Donations from nonprofit partners and corporations have provided 

significant support to park programs and projects, including interpretation 

and education, repair and rehabilitation of facilities, and cultural resource 

management and protection, among others. In addition, related 

partnerships have amplified the value of those donations with countless 

other benefits that go beyond dollar values or a simple tally of projects. 

Donations Have 

Provided Significant 

Support to Park 

Programs and 

Projects, and 

Partnerships Amplify 

These Donations with 

Intangible Benefits 

Donations Have Provided 

Significant Support to Park 

Programs and Projects 

Donations from several sources have provided support to park programs 

and projects. Donations from nonprofit partners—including the 

Foundation, cooperating associations, and friends groups—support 

various types of programs and projects at the national and park level. 

Donations from corporations have also supported the Park Service 

through various programs and projects and have promoted public 

engagement with parks, in many cases through advertising. 

Donations from the Foundation generally support programs and projects 

that are not federally funded, that meet the most critical needs of the park 

system, and have great impact across the Park Service. The Foundation, in 

consultation and collaboration with the Park Service, emphasizes the 

following themes when it raises funds and makes donations to the agency: 

(1) visitor experience; (2) volunteerism; (3) education; (4) community 

engagement; and (5) projects of national significance, such as the Flight 93 

Donations from Nonprofit 

Partners Support a Variety of 

Park Programs and Projects 

Page 12 GAO-09-386 Donations to National Parks
 

Memorial13 and the African American Experience.14 In 2005-2007, the 

Foundation addressed several of these themes through its donations to 

help create and improve Junior Ranger programs—which introduce 

children and families to the treasures of the national park system—in 

more than 90 parks.15 The Foundation’s donations supported volunteer and 

event coordination and community outreach and funded educational 

improvements, including redesigned program booklets, updated badges, 

and activity guides to attract children of different ages. As a result, 

according to the Foundation, parks are better able to attract families and 

educate the next generation of national park stewards. 

In contrast to the national focus of donations from the Foundation, 

donations from cooperating associations and friends groups generally 

support projects and programs at individual parks. The Park Service does 

not track these donations centrally, however, so we asked the 30 

cooperating associations and friends groups related to our sample of parks 

to identify the types of projects and programs their donations have 

supported in the last 3 years.16 We found that donations from these 

cooperating associations and friends groups generally supported projects 

and programs in one of nine categories, with the top three being 

interpretation and education, repair and rehabilitation, and cultural 

resource management and protection (see table 1). 

 

13The Flight 93 Memorial is a planned 2,200-acre national park where people can learn 

about the events of September 11, 2001. In April 2007, the Foundation was chosen to lead 

the fund-raising efforts for this memorial. 

14The mission of the African American Experience Fund is to connect Americans from all 

walks of life to the contributions of African Americans throughout our country’s history, by 

raising private funds to support educational, volunteer, and community engagement 

programs in national parks and historic sites that celebrate and tell the story of American 

history and culture. 

15The Junior Ranger Program has three goals: (1) to engage children in learning about 

history and nature by participating in activities that enhance their national park experience; 

(2) to extend the program’s reach to underserved audiences so that all parks can establish 

Junior Ranger programs; and (3) to develop and promote respect of, and appreciation for, 

our national treasures. 

16Parks and partners in our sample did not correlate one to one because some parks do not 

have a friends group, some parks do not have a cooperating association, and some 

cooperating associations serve multiple parks (see app. I for more information). 

Page 13 GAO-09-386 Donations to National Parks
 

Table 1: Types of Projects or Programs Supported by Donations from 30 Cooperating Associations and Friends Groups in 

Our Sample 

Project and program 

categories 

Number of cooperating 

associations and 

friends groups 

indicating this category Examples of projects or programs supported by donations 

Interpretation and 

education 

29 Funding for park interns, seasonal employees, conference attendance, and 

wayside exhibits; training for interpretive aides and for teachers in the park 

and in schools; Junior Ranger program support; printing and publishing 

support for interpretive supplies, field guides, and park newspapers; 

cultural arts 

Repair or rehabilitation of 

an existing facility 

23 Rehabilitating historic structures, including the Statue of Liberty and a park 

house for use by seasonal employees; repairing fencing, replacing roofs, 

and painting barns; remodeling backcountry trail shelters; restoring fountain 

to working order 

Cultural resource 

management or protection 

22 Restoring and preserving park archives, including early paintings, 

photographs, and film; digitizing slide files for online accessibility; 

preserving museum collections; acquiring Indian artifacts and rare books 

Natural resource 

management or protection 

16 Restoring endangered species habitat; restoring and maintaining a historic 

garden; supporting soil analysis and research of vegetation, soundscapes, 

and wildlife 

New construction 12 Supporting construction and design for sales area at new visitor center; 

supporting construction for a new science center and upgrades at a new 

visitor center, such as more interactive exhibits and building upgrade to 

“green building” status 

Trail maintenance, 

development, and access 

11 Providing self-guiding brochure dispensers at trail heads; purchasing shirts, 

pants, and boots to support student volunteers working on trails 

Other 9 Maintaining a superintendent’s account for miscellaneous expenses; 

cosponsoring a special event; supporting climate change research 

Search and rescue 6 Providing maps for search and rescue; helping purchase new search-andrescue vehicle; supporting canine unit 

Lands 5 Purchasing 80 acres of land in the middle of a battlefield to prevent 

development 

Source: GAO. 

The category most often cited by the partners in our sample was 

interpretation and education, with 29 of the 30 partners reporting that 

their donations had supported projects and programs in this category 

during the last 3 years. For example, donations supported free park 

newspapers, trail guides, and Junior Ranger program materials, as well as 

the creation and production of exhibits and podcasts to enhance visitor 

awareness and understanding of park resources (see fig. 3). In addition, 

several partners donated services to operate field institutes that provide 

on-site immersion experiences for visitors, such as learning about the 

ecology of different wildlife species or the art of fly-fishing, among others. 

Other partners donated their services to provide educational programs 

Page 14 GAO-09-386 Donations to National Parks
 

that reach audiences outside the parks. The Grand Canyon Association, 

for example, partners with a diverse group of nonprofit entities throughout 

the state of Arizona to produce free community lectures, for which they 

reported a doubling in attendance from 2006 through 2007. Still other 

partners have harnessed technology to provide virtual park experiences 

through video blogs and e-field trips. 

Figure 3: Yellowstone National Park Visitor Watching a Podcast 

Source: Yellowstone Association.

Visitors can create a customized electronic tour by downloading videos to a handheld electronic video 

player and using the park’s official Web site map to match the numbers of the videos to sites within 

the park. For those unable to visit the park in person, the videos provide a “virtual visit.” 

The second- and third-most common categories supported through 

partners’ donations, according to the partners in our sample, were repair 

and rehabilitation of facilities and cultural resource management and 

protection. Partners’ donations supported projects in these categories that 

are large and highly visible, as well as those that are more specialized and 

subtle but no less valuable. Some examples include: 

• Statue of Liberty and Ellis Island restoration. Since 1982, the Statue 

of Liberty-Ellis Island Foundation has raised over $500 million for, among 

other things, the largest historical restoration in the history of the United 

States. The foundation’s donations have paid for restoration activities that 

Page 15 GAO-09-386 Donations to National Parks
 

included replacing the statue’s torch, repairing its crown, and installing 

new elevators and an informative exhibit in the base. On Ellis Island, the 

Foundation has restored five buildings—including the Ellis Island 

Immigration Museum, where many rooms look as they did during the 

height of immigrant processing—and expanded and upgraded the Museum 

Library and Oral History Studio, among other projects. The Ellis Island 

Immigration Museum has welcomed nearly 30 million visitors since 

opening in 1990. 

• Wright Brothers National Memorial monument restoration. In 2008, 

the First Flight Foundation donated funds and services to complete the 

first major restoration in more than a decade of the monument at Wright 

Brothers National Memorial in North Carolina, improving safety 

conditions for visitors and Park Service staff and restoring public access 

to the monument (see fig. 4). The project cost over $400,000 and included 

cleaning the monument’s interior and exterior, repairing damaged mortar, 

replacing the electrical and mechanical systems, reworking the 

monument’s dome and beacon, and designing a new night-lighting scheme 

to enhance the architectural granite “wing” design. The project also 

included development of a new maintenance manual with specific 

instructions, which the park’s maintenance team will use for routine 

upkeep of the monument in years to come. 

Page 16 GAO-09-386 Donations to National Parks
 

Figure 4: The Monument at Wright Brothers National Memorial 

Source: National Park Service.

• Historic photograph and painting restoration at Yellowstone 

National Park. Donations from the Yellowstone Association have long 

funded conservation of irreplaceable treasures in the park’s collection. 

Examples include duplication of Yellowstone’s more than 90,000 historic 

photographs—many of which were stored only on the original 

deteriorating film negatives—and funding the conservation of an 1887 

painting by James Everett Stuart, whose paintings also grace the White 

House and homes of the Montana, Oregon, and Washington historical 

societies (see fig. 5). The association’s donations have also funded 

improved storage for the collected photographs and artwork to protect 

them from further damage. 

Page 17 GAO-09-386 Donations to National Parks
 

Figure 5: Historic Painting Before (left) and After (right) Restoration 

In addition to the top three categories of projects and programs that 

partners in our sample cited, several other categories were also supported 

through the partners’ donations. For example, some partners said their 

donations supported construction of new facilities. Friends groups tend to 

provide more support in this category than cooperating associations do, 

because the associations’ missions are generally more narrowly focused 

on interpretation, education, and research. From 2005 through 2008, 

friends groups contributed over $100 million for at least six construction 

projects. Among these is a new visitor center at Grand Teton National 

Park. The Grand Teton Foundation donated about $10 million, which was 

combined with an $8 million federal appropriation and about $600,000 

from the park’s cooperating association, to build the new visitor center. 

Two other categories supported by partners’ donations were (1) natural 

resource management and (2) trail maintenance, development, and access. 

Not only did several friends groups and some cooperating associations 

donate funds to support projects in these categories, but they also donated 

their services, often by coordinating volunteer programs. More than half 

Source: The Fine Arts Conservancy.

Page 18 GAO-09-386 Donations to National Parks
 

Page 19 GAO-09-386 Donations to National Parks 

the friends groups we spoke with support parks through volunteer 

services, which range from established programs to coordination of small 

groups. For example, through its Site Stewardship Program and with the 

support of local volunteers and education groups, Golden Gate National 

Parks Conservancy works to restore endangered species habitat at 

restoration sites in the Golden Gate National Parks. These sites are home 

to a number of endangered species, including the San Francisco garter 

snake and the mission blue butterfly (see figs. 6 and 7). 

Figure 6: Habitat Restoration Volunteer 

Source: Golden Gate National Parks Conservancy.
 

Figure 7: The Endangered San Francisco Garter Snake 

Another friends group, the Frederick Vanderbilt Garden Association, 

consists of about 150 members who donate time to maintain and restore 

the gardens at the Vanderbilt Mansion National Historic Site in New York. 

The group also raises funds in the local community to purchase equipment 

and supplies such as lawn mowers, garden tools, and plants for the 

gardens, but its primary donation to the park consists of its members’ 

time. 

Not only have donations from nonprofit partners provided significant 

support to parks by helping to implement projects and programs, but they 

have also enabled the Park Service to achieve broader goals, such as 

addressing deferred maintenance needs. Fourteen of the superintendents 

in our sample told us that one or more of their partners had supported a 

project in the last 3 years that addressed deferred maintenance needs in 

their park. For example, 79 percent of the approximately $4 million in 

grant funding that Yosemite National Park received from a friends group in 

2008 supported 14 deferred maintenance projects, including restoring 

scenic overlooks, rehabilitating historic structures, and replacing 

infrastructure such as bridges. 

Most of the superintendents we spoke with said that many projects would 

not have been possible without their partners’ support or that projects 

would have taken longer to complete. In a few cases, superintendents told 

us that they cannot meet their parks’ basic operating needs with 

appropriations, so the support they receive from their partners is critical 

Source: Golden Gate National Parks Conservancy.

Page 20 GAO-09-386 Donations to National Parks
 

to their ability to provide programs and make needed park improvements. 

Additionally, most superintendents said support from their partners 

helped decrease costs. For example, a friends group paid for the design 

and construction of a heli-rappel tower at Yosemite National Park, so that 

rangers and other rescue personnel, who conduct about 250 rescues per 

year, can train and maintain their certifications (see fig. 8). According to 

the Yosemite Superintendent, this project saves the park from renting 

helicopter time—at an estimated $1,500 per hour—and would not have 

been done were it not for the friends group funding. 

Page 21 GAO-09-386 Donations to National Parks
 

Figure 8: Heli-Rappel Tower at Yosemite National Park 

This tower simulates the experience of rappelling out of a helicopter, so that park rangers and other 

rescue personnel can train and maintain their certifications without helicopter rental expenses for the 

park. 

Source: Yosemite National Park.

Page 22 GAO-09-386 Donations to National Parks
 

Corporate donations include charitable gifts—from which little to no 

business benefit is expected in return—as well as gifts that support both 

park needs and the corporation’s business goals, such as through 

advertising. For example, a corporation might develop an advertising 

campaign that raises money for and promotes public engagement with 

parks, while also achieving its own goals, by appealing to environmentally 

conscious consumers through its affiliation with the national parks. 

Sometimes parks receive corporate donations directly; at other times, 

nonprofit partners accept corporate donations on behalf of individual 

parks or the Park Service. 

Corporate Donations Also 

Support Projects and Programs 

and Promote Public 

Engagement with Parks 

The Park Service does not track corporate donations on a national level, 

but we collected information from the parks and nonprofit partners in our 

sample about the corporate donations they have received in the last 3 

years. Of the 25 parks in our sample, 8 reported receiving direct charitable 

donations from corporations, none of which were tied to advertising. 

Individual corporate donations varied widely, but no single donation was 

valued at more than $70,000 (see table 2). These donations supported 

educational, search-and-rescue, and volunteer programs, as well as special 

events, maintenance, and resource management. 

Table 2: Corporate Donations Made Directly to Our Sample of 25 Parks, 2006-2008 

Park 

Number of 

donations 

Individual donation 

range

Total donations 

received Donors 

Cuyahoga Valley 

National Park 

2 $11,000-$69,500 

(estimated)a

$45,500-$80,500

(estimated)a

All Erection and Crane Rental; 

Glencairn Corporation 

Gettysburg National 

Military Park 

2 $50-$500 $550 Honeywell Hometown Solutions; 

Boeing 

Grand Teton National 

Park 

9 $100-$3,000 $10,350 Teton Mountaineering; Schapp 

Enterprises, Inc.; Clear Seas 

Communication, Inc.; Jackson Hole 

Seminars, Inc.; Hands On Design; 

High Mountain Group; Wal Mart 

Foundation; The Sandage Companies; 

Dornan’s Bar, Inc. 

Homestead National 

Monument of America 

1 $1,000 $1,000 E Energy Adams, LLC 

Statue of Liberty 

National Park 

6b$750-$30,000 $38,750 American Express; Clear Seas 

Communication, Inc.; Ritz Carlton; 

Oppenheimer; CMGRP; 20th Century 

Fox 

Yellowstone National 

Park 

3 $20-$100 $180 APN Media LLC; EP Consolidated 

Properties; HK Construction 

Page 23 GAO-09-386 Donations to National Parks
 

Park 

Number of 

donations 

Individual donation 

range

Total donations 

received Donors 

Yosemite National Park 2 $6,000-$40,000 $46,000 Pacific Forest and Watershed Lands 

Stewardship Council; Clear Seas 

Communication Inc. 

Zion National Park 11 $34-$6,000 $11,051 Orange Tree Productions, Inc.; 

Tennessee Valley Authority; Red 

Williams Insurance Agency, Inc.; JB 

Specialties, Inc.; Cap Insurance 

Company; PTI; BASF Corporation; 

Intermountain Farmers Association; 

UBS Financial Services, Inc. 

Source: GAO. 

a

In-kind donations; reported values estimated by park officials. 

b

Includes two in-kind donations for which park officials gave no estimated value. 

Of the 30 cooperating associations and friends groups in our sample, 15 

reported providing their parks over $1 million in annual support, including 

at least one corporate donation in the last 3 years.17 Most of these 

corporate donations were charitable gifts used to support various projects 

and programs; only three were tied to advertising. A Park Service 

headquarters official confirmed that charitable donations from 

corporations were more common than those tied to advertising. 

In addition to collecting information from parks and partners in our 

sample, we also reviewed information from the Foundation about the 

corporate donations it accepts on behalf of the Park Service and how 

these donations support the agency. Many of the corporate donations 

received by the Foundation serve a dual purpose—meeting parks’ needs 

while also supporting corporations’ goals. Generally, the Foundation 

manages these corporate donations under one of two models. Under the 

first model—the “Proud Partners of America’s National Parks” program—

corporations commit to making certain donations to support Park Service 

projects and programs. In return, the corporations receive several 

privileges that help them advance their business goals. Specifically, they 

are designated as Proud Partners, permitted to affiliate themselves with 

 

17We requested information from all the partners in our sample that reported on their tax 

forms providing more than $1 million in support to the Park Service in any one of the last 3 

reporting years to determine how many of these partners were receiving corporate 

donations. Because the beginning and end dates for each organization’s reporting year vary 

and do not all correspond to the same calendar or fiscal year period, the data we collected 

from partners came from the most recent 3 years of tax data they had submitted to the 

Internal Revenue Service (IRS). 

Page 24 GAO-09-386 Donations to National Parks
 

the Park Service in promotional materials, and granted national marketing 

exclusivity. To ensure marketing exclusivity, the Park Service agrees to 

abstain from entering into any other nationwide advertising agreements 

with companies that sell the same product or service as the Proud Partner. 

While corporate donations under this model support the Park Service, 

according to an agency official, they also require the agency to invest 

considerable resources in managing them and ensuring national marketing 

exclusivity. A foundation official said that the organization is phasing out 

this model and now has only two Proud Partners—down from five at the 

end of 2006. According to an official, the Foundation is interested in and 

continues to pursue long-term relationships with existing and new 

corporations but under a new model. In contrast to the proud partner 

model, this new model includes more limited marketing exclusivity— 

12 months, in the case of a Hertz Rental Car “green fleet” promotion 

(see fig. 9)—and permits an advertising affiliation with the Foundation, 

rather than the Park Service. Under this arrangement, the Park Service 

need not invest any resources in managing the relationship or ensuring 

marketing exclusivity, since the direct relationship links a corporation 

only with the Foundation. According to a Foundation official, such 

corporate donations benefit the Park Service through both the funds they 

provide and information in advertisements, which promotes public 

engagement with national parks (see figs. 9 and 10). Additionally, the 

official said, the Foundation understands the concern about 

commercialization within national parks, and the new model addresses 

that concern by having corporations affiliate with the Foundation rather 

than directly with the Park Service. This way, the corporate advertising is 

distanced from national parks. 

Page 25 GAO-09-386 Donations to National Parks
 

Figure 9: Hertz Green Fleet Promotion 

Source: National Park Foundation.

Hertz is committed to serving the environment. That’s why for every Hertz Green 

collection rental you make, Hertz will contribute $1 to the National Park Foundation, with a minomum guarantee of $1 million donated over the next year. With the 

Hertz Green Collection, you can drive economically and do something good for the 

environment at the same time. And we’re proud of our involvement in helping to make the 

world a greener place.

The Hertz car-rental 

company donated $1 to the 

National Park Foundation 

every time a car was rented 

from its “green fleet,” with a

guaranteed minimum 

donation of $1 million, in 

exchange for a 1-year, 

exclusive marketing 

association with the 

Foundation.

Right:

The shared position of the 

logos at the right illustrates

Hertz’s support of national 

parks through the National 

Park Foundation

Page 26 GAO-09-386 Donations to National Parks
 

Figure 10: Leaflet Advertising Macy’s Campaign 

Source: National Park Foundation.

During National Park Week 2008, Macy’s department stores nationwide helped generate awareness 

and cash support for the Foundation through the “One Good Turn” shopping event, which generated 

$2.7 million in unrestricted funds for the Foundation. Macy’s encouraged its customers to support the 

work of the Foundation with a $5 contribution in exchange for an in-store and online shopping pass 

for a 2-day discount on most clothing and home items. 

Page 27 GAO-09-386 Donations to National Parks
 

Related Partnerships Have 

Amplified the Value of 

Donations with Countless 

Other Benefits 

By supporting projects and programs that would not otherwise be 

accomplished, partners help enhance visitors’ experiences by offering 

visitors more than what they might have enjoyed without the partner’s 

involvement. Besides visible project and program support, partners also 

provide less-obvious enhancements that ultimately benefit visitors. These 

enhancements include intangible benefits supplied by cooperating 

associations; flexibility, efficiencies, and expertise afforded the Park 

Service by nonprofits as nongovernmental entities; and a meaningful 

connection to the local community for constituency building. 

The Park Service derives a substantial benefit from cooperating 

associations’ running retail outlets at multiple parks and using some model 

of revenue sharing with the parks where the outlets are located. This 

relationship allows even small parks to benefit from basic cooperatingassociation services, such as a bookstore. In addition, cooperating 

associations believe they offer parks and visitors attributes that for-profit 

retailers would not, such as site-specific publications and materials that 

might be unprofitable or not otherwise available, as well as more 

knowledge and heightened passion about the parks. Cooperating 

associations can also contribute to the continuity of visitors’ experiences, 

from Internet trip-planning resources to in-park retail sales, which give 

visitors an opportunity to take their experiences home to share with 

others and extend their visit long after they have left the park. 

In addition, partners afford parks increased flexibility to address 

unplanned needs, the ability to accomplish projects more efficiently, and 

expanded expertise. According to several agency and partner officials, 

because partners are not subject to the federal appropriations cycle or 

government procurement regulations, they are more nimble than 

government and can help meet parks’ immediate or unexpected needs, 

such as buying new computers or a video projector. Some partners also 

set aside a small amount of money that superintendents are able to use for 

expenses, such as giving gifts to visiting dignitaries or hosting a thank-you 

lunch for summer interns, for which they may not be permitted to use 

federal funds. Similarly, partner resources often go further because 

partners can earn interest on their money and can complete projects more 

efficiently—faster and for less money—than government. Several friends 

groups (6 of the 19 in our sample) have created and manage endowments 

to support capital improvements, conservation programs, and educational 

and community programs. When the costs of constructing a new science 

center at Great Smoky Mountain National Park suddenly increased in 

response to reconstruction demands after Hurricane Katrina, for example, 

the park’s partners had sufficient flexibility with their financial resources 

Page 28 GAO-09-386 Donations to National Parks
 

to cover the additional costs. Partners can also play a role in land 

acquisitions. Private real estate transactions typically move faster than 

government transactions, so parks benefit from their partners’ flexibility 

and resource availability when the partner acquires and preserves land on 

behalf of the government. The Rocky Mountain Nature Association, for 

example, has acquired several parcels of land and subsequently donated 

them to the Park Service. Of particular significance, according to the 

association’s Executive Director, was a scenic 13-acre parcel that the 

association quickly purchased upon learning it was for sale, resulting in 

the expansion of Rocky Mountain National Park’s border and preservation 

of the land from development by a local resort owner, who was also 

bidding for the land (see fig. 11). In less than 2 months after the land was 

posted for sale, the association was able to raise $400,000 and purchase 

the land. Additionally, it spent $15,000 cleaning up a 75-year-old dump and 

removing old structures from the site and about $7,000 in property taxes 

before the Park Service accepted the donation. The association’s 

Executive Director said that the nonprofit’s ability to be “Johnny-on-thespot” is one of the most significant ways it is able help the park. 

Page 29 GAO-09-386 Donations to National Parks
 

Page 30 GAO-09-386 Donations to National Parks 

Figure 11: Rocky Mountain Nature Association Land Purchase 

Also, nonprofit partners may bring expertise in areas that balance park 

staff members’ experience and can lead to healthy dialogue, productive 

debates, and innovative ideas. Such expertise is particularly advantageous 

in helping the Park Service maintain parks’ relevance to a diverse 

population of park users and balance the expectations of a technologically 

sophisticated generation with preservation of the natural environment. 

Finally, as professionals and members of their communities, partners help 

parks make meaningful connections with surrounding communities and 

build supportive constituencies. One way that partners perform 

community outreach and constituency building is through membership 

programs, which most of the partners in our sample have. For example, 

partners often send out newsletters or informational packets telling their 

members and park gateway communities about the latest park issues. 

Many partners also have annual reports informing local communities of 

parks’ various projects and activities and encouraging future involvement. 

Friends groups, in particular, spend a good deal of time and resources 

cultivating community relationships to build support for their parks. They 

Source: Rocky Mountain Nature Association.
 

encourage donors and communities to become stakeholders in the parks, 

thereby expanding parks’ support constituencies. The long-term personal 

relationships they build with community members and key business and 

political leaders furnish continuity between parks and surrounding 

communities despite frequent park staff turnover. Furthermore, these 

groups often serve as parks’ community liaisons and voices through 

advocacy, such as lobbying elected officials. Six of the 19 friends groups in 

our sample reported advocacy as one of the functions they perform.18

The Park Service’s policies and processes for managing donations and 

related partnerships establish a firm foundation to uphold the agency’s 

objectives—integrity, impartiality, and accountability—but shortcomings 

in some of the policies and processes make it difficult to consistently 

secure these objectives. The agency’s donations and fund-raising policy, as 

written, includes directives in important areas to fulfill agency objectives, 

but in practice parks do not always follow these policy requirements. In 

addition, the Park Service has improved its partnership construction 

process in response to past accountability concerns, but some gaps 

remain. These gaps in the partnership construction process, as well as 

weaknesses in the donations and fund-raising policy, hinder their 

effectiveness at protecting against risks that may accompany donations. 

The Park Service’s cooperating association policy works well to guide 

relations with associations, and the agency’s new procedures for 

Centennial Challenge projects show promise, but it remains to be seen 

how well they will work over time. 

Park Service Policies 

and Processes for 

Managing Donations 

Generally Work Well, 

but Some Could Be 

Strengthened 

Donations and Fundraising Policy 

Requirements Address Key 

Areas, but Weaknesses 

Remain in Implementation 

The Park Service’s donations and fund-raising policy requirements address 

key areas to protect the agency against risk, but their effect is diminished 

because parks and partners do not always follow them; ambiguities in the 

policy create challenges for parks and partners attempting to follow it; and 

the agency lacks a systematic, comprehensive approach for monitoring 

conformance. 

 

18According to the standard agreement with the Park Service, friends groups may not lobby 

Congress on issues or projects for which they are simultaneously raising funds. They can, 

however, advocate on other park-related issues. 

Page 31 GAO-09-386 Donations to National Parks
 

To ensure the integrity and appropriateness of donations and fund-raising 

activities, the agency’s donations and fund-raising policy includes 

provisions designed to protect against risks of undue donor influence, 

excessive future costs for parks, and potential commercialization. These 

provisions address donations made directly to parks or to Park Service 

programs, as well as donations made to partners, such as friends groups, 

for the benefit of parks or programs. As shown in table 3, the policy 

requires parks and partners to establish written agreements and plans, 

among other things, to advance the following objectives: 

Donations and Fund-raising 

Policy Includes Requirements 

to Protect the Park Service 

against Risk 

• ensure donations are used to meet park needs, 

• identify any potential conflicts of interest relating to prospective donors, 

• consider future costs that would result from donor-supported projects, 

• ensure accountability for donations received, 

• recognize donors appropriately, and 

• keep parks free of advertising and commercialism. 

Table 3: National Park Service Donations and Fund-raising Policy: Summary of Required Agreements and Documentation 

Agreement or 

document Description Objectivea

When required 

Donor recognition 

plan 

Sets out procedures for acknowledging 

and thanking donors in a manner 

consistent with the park’s mission, 

purposes, and plans 

Recognize donors 

appropriately; 

keep parks free of advertising 

and commercialism 

For all parks and programs that 

receive or are likely to receive 

donations 

Corporate campaign 

agreement 

Documents terms of agreement, 

including description of corporate 

donation and benefit provided to the Park 

Service, as well as prohibitions on 

marketing inside parks and stating or 

implying Park Service endorsement of 

products; describes specific promotional 

materials and where, how often, and how 

long they will be used 

Keep parks free of advertising 

and commercialism; 

ensure donations are used to 

meet park needs 

When a corporation makes a 

donation to the Park Service 

directly or through a partner and 

uses advertising and marketing to 

promote the donation and a 

relationship with the Park Service

Friends group 

agreement 

Establishes long-term relationship 

between the Park Service and a partner; 

may authorize fund-raising for ongoing 

agency needs 

Ensure donations are used to 

meet park needs 

To authorize fund-raising for 

ongoing programmatic needs, if 

not covered in fund-raising 

agreements; these agreements 

are not generally required 

Page 32 GAO-09-386 Donations to National Parks
 

Agreement or 

document Description Objectivea

 When required 

Fund-raising 

agreement 

Documents fund-raising target amount 

and intended use of funds, agreed-upon 

donor review process, and other terms 

Ensure donations are used to 

meet park needs 

When a fund-raising effort is 

designed to support a specific 

project or program and raise over 

$25,000 

Donor review 

procedures 

Stipulates an agreed-upon process for 

reviewing donors, which must be 

documented in fund-raising agreements 

Identify any potential conflicts 

of interest for prospective 

donors 

When a fund-raising effort is 

designed to support a specific 

project or program and raise over 

$25,000 

Fund-raising plan Details techniques, timing, staff needs, 

costs, and other components of a fundraising strategy 

Consider future costs that 

would result from donorsupported projects 

When a fund-raising effort is 

designed to support a specific 

project or program and raise over 

$25,000 

Feasibility study Assesses the likelihood that the fundraising effort will be successful Consider future costs resulting 

from donor-supported projects 

For fund-raising efforts intended 

to raise $1 million or more or 

involving national or international 

solicitations; may be waived by 

headquarters, depending on 

experience of park and partner 

Source: GAO analysis of Park Service data. 

a

This column represents our determination of which of six Park Service policy objectives (see 

preceding text) is fulfilled by the agreement or document. 

The donations and fund-raising policy sets forth the Park Service 

Director’s delegation of authority to regional officials to accept donations 

under $1 million and to approve most fund-raising agreements with a goal 

of less than $1 million.19 Donations of $1 million or more and fund-raising 

agreements with a goal of $1 million or more, or involving national or 

international solicitations, must be approved by the Director.20

For all donations made directly to parks, agency officials must ensure that 

the donation meets a legitimate need of the Park Service, would not 

require the commitment of unplanned funding, and does not reflect an 

attempt by the donor to influence agency decisions or receive special 

treatment. In addition, the donations and fund-raising policy describes 

appropriate and inappropriate ways to recognize donors. For example, 

donors’ names may be listed on a visitor center wall, on a Web site, or in a 

 

19Regional directors may delegate this or more limited authority to accept such donations 

to park superintendents or regional program managers. 

20The Director may delegate to regional directors the authority to approve certain fundraising agreements in which the goal is less than $5 million and there is no federal 

contribution of funds to the project or program. 

Page 33 GAO-09-386 Donations to National Parks
 

park newspaper but not on bricks, benches, or park furnishings; for 

corporate donors, recognition may not include marketing slogans under 

any circumstances. 

Under corporate campaigns, businesses may donate to parks or partners 

and promote their association with the Park Service through advertising,21

but the donations and fund-raising policy states that such advertising or 

product promotion may not appear inside parks and may not imply that 

the Park Service endorses a business or product. It further states that the 

Park Service must review and approve all marketing materials before 

distribution and that any corporate campaigns identifying the Park Service 

with alcohol or tobacco products will not be authorized. A written 

corporate campaign agreement must be in place and reviewed for legal 

sufficiency by Interior’s Office of the Solicitor. 

The Park Service does not regulate its fund-raising partners, but when 

partners such as friends groups raise over $25,000 to support a Park 

Service project or program, the donations and fund-raising policy 

generally requires a written agreement—a friends group agreement or a 

fund-raising agreement—to be in place before the agency accepts the 

donations.22 Friends group agreements establish long-term relationships 

between the Park Service and its partners and can be used to authorize 

fund-raising for ongoing Park Service needs. In addition, fund-raising 

agreements must be used when fund-raising activities are intended to raise 

over $25,000 for a specific project or program, such as a new visitor center 

or restoration of a historic site. Parks are encouraged to consult with 

Interior’s regional and Washington solicitors’ offices when drafting these 

agreements. Further, for all fund-raising efforts requiring a written 

agreement, the policy requires a fund-raising plan detailing techniques, 

timing, costs, and other components of a fund-raising strategy. 

 

21The Park Service may accept and recognize charitable gifts—which are not linked to 

advertising—from corporations and businesses under the provisions for direct donations in 

the donations and fund-raising policy. When corporations intend to use advertising and 

marketing to promote a donation and a relationship with the Park Service, certain 

standards apply, including that a corporate campaign agreement be established. 

22Small-scale, local efforts or events that seek funds not expected to exceed $25,000 for the 

Park Service do not require written fund-raising agreements. According to the donations 

and fund-raising policy, where a written agreement is required but has not been executed, 

the Park Service will not accept the donations without approval from the Associate 

Director for Partnerships and Visitor Experience. 

Page 34 GAO-09-386 Donations to National Parks
 

When partners’ fund-raising efforts are expected to garner $1 million or 

more, or involve national or international solicitations, the policy also 

requires a feasibility study to assess the likelihood of fund-raising success. 

The feasibility study evaluates the readiness of the partner to raise the 

funds, the willingness of prospective donors to support the effort, and any 

external factors that might affect the probability of success. Parks may 

request a waiver of this policy requirement, and according to the policy, 

headquarters officials determine whether to grant the waiver, depending 

on the partner’s experience in similar fund-raising efforts and the park’s 

experience in executing the type of project proposed. The policy goes 

further to explicitly recognize that each park and partner is unique, that 

one size does not fit all, and that flexibility is needed in how to relate to 

fund-raising partners having varying degrees of experience. 

The donations and fund-raising policy as currently written reflects 

improvements the Park Service has made in recent years to address past 

concerns about the policy and to better protect against risks that may 

accompany donations and related partnerships. In 2006, the agency issued 

a revised version of the policy with more-stringent requirements than in 

preceding versions. For example, this version 

• required—rather than encouraged—feasibility studies and donor 

recognition plans; 

• set limits on which officials could accept direct donations (including 

corporate donations) instead of broadly granting authority to multiple 

officials in headquarters, regional offices, and at parks; and 

• included additional requirements and a formal process for partnership 

construction projects. 

At the same time, the Park Service issued a reference guide with detailed 

guidelines and tools for park managers, such as templates for required 

agreements. Although these changes provided better safeguards against 

risk than existed earlier, they had the added repercussion of demanding 

more staff time and expertise to interpret more-complex policy and meet 

additional requirements. 

Partly to address this effect, the agency updated its policy in 2008, making 

changes to bring it in line with revised Interior policies and to streamline 

the process—such as increasing the dollar threshold for a written fundraising agreement from $2,500 to $25,000 and eliminating the formal 

review of donations from state and local governments. In addition, 

Page 35 GAO-09-386 Donations to National Parks
 

officials in headquarters and in the Washington Solicitors’ Office worked 

together to draft several model agreements and related documents 

intended to expedite approval and invest fewer resources in the process. 

These model agreements have been in draft for about 3 years, however, 

and still have not been finalized, although parks have been using the drafts 

as guides since July 2008. Officials in the Solicitor’s Office said they are 

using this time to pilot and refine the agreements to make sure they 

capture a wide variety of regularly occurring circumstances. Also, some of 

the model agreements that involve relatively greater risks to the Park 

Service and its partners—such as a construction agreement—must be 

reviewed at higher levels in the Solicitor’s Office. 

While the donations and fund-raising policy requirements address areas 

essential to achieving agency objectives and minimizing risks, their 

strength is reduced because in practice parks and partners do not always 

conform to the policy requirements, and headquarters sometimes waives 

them (see table 4). 

Parks and Partners Do Not 

Always Conform to Donations 

and Fund-raising Policy 

Table 4: Fulfillment of Donations and Fund-raising Requirements at 25 Sample 

Parks 

Agreement or 

document 

Number 

required

Number 

complete

Number 

in draft 

Number 

waived 

Number 

outstanding

Fund-raising agreement 20 8 8 0 4

Fund-raising plan 20 5 7 2 6

Feasibility study 14 7 0 5 2

Donor recognition plan 24 9 4 0 11

Corporate campaign 

agreement 1 1 0 0 0

Source: GAO analysis of Park Service data. 

At parks in our sample, shortfalls in conformance occurred for two 

primary reasons: park officials did not understand the requirement, or the 

documents required by the policy were in draft but not finalized, even 

though partners had already begun fund-raising in many cases. For 

example, of the 20 fund-raising agreements required at the parks in our 

sample, 8 were complete, with another 8 in draft. The remaining 4 required 

agreements were omitted—even though partners had already begun fundraising—because park officials did not understand the policy requirement 

or the agreements had expired. For example, one park official working on 

a $35,000 project believed the agreement was required only for higher-cost 

projects; another park had not completed the documents because the park 

and partner were still developing a strategy for the project and the 

Page 36 GAO-09-386 Donations to National Parks
 

Superintendent believed the project posed little risk to the agency; and at a 

third park, the campaign was authorized in an agreement that had expired. 

Several of the fund-raising agreements in our sample that were still in draft 

were not complete because solicitors’ offices had not yet approved them. 

According to officials in the Washington Solicitor’s Office, the most 

common reasons for delays in approving these agreements were that the 

project was large and complex; facts had changed or raised new issues 

that had not been addressed before; or parks and partners had not thought 

through all the details of the project and partnership, such as how to pay 

for future operations and maintenance costs for a new facility. Agency and 

department officials expressed concern about delays in approving 

agreements and said regional solicitors’ offices lacked sufficient personnel 

and expertise in partnerships and philanthropy, further contributing to 

delays. 

The Park Service also waived policy requirements in some cases, as 

allowed by the donations and fund-raising policy. Of the 14 required 

feasibility studies at parks in our sample, 7 were complete, and the 

requirement was waived in another 5 cases. For example, the Director 

waived the requirement for a project to establish an $11 million 

endowment to support educational programs at Rocky Mountain National 

Park, explaining in an approval memo that the waiver was justified 

because the partner organization had extensive fund-raising experience, 

the project did not involve construction, and it included components with 

independent utility. Consequently, the campaign presented a very low risk 

to the agency. The feasibility study requirement was also waived for a 

campaign to raise $3 million at Grand Teton National Park for 

construction of an auditorium addition to a visitor center. In this case, 

however, the agency did not document the rationale for waiving the 

requirement, although the partner organization had written a letter to the 

park describing its considerable experience with fund-raising, including 

raising over $10 million for the visitor center. A headquarters official said 

the agency approved the project without a feasibility study, in part 

because the park had reduced the project’s scope from its original plan but 

also because of political pressure. Although the donations and fund-raising 

policy allows for waivers of the feasibility study requirement and outlines 

some general factors to consider when granting waivers, the Park Service 

has no specific criteria or procedures for doing so. In this context, the 

agency could be vulnerable to political and other pressures. 

Headquarters officials acknowledged the shortfalls in conformance to the 

policy and the waivers exempting parks from certain provisions but 

believed they were justified because of specific circumstances in each 

Page 37 GAO-09-386 Donations to National Parks
 

case. For example, in several cases, they said the parks and partners in 

question had considerable experience and a track record of success in 

similar fund-raising efforts, and allowing them to begin fund-raising 

without a feasibility study or without a final fund-raising agreement in 

place did not pose a significant risk to the Park Service. While this 

approach is logical, it does not address the underlying issue—a disparity 

between the uniform rigor of the policy’s requirements as written and the 

varied level of risk to the agency in different situations. 

In some low-risk situations, the Park Service’s and partners’ investment of 

resources to conform to the policy appears to be excessive relative to the 

level of risk to the agency. Agency officials at several parks told us that 

agreements had been in draft for over a year and consumed extensive Park 

Service and partner resources but were still not final, even though they 

considered the projects to be relatively low risk. For example, officials at 

Golden Gate National Recreation Area and its partner, the Golden Gate 

National Parks Conservancy, have been through about 18 revisions of a 

fund-raising agreement over nearly 4 years and still do not have a final 

version. Numerous people—including Park Service officials in the park, 

regional office, and headquarters; conservancy staff and lawyers; regional 

and Washington office solicitors; and others—have invested considerable 

time in negotiating, drafting, reviewing, and revising the agreement, which 

does not warrant this sizable investment of resources for several reasons, 

according to agency officials. The conservancy has a long history of 

raising tens of millions of dollars for the park and has already raised over 

$30 million for this campaign. The park and its Superintendent similarly 

have decades of experience with partnerships, philanthropy, and working 

with the conservancy. Further, the fund-raising agreement has built-in 

safeguards to protect the Park Service against excessive risk. For example, 

the campaign, which is for a long-term “trails forever” project, is designed 

to raise funds to repair or build individual trail segments one or two at a 

time and includes a provision guaranteeing that no work shall begin until 

all the funds have been raised for a given segment, so the Park Service is 

not at risk of absorbing unplanned costs. In fact, several trail segments 

have already been completed, even though the fund-raising agreement is 

still in draft. 

Superintendents we interviewed also expressed concern about the policy’s 

failure to differentiate between parks and partners with considerable fundraising experience and those without. Ten of the 25 superintendents we 

interviewed said they faced challenges related to this issue. For example, 

several of these respondents said the donations and fund-raising policy is 

overly restrictive for proven partners with strong records of 

Page 38 GAO-09-386 Donations to National Parks
 

accountability, and policy requirements such as feasibility studies—which 

can cost tens of thousands of dollars—should be more flexible for parks 

and partners with established track records of success. On the other hand, 

some of the same respondents said that for newer or less-experienced 

parks and partners, the policy is appropriate. 

Compounding the challenges caused by the disparity between the 

donations and fund-raising policy’s requirements and the level of risk to 

the agency, and further compromising the effectiveness of the 

requirements, were challenges caused by a lack of clarity in the policy. For 

example, the policy allows some fund-raising to be authorized in friends 

group agreements, but it is not clear when a separate fund-raising 

agreement is required. In our sample of 25 parks, fund-raising was broadly 

authorized in at least seven friends group agreements. Under these 

agreements, partner organizations raised funds for projects costing as 

much as $3 million without having to prepare a fund-raising plan, record 

donor review procedures, or conduct feasibility studies. The parks and 

partners in these cases were generally experienced in large fund-raising 

efforts, had well-established partnerships and track records of success, 

and consequently probably posed little risk to the Park Service. 

Nevertheless, there is no assurance that all parks and partners operating 

with only a friends group agreement—and the projects they choose to 

support—would be low risk for the agency. In higher-risk cases, without 

the additional safeguards afforded through fund-raising agreements and 

other requirements, the Park Service could be vulnerable to partners’ 

exercising undue influence or failing to raise the funds they commit to 

raising, among other things. But the policy neither differentiates between 

higher- and lower-risk cases, nor clarifies when the additional safeguards 

must be in place for parks where fund-raising is authorized under a friends 

group agreement. 

Ambiguities in Donations and 

Fund-raising Policy Create 

Challenges 

Further, the donations and fund-raising policy is ambiguous about whether 

or when documents that the policy requires must be revised if 

circumstances change. Some parks and partners we talked with set out to 

reach a certain fund-raising goal, then increased the goal substantially 

without revising the required documents. For example, one friends group, 

along with its partner park, originally planned to raise under $1 million and 

met the associated policy requirements but then increased its target to 

well over the $1 million threshold—ultimately raising about $1.7 million—

without taking additional steps to meet the requirements for higher-cost 

projects. In another example, a friends group originally planned to raise 

about $52 million to build a new visitor center and restore the site where 

the old one had been. Accordingly, the park and partner completed a 

Page 39 GAO-09-386 Donations to National Parks
 

feasibility study, fund-raising agreement, and other required documents. 

Over time, however, the cost of the visitor center rose to over $100 million, 

so the friends group not only raised these funds and constructed the 

visitor center but also—8 years after the original agreement was signed—

began raising an additional $6 million for restoration of the old site 

without preparing any new agreements. Executive directors of several 

partner organizations told us that increasing the target was common in 

fund-raising efforts, and it was important for the Park Service’s policy to 

be flexible enough to adapt to changing circumstances. Without 

parameters, however, such flexibility can lead to policy violations. 

In another ambiguous area of the policy, two parks in our sample had 

begun fund-raising efforts with their partners but had not yet completed 

the documentation required by the policy because the efforts were in the 

“quiet phase”—a period when fund-raisers assess the feasibility of the 

effort, clarify the project’s scope, estimate its cost, and develop a fundraising strategy. Consequently, they did not yet have the necessary 

information to complete the documents. But the donations and fundraising policy, as written, is unclear about whether such a head start is 

allowable. Headquarters officials said that as they interpreted the policy, 

partners should not begin any fund-raising until the agreements are 

complete.23

Headquarters officials were generally aware of these ambiguities in the 

donations and fund-raising policy and said that such flexibility is 

important to accommodate the unique circumstances of individual parks 

and partnerships. They said they made case-by-case decisions when 

interpreting and applying the policy requirements, considering the totality 

of circumstances in each case. While the decisions about parks in our 

sample appear to be justified, this ad hoc approach does have 

disadvantages. For example, the approach makes it more difficult for 

parks and partners to anticipate how their cases will be assessed and 

which policy requirements they need to follow, leaving their decisions 

more vulnerable to outside influences. In an internal review, Park Service 

officials found that the donations and fund-raising policy contains many 

ambiguities, and it can be difficult to get clear answers to questions about 

how to interpret the policy, but parks tend to move ahead with projects 

 

23Large fund-raising campaigns often have a “quiet,” or private, phase during which an 

organization secures leadership gifts before making a public announcement about the 

campaign. By the time the public phase begins, supporters are more likely to offer 

donations because they see that the campaign is off to a successful start. 

Page 40 GAO-09-386 Donations to National Parks
 

and decisions anyway, responding to local pressures in the absence of 

clear guidance. In addition, reviewing individual cases creates a sizable 

workload for headquarters officials—diverting their attention from other 

issues, according to agency officials—and such a workload could 

contribute to delays in finalizing required documents. Several partners we 

talked to said the slow pace of the Park Service relative to the private 

sector contributed to difficulties because many donors expect to see the 

results of their gifts within 12 to 24 months, whereas some Park Service 

projects do not even have final versions of the required documents within 

that period. According to agency and friends group respondents, these 

delays create disincentives for donors to give to the Park Service rather 

than to an organization that can show results more quickly. 

Further compromising the effectiveness of its donations and fund-raising 

policy, the Park Service uses an ad hoc approach to monitoring 

conformance—rather than a nationwide, systematic process for doing 

so—and consequently, the agency lacks assurance that all parks and 

partners are meeting the applicable policy requirements. Officials in the 

Partnership Office said they usually know about conformance to the 

policy for projects requiring the Director’s approval, because they review 

the required documents that parks submit for these projects. Without a 

systematic process for tracking the information, however, they may not 

always know about conformance. For example, one park’s draft fundraising agreement calls for the partner to report any donations of 

$1 million or more to the Park Service for review and approval, but the 

partner organization said it did not report a $5 million donation, even 

though it recognized the donor on its Web site as a “featured sponsor.” 

Officials in the Partnership Office said they knew about the donation but 

did not vet it because the regional office told them this donation would be 

used for a portion of the project on the partner’s private land, rather than 

the portion on adjacent Park Service property. When we asked several 

times for an accounting of which donations were used for each portion of 

the project, however, neither the park nor the partner organization 

provided one, so we could not verify how the donations were used or 

whether they met the policy’s vetting requirement, and it is not clear how 

the Park Service verified this information. Also, while headquarters 

officials may know about conformance in many cases, institutional 

knowledge about parks’ conformance may be lost as current staff retire or 

change jobs, and without a more systematic way of tracking projects 

needing headquarters-level review, it would be difficult for new staff to 

ensure that parks and partners are meeting all of the applicable policy 

requirements. 

Park Service Lacks Systematic 

Approach for Monitoring 

Conformance to Its Donations 

and Fund-raising Policy 

Page 41 GAO-09-386 Donations to National Parks
 

Moreover, projects that do not require the Director’s approval under the 

donations and fund-raising policy are generally approved by regional 

directors, but none of the agency’s seven regions have systematic 

processes for monitoring conformance to this policy either. One regional 

partnership coordinator said he has many other duties and is not closely 

involved with donations and fund-raising activities at parks in his region. 

In the Northeast and Pacific West regions, partnership coordinators said 

they communicated frequently with parks about donations, related 

partnerships, and agency policy requirements but relied on parks to 

contact them for assistance, rather than actively monitoring parks’ 

activities and conformance to policies. They use this reactive approach 

partly because they do not supervise superintendents, who report to 

regional directors. 

Some regional coordinators advocated more active and comprehensive 

regional oversight of parks—including regularly soliciting information 

from parks and using a tracking system to monitor their conformance to 

policy requirements and to anticipate when parks may need assistance. 

Without a system to ensure that parks and partners meet the requirements, 

the agency may accept unnecessary risks. For example, one partnership 

coordinator expressed concern over an agreement that a park had 

negotiated and signed without involving the regional office; consequently, 

this agreement had never been reviewed to ensure that necessary legal 

mechanisms were in place to protect the Park Service. In another 

agreement negotiated without involving the regional office, according to 

agency officials, a park worked with a nearby city that agreed to construct 

facilities on Park Service land for $10 million and pay the facilities’ longterm operations and maintenance costs. After the facilities were built, 

however, a new mayor was elected, and the city no longer wanted to pay 

the operations and maintenance costs, according to the park’s 

Superintendent. The original agreement expired after 1 year, and the 

Superintendent (who arrived after the agreement had been signed) is now 

faced with determining how to cover the estimated $80,000 in annual 

operations costs. Given the park’s strained budget, the park will likely 

have to take staff from other park programs and operate the facilities at 

minimal staffing levels, according to the Superintendent. According to 

agency officials, had the region been involved earlier, this situation might 

have been prevented or mitigated—for example, by improving 

communication and transparency with the city and using an agreement 

with a longer term or exploring possible legal mechanisms that would 

have enabled the city to collect fees for the facility. 

Page 42 GAO-09-386 Donations to National Parks
 

In some cases where regional officials have learned of difficulties at parks, 

they have been able to help improve conditions. For example, according to 

a regional official, a newly formed friends group at one park offered to 

raise about $12 million for a new visitor center and arranged for pro bono 

work on the design. By the time the regional office learned about this 

initiative, however, the design was already complete, and it was 

considerably larger than the park needed, according to the official. In 

addition, the official said it became clear that the friends group was not 

experienced enough to raise $12 million. After consulting with regional 

officials, the park and friends group were able to negotiate a more 

appropriate agreement, and the group is now raising several hundred 

thousand dollars to help pay for new exhibits at the park, according to the 

regional official. 

The Park Service Has 

Taken Steps to Address 

Accountability Concerns in 

Its Partnership 

Construction Process, but 

Gaps Remain 

In 2005 the Park Service implemented a step-by-step process for 

negotiating, reviewing, and approving partnership construction projects, 

to address concerns among Members of Congress about the accountability 

of expensive projects constructed through partnerships. Specifically, some 

Members of Congress were concerned about projects in which partners 

fell short of meeting fund-raising targets and pursued congressional 

funding, often outside the Park Service’s normal process for setting 

priorities for projects; public expectations were developed without 

appropriate communication between the Park Service, the partner, and 

Congress; and the Park Service was at risk of absorbing additional 

operations and maintenance costs even if no federal funds were used in 

construction. 

Projects that go through the partnership construction process are subject 

to all the applicable requirements in the agency’s policy on donations and 

fund-raising, as well as a set of policy requirements that every Park Service 

construction project over $500,000 must meet, such as being identified as a 

priority at the park, regional, and headquarters levels. The process is 

organized into three phases (see fig. 12).24 First, during the project 

definition phase, parks and partners must sign a memorandum, stating 

 

24Originally, the Park Service developed a process with five phases but revised it in 2008 to 

have only three. Although the three-phase process is still officially in draft, it has been 

reviewed and approved by all levels in the Park Service, Interior’s budget office, and 

congressional appropriations subcommittees and has replaced the five-phase process in 

practice. A headquarters official said the agency expects to finalize the new version in 

spring 2009. 

Page 43 GAO-09-386 Donations to National Parks
 

their intent to work together on a construction project, and define the 

project’s size, function, and estimated cost, including long-term operations 

and maintenance costs. A review board evaluates the project to ensure its 

need is justified, its scope and size are appropriate, and the design is costeffective.25 Policy also requires that projects over $5 million be submitted 

to Congress for review and concurrence. Second, during the agreement 

phase, the park and partner draft a fund-raising agreement, fund-raising 

plan, and donor recognition plan, while the partner arranges for a 

feasibility study to be done and begins identifying potential donors. The 

required documents are reviewed and approved at the regional and 

headquarters levels and, for projects over $5 million, reviewed again for 

concurrence from Congress. Finally, in the development phase, the 

partner may publicly launch the fund-raising campaign. During this phase, 

the park refines its project plans, which must be approved once more by 

the review board. When all the funds have been raised, the park can begin 

contracting and construction. 

 

25The review board, known as the Development Advisory Board, comprises executive-level 

Park Service employees and external advisors, who review design and construction 

projects for cost-effectiveness and the responsible use of agency construction monies. 

Page 44 GAO-09-386 Donations to National Parks
 

Figure 12: Partnership Construction Process 

PROJECT DEFINITION PHASE AGREEMENT PHASE

Identify project compliance needs and

determine roles and responsibilities for how they

will be accomplished Begin general awareness with public

DEVELOPMENT PHASE

Draft 

fundraising 

agreement

Fundraising 

feasibility 

study

Fundrising 

plan

Park and 

partner 

develop

• draft 

fund-raising 

agreement,

• fund-raising 

feasibility study, and

• fund-raising 

plan.

For projects

<$5 million, 

regional office 

reviews and 

recommends

action

For projects

>$5 million, 

headquarters

reviews and 

recommends

action

Projects >$5 million 

submitted to Congress

for review if deviate from 

original budget 

submission

Park 

prepares

final design 

and cost 

estimate

Park 

implements

project

Review 

board 

approves

project

100% partnership

funds secured FUND-RAISING

• Director or 

regional 

director 

signs then...

• Superintendent and 

partner sign 

required 

agreement

Source: GAO adaptation of National Park Service flowchart.

Park 

identifies

project in 

planning 

documents

and submits

in annual 

priority list; 

through 

memo of 

intent, park 

and partner agree to work 

together

Park Service 

includes

project in 

agencywide 

priority list 

and 5-year 

plan; for 

projects

>$5 million, 

agency 

notifies

Congress

through 

budget 

submission

Region 

approves

and 

identifies

as regional 

priority

Review 

board 

assesses

project 

validity and 

partnership 

readiness

In 2007, Interior’s Office of Inspector General issued a report on the 

partnership construction process, calling the newly implemented process 

a positive step but making several recommendations for improvement.26

The agency has made progress on some but not all of these 

recommendations (see table 5). 

 

26Department of the Interior, Office of Inspector General Western Region, Partnership 

Construction Process a Positive Step, but Improvements Needed in Implementation 

(Sacramento, Calif., March 2007). 

Page 45 GAO-09-386 Donations to National Parks
 

Table 5: Partnership Construction Process: Summary of Inspector General’s Recommendations and Park Service Actions 

Recommendation Rationale for recommendation Park Service action 

Streamline review and approval The Park Service’s process was time-consuming, 

partly because of how many times documents were 

reviewed and how many people reviewed them. The 

report recommended that the Park Service develop 

standard agreement templates and designate a 

single point of contact to track projects through the 

process. 

The agency has worked with the 

Solicitor’s Office to draft agreement 

templates, but the Solicitor has not yet 

approved them, so they are not finalized. 

The agency also introduced a simplified 

method for obtaining congressional 

approvals when required and delegated 

approval authority to regions for lowercost projects. 

Expand training on the process The Park Service had provided training on the 

concepts behind the process but not on specific 

guidance and required documents. 

The agency developed and provided 

additional satellite and in-person 

courses. 

Ensure that all projects contain 

estimates of operations and 

maintenance costs 

Such estimates are necessary for the Park Service 

to assess the impact of projects on budget and 

make decisions accordingly. All Park Service 

construction projects require life-cycle cost 

estimates, including future operations and 

maintenance costs, but these estimates were not 

done consistently. 

The Park Service has taken no action to 

ensure conformance to the requirement, 

but all project proposals briefly describe 

expected changes in operations and 

maintenance costs and a plan for 

covering any increase. 

Establish a universe of partnership 

construction projects 

Without a defined universe, it is not clear which 

projects should be included, and there is no 

assurance that all projects are included. 

No action. 

Complete a tracking system for 

partnership construction projects 

A tracking system is a fundamental tool for 

monitoring the status of projects and ensuring that 

all applicable requirements have been met. The 

Park Service had begun but not fully implemented a 

system for tracking partnership construction 

projects. 

The Park Service still has not fully 

implemented its system for tracking 

projects. 

Source: Department of the Interior Inspector General and GAO analysis of Park Service data. 

Note: The Inspector General did not require a response from the Park Service to its report. 

The Park Service has taken steps to streamline and expand training on the 

partnership construction process. To streamline its review and approval 

process, the agency drafted standard agreement templates, simplified its 

method for obtaining congressional concurrence when required by policy, 

and delegated more decisions to regions. Under the revised process, the 

agency will include partnership construction projects in its annual budget 

submission to Congress, so Congress will see all the proposals at once, 

Page 46 GAO-09-386 Donations to National Parks
 

rather than one at a time.27 Not only will this practice expedite the process, 

but it will also enable Congress to see how partnership projects fit into the 

agency’s broader priorities for its construction program. Also, the revised 

process calls for projects under $5 million that are entirely partner funded 

to be approved by regional directors, rather than the Park Service 

Director, thus reducing the workload in headquarters, as well as any 

associated delays. In addition, the Park Service expanded training on the 

partnership construction process and related topics, providing satellite 

training to hundreds of agency employees; developing and presenting 

training during standard superintendent-training sessions; and holding 

sessions at conferences for partner organizations, among other things. 

In addition, although the agency has not taken action to ensure that all 

project proposals include accurate estimates of operations and 

maintenance costs, it does require that they include an explanation for 

how parks will cover any increases in such costs. For all Park Service 

construction projects, parks are required to estimate operations and 

maintenance costs in a project review form submitted to the review board, 

but the Inspector General’s report found that they did not always do so, 

and even when they did, the estimates were not always accurate. 

According to a headquarters official, the Park Service has not taken steps 

to respond to this finding because it already has procedures in place for 

ensuring that these estimates are included and accurate, and it has been 

focused on revising its partnership construction process.28 Since 2005, 

parks’ proposed plans for covering any increases in such costs have also 

been considered in the review and approval of projects and documented in 

headquarters approval memos. The language in the approval memos is 

general, however, and not always supported with written documentation. 

For example, of the 18 approval memos issued for partnership 

 

27The partnership construction process calls for congressional review of projects over 

$5 million at two points in the process—first, through the agency’s annual budget 

submission and second, for projects where there have been substantial changes to the 

project budget or scope, during the agreement phase. The budget submission will replace 

the first review but not the second. If Congress raises no objections in response to the 

budget submission, the agency moves the project into the next phase. 

28An agency office for construction is responsible for ensuring that the operations and 

maintenance estimates are included in the submission to the review board. According to a 

headquarters official, project proposals are returned to parks or regions for completion if 

this information is missing. 

Page 47 GAO-09-386 Donations to National Parks
 

construction projects since 2005,29 9 include plans for a partner to pay at 

least a portion of the costs, sometimes as part of an ongoing arrangement 

or using proceeds from an existing endowment and other times through a 

new arrangement, such as raising funds to establish an endowment. 

The Park Service does not require parks to establish written agreements 

when partners agree to pay all or a portion of operations and maintenance 

costs associated with a construction project. As early as 2004, Park 

Service officials found that parks commonly relied on informal 

understandings when partners agreed to pay a portion of operations and 

maintenance costs. In an internal report, they said, “For projects where 

organizations other than the Park Service are expected to contribute to the 

operational costs of a facility, such arrangements are frequently on an 

informal basis without specific commitments as part of a written 

agreement.” The agency still does not require such agreements to be in 

writing. 

As a result, the agency puts itself at risk of absorbing operations and 

maintenance costs if an unwritten agreement breaks down, as is 

demonstrated by the following example. In 2008 Grand Teton National 

Park entered into an agreement with the Grand Teton National Park 

Foundation to raise about $3 million for an auditorium addition to a visitor 

center. Park officials believed that, because of an oral agreement with a 

former Superintendent, the foundation would pay the facility’s operations 

and maintenance costs, and the project was approved on the condition 

that the Park Service would bear no new costs. Subsequently, the 

foundation proposed a design change—adding a wall-sized window—

which, according to an agency official, increased construction costs to 

$4.6 million and drove up projected operations and maintenance costs 

primarily because of expensive technical requirements for audiovisual 

equipment associated with the window. The park agreed to the design 

change, and the foundation agreed to raise the additional funds needed for 

construction. The foundation’s President does not believe she or the board 

agreed to pay the operations and maintenance costs, however, and said 

they prefer not to because doing so is not part of their mission. They 

consider such costs to be the government’s responsibility and their role to 

be supporting exceptional projects and programs that enhance the park, 

 

29The 18 approval memos provided to us by the Park Service include all partnership 

construction projects that have been approved since January 2005 and are undergoing 

fund-raising, substantially completed, or completed. 

Page 48 GAO-09-386 Donations to National Parks
 

according to the foundation’s President. Nevertheless, they want to help 

and have agreed to continue talking with the park and exploring possible 

alternatives to cover the costs, such as renting the auditorium to generate 

revenue. The issue is still unresolved, but the Superintendent said that 

before construction begins, she intends to resolve clearly in writing how 

the additional costs will be covered—and the foundation supports the 

idea. In general, the Superintendent said the Park Service should require 

such a written agreement for construction projects, detailing the expected 

operations and maintenance costs, which portions each party will pay for, 

and a contingency plan describing what will be done if the expenses 

cannot be covered as planned. 

Regarding the Inspector General’s final two recommendations, the agency 

has neither established a universe of partnership construction projects, 

nor completed a tracking system for the projects. A headquarters official 

told us the agency has criteria defining such a universe, but the criteria are 

not documented so they are not being implemented consistently. 

According to the official, the agency plans to issue guidance about which 

projects must go through the partnership construction process but it has 

not yet done so because headquarters officials have recently been focused 

on revising the process and did not want to issue new guidance until the 

revisions were approved and final. Until the Park Service defines a clear 

universe of projects, it will be difficult to track projects’ status and 

monitor whether they are meeting policy requirements, including the 

requirement to estimate operations and maintenance costs. 

The Park Service began developing a computer tracking system for 

partnership construction projects in 2005, but it is not complete. Nor is it 

clear which projects belong in the system and which ones do not. 

According to agency officials, several projects that are going through the 

process are not in the system. Some were not added because the agency 

was making the transition to a new version of the system and wanted to 

wait until the transition was complete, while others were left out because 

there is no clear universe of projects. Currently, headquarters officials 

enter information for partnership construction projects over $1 million, 

since these projects come through headquarters for review, but lower-cost 

projects are not included, even though all partnership construction 

projects over $500,000 are supposed to go through the process. Also, the 

Park Service has not decided at what point a project should be removed 

from the system, according to agency officials. One project completed in 

2005 and two others completed in 2007 are still in the system, even though 

nothing is left to track. And Centennial Challenge construction projects 

were omitted from the system—even though they must meet the same 

Page 49 GAO-09-386 Donations to National Parks
 

policy requirements—because the system could not be implemented 

quickly enough. Agency officials said they plan to expand the tracking 

system beyond construction projects to all partnership projects that 

require a fund-raising agreement, including Centennial Challenge projects, 

but they do not expect to reach this goal until around October 2010. 

Gaps in Donations and 

Fund-raising Policy and in 

Partnership Construction 

Process Hinder Their 

Effectiveness at Protecting 

against Risk 

The Park Service has made progress toward developing a donations and 

fund-raising policy and a partnership construction process that protect the 

agency against risks in many areas and address accountability concerns 

raised by Congress and others. Still, gaps remain, leaving the agency 

vulnerable to risks in some situations. To better ensure that parks follow 

the policy’s requirements while also reducing the agency’s investment of 

resources, some Park Service officials have suggested a certification 

process in which newer, less-experienced parks and partners would need 

to go through specific steps to develop experience and a track record. 

Initially, parks would have to follow a more-rigorous set of policy 

requirements, and regions would provide more assistance and oversight. 

For parks and partners that met certain criteria—such as demonstrating 

fund-raising success at various levels and financial accountability—the 

regional office could certify them to follow a modified set of policy 

requirements. Regional officials might evaluate the certified parks and 

partners periodically but invest more of their time with higher-risk, lessexperienced parks and partners, according to the officials. 

Toward the same end, some parks and partners have designed partnership 

arrangements that enable them to refrain from fulfilling the same policy 

requirements numerous times in a single year. For example, in a general 

friends group agreement authorizing the Yellowstone Park Foundation to 

raise funds, a formal priority-setting and project selection process is 

documented, thereby ensuring that donations are used to meet park needs 

(and protecting the Park Service against the potential for a partner to 

exercise undue influence), without preparation of individual fund-raising 

agreements for the many projects and programs supported each year. 

Great Smoky Mountains and Yosemite national parks achieve the same 

effect by following a grant proposal process each year in which they 

identify needs and submit proposals to their partners, and the partners 

approve some proposals for funding. Currently, the Park Service allows 

these arrangements through case-by-case interpretations of its donations 

and fund-raising policy. But to more effectively and efficiently protect 

against risks, the agency could finalize and implement its model friends 

group agreement—which routinely authorizes general fund-raising—and 

Page 50 GAO-09-386 Donations to National Parks
 

clarify criteria for when additional documents must be completed in 

higher- and lower-risk cases. 

As the agency continues to build on its improvements to the donations and 

fund-raising policy and the partnership construction process, it could 

benefit from clearly delineating the risks it aims to protect against, 

potential indicators of those risks, and factors that temper the risks (see 

table 6). In many cases, the agency has used this logic when making caseby-case determinations about applying policy requirements. Currently the 

Park Service lacks a comprehensive framework for methodically applying 

policy requirements and processes to whole categories of projects rather 

than individual cases. It also lacks an approach that could clarify 

ambiguities and increase predictability for parks and partners following 

the policies. 

Table 6: Examples of Risks, Potential Indicators of Risk, and Mitigating Factors Associated with Donations to the Park 

Service 

Examples of risks to Park Service Potential indicators of risk Sample mitigating factors 

Park Service left to absorb unplanned 

project costs because partner falls short of 

reaching fund-raising goal 

Construction 

High-cost project 

New fund-raising organization or 

superintendent with little fund-raising and 

partnering experience 

Project can be segmented into smaller, 

less-costly pieces with independent utility 

Project can be executed without reaching 

the full fund-raising target 

Partner and park have a track record of 

success 

Money is in hand or no fund-raising needed

Park Service must absorb unplanned 

operations and maintenance costs 

Construction Operations and maintenance costs are 

estimated and a plan for covering the costs 

is documented before fund-raising begins 

Partner exerts undue influence over Park 

Service priorities 

New fund-raising organization or 

superintendent with little fund-raising and 

partnering experience 

A process for setting priorities for projects 

and programs to be supported through 

donations is documented, or park and 

partner develop a joint strategic plan 

identifying such projects and programs 

Public confidence in the Park Service is 

compromised (because public expectations 

are raised but Park Service and partner do 

not follow through) 

Premature or widespread publicity Partner and park have a track record of 

success 

Parks and Park Service become 

commercialized 

Corporate donations made to parks or 

partners and tied to advertising 

In advertising materials, corporation 

affiliates itself with partner rather than with 

parks or Park Service 

Source: GAO. 

Page 51 GAO-09-386 Donations to National Parks
 

Cooperating Association 

Policy Works Well to Guide 

Relations with 

Associations 

In contrast to the donations and fund-raising policy and the partnership 

construction process, the Park Service’s cooperating association policy 

created few challenges for parks and partners we talked to. The policy 

governs relationships between the agency and the associations, which 

generally elicit few risks for the agency. According to the policy, the 

associations must be tax-exempt organizations that support the Park 

Service’s educational, scientific, historical, and interpretive activities. They 

must have a signed standard agreement to operate bookstores in parks, 

and the goods and services sold in the stores must support the purposes of 

the associations’ mission. In addition, associations must submit several 

documents to the agency each year, including a standard report of 

revenues, expenses, and donations to the Park Service and a narrative 

description of annual accomplishments (see table 7). 

Table 7: National Park Service Cooperating Association Policy: Summary of Required Documents 

Required document Description Purpose When required 

Cooperating association 

agreement 

Describes respective responsibilities 

of Park Service and association and 

sets forth general requirements for 

association’s activities 

Basis for the partnership 

between the Park Service 

and each association 

When association wishes to 

sell interpretive goods and 

services in national parks. 

For associations operating in 

a single region, agreement 

must be approved by 

regional director; for those 

operating in multiple regions, 

it must be approved by the 

Park Service Director. 

Annual report of operations and 

aid 

Reports annual revenues; expenses; 

and funds, goods, and services 

donated to Park Service and other 

federal agencies. Relates to 

information reported in Internal 

Revenue Service (IRS) forms for 

most recent year 

Collection of data for 

agencywide annual report on 

cooperating associations 

Due annually on March 31 

for all associations’ most 

recent fiscal year 

Tax return for tax-exempt 

organizations (IRS Form 990 and 

variations)a

Includes information on 

organizations’ governance, ethics 

policies, revenues, and expenses. 

Management and fund-raising 

expenses reported separately from 

expenses the association incurs 

pursuing its tax-exempt purpose 

(program service expenses) 

Proof of tax-exempt status, 

transparency, and 

accountability; verification of 

information in annual report 

of operations and aid 

Annually for all associations 

that are required to file 990 

forms 

Page 52 GAO-09-386 Donations to National Parks
 

Required document Description Purpose When required 

Financial statement (audited or 

reviewed)b

Documents associations’ assets, 

liabilities, revenues, and expenses. 

Audits assess whether the 

documents are free of misstatements 

and whether the financial position of 

the organization is presented fairly 

Financial accountability and 

verification of economic 

viability 

Annually for associations 

with gross revenues of 

$250,000 or more 

Narrative description of activities 

and accomplishments 

Details the association’s activities 

and accomplishments for each year 

Collection of information for 

agencywide annual report on 

cooperating associations 

Annually for all associations 

Source: GAO analysis of Park Service data. 

a

IRS requires organizations that normally have $25,000 or more in gross receipts to file these forms. 

b

Associations with gross revenues from $250,000 to $1 million must have their financial statements 

reviewed; associations with revenues of $1 million or more must have their financial statements 

audited. 

The 14 cooperating associations30 working with the parks in our sample 

had all met these policy requirements for the preceding year, and 

headquarters officials did not know of cases in which these requirements 

had not been met. To ensure that parks and associations are meeting the 

policy requirements, regional and headquarters officials monitor their 

activities and maintain copies of the standard agreements. In addition, to 

prepare the agency’s own annual cooperating association report, the 

Cooperating Association Coordinator in headquarters collects and reviews 

all other documents required each year. 

Although few cooperating association representatives we spoke with 

expressed concerns with the policy, those who did commented that the 

policy has been in a protracted and continuing revision process, which 

creates uncertainty about what to expect. Also, a headquarters official said 

challenges sometimes arise at parks because superintendents have only 

limited authority in their partnerships with associations, since cooperating 

association agreements are signed by regional directors or the Park 

Service Director, but day-to-day relations are between superintendents 

and associations. According to agency officials, they decided to delay 

issuing a new version of the policy while they evaluated this and other 

issues raised by the associations and agency leadership about the future 

role of cooperating associations in the Park Service. 

 

30The 14 cooperating associations included 3 that are also friends groups and raise funds 

for parks. These 3 organizations fulfilling both functions are subject to all the same 

directives applicable to all cooperating associations. 

Page 53 GAO-09-386 Donations to National Parks
 

To manage the $24.6 million appropriated for the Centennial Challenge 

program in 2008, as well as matching donations, the Park Service 

established a Centennial Office, appointed a Chief to manage the program, 

and developed eligibility criteria for projects. To be eligible for Centennial 

Challenge funding, projects had to align with one of the program’s five 

goals: 

Centennial Challenge 

Procedures Show Promise 

after First Year 

• Stewardship: lead America in preserving and restoring treasured 

resources 

• Environmental leadership: demonstrate environmental leadership to the 

nation 

• Recreational experience: offer superior recreational experiences where 

visitors explore and enjoy nature and the outdoors, culture, and history 

• Education: foster exceptional learning opportunities connecting people, 

especially young people, to parks 

• Professional excellence: achieve management and partnership excellence 

to match the magnificence of the treasures entrusted to its care 

In addition, parks had to show that their partners were prepared to match 

at least 100 percent of the federal contribution (with cash or in-kind 

donations) and that the funds could be obligated and the project under 

way within the fiscal year.31 In August 2007 the Park Service announced a 

list of 201 projects eligible for Centennial Challenge funding. By April 2008 

the project proposals had gone through six reviews, and the list was 

narrowed to 110 projects approved for funding.32 Meanwhile, agency 

officials developed a business plan for the Centennial Challenge, which 

was also adopted in April 2008. The business plan defines roles and 

 

31Federal law mandates that matching donations must be equal to or larger than the federal 

contribution, and the Park Service Director called for funds to be obligated and projects 

under way before year’s end. 

32The six reviews were conducted by (1) regional directors and an agency leadership 

council; (2) an agency project management system that applied “screen-out” criteria; (3) 

teams of agency employees using the “Choosing by Advantages” methodology in which the 

relative advantages of each alternative were considered in the context of costs; (4) an ad 

hoc Centennial Challenge project review team; (5) regional directors and the agency 

leadership council a second time, to narrow the list; and (6) the Centennial Challenge 

project review team once more (including contracting, agreements, and solicitors’ staff 

review). 

Page 54 GAO-09-386 Donations to National Parks
 

responsibilities for the many offices involved, the selection process for 

2008 projects, requirements that must be met for various types of projects, 

and a strategy to meet the increased need for training that may accompany 

the program’s launch. 

Once the final 110 projects were approved, parks still had to meet several 

policy requirements described in the business plan before Centennial 

Challenge funds were released to them. For example, for each project, 

parks had to have a partnership agreement or letter outlining the 

responsibilities of each party, as well as a budget and a project plan (see 

table 8). 

Table 8: National Park Service 2008 Centennial Challenge Procedures: Summary of Required Documents 

Required document Description When required 

Partnership instrument Outlines the responsibilities of each party; one of three 

instruments required 

For all Centennial Challenge projects 

Donation acceptance 

letter 

Acknowledges donation, states how it will be used, and 

describes any in-park donor recognition; for in-kind 

donations, letter to include attachment with partner’s 

valuation of the donation (determined following a specified 

methodology) 

When Park Service accepts donated funds 

or in-kind goods and services with no or 

minimal restrictions on use of the donation 

Cooperative agreement Describes project and how much each party will contribute; 

includes statement of work to be performed by each party 

and agreement to jointly develop project progress reports 

When Park Service transfers any federal 

funds to a partner to accomplish a project 

(may not be used for in-park construction); 

partnership and project must also meet 

three tests required for the use of 

cooperative agreements 

Cost-share agreement Describes project, what the Park Service and partner agree 

to do jointly, what each party agrees to do individually, and 

how much each party will contribute; includes agreement to 

jointly develop project progress reports 

When partner is involved in developing and 

implementing a Park Service project or 

program, and Park Service does not 

transfer funds to the partner (may not be 

used for in-park construction) 

Project budget Itemizes expected Park Service and partner costs for 

personnel, contractors, travel, supplies and materials, 

equipment, and other items, with total project costs for 

each party 

For all Centennial Challenge projects, 

before receiving federal funds 

Project plan Summarizes park needs to be met by the project, partner’s 

role, project deliverables, schedule, and tangible results 

expected 

For all Centennial Challenge projects, 

before receiving federal funds 

Progress or completion 

report 

Summarizes work accomplished and funds obligated; 

submitted into Park Service’s project management system 

For all Centennial Challenge projects 

Source: GAO analysis of Park Service data. 

The Centennial Office, in consultation with the Solicitor’s Office, 

developed model partnership agreements and a model donation letter to 

guide parks and partners in preparing the documents and to expedite 

Page 55 GAO-09-386 Donations to National Parks
 

approval. When Park Service financial and contracting officials verified 

that the documents required by the program were in place and regional 

officials verified that the donated funds had been deposited, funds were 

released to parks, and they began implementing the projects. During 

implementation, parks were required to enter periodic progress reports 

into a centrally accessible computer system, and upon completion, they 

were required to enter final reports. To ensure that all program 

requirements were met for each project, the Centennial Office recorded 

the information on a checklist it maintained in each project file. 

Eleven of our 25 sample parks had a total of 20 Centennial Challenge 

projects approved in 2008 and completed all the required documents for 

them.33 Nevertheless, they identified several difficulties in the first year’s 

implementation of the program. The most common challenge that 

superintendents in our sample cited was the process’s administrative 

burden, followed by unclear procedures, uncertainty about future funding, 

and the late timing of federal funds. Specifically, superintendents said the 

project review and approval process required considerable effort and 

changed multiple times, and the rationale for approving or rejecting a 

project was not always transparent. The uncertainty about future years’ 

funding made it difficult to plan ahead, and some park officials expressed 

concern about the sustainability of programs started with Centennial 

Challenge funds. In addition, many parks did not receive the federal 

portion of the funds until June or July 2008—and some parks scarcely 

received the funds before the end of the fiscal year, which was the 

deadline the Park Service Director imposed for obligating all of the funds. 

This timing was particularly difficult for projects that involved hiring staff 

because parks did not want to hire people and lay them off only a month 

or two later. One park reported getting permission from headquarters to 

extend the staff needed for the project beyond the end of the fiscal year. 

Many friends groups and cooperating associations commented on the 

substantial potential for the Centennial Challenge program, but they 

expressed concerns as well. One Executive Director said, “We love the 

vision,” but cautioned that without a good system of execution, the vision 

might not be realized. Like superintendents, friends groups and 

cooperating associations identified some of the main difficulties with the 

 

33Parks were directed to obligate Centennial Challenge funds by year’s end, but not 

necessarily to complete all the work. Consequently, some parks have not completed 

Centennial Challenge projects or entered completion reports. 

Page 56 GAO-09-386 Donations to National Parks
 

program to be the administrative burden, unclear procedures, and the late 

timing of federal funds. Another Executive Director said, “We’ll think long 

and hard about whether to apply for Centennial Challenge funding in the 

future,” explaining that at some point, the program’s administrative cost 

and burden outweighed its benefits. In addition, several friends groups and 

cooperating associations commented that the program could be more 

inclusive of smaller parks with less-experienced partner organizations. 

Both parks and partner organizations also acknowledged that certain 

challenges resulted from circumstances beyond the Park Service’s control 

and that because 2008 was the first year of the Centennial Challenge 

program, some stumbling blocks were to be expected. On the other hand, 

several respondents cautioned that these challenges could be magnified in 

future years because many 2008 Centennial Challenge projects were 

already “in the pipeline,” so partners had already raised funds for them and 

parks had completed planning documents, which may not be true in future 

years. One year is generally not long enough to plan a project, start and 

finish a fund-raising campaign, and implement the project, according to 

respondents. Furthermore, some Park Service officials said, if Centennial 

Challenge funding increases in future years—as the agency has 

requested—the Park Service will need to increase its capacity to manage 

the greater volume of federal funds, donations, and required documents. 

Recognizing that parks had concerns and challenges in the first year of the 

program, the Centennial Office solicited suggestions from them and 

adjusted the program for 2009. For example, the office plans to add 

information to its Centennial Challenge Web site, such as transparent 

project selection criteria, clear roles and responsibilities for national and 

regional Centennial Challenge staff, and standard procedures for valuing 

in-kind donations. To avoid duplicate solicitor reviews of agreements and 

contracts, regional solicitors will review the documents in their respective 

regions. They also plan to develop and provide training on preparing the 

agreements and contracts required for the program. And to track projects’ 

conformance to applicable program requirements, they will develop online 

spreadsheets accessible to parks, regions, and headquarters. As it begins 

its second year, the Centennial Challenge program shows promise in 

helping to achieve Park Service goals while also incorporating 

accountability provisions and safeguards against risks, but it remains to be 

seen how well the program will work over time. 

Page 57 GAO-09-386 Donations to National Parks
 

Enhancements to 

Park Service 

Management of 

Donations Could 

Strengthen 

Accountability, 

Efficiency, and 

Partner Relations 

The Park Service could enhance its management of donations and related 

partnerships by taking several steps. By using a more strategic approach, 

the agency could more efficiently and effectively meet its goals. And by 

further refining its information on donations, it could support such an 

approach while also enhancing its accountability. Also, by increasing 

employees’ knowledge and skills in working with nonprofit and 

philanthropic partners, the agency could improve partner relations and 

better protect itself against the risks that may accompany donations. 

A More Strategic Approach 

to Management of 

Donations Could Enhance 

Effectiveness and 

Efficiency 

Even as the potential for a dramatic expansion of donations increases with 

the Centennial Challenge program, the Park Service has no long-range 

vision for philanthropy and related partnerships and no plans for how to 

achieve such a vision. In part, this lack of a strategic vision stems from the 

Park Service Partnership Office’s focus on responding to concerns among 

Members of Congress about its management of donations and related 

partnerships—for example by revising its donations and fund-raising 

policy and implementing a partnership construction process. Further, the 

Partnership Office devotes considerable resources to shepherding 

individual projects through the policy requirements, making case-by-case 

decisions to interpret policy, and providing technical advice to parks and 

partners on the projects. While these are worthy activities, they have left 

little time and resources for thinking strategically about the desired role of 

donations and related partnerships in the Park Service—now and in the 

future. 

Meanwhile, indications have been growing that such strategic thinking is 

needed now. For example, recent events at several parks have contributed 

to a climate of uncertainty and insecurity for cooperating associations in 

the Park Service. In particular, in 2006 Gettysburg National Military Park 

terminated the agreement with its cooperating association, Eastern 

National, choosing instead to allow its friends group, the Gettysburg 

Foundation, to oversee the bookstore arrangement in a new visitor center. 

Accordingly, the foundation solicited proposals from bookstore operators 

in an open competition (and Eastern National submitted a proposal along 

with several others), but the foundation ultimately rejected Eastern 

National in favor of a for-profit company that offered a higher rate of 

return to the foundation. Because Gettysburg was one of Eastern 

National’s most profitable locations—typically generating about $3 million 

Page 58 GAO-09-386 Donations to National Parks
 

in sales annually—the loss had an effect on more than 130 parks that 

Eastern National supports.34 The association decreased its annual 

contributions to these parks as a result of Gettysburg’s withdrawal, 

according to a representative. The loss also hurt Eastern National, raising 

concerns among other cooperating associations about whether the Park 

Service will open bookstore operations more often to competitive bidding 

in the future and prompting broader questions about the future role of 

cooperating associations in the Park Service. 

Partly because of these concerns, a group of over 30 cooperating 

associations wrote a letter to the Director in 2007, requesting that 

cooperating associations be aligned under the Partnership Office, where 

activities related to friends groups and fund-raising are managed, instead 

of the office overseeing interpretation. They said that “misunderstandings 

about the National Park Service’s goals for national park cooperating 

associations are becoming a source of friction between cooperating 

associations, the National Park Service, and other park partners”; they 

believed that under the Partnership Office, they would be better informed 

about and engaged in issues critical to their support of the Park Service. 

The Park Service decided to retain the program within the office 

overseeing interpretation35 but established a steering committee to 

examine the concerns raised by the cooperating associations, as well as 

some raised by Park Service staff. 

The steering committee is one of many new offices, councils, committees, 

and positions the Park Service has created to help manage donations and 

related partnerships in recent years, but no focused effort has aimed to 

coordinate the entities or think holistically about donations and 

partnerships in the Park Service. Some members of these councils and 

committees, as well as other agency officials, have spoken out about the 

need for strategic thinking. According to a regional reference manual, the 

agency’s approach to partnerships is primarily reactive. As a result, 

partnership efforts are not necessarily fulfilling the agency’s greatest 

needs. To remedy this problem, the manual calls for the Park Service to 

 

34To compensate for this loss, the Foundation agreed that if its revenues exceed a certain 

threshold in any given year, it will return $420,000 to the Park Service to use at its 

discretion. 

35In a 2007 letter to the cooperating associations, the Park Service Director explained that 

because the law establishing the associations says they are to support interpretation, 

education, science, and research, the agency decided to retain the program in the office 

that most closely aligns with that mission. 

Page 59 GAO-09-386 Donations to National Parks
 

focus attention on the issue and systematically develop a clear approach 

to partnerships. Superintendents we interviewed—including some that 

had served on partnership committees and councils—reinforced and 

expanded on this notion. For example, one said the Partnership Office is 

understaffed and cannot provide leadership because it is too busy 

reviewing individual fund-raising projects; the role of the Partnership 

Office should be setting broad policy, aggregating national reports, and 

performing other high-level activities. Another superintendent said that 

while significant potential exists for expanding the role of philanthropy in 

the Park Service, the agency has not yet developed a mature construct to 

realize that potential. Several superintendents questioned the rationale for 

managing friends groups and cooperating associations out of separate 

offices and for creating a Centennial Office apart from the Partnership 

Office. One said that while it was shrewd to create a position for someone 

to think separately about the Centennial Initiative, it was unnecessary and 

excessive to create a separate set of procedures for Centennial Challenge 

projects. 

Although the multiple committees, councils, and offices are generally 

focused on relatively narrow issue areas, some of them have begun to 

address broader strategic issues related to the future of donations and 

partnerships. For example, both the Park Service and Interior have 

explicitly endorsed partnerships as a way to leverage strained budgets and 

engage the public. Toward this end, the Park Service established a 

partnership council to formulate a vision, direction, and framework for an 

agencywide partnership investment and delivery program. The council’s 

vision statement describes a model in which the agency’s “leadership and 

employees have embraced the use of partnerships as a primary way of 

doing business and accomplishing its core mission,” and its organization 

empowers “parks, programs, regional offices, and service centers to take 

individual initiative in efficiently and creatively fulfilling the mission of the 

organization.” Also, the cooperating association steering committee has 

worked to clarify the Park Service’s priorities and expectations for 

cooperating associations over the long term, and the Centennial Office has 

developed a business plan for the Centennial Challenge fund, which 

outlines a strategy for the program. 

Building on these efforts, we believe, the Park Service could benefit from 

clarifying what its specific goals are for partnerships involving donations 

and philanthropy, what steps the agency will take to support these goals, 

and how the various elements will fit together. For example, through 

strategic planning, the Park Service could work with its partners to 

consider questions such as whether the agency wants to encourage more 

Page 60 GAO-09-386 Donations to National Parks
 

donations in the future, whether it is appropriate to use donations to 

support core operations, and whether it wants more parks to have friends 

groups. Once the agency—in collaboration with its partners—has 

answered some questions like these, it could resolve questions about what 

resources and actions are needed to achieve the desired vision. Doing so 

could enhance the agency’s effectiveness and efficiency—for example, by 

ensuring that people with key partnership skills are positioned where they 

are needed, when they are needed—and could better position Congress 

and the agency to make sound decisions about allocating resources and 

planning for the future. 

Further Refinements to 

Information on Donations 

Could Strengthen 

Accountability and 

Transparency 

The Park Service is further constrained in its ability to pursue a strategic 

approach for donations and related partnerships because it has limited 

information on donations. Because the Park Service receives some 

donations in the form of funds—for example, when visitors drop cash into 

donations boxes, when corporations send checks to parks, or when 

friends groups and cooperating associations provide funds to parks—and 

other donations in the form of goods and services—such as when 

corporations donate lumber, when cooperating associations publish 

books, or when friends groups construct new trails for parks—it has 

multiple systems for tracking information on donations. As summarized in 

table 9, the agency has a separate set of procedures for tracking donations 

data in five overlapping categories: funds received in Park Service 

donations accounts, donations received under the Centennial Challenge 

program, support provided by cooperating associations, support provided 

by friends groups, and support provided by the Foundation. 

Table 9: Donations and Support Information Tracked by the Park Service 

Category of donations 

data Information tracked 

Funds received in Park 

Service donations 

accounts 

Amount received; receiving park or program 

Donations received under 

Centennial Challenge 

program 

Amount or value received; receiving park; project or program 

supported; Centennial Challenge goal supported; qualitative 

descriptions of projects and programs supported 

Support provided by 

cooperating associations 

Amount of direct financial aid to the Park Service, amount 

spent in support of associations’ missions (by category), as 

reported to the Internal Revenue Service (IRS); qualitative 

descriptions of some projects and programs supported 

Page 61 GAO-09-386 Donations to National Parks
 

Category of donations 

data Information tracked 

Support provided by 

friends groups 

Amount spent in support of organizations’ missions, as 

reported to IRS 

Groups’ net assets and revenue, as reported to IRS 

Support provided by the 

Foundation 

Amount spent in support of National Park Service, as 

reported by the Foundation 

Source: GAO. 

For donated funds deposited into Park Service accounts, the agency 

reliably tracks information on the amount received annually by each park 

and reports the total amount received agencywide in its budget 

justification.36 The Park Service does not, however, centrally track or 

report how the donations or donors’ identities were used, although 

individual parks we spoke with frequently maintain this information in 

files or spreadsheets. For donations received under the Centennial 

Challenge program in 2008, the agency tracked and reported data on the 

amount of cash and the value of in-kind donations received, the specific 

projects and programs supported, the parks receiving the donations, and 

which of the program’s five goals were supported by each donation. In 

addition, the Park Service collected narrative descriptions for each 

supported project or program and included some of these along with 

photographs in its year-end progress report. 

For donations provided by friends groups, tracking the data is more 

difficult because the groups often spend money on behalf of the Park 

Service, and the agency has no record of the expense. For example, to 

support a trail maintenance project, a friends group might donate services, 

such as organizing a group of volunteers and overseeing the work, and 

spend money for supplies and salaries, but the park would not typically 

have a record of the total value of the goods and services it received (even 

though several parks we talked to were well aware of such donations). 

Regional offices and headquarters know less than parks do about the 

specific donations that friends groups make to parks because no Park 

Service record is kept of in-kind or cash donations received from these 

groups. Although the agency tracks data on cash donations, there is no 

 

36The agency’s financial system uses codes for park administrative units, which for the 

most part are the same as individual parks. In some cases, however, multiple parks are 

tracked under a single code, and it cannot be determined centrally how much each park 

received (although the parks have a record of this information). For example, donations 

received by the Thomas Jefferson Memorial are recorded under the National Mall and 

Memorial Parks administrative unit. 

Page 62 GAO-09-386 Donations to National Parks
 

way to centrally determine what portion comes from friends groups 

because the data do not include the donors’ identities. 

To estimate the extent of support friends groups provide, in 2006 the Park 

Service began gathering information from publicly accessible Internal 

Revenue Service (IRS) forms submitted by the groups, but this information 

is incomplete, not up-to-date, and based on inconsistent determinations of 

support. The information is incomplete for several reasons. First, the 

Partnership Office’s method for identifying all its friends groups is to 

solicit the information from regional offices. The regions, however, may 

not always provide complete and accurate data, and because the Park 

Service defines friends groups broadly, regions have different opinions 

about which groups to include. Once the Partnership Office has a list of 

friends groups, agency officials collect available IRS forms for the groups 

from publicly accessible Web sites such as GuideStar,37 where the forms 

are posted along with other information about the organizations in an 

effort to increase transparency to the public. Because only organizations 

with gross receipts over $25,000 are required to file this form, some friends 

groups do not need to file it. The Park Service estimated that for 2006, only 

27 percent of its estimated 186 friends groups met the threshold requiring 

the form. Also, even for those groups required to file the form, the Web 

site does not always post the forms. In such cases, agency officials follow 

up directly with the group to get the information, but this approach is not 

always successful. 

In addition, the information is not up-to-date, because the forms are not 

generally available on the Web site until more than a year after the filing 

year, and once they are available, it takes time for agency officials to 

collect missing data and compile the information into a report.38 For 

example, in April 2008 the agency reported information from the friends 

groups’ 2006 tax year. The information from IRS forms is also based on 

 

37GuideStar USA Inc. is a 501(c)(3) public charity founded in 1994. GuideStar’s mission is to 

“revolutionize philanthropy and nonprofit practice by providing information that advances 

transparency, enables users to make better decisions, and encourages charitable giving.” 

GuideStar advances its mission in part by posting nonprofit organizations’ IRS 990 forms on 

its Web site. 

38The organizations are not required to file the forms until the 15th day of the fifth month 

after the end of their fiscal year, and some groups’ fiscal years go well into the following 

calendar year. For example, a friends group’s fiscal year 2006 may go from July 1, 2006, 

through June 30, 2007, in which case the group would not be required to file the form until 

mid-November 2007. 

Page 63 GAO-09-386 Donations to National Parks
 

inconsistent determinations of support. On the IRS forms, friends groups 

report the amount of funds they spend annually in support of program 

services,39 or their missions, which are typically centered on supporting a 

park or a number of parks. For example, one friends group’s mission is “to 

engage public support for the park and enhance public use and enjoyment 

of the park.” When reporting program services expenditures, organizations 

make subjective decisions about what to include, such as what portion of 

salaries and benefits to count as furthering the organization’s mission, and 

consequently, they do not always use the same approach. Park Service 

officials acknowledged these weaknesses in the data but said that 

collecting and reporting information that gives some indication of support 

provided by friends groups is an improvement over collecting no 

information centrally, which was the agency’s practice before 2006. 

To estimate the extent of support provided by cooperating associations, 

the Park Service requires associations to fill out a government form with 

data including gross sales revenue; cost of goods sold; net profits; sources 

of income other than sales; and cash and in-kind donations to each federal 

agency the association supports, in categories such as interpretation, 

research, and free publications. In addition, associations must provide 

financial documents and narrative reports on their annual 

accomplishments. Agency officials use information from the required 

documents to produce an annual report with nationwide and, in some 

cases, association-specific information on the following: 

• revenues in categories such as sales and membership income; 

• expenses in categories such as program service operating expenses and 

direct donations to parks; 

• financial aid provided to the Park Service in categories such as 

interpretation, free publications, and research; and 

• narrative descriptions and pictures illustrating examples of the support 

provided by cooperating associations. 

Because the information on cooperating associations’ support to the Park 

Service is collected annually directly from cooperating associations, it is 

 

39According to the IRS instructions for the 990 form, “A program service is an activity of an 

organization that accomplishes its exempt purpose.” The instructions further specify that 

organizations should generally not report fund-raising as an exempt activity. 

Page 64 GAO-09-386 Donations to National Parks
 

more complete and up-to-date than that collected for friends groups from 

the Web site. Like the friends group information, however, it relies on the 

numbers from IRS forms, which are subjectively determined on the basis 

of an expansive concept of support. Therefore, the information on 

cooperating associations should still be understood as an indicator of 

support, rather than a precise accounting of the value of donations. Also, 

cooperating associations are not required to report information on the 

support they provide to individual parks; instead, they report their support 

to the Park Service overall. This means that the Park Service currently 

does not know how much each park receives from associations that 

partner with multiple parks, such as Eastern National, which partners with 

more than 130 parks and provided $12.4 million in support to those parks 

in 2007, according to the annual report. The Park Service is considering 

requiring this information in the future. 

Like cooperating associations, the Foundation provides information 

directly to the Park Service, so agency officials do not have to collect it 

from a Web site, but the information has several limitations. Unlike the 

agency’s data on associations and friends groups, the information from the 

Foundation has come from various sources in the past 3 years, partly 

because the Foundation is not required to file the IRS 990 form. For 2 

years, the Park Service collected information from the Foundation’s 

annual reports, but in the third year, the Foundation did not produce an 

annual report, so the Park Service obtained the data through a 

conversation with the Chief Financial Officer and from a presentation 

made by the Foundation.40 The source of this information is unclear and 

does not match numbers in the financial statement the Foundation 

submits annually to the Park Service. When asked, Park Service officials 

said they too wondered what the number was based on but had not been 

able to get a clear answer from the Foundation. The Park Service’s 

information on support provided by the Foundation is further limited 

because the agency does not systematically track how the Foundation’s 

donations were used or which parks and programs received the donations, 

although an agency official said he meets frequently with Foundation staff 

and is familiar with their activities. 

The Park Service acknowledges that its estimates of support provided by 

partner organizations are not precise measures of the value received, but 

agency officials believe that the costs of developing precise, reliable data 

 

40As of February 2009, the Foundation had posted 5 years of financial data on its Web site. 

Page 65 GAO-09-386 Donations to National Parks
 

would outweigh the benefits to the agency, especially because they believe 

the total value of such donations to be relatively small. It would be costly 

because it would take considerable time for staff to collect the data, enter 

it into a system, and verify its accuracy. And new databases require longterm maintenance, so the costs would continue into the future. It would be 

particularly costly to collect information on donations from partner 

organizations because the information originates with multiple, dispersed, 

independent organizations that the Park Service does not have authority 

over. And the donations are received by multiple divisions within parks. 

For example, the maintenance division might receive a donated car or trail 

repair services, the interpretive division might receive published 

brochures or front-desk support, and the resource management division 

might receive wildlife photos or assistance removing invasive plants. Also, 

the Park Service appreciates the support it receives from its partners and, 

according to agency officials, is reluctant to impose onerous and costly 

data-reporting requirements on them. 

More importantly, even if the agency invested the necessary resources in 

managing the data and asked friends groups, cooperating associations, and 

the Foundation to provide more-precise valuations of their donated funds, 

goods, and services, it is not clear for several reasons that the data would 

be reliable. First, it would be difficult to ensure that all partner 

organizations—especially newly established or small organizations—

followed a consistent method to produce accurate and complete data. 

Also, according to agency officials, it would be difficult for the Park 

Service to clearly define a universe of donating partners and donations. 

For example, the agency would have to decide whether the following 

nonprofit partners and their contributions should be included in such a 

universe: 

• The Teton Science School in Wyoming provides interpretive and 

educational services to visitors at Grand Teton National Park through an 

environmental education center located inside the park. 

• Yosemite Renaissance is a nonprofit organization in California supporting 

art in Yosemite National Park. The organization puts on an annual juried 

art show in the park for 3 months and then tours around the state for a 

year. The organization receives about $15,000 from the county, but the 

Park Service does not provide any financial support in return for the 

service, according to agency officials. 

• The Cuyahoga Valley Scenic Railroad in Ohio spends about $2.8 million 

annually to operate a train service on Park Service tracks and offer 

Page 66 GAO-09-386 Donations to National Parks
 

educational and recreational train rides for the park. The Park Service 

owns and maintains the tracks and infrastructure and supplies about 

$200,000 to subsidize the nonprofit operation. 

• The Bay Area Discovery Museum in California has raised about $25 million 

to restore Park Service buildings where it now operates a children’s 

museum at Golden Gate National Recreation Area, consistent with the 

park’s mission. Golden Gate has similar arrangements with a number of 

other park partners. 

Finally, to develop reliable, accurate data, the Park Service would also 

have to ensure that all in-kind donations of goods and services were 

valued using a consistent methodology. Yet some donated goods—such as 

early settlers’ wagon wheel spokes or some antique eating utensils—have 

very little monetary value and could cost more to appraise than they are 

worth, despite their significant educational or historic preservation value 

to parks. Other donations, such as wildlife art, historic photographs, or 

equipment used by pioneering rock climbers, have difficult-to-quantify 

value. If the Park Service required that such donations be appraised, 

donors might choose to make their donations elsewhere. And donated 

services can be just as difficult to value. For example, the Park Service or 

its partners would have to determine what portion of salaries to count for 

friends groups and cooperating associations that provide services such as 

answering visitor questions, staffing visitor center desks, raising 

awareness about parks with their local communities, or managing projects 

and programs in parks. At some parks, students or professors conduct 

research that benefits the Park Service, and lawyers, businesspeople, or 

consultants furnish professional services for no fee. 

Not only do many Park Service officials believe that the costs of collecting 

precise data on donations would be high, some of them also believe that 

the benefits would be minimal at best. At the park level, several 

superintendents told us they did not see a use for a database with precise 

values. They were generally aware of the donations their parks received 

and said they could always ask their partners for more specific 

information if needed. At the headquarters level, officials in the 

Partnership Office said they rarely use the information they develop on 

estimated indicators of support, generally only to respond to occasional 

congressional inquiries. An official in the budget office said the volume of 

donations does not warrant the effort, and such information would not 

affect the agency’s allocation of resources. He noted, however, that if the 

magnitude of donations increased significantly—for example if the 

Centennial Challenge program grew—the information might be warranted. 

Page 67 GAO-09-386 Donations to National Parks
 

On the other hand, some superintendents told us they believed that 

notable benefits would come from collecting better data on donations, and 

the benefits would outweigh the costs. For example, one superintendent 

said it has become more apparent in recent years why the information is 

important, noting that currently some donations—and their associated 

benefits—are not reported anywhere. And several agency officials said it 

would not be too burdensome to track in-kind donations if an existing 

system could be used rather than creating a new one. Some parks have 

already begun to collect more information on donations. For example, a 

partnership coordinator at Cuyahoga Valley National Park recently began 

using a tracking form to collect information from the park’s division chiefs 

on cash and in-kind donations they receive, including a description of the 

donation, its value or estimated value, the donation’s purpose, donor 

category (such as individual, corporation, or nonprofit organization), and 

donor’s name. The park initially started the tracking effort to meet a 

requirement in an earlier version of the Park Service’s donations and fundraising policy, but the requirement was subsequently eliminated. 

Nevertheless, park officials intend to keep tracking the information 

because they said it provides useful information left out of the financial 

system’s data on cash donations, and the superintendent uses the data 

when talking with partners and the public about the value of philanthropy 

to the Park Service. 

While it may be impractical to collect precise quantitative information on 

all donations, some refinements to the current approach—such as 

requiring parks to collect information from their friends groups—could 

improve estimates and, consequently, the Park Service’s accountability 

and transparency. Moreover, improving information for some high-risk 

categories of donations may warrant the costs. For example, under the 

Centennial Challenge program, the requirement that donations match or 

exceed the federal contribution calls for heightened controls and justifies 

a greater investment of resources to track the data. Likewise, given the 

heightened level of risk associated with corporate donations, the agency 

might benefit from closer data tracking and monitoring. Equipped with 

refined information on donations and a strategic approach, the Park 

Service would be well positioned for its approaching centennial 

anniversary, and Congress could make informed decisions about 

allocating resources. 

Page 68 GAO-09-386 Donations to National Parks
 

Park Service employees and partner organizations identified challenges 

with understanding each other’s cultures, policies, and constraints and 

said they lack sufficient skills in these areas, which they believe are 

critical for successful partnerships.41 Although the Park Service and its 

nonprofit partners share a common interest in enhancing parks and 

programs, they have distinctly different cultures and frameworks, 

motivations, and needs. For example, nonprofit organizations are 

incorporated under state law and must meet applicable state requirements. 

As tax-exempt organizations, they must also comply with relevant IRS 

requirements. They have their own policies, and are accountable to their 

boards of directors, any donors or members, and the public. Partner 

organizations generally said they want to feel appreciated and respected; 

be involved in decision making; and be responsive to donors’ interests, for 

example by showing results quickly and ensuring that their gifts are used 

as intended. For its part, the Park Service has numerous policies and 

regulations, and specific processes that it must follow. Many agency 

officials we interviewed noted the importance of following these 

processes and protecting the agency against excessive risk, as well as the 

value of encouraging support from partners that can enhance limited park 

resources. Partly because of the required processes, the agency tends to 

operate more slowly than the private sector, according to agency officials 

and partners. In addition, Park Service superintendents and staff 

sometimes rotate as often as every 2 or 3 years as they advance in their 

careers. 

Additional Skills and 

Knowledge about Working 

with Nonprofit and 

Philanthropic 

Organizations Could 

Promote More-Effective 

Partnerships 

In recognition of these challenges, and to help identify training needs, the 

Park Service contracted with Clemson University to study agency 

employees’ knowledge, skills, abilities, and attitudes related to 

partnerships. Researchers surveyed employees, asking them to rate the 

importance of, and their preparedness in, a number of Park Service 

competencies related to partnerships. They issued a report in 2007, 

identifying gaps where respondents reported feeling ill prepared relative to 

the importance of a given competency. The largest gap they found was in 

employees’ ability to collaborate with philanthropic and grant-making 

entities to leverage funds toward achieving Park Service goals, followed by 

their ability to ensure that all partnership construction projects meet 

agency requirements and their knowledge of the partnership construction 

 

41In 2008, we reported on similar challenges in GAO, Natural Resource Management: 

Opportunities Exist to Enhance Federal Participation in Collaborative Efforts to Reduce 

Conflicts and Improve Natural Resource Conditions, GAO-08-262 (Washington, D.C.: Feb. 

12, 2008). 

Page 69 GAO-09-386 Donations to National Parks
 

process. Also among the top 25 percent of identified gaps was knowledge 

of the concepts, policies, and practices related to donations and fundraising partnerships in the Park Service. 

Results from our own interviews are consistent with these findings. When 

asked what factors contribute to difficulties between partner organizations 

and the Park Service, friends groups and cooperating associations most 

often cited culture differences and related limitations in capacity. 

Similarly, superintendents most often cited greater capacity when asked 

what improvements could be made to the agency’s management of 

donations. For example, several partner organizations said Park Service 

officials do not always understand retail business and sometimes expect a 

greater portion of revenues to be returned to the park or inadvertently 

make decisions that can result in lower revenues. Others said park 

officials sometimes focused too much on their financial contributions 

without appreciating other, less tangible forms of support they provided. 

And a number of partner organizations said it was sometimes difficult to 

understand Park Service culture, with its bureaucracy, chain of command, 

protocols, policies, and procedures. Several superintendents said it was 

challenging to ensure that their partners understood agency policies and 

procedures and had realistic expectations. Some said they needed more 

skills and expertise in building partnerships, and others said they needed 

greater capacity to think strategically about how to increase partnerships 

and donations and to more actively seek out partners. 

In a 2004 Park Service review of its partnership projects, a team found that 

agency personnel needed training in building and maintaining successful 

relationships to enable them to deal more effectively with partners and 

partnership projects. The team said the training should include skills in 

collaboration; forming relationships; consensus building; looking for winwin solutions; negotiating; and how to work with strong, well-connected 

partners without compromising the agency’s integrity. Further, in 2007 a 

departmentwide team for facilitating the partnership process concluded 

that partnership training and capacity building were severely undervalued 

in Interior. In particular, the team emphasized that a key component of 

capacity building is hiring and training additional contracting officials and 

solicitors who understand how to operate within the scope of the law with 

partners. Toward this end, the team recommended that Interior provide 

additional training for contracting officers and solicitors. Also, it 

concluded that both regional solicitors’ and contracting offices lack 

sufficient personnel to work on partnership activities, cautioning that the 

Centennial Challenge will place significant additional workload on these 

Page 70 GAO-09-386 Donations to National Parks
 

offices; the team recommended hiring applicants with skill sets directly 

relevant to partnering activities. 

To increase employees’ knowledge, skills, and capacity related to 

partnerships, fund-raising, and nonprofit organizations, the Park Service 

has initiated efforts on several levels. In headquarters, the agency’s 

Partnership Office has developed and provided additional training to Park 

Service employees and partners on its donations and fund-raising policy, 

the partnership construction process, and partnering with cooperating 

associations. The latter category includes sessions on tangible and 

intangible support provided by associations, their structure and 

governance, business practices, and how to work together, for example. 

The agency also established a partnership council to discuss concerns, 

suggest and test new ideas, and make recommendations on partnership 

issues, and it created a partnership Web site with guidance, tools, case 

studies, and other information. 

Some regions and parks have also taken steps to increase capacity. The 

intermountain region recently held two multiday workshops, bringing 

together superintendents and executive directors of partner organizations 

to discuss topics such as what the Park Service and partners can do to 

benefit each other, strategies to resolve conflicts, and training needs for 

parks and partners. Demonstrating its desire to bridge the two cultures, 

the region also hired a full-time partnership coordinator from the 

Association of Partners for Public Lands, a nonprofit association of 

cooperating associations and friends groups. In the Pacific West region, 

agency officials established a partnership advisory committee—largely 

made up of superintendents with partnership experience—to provide 

technical assistance to parks and partners. The group surveys parks in the 

region annually to identify their needs and schedules custom-tailored 

consultations throughout the year to provide assistance and build capacity 

in the region. For example, in 2007, the group consulted with 10 parks and 

their partners, on themes including building a friends group, increasing 

board capacity for fund-raising, cultivating a partnership culture, writing 

fund-raising agreements, and building earned-income capacity. In addition, 

parks have initiated their own efforts to increase capacity. For example, 

Cuyahoga Valley National Park created a position for a full-time 

partnership coordinator, Minute Man National Historic Park hosted a 

training workshop put on by the Association of Partners for Public Lands 

for parks and partners in the Northeast region, and Valley Forge National 

Historic Park arranged for the National Parks Conservation Association to 

conduct a study identifying best practices in friends groups and national 

parks. 

Page 71 GAO-09-386 Donations to National Parks
 

While these efforts represent progress, more could be done. The 2007 

Clemson University study, the departmentwide partnership team’s 2007 

recommendations, and our 2008 interview results all confirm that agency 

officials and partners still face significant challenges working across 

culture differences and would benefit from increased knowledge and skills 

in this area. Not only would such increased capacity result in moresuccessful partnerships in the near term, but it could also reduce 

vulnerabilities arising when employees lack the requisite knowledge and 

skills to protect the agency against risks that may be associated with 

accepting donations. 

For decades, donations and related partnerships have provided vast 

benefits to the Park Service, and philanthropy holds great potential for 

supporting the national parks in future generations. Yet along with 

benefits come risks. Faced with the difficult task of weighing the benefits 

against the risks, the Park Service has taken strides in the right direction, 

although it has not yet achieved an optimal balance. Over time, the agency 

has issued ever more complex policies and procedures intended to shield 

itself from possible risks, but the outcome may be counterproductive. 

Confronted with numerous and sometimes ambiguous directives, parks 

interpret the policy inconsistently, and regions and headquarters apply the 

policy on an ad hoc basis, reviewing only the portion of projects that 

comes to their attention. The result is inconsistent conformance and an 

agency exposed to the very risks the policies are designed to protect 

against. The challenge lies in finding equilibrium: that mix where policy 

requirements are thorough and their enforcement unyielding when risks 

are serious—as with partnership construction projects and related 

operations and maintenance costs—and where requirements are less 

demanding when risks are not serious, so as to provide sufficient 

safeguards while smoothing the way for the Park Service to continue 

enjoying the wide-ranging benefits of donations. 

Conclusions 

But even flawless policies may not be enough to manage donations to the 

Park Service effectively, especially with the potential for a dramatic 

expansion in donations under the Centennial Challenge. The Park Service 

will also need to turn away from its reactive stance toward a forwardthinking one and develop a comprehensive vision for philanthropy and 

related partnerships, with a master plan to guide its course in achieving 

the vision. To inform such a plan, as well as to provide accountability and 

transparency, the agency will need to continue improving its data on 

donations, while regularly assessing the costs against the benefits of 

implementing such improvements. With improved information and a 

Page 72 GAO-09-386 Donations to National Parks
 

strategic plan, the Park Service will be better positioned to recognize 

trends early and to make needed programmatic and management changes 

in areas such as policy, staffing, and training. And finally, it is clear that 

although the Park Service has taken steps to identify critical skills and 

knowledge needed for successful partnerships with nonprofit and fundraising organizations—and has provided additional training in some 

cases—the agency needs to do more to foster an environment where such 

skills are consistently cultivated and rewarded. 

We are making seven recommendations to the Secretary of the Interior. To 

more effectively uphold the Park Service’s integrity, impartiality, and 

accountability while promoting positive partnerships, we recommend that 

the Secretary direct the Park Service Director to take the following three 

actions: 

Recommendations for 

Executive Action 

• Tailor the Park Service’s donations and fund-raising policy requirements to 

be commensurate with the level of risk to the agency; for example, allow 

parks and partners that meet certain conditions to follow a modified 

process. 

• Develop a systematic approach to oversight, including a comprehensive 

method for monitoring whether parks and partners are following policy 

requirements on all partnership projects that call for fund-raising 

agreements—for example, through completion and expansion of the 

database used for partnership construction projects—and delegation of 

oversight responsibilities on the basis of risk level to the Park Service. 

• Ensure that all partnership construction projects contain estimates of 

operations and maintenance costs and, when partners agree to pay all or a 

portion of such costs, require that written agreements be executed. 

To increase transparency and efficiency, we also recommend that the 

Secretary direct the Solicitor to work with the Park Service Director to 

• expedite finalization of the draft model agreements related to donations 

and fund-raising. 

In addition, to better position Congress and the agency to make informed 

decisions and plan for the future, we recommend that the Secretary direct 

the Park Service Director to take the following two actions: 

• In collaboration with representatives of friends groups, cooperating 

associations, and the National Park Foundation, develop a strategic plan 

Page 73 GAO-09-386 Donations to National Parks
 

that defines the agency’s vision for donations and related partnerships; 

sets short- and long-term management goals; delineates desired roles and 

responsibilities for agency offices and employees involved in managing 

donations and partnerships, so as to maximize efficient allocation of 

resources; and identifies steps to take in the short and long terms to 

achieve agency goals. 

• Refine data collection procedures to improve estimates of support 

provided by friends groups and work with Congress to identify any 

additional reporting on donations it needs to be fully informed and to 

ensure accountability and transparency. 

Finally, to create and sustain more-effective partnerships with 

organizations that make donations, we recommend that the Secretary 

direct the Park Service Director to 

• improve Park Service employees’ knowledge, skills, and experience about 

fund-raising and partnerships with nonprofit organizations—and 

encourage employees to improve nonprofits’ understanding of the Park 

Service—through targeted training, resource allocation, recruiting, and 

promotion practices. 

We provided the Secretary of the Interior with a draft of this report for 

review and comment. Interior generally agreed with our findings and 

concurred with six of our seven recommendations; it did not concur, 

however, with our recommendation that the Park Service develop a 

strategic plan that defines the agency’s short- and long-term goals for 

managing donations and related partnerships. In addition, although 

Interior said it generally concurred with our recommendation that the 

Park Service tailor its donations and fund-raising policy requirements to 

be commensurate with risk, and described relevant steps the agency has 

taken and intends to take, we believe these steps fall short of meeting the 

intent of our recommendation. Interior’s written comments are 

reproduced in appendix III. 

Agency Comments, 

Third-Party Views, 

and Our Evaluation 

Regarding our recommendation that the Park Service develop a strategic 

plan, Interior commented that (1) the role of partnerships in helping 

accomplish Park Service goals is “woven through and supported by” the 

agency’s policies, including its 2006 Management Policies and its 

donations and fund-raising policy; (2) the agency cannot identify specific 

monetary goals for donations because it is not authorized to solicit them 

and some factors, such as donor interests and the state of the economy, 

Page 74 GAO-09-386 Donations to National Parks
 

are beyond the agency’s control; and (3) the agency already does strategic 

planning on a case-by-case basis with individual partners, such as the 

Foundation. Nevertheless, we continue to believe that the Park Service 

would benefit from an agencywide strategic plan that clarifies its shortand long-term vision for the future role of donations and related 

partnerships, and defines goals and objectives to achieve that vision. 

First, neither the agency’s Management Policies nor its donations and 

fund-raising policy sets out such a plan—or any plans—or describes a 

vision or goals for the role of donations and related partnerships in the 

Park Service. Rather, the Management Policies embrace partnerships as a 

way to help accomplish the agency’s mission and planning as a critical tool 

in decision making, call for managers to identify and accomplish 

measurable long-term and annual goals, and provide guidance on how and 

under what conditions parks should develop strategic and other plans. 

Thus we believe that, contrary to serving as a substitute for a strategic 

plan, this guidance supports our recommendation. The donations and 

fund-raising policy—which provides guidance for employees’ conduct in 

relation to donation activities and fund-raising campaigns—does not serve 

as a substitute for a strategic plan either. Second, we agree that the Park 

Service should not set monetary goals for donations because, as Interior 

asserted, it has no control over certain factors and is not authorized to 

solicit donations to achieve those goals. But in our view, this does not 

prevent the agency from crafting a vision for the desired role of donations 

and related partnerships, setting specific management goals toward that 

end, or identifying actions needed to reach the goals. To clarify this point, 

we revised our recommendation to specify that goals in the strategic plan 

should be related to management. And third, we commend the Park 

Service for working to help the Foundation develop its strategic plan and 

for working with partners on park-specific plans, but we do not believe the 

Foundation’s plan can substitute for a Park Service plan or that park-level 

plans can substitute for the much-needed agencywide plan that we are 

recommending. 

In response to our recommendation that the Park Service tailor its 

donations and fund-raising policy requirements to be commensurate with 

risk, Interior generally concurred, but said that for three reasons, it does 

not support modifying agency requirements. First, Interior explained that, 

in an effort to minimize the time needed to secure approval for a project, 

the Park Service has recently taken steps to speed the approval process 

for two categories of projects: partnership construction projects and 

certain projects with a fund-raising goal between $1 million and $5 million. 

While these actions may be warranted, they do not align policy 

Page 75 GAO-09-386 Donations to National Parks
 

requirements with risk level—as our recommendation calls for—because 

the categories apply uniformly to low- and high-risk projects. Second, 

Interior said, the current provision allowing for waivers of some 

requirements enables the Park Service to apply its policies 

comprehensively and uniformly, maintain accountability, and minimize 

risks. We are not convinced, however, that a policy under which officials 

use their judgment to make case-by-case decisions about granting waivers 

achieves these objectives. And, as described in this report, our findings 

suggest otherwise. We found that parks and partners do not always 

conform to the donations and fund-raising policy, indicating that the policy 

is not being applied comprehensively across all the national parks. We 

found ambiguities in the policy that led to inconsistent, not uniform, 

interpretation and application of the policy. In addition, we found that the 

agency lacks a systematic approach for monitoring conformance to the 

policy, and does not always record key decisions in writing, raising 

questions about the agency’s accountability in this area. And we do not 

believe the agency will be doing as much as it can to minimize risks until it 

takes action to ensure more consistent conformance to the policy. Finally, 

Interior asserted that only three waivers have been justified, suggesting 

that its policy does not need modification. Yet as we state in our report, we 

found seven instances, at just 25 of the agency’s 391 parks, where waivers 

were granted in the last 3 years. Further, these include waivers for 5 of the 

14 required feasibility studies in our sample, indicating that over one-third 

of these required studies in our sample were waived. Instead of modifying 

Park Service policy requirements, Interior said the agency would provide 

additional information to parks on the criteria headquarters uses to decide 

whether to grant a waiver and that headquarters would document all the 

waivers it grants so it can establish a record to use in determining whether 

the policy needs to be modified. While we support the Park Service in 

taking these actions, we do not believe they fulfill the intent of our 

recommendation, and we continue to believe the agency could benefit 

from tailoring its donations and fund-raising policy requirements to be 

commensurate with risk. 

Because of our report’s discussion of, and potential impact on, partner 

organizations, we also sought and received oral comments on the draft 

report from the Association of Partners for Public Lands, the Friends 

Alliance, and the National Park Foundation. All three organizations agreed 

with our findings and recommendations. In addition, they all emphasized 

the importance of the recommendation on strategic planning and 

commented that it would be essential for partners to be involved in such a 

process if it is to be successful. We agree that partners need to play a role 

in this process, as we stated in our report. We modified our 

Page 76 GAO-09-386 Donations to National Parks
 

recommendation to explicitly convey this point. Both the agency and the 

partner organizations also provided technical comments, which we 

incorporated as appropriate. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to interested 

congressional committees, the Secretary of the Interior, the Director of the 

National Park Service, and other interested parties. In addition, the report 

will be available at no charge on the GAO Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841 or nazzaror@gao.gov. Contact points for our offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix IV. 

Sincerely yours, 

Director, Natural Resources and Environment 

Robin M. Nazzaro

Page 77 GAO-09-386 Donations to National Parks
Appendix I: Objectives, Scope, and 

Methodology 

Page 78 GAO-09-386 

We were asked to determine (1) how donated funds, goods, and services 

and related partnerships have supported the National Park Service (Park 

Service); (2) the policies and processes the agency uses to manage 

donations and related partnerships and how well they are working; and (3) 

what, if anything, could enhance the agency’s management of donations 

and related partnerships. 

To address these objectives, we reviewed applicable laws, policies, and 

processes; agency data on cash donations received; and information from 

the Park Service and partner organizations on noncash donations provided 

by partner organizations. We also interviewed Department of the Interior 

(Interior) and Park Service officials, as well as representatives of partner 

organizations and others, at the national, regional, and park levels. At the 

park level, we obtained information from a nongeneralizable sample of 

superintendents and other Park Service officials, and from representatives 

of the affiliated cooperating associations and friends groups, at 25 of the 

391 parks (see table 10). To obtain the information, we used a Web-based 

structured interview protocol, in person for 9 parks and by telephone for 

the other 16 parks. 

Table 10: Parks and Associated Partner Organizations Visited or Interviewed by Telephone 

Region Park name Cooperating association Friends group(s) 

1 Alaska Wrangell-Saint Elias National 

Park 

Alaska Geographic None intervieweda

2 Intermountain Grand Canyon National Park Grand Canyon Association None interviewed 

3 Intermountain Grand Teton National Park Grand Teton Association Grand Teton National Park 

Foundation 

4 Intermountain Rocky Mountain National Park Rocky Mountain Nature 

Association* 

Rocky Mountain Nature 

Association* 

5 Intermountain Yellowstone National Park Yellowstone Association Yellowstone Park Foundation 

6 Intermountain Zion National Park Zion Natural History Association* Zion National Park Foundation* 

7 Midwest Cuyahoga Valley National Park Eastern National Cuyahoga Valley National Park 

Association 

8 Midwest Homestead National Monument 

of America 

Eastern National Friends of Homestead National 

Monument of America 

9 Midwest Indiana Dunes National 

Lakeshore 

Eastern National None interviewed 

10 Midwest Jewel Cave National Monument Black Hills Parks and Forests 

Association 

None interviewed 

11 National Capital Ford’s Theatre National 

Historic Site 

Eastern National Ford’s Theatre Society 

12 National Capital Rock Creek Park Eastern National Friends of Peirce Mill 

Appendix I: Objectives, Scope, and 

Methodology 

 Donations to National Parks 
Appendix I: Objectives, Scope, and 

Methodology 

 Region Park name Cooperating association Friends group(s) 

13 National Capital Thomas Jefferson Memorial Eastern National None interviewed 

14 Northeast Appalachian National Scenic Trail None interviewed Appalachian Trail Conservancy 

15 Northeast Gettysburg National Military 

Park 

None interviewed Gettysburg Foundation 

16 Northeast Minute Man National Historic 

Park 

Eastern National Friends of Minute Man National 

Park 

17 Northeast Statue of Liberty National 

Monument 

None interviewed Statue of Liberty-Ellis Island 

Foundation Inc.; Save Ellis 

Island Inc. 

18 Northeast Vanderbilt Mansion National 

Historic Site 

Roosevelt-Vanderbilt Historical 

Association 

Frederick W. Vanderbilt Garden 

Association 

19 Pacific West Eugene O’Neill National Historic 

Site 

Western National Parks Association Eugene O’Neill Foundation, Tao 

House 

20 Pacific West Golden Gate National 

Recreation Area 

Golden Gate National Parks 

Conservancy* 

Golden Gate National Parks 

Conservancy* 

21 Pacific West Kaloko-Honokohau National 

Historic Park 

Hawaii Natural History Association None interviewed 

22 Pacific West Yosemite National Park Yosemite Association The Yosemite Fund 

23 Southeast Great Smoky Mountains National 

Park 

Great Smoky Mountains Association Friends of Great Smoky Mountains 

National Park 

24 Southeast Jimmy Carter National Historic 

Site 

Eastern National None interviewed 

25 Southeast Wright Brothers National 

Memorial 

Eastern National First Flight Foundation 

Source: GAO. 

Notes: Bold text indicates the parks and associated nonprofit groups that we visited in person. 

Asterisks indicate that the cooperating association and the friends group is the same organization. 

a

We identified cooperating associations and friends groups to interview on the basis of information 

from the Park Service and the Association of Partners for Public Lands (APPL) and corroborated 

those we identified with park superintendents. “None interviewed” generally indicates that either the 

park does not have this type of partner or that the superintendent did not identify this type of partner. 

To develop our Web-based structured interviews, we first met with 

headquarters and regional Park Service officials, representatives of 

national associations of friends groups and cooperating associations, and 

park superintendents and friends group and cooperating association 

executive directors from several parks to learn about donations and 

related partnerships. In particular, we obtained information about fundraising, the Centennial Challenge, agency policies and procedures, 

challenges related to the agency’s management of donations, and relevant 

data tracking. We used this information to develop a draft structured 

interview, which we shared with headquarters officials and partner 

organizations, and made revisions to it in response to their suggestions. To 

minimize nonsampling error that can introduce unwanted variability into 

Page 79 GAO-09-386 Donations to National Parks
Appendix I: Objectives, Scope, and 

Methodology 

the results (for example, differences in how a particular question is 

interpreted), we pretested the interview with four parks and their 

associated friends groups and cooperating associations. (Pretests were 

conducted in person for two parks and by phone for the other two parks.) 

Through our pretest process, we asked questions to ensure that the 

(1) interview questions were clear and unambiguous, (2) terms we used 

were precise, (3) interview did not place an undue burden on those 

completing it, and (4) interview was independent and unbiased. On the 

basis of feedback from the pretests, we modified the questions as 

appropriate. 

We selected two samples of parks—one sample for site visits and another 

for telephone interviews. For site visits, we selected a purposeful sample 

of 9 parks that reflected geographic diversity and emphasized parks with 

high levels of donation activity, because we believed they would have the 

most practical experience with Park Service policies and procedures on 

donations and fund-raising and would be more likely to encounter the 

potential risks associated with accepting donations. For telephone 

interviews, we selected another 16 parks, mainly using a stratified random 

sample. Specifically, we randomly selected up to 3 parks per region 

including 1 with high (over $10,000) and 2 with low (less than $10,000) 

maximum annual donations for 2004 through 2006 from friends groups and 

cooperating associations. From among the 3 randomly selected parks in 

each region, we generally chose 2 to interview, on the basis of factors such 

as presence or absence of cooperating associations and friends groups, 

visitation rates, and type of park. (In the Alaska region, we selected only 1 

park because none of its parks were in the high donation category, and in 

the Southeast region, we selected an additional park outside of the 

random sample because we did not visit any of its parks and we wanted to 

ensure sufficient coverage of potential regional issues.) We also selected 2 

additional parks that were outside of the random sample and had recently 

started or ended relationships with friends group because we wanted to 

ensure our interviews were applicable to parks in such situations; these 

parks were among those we contacted for pretesting. 

To develop the data for drawing our sample, we used information from the 

Park Service and the Association of Partners for Public Lands (APPL) on 

donations from friends groups and cooperating associations, park 

visitation rates, and park type for all 391 parks. We subjected these data to 

electronic and logic testing and followed up with Park Service and APPL 

officials regarding questions. After these verification and testing efforts, 

we considered the data sufficiently reliable as a source for our sample 

selections. In total, we completed structured interviews with 25 parks plus 

Page 80 GAO-09-386 Donations to National Parks
Appendix I: Objectives, Scope, and 

Methodology 

11 cooperating associations, 16 friends groups, and 3 organizations that 

served both roles. 

To analyze the narrative responses to some of the structured interview 

questions, we used the Web-based system to perform content analyses of 

select open-ended responses. To develop statistics on agreement among 

the answers, two reviewers collaboratively developed content categories 

based on interview responses to each question. Subsequently, they 

independently assessed and coded each interview response into those 

categories. Intercoder reliability (agreement) statistics were electronically 

generated in the coding process. We resolved coding disagreements 

through reviewer discussion; agreement on all categories was 90 percent 

or above. In addition, we conducted statistical software analyses of the 

closed-ended responses. 

To determine how donations and related partnerships have benefited 

parks, we analyzed interview responses and documents we collected from 

the respondents, reviewed agency and partner reports describing 

accomplishments, and visited some projects to view them in person. We 

also obtained and analyzed cash donation data from the Park Service’s 

financial system. To assess the reliability of this information and learn 

about the agency’s related internal controls, we interviewed staff 

responsible for compiling and reporting the data in the Park Service’s 

Office of the Comptroller and at the park locations we visited, and we 

reviewed an external audit of the data. 

To determine what policies and processes the Park Service uses to 

manage donations and related partnerships and how well they are 

working, we reviewed pertinent Interior and Park Service policies and 

procedures and interviewed agency officials to better understand how 

they interpret and apply them; obtained documents required by the 

policies and assessed parks’ conformance to the policy requirements over 

the last 3 years; reviewed relevant agency and Inspector General reports; 

and interviewed headquarters, regional, and park officials and partner 

organizations about related challenges. 

To determine what could enhance the agency’s management of donations 

and related partnerships, we analyzed interview responses to questions 

about challenges and potential improvements; reviewed relevant Interior 

and Park Service reports and a Clemson University study on agency 

employees’ knowledge, skills, abilities, and attitudes related to 

partnerships; and interviewed agency and partner financial officers to 

understand how they tracked and reported information on donations. We 

Page 81 GAO-09-386 Donations to National Parks
Appendix I: Objectives, Scope, and 

Methodology 

also obtained information on fund-raising best practices and state and 

Internal Revenue Service policies applicable to nonprofit organizations, 

interviewed officials at a university and its associated foundation to 

understand how donations were managed there, and attended two 

nationwide meetings of friends groups and cooperating associations—

including training sessions on topics such as the Park Service donations 

and fund-raising policy and the basics of fund-raising. 

We conducted this performance audit from December 2007 through June 

2009, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Page 82 GAO-09-386 Donations to National Parks
Appendix II: Statutory Provisions Relating to 

Cooperating Associations and Friends Group Appendix II: Statutory Provisions Relating to Activities at National Parks 

Cooperating Associations and Friends Group 

Activities at National Parks 

16 U.S.C. § 1. Establishes the National Park Service and the basic mission 

of the agency: “to conserve the scenery and the natural and historic 

objects and the wild life therein and to provide for the enjoyment of same 

in such manner and by such means as will leave them unimpaired for the 

enjoyment of future generations.” 

16 U.S.C. § 1a-2(g). Authorizes the Secretary of the Interior to enter into 

contracts, including cooperative arrangements, with respect to conducting 

living exhibits and interpretive demonstrations. 

16 U.S.C. § 1b(5). Authorizes the Secretary of the Interior to provide, on a 

reimbursable basis, supplies and equipment to persons that render 

services or perform functions that facilitate or supplement the activities of 

the Park Service. 

16 U.S.C. § 1g. Authorizes the Park Service to enter into cooperative 

agreements that involve the transfer of Park Service appropriated funds to 

state, local and tribal governments; other public entities; educational 

institutions; and private nonprofit organizations for the public purpose of 

carrying out National Park Service programs pursuant to 31 U.S.C. § 6305. 

16 U.S.C. § 3. Authorizes the Secretary of the Interior to issue rules and 

regulations for use and management of park areas. 

16 U.S.C. § 6. Authorizes the Secretary of the Interior to accept donations 

of lands, other property, and money for the purposes of the National Park 

System. 

16 U.S.C. § 17j-2(e). Authorizes the use of Park Service appropriations for 

the services of field employees in cooperation with nonprofit scientific 

and historical societies engaged in educational work in the parks. 

16 U.S.C. § 18f. Authorizes the Secretary of the Interior to accept 

donations and bequests of money or other personal property and to use 

and administer these for the purposes of increasing the public benefits 

from museums within the National Park System. 

16 U.S.C. § 19e. Establishes the National Park Foundation, a charitable and 

nonprofit corporation, to accept and administer gifts of real and personal 

property for the benefit of, or in connection with, the National Park 

Service, its activities, or its services. 

Page 83 GAO-09-386 Donations to National Parks 
Appendix II: Statutory Provisions Relating to 

Cooperating Associations and Friends Group 

Activities at National Parks 

16 U.S.C. § 19jj-4. Authorizes the Secretary of the Interior to accept 

donations of money or services to meet expected, immediate, or ongoing 

response costs concerning destruction, loss, or injury to park system 

resources. 

16 U.S.C. § 462(e). Authorizes the Park Service to enter into contracts and 

cooperative agreements with associations and others to protect, preserve, 

maintain, or operate any historic or archaeologic building, site, object, or 

property in the National Park System. 

16 U.S.C. § 464(a). Authorizes the Secretary of the Interior, in 

administering historic sites, buildings, and objects of national significance, 

to cooperate with and seek and accept the assistance of any federal, state, 

or municipal department or agency; any educational or scientific 

institution; or any patriotic association or individual. 

31 U.S.C. § 6305. Authorizes federal agencies to use cooperative 

agreements when (1) the principal purpose is to transfer a thing of value to 

the recipient to carry out a public purpose and (2) substantial involvement 

is expected between the agency and the recipient when carrying out the 

activity contemplated in the agreement. 

Page 84 GAO-09-386 Donations to National Parks
Appendix III: Comments from the Department Appendix III: Comments from the of the Interior 

Department of the Interior 

Page 85 GAO-09-386 Donations to National Parks 
Appendix III: Comments from the Department 

of the Interior 

Page 86 GAO-09-386 Donations to National Parks
Appendix III: Comments from the Department 

of the Interior 

Page 87 GAO-09-386 Donations to National Parks
Appendix III: Comments from the Department 

of the Interior 

Page 88 GAO-09-386 Donations to National Parks
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 89 GAO-09-386 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

Robin Nazzaro, (202) 512-3841 or nazzaror@gao.gov

In addition to the individual named above, David P. Bixler, Assistant 

Director; Kevin Bray; Ellen W. Chu; Chase Cook; Christine Feehan; 

Richard Johnson; Jamie Meuwissen; Tony Padilla; and Rebecca Shea made 

key contributions to this report. Michael Brostek, Mae Liles, Kim Raheb, 

and Tom Short also made important contributions to the report. 

 Donations to National Parks 

GAO Contact 

Staff 

Acknowledgments 

(360904) 
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