National Park Service: Donations and Related Partnerships Benefit Parks, but Management Refinements Could Better Target Risks and Enhance Accountability
Published: 2009-06-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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  of Congress, GAO, 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  audit objectives. (App. I discusses our scope and methodology in more  detail.)
subsections: section_title: Background
paragraphs: 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. 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.
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.” 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. As with any  federal program, the Park Service is expected to manage within whatever  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. In addition, the  park system faces a maintenance backlog of about $9 billion, according to  Interior fiscal year 2006 estimates. 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. These matching funds, combined with an additional  $11.3 million of in-kind contributions, supported 110 Centennial Challenge  projects at 75 parks in 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.
The Park Service is statutorily authorized to accept donations—both cash  and in-kind goods and services—from various sources, including  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,  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. 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 organizations and employs a  standardized cooperating association agreement, identifying the specific  federal statutes and agency policies governing agency and association  responsibilities. Some of the nonprofit partners acting as cooperating  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.
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  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    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.
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.
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 donor- 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.
section_title: Donations Have Provided Significant Support to Park Programs and Projects, and Partnerships Amplify These Donations with Intangible Benefits
paragraphs: 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.
subsections: section_title: Donations Have Provided Significant Support to Park Programs and Projects
paragraphs: 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.
subsections: section_title: Donations from Nonprofit Partners Support a Variety of Park Programs and Projects
paragraphs: 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  Memorial and the African American Experience. 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. 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. 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).
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  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.
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  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.
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.
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  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).
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  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.
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.
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.
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. 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  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.
section_title: Related Partnerships Have Amplified the Value of Donations with Countless Other Benefits
paragraphs: 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 cooperating- association 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  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-the- spot” is one of the most significant ways it is able help the park.
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  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.
section_title: Park Service Policies and Processes for Managing Donations Generally Work Well, but Some Could Be Strengthened
paragraphs: 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.
subsections: section_title: Donations and Fund- raising Policy Requirements Address Key Areas, but Weaknesses Remain in Implementation
paragraphs: 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.
subsections: section_title: Donations and Fund-raising Policy Includes Requirements to Protect the Park Service against Risk
paragraphs: 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:    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.
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. 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.
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  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,  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. 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.
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 fund- raising agreement from $2,500 to $25,000 and eliminating the formal  review of donations from state and local governments. In addition,  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.
section_title: Parks and Partners Do Not Always Conform to Donations and Fund-raising Policy
paragraphs: 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).
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 fund- raising—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  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  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 fund- raising 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  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.
section_title: Ambiguities in Donations and Fund-raising Policy Create Challenges
paragraphs: 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.
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  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 fund- raising strategy. Consequently, they did not yet have the necessary  information to complete the documents. But the donations and fund- raising 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.
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  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.
section_title: Park Service Lacks Systematic Approach for Monitoring Conformance to Its Donations and Fund-raising Policy
paragraphs: 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 fund- raising 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.
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’ long- term 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.
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.
section_title: The Park Service Has Taken Steps to Address Accountability Concerns in Its Partnership Construction Process, but Gaps Remain
paragraphs: 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). First, during the project  definition phase, parks and partners must sign a memorandum, stating  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 cost- effective. 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.
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.  The agency has made progress on some but not all of these  recommendations (see table 5).
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,  rather than one at a time. 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. 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  construction projects since 2005, 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,  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  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.
section_title: Gaps in Donations and Fund-raising Policy and in Partnership Construction Process Hinder Their Effectiveness at Protecting against Risk
paragraphs: 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, less- experienced 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  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 case- by-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.
section_title: Cooperating Association Policy Works Well to Guide Relations with Associations
paragraphs: 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).
The 14 cooperating associations 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.
section_title: Centennial Challenge Procedures Show Promise after First Year
paragraphs: 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:    Stewardship: lead America in preserving and restoring treasured    Environmental leadership: demonstrate environmental leadership to the    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. 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. Meanwhile, agency  officials developed a business plan for the Centennial Challenge, which  was also adopted in April 2008. The business plan defines roles and  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).
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  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. 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  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.
section_title: Enhancements to Park Service Management of Donations Could Strengthen Accountability, Efficiency, and Partner Relations
paragraphs: 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.
subsections: section_title: A More Strategic Approach to Management of Donations Could Enhance Effectiveness and Efficiency
paragraphs: 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  in sales annually—the loss had an effect on more than 130 parks that  Eastern National supports. 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 interpretation 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  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  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.
section_title: Further Refinements to Information on Donations Could Strengthen Accountability and Transparency
paragraphs: 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.
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. 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  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, 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. 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  inconsistent determinations of support. On the IRS forms, friends groups  report the amount of funds they spend annually in support of program  services, 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  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. 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  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 long- term 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  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.
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 fund- raising 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.
section_title: Additional Skills and Knowledge about Working with Nonprofit and Philanthropic Organizations Could Promote More-Effective Partnerships
paragraphs: 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. 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.
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  process. Also among the top 25 percent of identified gaps was knowledge  of the concepts, policies, and practices related to donations and fund- raising 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 win- win 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  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.
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 more- successful 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.
section_title: Conclusions
paragraphs: 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.
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 forward- thinking 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  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 fund- raising 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.
section_title: Recommendations for Executive Action
paragraphs: 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:    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  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.
section_title: Agency Comments, Third-Party Views, and Our Evaluation
paragraphs: 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.
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,  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 short-  and 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  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  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.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: 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.
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 fund- raising, 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  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  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  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.
section_title: Appendix II: Statutory Provisions Relating to Cooperating Associations and Friends Group Activities at National Parks
paragraphs: 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.  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.
section_title: Appendix III: Comments from the Department of the Interior
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: 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.