National Park Foundation: Better Communication of Roles and Responsibilities Is Needed to Strengthen Partnership with the National Park Service
Released: 2004-05-25T00:00:00

Letter

Background

The national park system is comprised of 387 parks, including a diverse array of national parks, military parks, national monuments, national historic sites, recreation areas, and other designations. The Park Service manages the park system and is charged with preserving and protecting these public lands for future generations. To manage this diverse system, parks are arranged under seven regional offices. These offices offer administrative or specialized support that is not always available at the local park level. Within these regions, a superintendent manages each park and has considerable decision-making authority over local park operations.

Federal appropriations to the Park Service have increased from about $2 billion to about $2.5 billion over the past 5 years, but these funds still fall short of addressing system needs. For example, the park system has a maintenance backlog estimated to be about $5 billion. In addition to federal appropriations, the Park Service relies on support from various sources. For example, the Park Service receives additional support through (1) admission and user fees collected at park sites; (2) franchise fees paid by over 600 park concessionaires; and (3) donations from various individuals and groups, such as nonprofit organizations, which provide, among other things, technical, volunteer, and financial assistance to parks. The Park Service is actively increasing its partnerships with nonprofit organizations as an additional source of support.

In 1967, the Congress chartered the Foundation as the official national, nonprofit fund-raising partner of the Park Service. The Foundation’s primary purpose is to encourage private contributions that benefit park programs, activities, or services. The Foundation’s charter was expanded in 1998 to assist and promote fund-raising at individual national parks. The Foundation is governed by a board of directors. The Secretary of the Interior is the board’s chairperson and appoints all board members, who serve without pay or other compensation. With the exception of appointment powers, most of the chairperson’s responsibilities for overseeing Foundation operations are delegated to the board’s vice chairman, who is the private citizen leader of the board. The Foundation has a staff of about 40 employees, including a chief executive officer/president who is responsible for managing the Foundation’s day-to- day operations. Although congressionally chartered, the Foundation does not receive federal appropriations. Its expenses are paid from the revenues that it collects.

The Foundation’s revenues and expenses have dramatically increased in recent years. Foundation revenues more than doubled from about $24 million in fiscal year 1999 to about $52 million in fiscal year 2003. Similarly, the Foundation’s expenses, which are mostly contributions to the parks, have increased from $16.5 million to over $48 million during this period. Figure 1 show the trends in the Foundation’s revenues and expenses for fiscal years 1999 through 2003.

The total Foundation revenues for fiscal years 1999 through 2003 amounted to about $200 million. Of these, contributions (cash and in-kind) were the largest category of revenues, accounting for about $160 million, or 80 percent. Other revenue sources included income from investments, payments from federal agencies, litigation settlements, and fees imposed for services provided to other nonprofit organizations. On the other hand, the Foundation’s total expenses were about $176 million during this time. The majority of these expenses were for direct program support and grants, amounting to $160 million, or 91 percent, of all expenses. Other expenses were for general and administrative costs and fund-raising costs. These costs included rent payments, purchases of equipment and supplies, and salaries for administrative personnel. Figure 2 shows the Foundation’s total revenues and expenses for fiscal years 1999 through 2003, by category.

The National Park Foundation Has Considerable Discretion in Raising and Distributing Private Donations to Parks

The Foundation has considerable discretion in raising and distributing private contributions to the Park Service. The Foundation’s chartering legislation does not prescribe a specific process to be used by the Foundation in raising donations for the Park Service. The Foundation has determined that systemwide projects that are unlikely to receive federal funding have the greatest potential for fund-raising success.

Legislative Charter Provides Broad Discretion in Fund- raising

The 1967 legislative charter provides the Foundation with broad discretion in determining its fund-raising approach. Under the legislation, the Foundation is authorized to “accept, receive, solicit, hold, administer, and use any gifts, devises, or bequests, either absolutely or in trust of real or personal property or any income therefrom or other interest therein for the benefit of or in connection with, the National Park Service, its activities, or its services.” In 1998, the Congress amended the Foundation’s charter and also required it to “design and implement a comprehensive program to assist and promote philanthropic programs of support at the individual national park unit level.”

Fund-raising Is Targeted at Systemwide Projects That Are Not Federally Funded

In general, the Foundation attempts to secure private support for systemwide projects that are not federally funded. Foundation officials refer to this selection approach as its “Bright Line Theory.” This theory is based on the view that donors will typically not make a contribution if they believe their donations will simply be used to supplant government funds or if their donations do not provide additional value. The Foundation considers projects that are systemwide and nonfederally funded to be above the bright line and to have the greatest possibility of attracting private support. The Foundation usually identifies these projects in consultation with Park Service headquarters officials. Such projects include the Park Service’s Junior Rangers Program, which seeks to provide school children with knowledge about the benefits of national parks, and the Parks as Classrooms Program, whereby teachers are encouraged to supplement learning about nature by visiting local parks. Because the Foundation focuses on systemwide, nonfederally funded projects, it does not typically attempt to secure private donations for certain individual park priorities, which, Foundation officials believe, fall below the bright line and would potentially be viewed by donors as a federal responsibility.

Corporations Contributed to Significant Rise in Private Support

For fiscal years 1999 through 2003, private contributions more than doubled, from approximately $18 million in 1999 to just over $41 million in 2003. Cumulative private contributions during this period were about $160 million, with the majority of these contributions coming from corporations. Most corporate donations are targeted for a specific use (restricted). The Foundation is in the process of revising its current fund-raising approach in an effort to increase its pool of discretionary donations. The Foundation hopes to satisfy more individual park needs with these discretionary donations.

Corporations Are a Major Source for Private Donations

The Foundation has made a concerted effort to direct its fund-raising efforts primarily at corporations. Of the approximately $160 million that the Foundation raised in private donations for fiscal years 1999 through 2003, $120 million, or 75 percent, came from corporations. Individuals and foundations accounted for the remaining $40 million, or 25 percent. Figure 3 shows the percentage of donations, by source, for fiscal years 1999 through 2003.

In-kind contributions comprised about 52 percent of the corporate contributions during this time. As shown in figure 4, in-kind contributions have increased, whereas cash contributions have decreased in fiscal years 2002 and 2003, due largely in part to the implementation of the Foundation’s Proud Partners Program.

The Foundation’s fund-raising and grant-making processes consist of several phases. Fund-raising efforts typically begin with the Foundation’s board members identifying corporate donors that could potentially provide donations in support of the Park Service. After identifying these corporate donors, the Foundation researches their philanthropic interests, such as demonstrated support for educational programs. Next, the Foundation contacts potential donors to explore the donors’ philanthropic interests and to ascertain their willingness to make donations in support of the Park Service. If the donors are willing to contribute, the Foundation then contacts Park Service headquarters officials with relevant subject matter expertise to help identify potential systemwide projects that correspond with the donors’ interests. The Foundation then presents these projects to the donors for their consideration. The donors then may decide to make a cash or in-kind contribution through the Foundation to support (1) one or more of the proposed systemwide projects, (2) projects in a specific park, or (3) general Park Service activities. In instances where the donors decide to support systemwide projects, the Foundation requests that all interested parties submit grant proposals, indicating how they would use these donations. The Foundation, in consultation with Park Service officials, reviews the submitted proposals and selects recipients for the awards. In instances where the donors decide to support projects in a specific park, the Foundation makes a grant to the selected park. The Foundation may use various means to distribute general donations to support park activities. Figure 5 illustrates the steps involved in the Foundation’s fund- raising and grant-making processes. Appendix II provides additional details on the grant-making process.

To better align its fund-raising with Park Service programs, the Foundation is currently expanding its fund-raising approach and reviewing, with the Park Service, the priority uses of the funds raised. Under its expanded approach, the Foundation and the Park Service have identified five program areas—Volunteerism, Visitor Experience, Education, Community Engagement, and Programs of National Significance—for which to target donations. Within each of these five program areas, the Foundation and the Park Service have identified systemwide programs that donors can support. Moreover, these programs will be used as a basis for identifying potential donors that have a history of supporting similar type programs.

Proud Partners of America Program

Corporate donors support the Foundation’s Proud Partners of America Program, which was initiated in November 2000. The Foundation names as Proud Partners those corporations that have committed to multiyear support to help raise awareness about national parks, promote interest and support through sales of the National Park Pass, and encourage and provide meaningful experiences for park visitors. Currently, there are five Proud Partners: American Airlines; Discovery Communications, Inc.; Ford Motor Company; Eastman Kodak Company; and TIME magazine. Each Proud Partner is expected to pledge a minimum of $12 million over a 3-year or longer period, and, according to Foundation officials, the Proud Partners have committed an estimated $88 million to the parks. The program was limited to five corporations to allow close management of the program and to minimize potential conflicts with donations tied to advertising at individual parks. A Foundation official stated that they have, however, recently initiated discussions with the Park Service and the Foundation’s Board of Directors about doubling the number of partnering corporations to 10.

Under the Proud Partners Program, the Foundation receives both cash and in-kind donations from corporations. This support is centered on (1) increasing public awareness of the breadth and depth of the parks, (2) engaging the public in support of parks through purchase of the National Park Pass and encouraging voluntary contributions, and (3) providing grants to parks for pilot programs intended to help improve the visitor experience. Appendix IV provides more detailed information on the Proud Partners Program and its related support.

Bulk of Donations to the Foundation Is Restricted for a Specific Use

The bulk of the private donations received by the Foundation is restricted or targeted for specific uses. For example, about $139 million, or 87 percent, of the $160 million in donations that the Foundation received for fiscal years 1999 through 2003 were restricted. Conversely, the Foundation raised $21 million—the remaining 13 percent—in discretionary donations, most of which were used to support systemwide programs. Figure 6 shows the amount of restricted and discretionary donations for fiscal years 1999 through 2003.

The Foundation is also developing procedures to secure more discretionary funds from corporations and individuals. With regard to corporations, the Foundation plans to develop a pool of discretionary donations within each of its five program areas. Corporations can make discretionary donations within these broad program areas that can then be used to support individual park needs. To increase discretionary donations from individuals, the Foundation is exploring various means to better target individual donors. For example, the Foundation and the Park Service are exploring the feasibility of allowing park visitors to volunteer their contact information in order to follow up and ascertain how they can support national parks.

Poor Communication and Documentation Affect Efforts to Assist the National Park Service

Poor communication and documentation problems as well as weaknesses in management oversight hamper the Foundation’s partnering relationship with the Park Service. We identified three factors that contribute to the problems that affect the Foundation’s efforts in assisting the Park Service: (1) no written agreement exists between the Foundation and the Park Service describing the Foundation’s fund-raising strategy and clarifying the roles and responsibilities of each partner, (2) the lack of written agreements on certain fund-raising and donation projects and the lack of effective management procedures to ensure that documentation standards are met, and (3) disagreement about the Foundation’s fund-raising and donation strategy and the objectives of the Proud Partners Program. The Foundation and the Park Service have efforts under way to improve communication and enhance the partnering relationship, but these efforts have not addressed the need for written agreements.

The Foundation and the Park Service Lack Comprehensive Agreement Specifying Their Respective Partnering Roles and Responsibilities

The Foundation and the Park Service have not documented in a written agreement the Foundation’s fund-raising and donation strategy, the roles and responsibilities of the parties to implement the strategy, the approach for accomplishing the strategy, or the specific guidelines and procedures that should be followed to implement the strategy. The lack of a written agreement providing more specificity has created confusion about how the Foundation performs its role of supporting the Park Service. Foundation officials informed us that they view the Foundation’s charter as the overarching agreement between the Foundation and Park Service, and that certain activities of the partners are further documented through standard operating procedures as well as a memorandum of agreement. While (1) the Foundation’s legislative charter provides a basic framework for its fund-raising efforts, (2) the memorandum of agreement addresses advertising and promotional campaigns for Proud Partners, and (3) the Foundation’s standard operating procedures provide direction with regard to grant-making activity, there is no one comprehensive document that clearly discusses the Foundation’s fund-raising strategy, work requirements, and roles and responsibilities of the Foundation and the Park Service in their partnering relationship. The Park Service does, however, enter into detailed written agreements with other nonprofit organizations that include detailed descriptions of the fund-raising approach to be used and the work to be performed by each partner. Park Service headquarters officials said that an agreement, similar to those it requires for other nonprofits, would benefit the partnership with the Foundation and help to minimize confusion on the partners’ roles and responsibilities.

The Foundation and Individual Parks Sometimes Enter into Verbal Fund- raising Agreements

The Foundation and individual parks sometimes rely on verbal agreements in conducting fund-raising, leading to misunderstandings between the Foundation and the Park Service officials regarding the roles and responsibilities that each party is to perform, such as the specific fund- raising objectives and agreed-upon fund-raising actions. Furthermore, neither the Foundation nor the Park Service tracked fund-raising requests or verbal agreements. Thus, neither agency can measure whether performance under these agreements met expectations. We requested the views of officials from all seven regional offices about their relationship with the Foundation. Deputy and associate regional directors confirmed that some field staff are dissatisfied with the Foundation for not keeping its fund-raising promises. For example, some regional Park Service officials told us that they had verbal fund-raising agreements with the Foundation, and that the Foundation did not honor its commitments. In one instance, a Park Service regional official stated that the Foundation agreed to raise $500,000 for a restoration of a historic site in Atlanta, Georgia. The Foundation denied it had made the commitment and attributed the misunderstanding to erroneous information provided by a Park Service headquarters official. Similarly, a Park Service regional official stated that the Foundation had verbally agreed to raise support for the region’s top priority—construction of a Native American memorial at Little Bighorn Battlefield National Monument. In this case, Park Service regional and Foundation officials collaborated on a work plan that identified these priorities for Foundation assistance. However, the support never materialized. According to the Foundation, it was unable to attract sufficient private contributions to implement all of the early phases of its campaign.

Without written fund-raising agreements and a system for tracking verbal agreements, the Park Service and the Foundation cannot ensure proper management oversight that is consistent with sound internal control and management practices. Specifically, internal control standards specify that all transactions and other significant events need to be clearly documented, that the documentation should be readily available for examination, and that all documentation and records should be properly managed and maintained. Other fund-raising efforts on behalf of the Park Service must comply with Director’s Order 21—the Park Service’s guidance on fund-raising and donations—and be authorized in a written agreement. Under Director’s Order 21, fund-raising agreements should include the (1) project or programs to be funded and the priority order of funding; (2) procedures under which the fund-raising will be conducted, including adherence to Park Service policies; and (3) procedure for Park Service review and approval of planning, design, and construction when appropriate. An official from Interior’s Office of the Solicitor told us that this order does not apply to the Foundation given its unique status as a congressionally chartered fund-raiser. Although Foundation officials stated that they comply with the order on a voluntary basis, and that their procedures require written agreements for fund-raising involving specific park projects, we found that there were no written agreements. Foundation officials stated that this is a recent policy and that they have not entered into any local park agreements since this policy was adopted. In any event, the Park Service and the Foundation could improve their internal control procedures by entering into written fund-raising agreements. Doing so would provide a means for the Park Service and the Foundation to improve their management oversight of fund-raising activities.

Some Park Service Officials Disagree with the Foundation’s Fund-raising Strategy and Key Aspects of the Proud Partners Program

There is also disagreement within the Park Service about the effectiveness of the Foundation’s fund-raising strategy for raising funds to support Park Service programs. Some Park Service headquarters officials agree with the Foundation’s fund-raising strategy and the Secretary of the Interior and the Director of the National Park Service serve on the Foundation’s Board of Directors, which approves all fund-raising activities of the Foundation. However, some regional Park Service officials, while appreciative of the Foundation’s support, disagree with the Foundation on its fund-raising strategy and objectives of the Proud Partners Program. With regard to the fund-raising strategy, these officials told us that the Foundation’s strategy should be targeted at the priority needs of individual parks. For example, several regional officials commented that the Foundation’s unfamiliarity with park needs resulted in missed opportunities to solicit contributions for important park projects. In addition, these officials suggested that the Park Service periodically provide its list of individual park priorities to the Foundation for fund-raising consideration. Although the current park priority listing focuses on projects eligible for funding from over 80 federal sources, the officials believe the list could be modified to include projects for which nonprofit funding is needed and appropriate. Foundation officials believe that individual park priorities can be better addressed by local nonprofit organizations. Foundation officials acknowledge that, in some cases, donors are interested in supporting a park priority need that could be viewed as a federal responsibility. For example, one corporation agreed to raise $5 million to support the restoration of the Washington Monument in Washington, D.C.—a project that was on the Park Service’s priority list in anticipation of future federal funding.

Some regional officials stated that some support provided through the Proud Partners Program was unrelated to park needs. For example, one company donated 500 electric vehicles, valued at about $4.2 million, to national and state parks in California, and, according to one Park official, the actual funds would have better met park needs. Park Service headquarters’ officials recognize that much of the Foundation’s corporate revenues are restricted and heavily tied to promotional or advertising objectives, but they believe these contributions have nevertheless provided valuable assistance.

In addition, the Park Service and the Foundation appear to have differing viewpoints with respect to one of the three objectives of the Proud Partners Program. In a May 2001 memorandum sent to the Park Service’s Leadership Council, the Acting Park Service Director communicated to the service’s regions and local park superintendents that the objectives of the Foundation’s Proud Partner Program includes providing “direct support for National Park Service priorities.” According to Foundation officials, the objectives of the Proud Partner Program were designed to support systemwide Park Service programs, not individual park priorities. The Foundation’s published objectives for the Proud Partner Program are to provide servicewide benefits to the park system by (1) raising awareness about the breadth and depth of national parks, (2) generating individual interest and support for parks through sales of the National Parks Pass and encouraging contributions, and (3) piloting visitor experience grant programs to help the Park Service address the challenges of encouraging and providing meaningful park experiences while preserving park resources. In practice, however, the Foundation policy has not always been followed. For example, the Director of the Park Service and the Park Service’s Associate Director for Partnerships, Interpretation and Education, Volunteers, and Outdoor Recreation, recently stated that the Proud Partners Program has supported some local park projects, such as the restoration of the historic fleet of red buses at Glacier National Park at a cost of about $8 million. Such inconsistencies in communication and practice have led to misunderstandings about the kinds of projects the program will support.

Lastly, Foundation and Park Service officials have different views about the exclusivity terms in the Proud Partner agreements. A memorandum of agreement between the Foundation and the Park Service, originally signed in 1994, established policies and guidelines that should be followed in managing commercial advertising and promotional campaigns, such as the Proud Partner Program. Although predating the Proud Partner Program by 6 years, this agreement, along with an earlier internal Park Service memorandum, establishes the Foundation’s responsibility for managing national, cause-related marketing campaigns. The 1994 agreement also stipulates that all promotional and advertising arrangements will be consistent with Park Service policies and provides for Park Service review of promotional material before their public distribution. Additionally, the agreement authorizes the Foundation to sign letters of agreement with corporate partners and to provide product or service category exclusivity.

The issue in question is whether these exclusivity arrangements preclude other nonprofits from making park-based marketing agreements with businesses that promote products or services that fall within the Proud Partners’ categorical areas of operation. Foundation officials advised us that the terms of their agreements with corporate partners do not prevent other Park Service nonprofit partners from negotiating park-based marketing agreements with businesses that provide the same type of product or services as the Foundation’s five national partners. However, the Interior’s Office of the Solicitor officials, along with nonprofit officials with whom we spoke, believe that such park-based agreements are generally prohibited. Under this interpretation, a local friends group at any national park, for example, generally could not negotiate a park-based automotive-related marketing agreement with the Toyota Corporation because the Ford Motor Company is a Proud Partner and has exclusive marketing rights within the automotive product category. Because the Foundation has provided nondisclosure guarantees to its Proud Partners, it does not make the actual terms within the specific agreements between the Foundation and the Proud Partners available for Park Service review (see app. IV for more details).

The Foundation and the Park Service Have Efforts Under Way to Improve Collaboration and Communication

Both the Park Service and the Foundation have several ongoing efforts, which when fully implemented should help address recognized communication problems between their organizations. In April 2003, the Park Service and the Foundation jointly created the Partnership Committee to take actions to, among other things, ensure common, consistent, open, and timely communication between the two entities. This committee, comprised of Park Service headquarters officials and regional directors and Foundation board members and staff, also focuses on achieving shared goals and recommending actions to resolve differences between the two organizations. In addition, the Director of the Park Service and Foundation officials recently agreed to meet monthly to find ways to promote better communication. Although this committee has been formed, it has yet to develop any action plans to address specific communication issues that it has identified.

The Foundation and the Park Service are also taking independent actions to improve communication. For example, the Foundation is providing quarterly reports to the Park Service’s National Leadership Council that provide updated information on the Foundation’s grants, Proud Partners Program, funding, and partnership highlights. The reports are then distributed to all park superintendents, program managers, and other staff in the Park Service. The Foundation also plans to provide briefings to Park Service regional staff that discuss and clarify the Foundation’s roles and responsibilities and fund-raising policies. Similarly, the Park Service established the NPS Partnership Council in 2002 that facilitates open communication and dialogue among the Park Service’s field, regions, and directorate; the National Park Foundation; and other nonprofit partners. The council consists of 24 members, including Park Service headquarters officials, regional directors, and field representatives (preferably at the superintendent level) and a Foundation representative. In addition, Park Service officials said that they were considering a proposal for a general agreement between the organizations to clarify the roles and responsibilities of the Foundation and the Park Service in their partnering relationship.

Although the Foundation and the Park Service have taken positive steps to improve communication, these actions are recent and have not been fully implemented. For example, although the Foundation has recognized the need to provide briefings to Park Service regional officials, the briefings have not been provided to date.

Conclusions

Although the Foundation’s support has contributed to the betterment of the Park System, poor communication between the Foundation and the Park Service has caused confusion regarding how each of the parties is operating in the partnership. Much of this confusion stems from the lack of a written agreement that clearly describes the Foundation’s fund-raising strategy and clarifies the roles and responsibilities of the Foundation and the Park Service in its partnering relationship. Until roles and responsibilities are better defined and policies and procedures are outlined to implement fund-raising efforts, confusion and uncertainty may result and fund-raising opportunities may be overlooked.

The Foundation’s approach to fund-raising for systemwide programs has led some Park Service officials to contend that the Foundation’s support is not being focused where it could do the most good—to better support individual higher priority projects at local parks. Although the Foundation is attempting to increase its discretionary funds that could be used for individual park priorities, the Foundation could also benefit from a list of individual park priorities, which the Park Service has not yet provided.

Some Park Service officials are concerned that the Foundation has not fulfilled its commitments to provide fund-raising support. Without written fund-raising agreements, neither the Foundation nor the Park Service can demonstrate that they met fund-raising commitments and that the agreements were carried out.

The Foundation and the Park Service are embarking on several initiatives to remedy some of these problems, such as providing formal briefings to Park Service regional officials on the Foundation’s roles and responsibilities. Moreover, the Park Service is currently considering the development of an overall written agreement with the Foundation that clearly articulates each party’s roles and responsibilities in the partnering relationship. While these are steps in the right direction, many of these initiatives are still in the initial planning phase. However, the proper implementation of these steps should help resolve the communication problems that exist between the Foundation and the Park Service and strengthen their partnership.

Recommendations for Executive Action

To reduce the confusion and misunderstanding and improve communication between the National Park Foundation and the Park Service, we are recommending that the Secretary of the Interior require the Director of the National Park Service to take the following five steps: work collaboratively with the Foundation to develop an overall written agreement that, among other things, articulates the Foundation’s fund- raising strategy and clarifies the roles and responsibilities of the Foundation and the Park Service in their partnering relationship; identify and document all current and future fund-raising agreements made with the Foundation, specifying the terms of work agreed to by each party; provide a list of individual park project priorities, including those potentially fundable by nonprofits, and communicate them to the Foundation for consideration in fund-raising; develop and implement internal controls such that fund-raising agreements are documented in writing and subsequent performance is tracked against the agreement; and clarify whether the exclusivity terms in Foundation agreements with Proud Partners apply to park-based cause-related marketing arrangements and communicate this information to all of the Park Service’s fund-raising partners.

Recommendations to the National Park Foundation

To improve its communication with the Park Service and improve management controls, we are making four recommendations to the National Park Foundation, namely that it take the following four steps: enter into an overall written agreement with the Park Service that includes its fund-raising strategy and clarifies the roles and responsibilities of the Foundation and the Park Service in their partnering relationship; identify and document all current and future fund-raising agreements made with the Park Service, specifying the terms of work agreed to by each party; develop a process, either through training or briefings, to help ensure complete and consistent understanding of its fund-raising strategy and roles and responsibilities with the Park Service headquarters, regional, and local park officials; and in developing its fund-raising approach, consider the list of individual park priorities compiled and provided by the Park Service—this list could be used for identifying patterns of park needs for systemwide projects as well as for identifying specific needs that may be of interest to potential donors.

Agency Comments and Our Evaluation

We provided a draft of this report to the National Park Service and the National Park Foundation for review and comment. Both provided written comments. The Park Service agreed with the five recommendations we made to the Secretary of the Interior. The Foundation agreed with three of the four recommendations that were directed to it and stated that it is committed to working with the Park Service to ensure the implementation of these recommendations. While the Foundation agreed that close coordination with the Park Service is important, it disagreed with our recommendation calling for the development of a comprehensive written agreement that clarifies the respective roles and responsibilities of the two parties. The Foundation stated that such a written agreement is unnecessary because cooperation is already adequately ensured by its chartering legislation and the positions held by the Secretary of the Interior and the Director of the Park Service, who serve as chairperson and secretary, respectively, on the Foundation’s Board of Directors. Moreover, the Foundation cited that the powers of the board’s chairperson to appoint all board members as an effective means of ensuring cooperation. Finally, the Foundation stated that its recent efforts to consult extensively with the Park Service regarding fund-raising and grant-making, as well as its efforts to create standard operating procedures, underscores the Foundation’s commitment to furthering cooperation between the two entities.

We agree that the Foundation’s charter and the positions held by the Secretary of the Interior and the Director of the Park Service on the Foundation’s board are important elements of coordination between the Foundation and the Park Service. This arrangement is an important part of the Foundation’s governance structure. Because neither the Secretary of the Interior, nor the Director of the Park Service, nor the appointed board members are responsible for, or involved with, daily operational relationships, additional safeguards are needed at the operational levels to help ensure effective communication and working relationships. Although board policies and guidance can facilitate effective communication and working relationships, it is the Foundation’s managers and staff that are responsible for the implementation of such policies and guidance. As our report indicates, implementation can be improved. We continue to believe that a comprehensive written agreement between the Foundation and the Park Service would further enhance communication, working relationships, and management controls at all levels of the partnership. In commenting on the draft report, the Park Service also stated that such an agreement would enhance the communication between it and the Foundation.

The Park Service comments are contained in appendix VI, and the Foundation comments are provided in appendix VII.

As arranged with your offices, unless you publicly announce the contents of this report earlier, we will plan no further distribution of this report until 30 days after the date of this letter. At that time, we will send copies of this report to other interested congressional committees, the Secretary of the Interior, and the National Park Foundation. We will make copies available to others upon request. In addition, the report will be available at no charge on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions, please contact me at (202) 512-3841 or hillbt@gao.gov. Key contributors to this report are listed in appendix VIII.

Scope and Methodology

We examined the partnership relationship between the National Park Foundation (Foundation) and the National Park Service (Park Service), focusing primarily on the Foundation’s efforts to provide assistance to the Park Service in accordance with its stated charter.

To identify the Foundation’s roles and responsibilities, we gathered and reviewed several documents. We reviewed the Foundation’s legislative charter, and its amendments, to identify the purpose for which the charter was established and what functions it is responsible for performing. We discussed the basis and application of the authorities with Foundation and Park Service officials to understand how the Foundation should perform its fund-raising to support the Park Service. We also reviewed the Foundation’s bylaws and the policies and procedures that govern its fund- raising and donation strategies and operations, and we discussed their application with Foundation officials. We reviewed Park Service rules, regulations, and guidance, specifically director’s orders governing fund- raising and donation activities and agreements. We discussed the application of these rules, regulations, and guidance with the appropriate Park Service and Foundation officials to gain an understanding of how they are to be applied to the Foundation’s roles and responsibilities. In addition, we reviewed the Foundation’s strategic plans and 41 existing cooperative agreements between the Foundation and the Park Service or other federal agencies to ascertain the roles and responsibilities contained therein.

We examined Foundation financial and management reports to determine the amount and kinds of donations that the Foundation has raised on behalf of the Park Service. Specifically, we collected, reviewed, and analyzed the Foundation’s audited financial statements for fiscal years 1999 through 2003 to identify the revenues and expenses of the Foundation. From these statements, we identified the sources and amounts of contributions made. We discussed with Foundation officials their fund- raising and grant-making processes and activities, including the Proud Partners of America Program. The Foundation provided us with data describing how the Proud Partners and other grants were allocated within the Park Service. In assessing the reliability of these data through (1) interviews with knowledgeable officials and (2) reviews of existing information, we found problems with the accuracy and completeness of these data. Nevertheless, we determined that the reliability of these data was adequate to describe the grants within the Park Service. We performed an analysis of this information to determine the (1) sources of donations, such as corporations, individuals, or other foundations; (2) amounts received from these sources; (3) types of contributions, for example, cash versus noncash (in-kind); and (4) amounts of contributions that were for discretionary use or dedicated for a specific purpose (restricted). We also developed a list of cooperative agreements using data provided independently by the Foundation and the Park Service. We assessed the completeness of this information by comparing the documentation provided by the two organizations. We collected the source documents for all of the cooperative agreements to ensure the accuracy of the information.

To determine the extent that contributions assisted the Park Service in addressing park priorities, we reviewed the Foundation’s grant awards and available discretionary funds and interviewed Foundation officials about how these funds are raised and used to fulfill individual park requests. We discussed with current and former Park Service officials the support provided by the Foundation. These individuals included officials at Park Service headquarters, regional offices, and some individual park units. We discussed with these officials their views regarding the usefulness of the support provided by the Foundation, such as how the support addressed local park priorities. We did not attempt to track each park’s receipt and use of contributions due to the time that would be required to review such data. We also reviewed internal control documentation standards to ascertain whether the agreements between the Park Service and the Foundation met those standards. Finally, we analyzed the Foundation’s financial statements for fiscal years 1999 through 2003, which received an unqualified opinion by independent auditing firms.

We conducted our work from August 2003 to May 2004 in accordance with generally accepted government auditing standards.

Grants to National Parks as Reported in the National Park Foundation’s GIFTS Database

The Foundation uses its GIFTS database to, among other things, monitor the number of grants awarded to national parks. The information contained in this appendix is based on a query of this database. According to Foundation officials, GIFTS is a newly installed database and does not contain all of the grant information for fiscal years 2000 through 2003. We performed several tests of the database and found that the data were indeed incomplete. For example, although GIFTS includes some information on grants awarded to Glacier National Park for the renovation of its red bus fleet, the database does not contain all grants awarded for this project. Though we found that the data in the GIFTS system were incomplete in our reliability assessment, we present the data in this appendix as background information on grants awarded to national parks. Consequently, information pertaining to grant award amounts and allocations may be underreported.

According to the GIFTS database, for fiscal years 2000 through 2003, the Foundation awarded 768 grants totaling approximately $58 million to support the Park Service. Of this, 610 grants for $32 million went to 210 national parks. In addition, Park Service offices received 88 grants totaling $22 million. The remaining 70 grants went to such entities as foundations, societies, and local friends groups for activities in support of the Park Service. Grants included both monetary and nonmonetary (in- kind) contributions, such as photoimaging equipment and electric vehicles.

The Foundation typically awards grants through a competitive process. Grant applicants must submit proposals for specific funds indicating, among other things, how they plan to use the grant. A selection committee, comprised of Foundation and Park Service officials, reviews all proposals and makes a selection. The committee then presents its selection to the Foundation Board of Directors for approval. To be approved, (1) grant proposals must have gone through the standard review process or be for a grant that a donor has directed for a specific purpose; (2) grant proposals must fall within one of the Foundation’s four program areas—Visitor Experience, Volunteerism, Education, or Community Engagement—or fill a pressing need for the Park Service under the category of Programs of National Significance; and (3) funds must be available. A grant agreement is then forwarded to the recipient for signature, and once it is received by the Foundation, a disbursement is made. The Foundation tracks the grants throughout the process using its GIFTS database. Figure 7 shows the total grant dollars awarded for fiscal years 2000 through 2003 as reported in the Foundation’s GIFTS database and audited financial statements.

The GIFTS database shows that the number of grants awarded by the Foundation significantly increased in recent years. Foundation grant awards doubled from fiscal years 2000 through 2003, from about 120 grant awards to just over 265 grant awards, as shown in figure 8.

For fiscal years 2000 through 2003, the Foundation provided grants to 210 national parks. On the basis of the grants included in the GIFTS data, the top 3 national parks receiving grant assistance during this time were Edison National Historic Site, Glacier National Park, and Yellowstone National Park. These 3 national parks combined received about $13 million, or 22 percent, of the total grant dollars awarded during this time. Edison National Historic Site received the largest grant awarded— approximately $5 million for building restoration. Table 1 provides selected national park grant recipients for fiscal years 2000 through 2003.

Cooperative Agreements and the National Park Pass Contract

Since fiscal year 1997, the Foundation has entered into 41 cooperative agreements with federal agencies that total over $3.1 million. Of these 41 agreements, 37 are with the Park Service, and 4 are with the Bureau of Land Management and the U.S. Fish and Wildlife Service, respectively, to support joint programs between those agencies and the Foundation. Each agreement establishes the responsibilities of the Foundation and its federal partner, specifying the product or service the Foundation must provide as well as the funding the federal partner must provide. These agreements between the Foundation and federal agencies have often been modified and extended. Table 2 provides a detailed list of the Foundation agreements with the Park Service and other Department of the Interior agencies.

Not all of the 37 agreements that the Foundation has with the Park Service have been completed. Park Service contracting officers who are responsible for monitoring these agreements reported that, for those completed, the Foundation successfully met agreement terms. The Foundation also has a contract with the Park Service to administer the National Park Pass Program. This program allows park visitors to purchase a pass, good for 1 year, that allows for admission to parks with entry fees. Current contract terms allow for cost reimbursement for administration, limited to 15 percent of the National Park Pass revenue. In October 2003, the Park Service contract officer expressed concern with the Foundation’s reimbursement request because it exceeded the program budget by over $300,000. Upon review, the contracting officer agreed that most of these costs were appropriate, disallowing about $33,000.

In March 2004, the Foundation and the Park Service signed a general agreement that lays out policies related to cooperative agreements. Among other things, the agreement lists the prerequisites for entering into cooperative agreements. Specifically, these criteria are that the activity covered by the agreement (1) is of a type that is consistent with the mission of the Park Service, (2) is not normally undertaken through a procurement contract, (3) requires the Park Service and the Foundation to be active participants, and (4) is consistent with congressional mandates for both the Park Service and the Foundation. In addition, the agreement details various procedural requirements. Table 2 provides the name of the agreement and information on the original and modifications to it, the product or service to be delivered, and the awarded funding amount for each agreement from fiscal years 1997 through 2003.

Proud Partners of America Program Contributions and Pledges as Reported by the National Park Foundation

The Foundation representatives provided us with data estimating the value of Proud Partners’ contributions that directly benefited national park units. Subsequently, Foundation officials stated these data were not reviewed by management and were inaccurate. They provided new data that made significant changes, including how systemwide and park-specific support was allocated. In assessing the reliability of these data through interviewing knowledgeable officials, we found problems with accuracy. For example, the Foundation had listed about $10 million as a park-specific contribution to Glacier National Park. In reviewing the supporting material for that contribution, we determined that about $2 million of the $10 million was a systemwide contribution. As a result, these data should be viewed as background information on contributions and pledges made under the Proud Partners of America Program.

Under the Proud Partners Program, five large corporations and the Foundation develop a marketing campaign that provides mutual promotional benefits to the Park Service and the corporation. Since the program’s inception in November 2000, the Foundation estimates that partners have provided or committed $93 million to the parks. Foundation data show that about $62 million has been received and used primarily for systemwide ($38 million) and park-specific support ($13 million). Included in these data, as systemwide support, is over $6 million of in-kind contributions for on-air programming featuring individual national parks. For example, Discovery Communications, Inc., donated programming for films on Glacier National Park valued at $630,000, Grand Canyon National Park valued at $1.7 million, and Yellowstone National Park valued at $1,365,000. Foundation officials stated that these films were part of a broader effort to raise awareness about all national parks and were considered systemwide, rather than park-specific support. Proud Partner park-specific support has directly benefited about 190 parks, with Glacier National Park being the primary recipient because of the Ford Motor Company’s red bus renovation initiative.

In addition to providing systemwide and park-specific support, nearly $3 million of the Proud Partner funds supported entities outside of the Park Service, such as other federal and state organizations and nonprofits. For example, Ford’s donation of 500 electric vehicles included 225 vehicles, valued at about $1.8 million, which benefited non-Park Service operations—mostly California state parks. Also, Eastern National, a Park Service cooperating association, received a professional digital camera donation from the Eastman Kodak Company valued at $3,000, and the National Park of American Samoa received photoimaging equipment from Kodak valued at $2,000. The Foundation reports that administrative and fund-raising costs associated with the Proud Partners Program have totaled about $7 million.

The Proud Partner Program is based on the view that large corporate sponsors seek to invest in the positive image, exposure, visibility, and public acceptance that are associated with the national parks. Recognizing this, Foundation staff attempt to customize a promotional program for each partner that meets corporate marketing, philanthropic, and public affairs objectives and that is consistent with the Foundation’s principal program objectives for benefiting the park system.

The Foundation’s Board of Directors plays a key role in developing corporate partnerships. Usually, board members identify prospective partners. They also may contact the corporation directly or facilitate contacts by Foundation staff. Before meeting with a prospective partner, Foundation staff perform research to identify the corporation’s philanthropic and promotional interests. Also, informal discussions may occur among the board, Foundation staff, and the Park Service to ensure that the corporation’s values are in-line with those of the Park Service and the Foundation.

As the process continues, Foundation representatives make a customized presentation to the potential partner. The presentation uses information gleaned from staff research, such as the corporation’s philanthropic interests, and identifies partnering contribution requirements as well as broad program benefits that corporations might expect. For example, if a corporation has a philanthropic interest in education, Foundation representatives would note educational opportunities and needs associated with the national parks. Among the broad benefits, the representatives note that by aligning their corporate image with the popularity of the national parks, corporate sponsors can demonstrate excellent corporate citizenship, increase sales, heighten brand awareness, and target specific markets and consumer demographics. Information on specific program benefits may also be provided during the presentations. Foundation staff point out, for example, that Proud Partners receive the following: exposure through Proud Partner advertising and promotional literature, outreach to park visitors, exclusive advertising and promotional rights, unique hospitality opportunities, and the use of a highly visible Foundation Web site.

As with other Foundation programs and grants, Proud Partners Program initiatives and grants are reviewed and approved by a board committee and require board approval. Grants are expected to align with program objectives identified during a planning process that entails considerable Park Service input. Also, the distribution of partner donations, via grant awards, works much the same as with other Foundation grants, implementing a standard request for proposals process to direct partner support to the parks. At times, a representative of the Proud Partners participates in the review of grant applications.

The Foundation provided us with data describing how the Proud Partners’ contributions were allocated within the Park Service. In examining data provided by the Foundation, we found that it was not clear how these contributions were allocated systemwide versus to specific parks. For example, the Foundation categorized a contribution for filmmaking at Glacier Park as systemwide because it viewed the film as benefiting the whole national park system. We also performed tests to determine the completeness and accuracy of these data and found problems. Due to time constraints, we did not assess the complete reliability of the Proud Partners data. Thus, we present these data in this appendix as background information on contributions and pledges made under the Proud Partners Program.

Table 3 identifies the Proud Partners, the category of product or services they provide, and the term of their agreement with the Foundation. It also shows each partner’s reported total contributions as of June 30, 2003, and estimated contributions over the program’s life. Contributions as of June 2003 do not include $7 million in administrative support contributed by the Proud Partners.

Proud Partners’ support is commonly directed at promoting visitor interest in the parks. However, the support initiatives designed to accomplish this differ markedly from partner to partner. Moreover, while most initiatives are intended to support servicewide benefits, considerable Proud Partner support has benefited individual parks.

TIME magazine, for example, focuses on raising awareness of parks through special magazine features and advertising in its magazine, as does Discovery Communications, Inc., through public service advertisements and television programming. American Airlines supports the objective of generating interest and support for the parks through sales of the Park Pass and encouraging contributions. The airline’s support initiatives include offering frequent flyers extra miles for contributions and providing funding for migratory bird conservation and education projects within national parks. Kodak also promotes Park Pass sales and enhancing visitor experiences. Kodak initiatives include supporting an annual national park photo contest and a national park “photo quilt” on its Web site. Table 4 shows the major Proud Partner initiatives and their estimated value.

The Proud Partner agreements provide considerable support to the Park Service, but the Park Service does not review the agreement and is not a signatory. The Foundation advised us that Proud Partner agreements provided corporate partners with nondisclosure assurances, and that the agreements are kept confidential because of proprietary information contained therein. Instead, the Foundation makes agreements with corporations and then provides the Park Service with information describing the terms of their partnering agreement. The Foundation also provides advertisements and other promotional materials intended to be used for the Proud Partners Program to the Park Service for its review before distribution. The Foundation did not provide agreements to us for our review, but they did provide us with a standard contract template that, according to Foundation officials, is included in each agreement. Although the template does not address financial arrangements or specifically refer to Park Service policies or guidelines, it appears to promote conformity with the Park Service’s advertising and promotional policies.

When the Proud Partners Program was first announced, several Park Service regional directors requested additional information on how the program related to park fund-raising efforts. Park Service and local nonprofit officials also voiced concern about categorical exclusions limiting fund-raising opportunities by other partners without Park Service review of the partner agreements. To date, neither the Foundation nor the Park Service has conducted a formal assessment of the extent to which exclusivity terms that are part of the Proud Partners’ agreements affect local nonprofits. Table 5 provides a detailed list of national parks that have received direct program contributions. The table also contains an unverified estimate, provided by the Foundation, of the value of those contributions ($13 million).

Foundation Compensation

The Foundation’s Board of Directors establishes compensation for the chief executive officer (CEO) on the basis of comparisons with persons in similar positions in big foundations and major nonprofits. The CEO, within the established Foundation budget, sets compensation for the Foundation’s staff. In 2003, the Foundation’s CEO received compensation of $311,000 (excluding fringe benefits). This amount included the following: $51,000—retirement contributions and deferred compensation In fiscal 2002, compensation (excluding fringe benefits) for other senior management staff was as follows: $132,471—senior vice president, marketing and communications $120,743—vice president, field development $87,419—senior director, finance The salaries of executive directors of the Foundation’s affiliated groups in fiscal year 2002 ranged from $84,000 at Outside Las Vegas to $40,000 at the Glacier Fund.

Generally, reasonable compensation is defined as an amount that similar persons in similar positions with similar duties at similar organizations are paid. Although there are no hard-and-fast rules for setting compensation, the Internal Revenue Service applies three conditions when evaluating the reasonableness of executive compensation set by foundations and nonprofits: (1) approval by a board of directors that does not have a conflict of interest with respect to the compensation arrangement, (2) reliance on comparable data such as compensation surveys, and (3) adequately document the basis for the determination concurrently with making the determination. The Foundation has not made its salary information publicly available. The Foundation is exempt from all taxes, and the Internal Revenue Service has issued an opinion that the Foundation need not file a tax-exempt report. The Foundation recently decided that it would file a tax report for fiscal year 2003.

In setting its CEO’s compensation, the Foundation’s Executive Committee relied on a compensation survey published in the Chronicle of Philanthropy that captured CEO compensation (mainly salary) and total assets managed by the organizations. Although the Foundation’s total assets were about $89 million in fiscal year 2003 (revenue was $52 million and program contributions were about $43 million), Foundation officials decided that compensation data from the survey’s list of “Big Foundations” and “Major Nonprofit Organizations” ($500 million to $1 billion organizations) were most applicable to the Foundation. Foundation officials explained that the Foundation provides benefits (including direct grants) of $50 million a year, and that grant-making foundations with $500 million in assets would ordinarily make grants of 5 percent of that amount, or $25 million. On the basis of its comparison with big foundations and major nonprofit organizations, the Foundation’s Executive Board concluded that its CEO compensation was within the correct range.

Table 6 compares CEO compensation among the Foundation and nine nonrandomly selected nonprofit organizations, as recorded on their tax reports. Six of the nine organizations we included had greater revenues and assets than the Foundation; of these six, four compensation packages were below the Foundation CEO’s compensation. Two of the nine organizations had revenue and assets that were below the Foundation’s; both had compensation that was below the Foundation CEO’s. One organization had lower revenues but higher assets. The CEO’s compensation for this nonprofit was below that of the Foundation’s CEO. According to the Congressional Budget Office, the median salary for chief executives at nonprofits with annual budgets of $25 million or more was about $176,800 in 2002. We focused on CEO compensation because, although other employees are hired and can resign or be terminated relatively freely, CEOs are generally hired on a contractual basis and the terms of their employment can vary considerably. In addition, CEO compensation, including CEO nonprofit compensation, has been the subject of considerable scrutiny and criticism in recent years.

Comments from the National Park Service

Comments from the National Park Foundation

The following are GAO’s comments on the National Park Foundation’s letter dated April 22, 2004.

GAO Comments

1. We agree that the Foundation’s charter and the positions held by the Secretary of the Interior and the Director of the Park Service on the Foundation’s board are important elements of coordination between the Foundation and the Park Service. This arrangement is an important part of the Foundation’s governance structure. Because neither the Secretary of the Interior, nor the Director of the Park Service, nor the appointed board members are responsible for, or involved with, daily operational relationships, additional safeguards are needed at the operational levels to help ensure effective communication and working relationships. Although board policies and guidance can facilitate effective communication and working relationships, it is the Foundation’s managers and staff that are responsible for ensuring the actual implementation of such policies and guidance. As our report indicates, implementation can be improved. We continue to believe that a comprehensive written agreement between the Foundation and the Park Service would further enhance communication, working relationships, and management controls at all levels of their partnership. Furthermore, as evidenced by the Park Service’s comments, it also agrees that such an agreement is needed to help improve communications between it and the Foundation. 2. Although we recognize the influences that donors have in directing support provided through the Foundation (see pp. 9 and 38 of the report), we believe that the Foundation’s comments are overall inconsistent with its literature, our prior conversations with its officials, the views of some Park Service regional officials, and our review of Proud Partner Program grants. As stated on page 19 of the report, and supported by discussions with Foundation officials, the literature of the Foundation does not mention providing direct support for National Park Service priorities as an objective of the Proud Partners Program. Moreover, as noted on page 18, this interpretation is inconsistent with views held by several park regional officials who believed that the program should be targeted at securing support for individual park priorities as opposed to systemwide needs. Finally, this interpretation appears incongruent with some grants that have been issued under the Proud Partner Program. As noted on page 19 of the report, our review found that some Proud Partner grants, such as those used to restore the red bus fleet at Glacier National Park, principally appear to support local, rather than systemwide, Park Service priorities. 3. The Foundation takes issue with our mentioning the Glacier red bus renovation as an example of an inconsistency in application of its program strategy. Although we agree that several cited transportation initiatives provided systemwide benefits, most of these initiatives’ support did not provide systemwide benefits. For example, of about 500 electric vehicles donated during the period we examined, 225 went primarily to California state parks (parks not affiliated with the National Park Service). Additionally, virtually all of the 275 electric vehicles donated to Park Service units were directed to park units only in California. Further, the National Park Service Director as well as the Park Service’s Associate Director for Partnerships, Interpretation and Education, Volunteers, and Outdoor Recreation referred to the Glacier bus restoration as supporting a local park project (see p. 19). 4. We do not agree with the Foundation’s position that potential conflicts only arise under circumstances where a park-based project involves a national marketing component. Director’s Order 21 states that when the Foundation has a national cause-related marketing arrangement, this may take precedence over a park-based cause-related marketing effort in the same business category. The order does not specify that the precedence applies only when the park-based project has a national marketing component as interpreted by the Foundation. Further, as reported on page 20, Interior’s Office of the Solicitor officials, along with nonprofit officials with whom we spoke, believe that park-based agreements, in the same business category as a Proud Partner, were generally prohibited. Thus, we continue to believe (1) that there is general confusion in the Park Service, especially in the field locations, regarding the applicability of the Proud Partner exclusivity terms to park-based cause-related marketing arrangements and (2) that the Foundation should help further clarify this issue. 5. Although there is evidence that the Foundation has contributed funding toward renovation of the Ebenezer Baptist Church (a facility within the Martin Luther King, Jr., National Historic Site) and did complete a feasibility study for the Native American monument at the Little Bighorn National Monument, the exact terms and conditions for these two fund-raising efforts is speculative because there was no written agreement. Our point in this section is not whether the Foundation did or did not provide support. Rather, the examples illustrate that verbal fund-raising agreements can lead to disagreements about whether commitments were met. Verbal agreements also provide little means for measuring performance in such arrangements. 6. We agree that the information contained in figure 8 may understate the full amount of grants issued by the Foundation for fiscal years 2000 through 2003. On page 28, we clearly stated that the GIFTS database was incomplete. At the time we completed our audit work, the Foundation had not provided us with information showing the extent to which the database was incomplete. We have revised figure 8 to reflect those total grant amounts contained in the Foundation’s audited financial statements.

GAO Contact and Staff Acknowledgments

GAO Contact

Barry T. Hill (202) 512-3841 (hillbt@gao.gov)

Staff Acknowledgments

In addition to the individual named above, John C. Johnson, Roy K. Judy, Stephanie A. Luehr, Jonathan S. McMurray, Peter J. Oswald, and Amy E. Webbink made key contributions to this report.

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