Pew Offers Feedback to National Park Service Director on Proposed Policy Changes

On May 16, 2016, Marcia Argust, director of Pew’s initiative to restore America’s parks, submitted written comments to the National Park Service regarding Director’s Order No. 21. Pew hopes the director’s order will facilitate more opportunities for public-private partnerships to address the estimated $12 billion backlog of deferred maintenance projects within the National Park System. 

Pew’s Letter to National Park Service Director Jonathan Jarvis 

Dear Director Jarvis:

The Pew Charitable Trusts welcomes the opportunity to express our views on the National Park Service’s proposed revisions to Director’s Order #21, relating to philanthropic partnerships. Pew encourages public-private collaboration that may help ensure our National Park System is adequately prepared to maintain, protect, and interpret the agency’s tremendous inventory of assets for generations to come.

It is imperative, however, that implementation of this Order not be viewed as rationale to decrease federal appropriations for the National Park Service (NPS), the primary source of funding for the agency. With that caution, we recognize there may be opportunities to leverage and supplement, not replace, congressional support. We recognize and appreciate that it is the intent of the proposed revisions to Director’s Order #21 to provide such opportunities. Several specific suggestions and concerns follow.

By its own estimate, NPS has a deferred maintenance backlog of nearly $12 billion. The Director’s Order should provide more guidance to NPS managers about including deferred maintenance needs as criteria when evaluating philanthropic arrangements. Without more guidance, maintenance needs that are critical to the health of a park unit, but not necessarily visible to the public or of interest to a potential donor, may remain neglected. Specifically,

• Section 3.1.3, Authorized Employees. Line 189, subsection a) should be modified to state, “Identify NPS projects, including deferred maintenance projects; programs; activities; or objectives suitable for philanthropic support.”
• Section 3.1.7, WASO Division Chief, Office of Partnerships and Philanthropy. We urge adding a bullet stating that the Division Chief will “Encourage philanthropic partnerships and donations that address deferred maintenance projects.”
• Section 3.1.11, Superintendents and Section 3.2, Philanthropic Partners. The respective requirement that superintendents and philanthropic partners will “develop an annual work plan with the philanthropic partner/the park superintendent based on the identified needs of the park and program areas” should include language stating the work plan will lay out how future maintenance needs will be handled.
• Section 4.3, Fundraising Campaigns. A subsection (e) should be added that states, “Consider projects in the deferred maintenance backlog.”
• Section 5, Donor Review. We urge the addition of a bullet that states, “Ensure the broad array of park needs are equally attended to.”

NPS managers should evaluate philanthropic partnerships for opportunities to repurpose existing facilities and/or assets, before considering the construction of new facilities.

• Section 4.2, Use of Donations. Subsection 4.2(b) should reference the guidance in Section 7 in more detail and explain that the existing NPS Partnership Construction Process will be invoked for philanthropic partnerships that involve construction. We suggest that Section 4.2(b) indicate that scrutiny will be given to new construction proposals to evaluate if existing NPS facilities could be used—with renovation and/or modification—in lieu of constructing new assets.
• Section 7, Partnership Design and Construction Projects. This section should do more to highlight the importance of the sustainability of existing park resources and assets, as well deferred maintenance needs. We suggest that lines 966-969 be modified to include a statement that NPS will consider the use/repurposing of existing assets before considering the construction of new assets as part of a philanthropic partnership.
• Section 7.1, Design Competitions. Another bullet should be added that states, “That new construction is warranted, and there are not already existing constructed assets that could serve the needs of the philanthropic partnership.”
• Section 3.1.12, NPS Partnership Council. The NPS Partnership Council should include the Chief Financial Officer, to ensure full consideration of financial and contract issues in philanthropic partnerships.

Again, we appreciate the need for NPS to seek new and nimble sources of supplemental funding. We are wary of the additional time constraints Director’s Order #21 may place on NPS managers and hope that other key aspects of their jobs—the protection of natural, historic, and cultural resources, planning and management, and interpretation—do not fall behind because of increased requirements that may not be matched with increased staff capacity.

Thank you for your consideration of our comments.

Sincerely,

Marcia Argust

Director, Restore America’s Parks, The Pew Charitable Trusts