I wrote and illustrated a children’s called Star Wars Camping Adventures. Go read it!
I wrote and illustrated a children’s called Star Wars Camping Adventures. Go read it!
National parks are cherished for their wilderness value, but visitors may reasonably expect to see any number of non-natural scenes. Well-maintained trails make the wilderness accessible. Rangers at visitor centers tell us where to begin exploring. Historic markers speak of those who came before us.
However, there are non-natural scenes that visitors do not expect to see: Logo-emblazoned informational kiosks. Theaters named in honor of corporate donors. Corporate logos in park brochures.
The National Park Service (NPS) has proposed a new version of Director’s Order 21 (DO-21), which would potentially allow all these things.
National Park Service (NPS) operations are governed by everything from the loftiest tenants of Constitutional law to the sleep-inducingest memoranda on interim policy guidance. Between those poles lie a set of documents called Director’s Orders. According to NPS, Director’s Orders are “operational policies and procedures that supplement” the agency’s management policies.
Director’s Orders cover everything from housing management to law enforcement. These orders are periodically updated as circumstances dictate. DO-21 is the order that covers fundraising and donations — or “philanthropic partnerships,” to borrow language from the proposed update.
The short answer: Because circumstances dictate.
There are many circumstances that seem to have prompted this update. Not least among them is a nearly $12 billion backlog of deferred maintenance. These are maintenance projects NPS simply cannot afford to complete on its annual Congressional appropriation of $2.6 billion. It’s obvious why fundraising would be important to NPS and its affiliated nonprofit partner organizations.
According to the nonprofit group Public Employees for Environmental Responsibility (PEER), the revision would:
It would also allow:
Of the proposed changes that have received press attention, I generally think they are a bad idea. I submitted the following public comments on the proposed revision to DO-21:
Thank you for making available the draft version of Director’s Order 21 and allowing the public an opportunity to comment. Partnerships and philanthropy are undoubtedly an important part of the National Park Service’s future. Because NPS has worked hard to foster positive relationships with park partners, the open and protected status of our public lands enjoys greater certainty than it otherwise would.
I also appreciate NPS’ willingness to further develop its relationships with philanthropic partners. Many elements of the proposed update to DO-21 are reasonable and necessary to keep pace with the changing landscape of fundraising. For example, it makes sense to explicitly allow crowd funding campaigns, at least by nonprofit park partners. However, several elements of the proposed update to Director’s Order 21 represent an unwise step toward the unnecessary commercialization of public spaces. There is no need to open up our park units to the additional presence of corporate logos. The Park Service itself states the case on its website:
“Most institutions that attract significant donations insist on equity in recognizing corporate gifts alongside individual and foundation gifts by using the same typeface and not displaying the donor organization’s copyrighted script or logo. This affords equal recognition for donors and avoids corporate branding or the perception of commercialization. This is the direction that the NPS has chosen based on concerns that parks remain a refuge from corporate branding which is otherwise so pervasive in our society. This still leaves many opportunities for vital corporate partnerships in support of parks.” (Source)
The text is clear: There are still “many opportunities for vital corporate partnerships” without opening the door to a flood of logos. The increased presence of corporate logos in our parks will invariably cause a perception of commercialization.
The new version of DO-21 represents an extreme departure from this philosophy. Although the existing version of DO-21 allows corporate logos and name script in credit lines, it also includes clearly defined limitations on where and how these credits may be displayed. Under the old version of DO-21, corporate logos and name script may not appear on kiosk casings, as digital graphics or overlays present in the main body of a presentation, or on signage that persists after work has been completed on a project. Corporate logos and name scripts may not appear on any donated or donor-funded items.
The proposed text jettisons all of these restrictions. Corporate branding could appear on “temporary” signage that persists for years after the completion of a construction project. It could appear as an intrusive graphic or a persistent watermark visible throughout the entirety of a digital media presentation. It could appear on the body of an informational kiosk. It could be emblazoned on donated items and donor-funded items.
These sensible restrictions should remain intact in the new version of DO-21. Please amend the updated version of DO-21 to retain the existing limitations on the display of corporate logos and name script.
The naming of interior spaces and other park facilities is another step in the wrong direction. The 2008 version of DO-21 specifically prohibited such naming rights. The proposed version of DO-21 represents a 180-degree about face from that prudent restriction. It is simply impossible to avoid the perception of commercialization when visitors are directed to a (hypothetical) “Anheuser-Busch Theater, located within the visitor center.”
These are common spaces owned by the American public and open to the world. They should not be named after corporate sponsors. Doing so erodes the public’s ability to understand that our national parks are held in equal measure by and for all of us. When the public loses sight of this truth, the long-term viability of our national parks is compromised. Parks and park facilities should not be perceived as beneficent gifts from a magnanimous few.
The public perception of the Park Service’s integrity is susceptible to further erosion when a donor with naming rights is involved in scandal or corruption. Indeed, the proposed version of DO-21 specifically allows the Park Service to accept donations from (and therefore grant naming rights to) entities that NPS or DOI is litigating against.
Imagine the perception the public would have had if, fifteen years ago, they visited an “Enron Learning Center” in a national park. There is precedent for this kind of PR disaster: In 2002, the Houston Astros paid $2.1 million to buy back the naming rights for what was then known as Enron Field. Under a worst case scenario, you could have an “American Lands Council Welcome Kiosk” within a visitor center while at the same time the ALC is suing the DOI or NPS over land use or land ownership issues.
I urge NPS to continue its existing policy which forbids the naming of rooms, features, or park facilities as a form of donor recognition.
I also urge NPS to reverse course on their willingness to accept donations from parties that are fighting the Department of Interior or any DOI agencies in court.
NPS should also reverse course on their willingness to accept quid-pro-quo advertising agreements. Such agreements are explicitly authorized in section 6.5 of the proposed update to DO-21:
“Financial Support: A financial sponsor pays a set amount of money in exchange for benefits outlined in a sponsorship agreement. Examples of benefits include an advertisement or mention in event programs, NPS or philanthropic partner newsletters or press releases; signage; or logos on promotional materials.”
These agreements seem to be prohibited by 36 CFR 5.1:
“Commercial notices or advertisements shall not be displayed, posted, or distributed on federally owned or controlled lands within a park area unless prior written permission has been given by the Superintendent. Such permission may be granted only if the notice or advertisement is of goods, services, or facilities available within the park area and such notices and advertisements are found by the Superintendent to be desirable and necessary for the convenience and guidance of the public.”
Any advertisements and there can be no doubt that naming rights and a quid-pro-quo agreement for logo display are indeed advertisements would seem to fall afoul of this regulation. Any notices and advertisements must be both desirable and necessary for both the convenience and guidance of the public.
Even when logo recognition is desirable, it is not strictly necessary. And I can imagine no case where public convenience and guidance are both served by the display of a corporate logo within a park unit.
If the public loses trust in the integrity of NPS and its leadership, the organization will begin its next century of service with an uphill battle to preserve and our public lands. Please do not take any steps that would erode public confidence in the Park Service the revisions to DO-21 have received little press, but almost all of it is negative. As press coverage continues to grow, it will invariably become more negative as the details of this revision become better known.
The legislation that allowed changes to donor recognition was tucked away at the end of the 2015 National Defense Authorization Act. At what point in the legislative process was this added to the NDAA? Suppose that it was inserted at the last minute without meaningful debate. Would eleventh-hour legislative sleight-of-hand inspire public confidence in the good-faith actions of the Park Service?
And although it explicitly provides for certain types of recognition, it is not even clear to me that section 3054 of the 2015 NDAA actually authorizes NPS to recognize donors with room naming rights. Indeed, it explicitly forbids “naming rights to any unit of the National Park System or a National Park System facility, including a visitor center.” There is nothing to indicate that Congress intended any exceptions to this prohibition.
Are rooms and displays within a visitor center or other building not also facilities in and of themselves? The theater at a visitor center is a theater facility. An interpretive exhibit is an educational facility. A broom closet is a janitorial facility. (It seems clear that the “Rubbermaid Broom Closet” would be an example of a facility naming that Congress intended to forbid.) A quick Google search for the phrase “room facility” will confirm that the use of the word “facility” is commonly used by English language speakers to refer to interior spaces. If there is any doubt, consider the fact that “facilities” is often used as shorthand to refer to restroom facilities, which are generally located in interior spaces. The point here is that the prohibition on NPS “facilities” is not limited strictly to building names.
The appendix to the revised version of DO-21 contains definitions for important terms. However, the word “facility” is missing from the definitions list. The appendix should include a definition of “facility” that is consistent with its common use: “space or equipment necessary for doing something,” and “an amenity or resource.”
Finally, it is worth considering the draft version of DO-21 in relation to the recommendations from the National Park System Advisory Board report “Toward a New Era of Philanthropy and Partnerships.” The report identifies four areas for improvement, including “increasing diversity and inclusion.” I can find nothing in DO-21 that appears intended to address this issue. DO-21 should include language that encourages NPS to create and foster partnerships that will increase minority representation among park visitors, volunteers, donors, and other stakeholders. It should also direct NPS to periodically undertake a review that evaluates the success of such efforts, or to perform that evaluation as a part of diversity reports that are already planned.
I am sincerely thankful for the Park Service’s ongoing efforts to increase stakeholder diversity. I understand that outreach coordinators working at various park units are working to improve visitor diversity, and I know that there is also a high-level commitment within NPS to fully represent the ethnically and culturally diverse nature of the American public.
Because NPS takes these concerns seriously, I suggest that decision-makers carefully consider the implicit messages that may be broadcast if corporate logos are allowed to proliferate. Consider that park visitation is disproportionately white, and that the generosity of prospective corporate partners might correlate with their customers’ tendency to visit parks. Under such a scenario, park units might see a proliferation of logos that underrepresent the interests of minority consumers. Visitors might misperceive an implicit message that national parks are not or should not be important to minority consumers.
I understand that our national parks are desperately underfunded. I understand that our parks have an enormous backlog of deferred maintenance. But the value of the public perception of the Park Service far eclipses the dollar value of this much-needed maintenance.
The new version of DO-21 focuses far too much on sweeping changes and quid-pro-quo arrangements that erode the public’s goodwill toward NPS. Substantial revisions need to be made, and they need to focus on sensible implementation of incremental changes. I previously mentioned the explicit allowance for crowd funding projects by park partners. This is a great idea — but shouldn’t it be spelled out in greater detail? What if only a mere three percent of net revenue from a crowd funding project was donated to NPS? There need to be guidelines in place that allow the Park Service to define what is actually a helpful project, and what is in essence an excuse for a corporate donor to affix their reputation to that of the Park Service.
Thank you for the opportunity to submit comments, and thank you for their consideration. I look forward to seeing what changes are brought as a result of public involvement, and I am optimistic that the final version will be better because of it.
Policy documents and reports:
Remarks from conservation and advocacy groups:
In 2012, I launched a Kickstarter project called Greetings from the Back of My Van. While traveling across the country in my Vanagon, I sent original postcards and letters to project backers. I originally created this website as a place to display all of the artwork and writing that I sent to project backers: I registered the domain name and got set up with a hosting provider on a 3G connection near Bryce Canyon, created the Kickstarter pitch video near the banks of the Mississippi River, and posted project updates from across the Upper Midwest and American West.
Since the conclusion of the project, the website has grown as I’ve added content from other projects. I continue to make the occasional custom postcard and post those online as well. This project page is an archive of the creative work I did for Greetings from the Back of My Van.
Here’s the project page on Kickstarter.
The links below will take you to backer rewards and other stuff that I created as part of this project. The archives are broken down by product type. The net result was hundreds of postcards and letters, as well as some side projects and travel dispatches that happened along the way.
These mostly chronicled my travels in the Upper Midwest.
I sent out jumbo-size collage postcards in a couple different batches. The first postcards were created and written in South Dakota, Wyoming, Colorado, Utah, Nevada, and California. The first batch also incorporated some found materials from earlier in the trip (for example, the Wisconsin-themed giant postcard). The second batch was created and written in Eastern Oregon.
The letters I sent were more than just text. They included comics and drawings, pasted-in ephemera, and a few random collages here and there.
And here is some postcard stuff that didn’t fit under the other categories:
When my travels were interrupted by a wild pig attack, I was stuck in Northern California while I recovered. During this time, I had the opportunity to conduct a couple interviews at the Charles M. Schulz Museum and Research Center.
Finally, I posted sporadic travel updates on this website. I’ve listed them here in chronological order, grouped by place:
Sunset near Newberry Crater
The view from Paulina Peak
Crater Lake Dispatch
High desert country: Hart Mountain National Antelope Refuge
Frenchglen: 80 kilometers of bad roads pay off
Steens Mountain: Yow
The Alvord Desert
The pitch video was well-received. I launched the project expecting it to receive minimal interest. Instead, I sold out of all my rewards a little over a week after launching. The actual postcards and letters also worked out well: My cut-and-paste collage skills improved over the course of the project, and writing to strangers forced me to frame my experiences in a different way.
It also kept me writing at a pace that I hadn’t ever sustained before. Last winter I transcribed everything I wrote during my travels, and it worked out to over 200,000 words — that’s 200 single-spaced pages. A lot of that was from my journals, which wound up serving almost as a rough draft for much of what I sent to project backers. In the process of writing, I would recognize what made for a good story, what didn’t, and what could actually fit on the back of a postcard.
Postcards are little travel haikus. Space constraints meant that I couldn’t give a full account of any place or event. I described my experiences by conveying a few select details of that experience. It also encouraged me to focus on “smaller” experiences that could be more succinctly recounted.
Conversely, the longer letters afforded more space and more flexibility. I could actually draw things on the bristol board I was using for letters. If I had to redo the project from scratch, I would place more emphasis on the letters: Drawing little mini-comics allows me to tell stories that I just can’t tell in postcard form. In retrospect, more letters and fewer postcards also would have struck a better balance in content.
The project hit a couple of major snags along the way: My transmission failed, and I got attacked by a wild boar.
The first snag was rectified with the purchase and installation of a new transmission. I borrowed shop space from my former neighbors in Iowa and swapped in the new unit on my own. I had never done anything like that before, and it was super gratifying.
The second snag was worse. Wild pigs have tusks, and above their tusks they have a pair of specialized teeth called whetters. “Whetters” is shorthand for “whetstones.” Every time the pig closes its mouth, it sharpens the tusk on its lower jaw against the whetter on its upper jaw. Pigs attack by lowering their heads, charging, and slashing upward. These attacks are characterized by injuries to the victim’s lower extremities.
The medical literature describes what happens next: “This repeated nature of attack continues till the victim is completely incapacitated due to multiple penetrating injuries, which can have a fatal consequence.” Most fatal pig attacks are a result of head trauma or evisceration that occurs after the victim is felled. I am happy to have escaped with “extensive bilateral lacerations to the lower extremities.”
So, after a chance encounter with a wild pig, that’s how I found myself on the ground looking at about twelve inches of exposed shinbone on each leg. I’m extremely grateful to my dog Kaida, who held the pig off long enough for me to get up and get out. I was trying to save her; she wound up saving me.
After I hobbled off, the pig charged Kaida and severed one of her jugular veins. She was lucky to survive. I was in the human hospital in Santa Rosa, California for three days. Kaida was in the animal hospital a little longer than that.
In one of my project updates, I wrote that I was looking forward to writing about the pig attack in my letters. This was a blatant lie. At one point in the hospital, I spent several hours staring at a blank sheet of paper, not knowing what to write and not wanting to write it. My journal contains no more than a few brief sentences about the pig attack. I have spent far more time reading medical literature and case studies about other people’s pig attacks than I have writing about my own.
I spent several weeks in the Bay Area while I recovered from the attack. I was walking ten miles at a time within a couple of weeks, albeit with pretty significant swelling. Other than the scars, things were mostly back to normal within six months of the attack. Dreams and nightmares about wild pigs have become less frequent over time.
At any rate, this had the effect of pushing my schedule back somewhat. My advice for anyone starting a Kickstarter project is to avoid wild animals.
My favorite thing about this project is that it took me to Portland, Oregon, where I met my wife. And she took me to the Grand Canyon, where I live today.
I have a friend named Flink. We send each other stuff in the mail. In 2012, I started work on an enormous letter to him. I call this project the Great Big Letter. Various parts of the Great Big Letter were written at various times between 2012 and 2015.
The postcard above — written in late 2011 and announcing a hot new missive arriving in your mailbox sometime before 2014 — assumed a lengthy but somehow still wildly optimistic timeframe. This estimate was based on a previous Very Long Letter I had written to Flink over the course of several months in late 2010.
The Very Long Letter of 2010 was somewhere north of 100 pages. The Great Big Letter contains over 160 pages of text, and almost as many pages of collage. It was a different writing process.
The end result was a disgusting-looking ball of paper. So I scanned every page, printed the letter, and neatly bound it. The finished product is a thick brick of text that doubles as a doorstop.
I’ve posted a few snippets from the letter on Fully Psyched, and will likely be posting a few more every now and again. You can view all these excerpts by going to the category page for the Great Big Letter.
When I lived in Iowa, I lived in a rural area. When I moved to Seattle I couldn’t take the soundscape with me, so I recorded it. Here it is: bugs and birds and frogs and the occasional distant truck. Enjoy.