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H.R. 588: A bill to provide for donor contribution acknowledgements to be displayed at the Vietnam Veterans Memorial Visitor Center




STATEMENT OF DR. HEBERT C. FROST, ASSOCIATE DIRECTOR, NATURAL RESOURCE STEWARDSHIP AND SCIENCE, NATIONAL PARK SERVICE, DEPARTMENT OF THE INTERIOR, BEFORE THE SUBCOMMITTEE ON PUBLIC LANDS AND ENVIRONMENTAL REGULATION OF THE HOUSE NATURAL RESOURCES COMMITTEE CONCERNING H.R. 588, TO PROVIDE FOR DONOR CONTRIBUTION ACKNOWLEDGEMENTS TO BE DISPLAYED AT THE VIETNAM VETERANS MEMORIAL VISITOR CENTER, AND FOR OTHER PURPOSES.

 MARCH 14, 2013

Mr. Chairman, thank you for the opportunity to present the views of the Department of the Interiorregarding H.R. 588, a bill to provide for donor contribution acknowledgements to be displayed at the Vietnam Veterans Memorial Visitor Center, and for other purposes.

The Department supports H.R. 588, as amended in accordance with this testimony.We strongly recommend that this legislation be broadened to provide a donor recognition policy for commemorative works on lands under jurisdiction of the Commemorative Works Act (CWA). We would like to work with the committee, the U.S. General Services Administration, the U.S. Commission of Fine Arts, and the National Capital Planning Commission on amendments to the bill.

H.R. 588 would amend the legislation that authorized the Vietnam Veterans Memorial (P.L. 96-297) to allow a display of donors that contributed to the Vietnam Veterans Memorial Visitor Center.The display would have to meet certain criteria and would require the approval of the Secretary of the Interior.This legislation is necessary for a display of donors to be allowed because Congress directed, in P.L. 108-126, that the Vietnam Veterans Memorial Visitor Center be constructed in accordance with the CWA (40 U.S.C. Chapter 89),and the CWA (40 U.S.C. 8905(b)(7)) forbids donor acknowledgement in any manner as part of a commemorative work or its site.

The CWA prohibition on donor recognition helps preserve the unique civic character of Washington's public realm, including commemorative works. Memorials honor events and figures of national significance and are often located in prominent historic and cultural settings within the nation's capital. Through the design process outlined in the CWA, we work with Congressionally-authorized sponsors to build memorials that appropriately convey commemorative themes and subjects for the benefit of all Americans. Donor recognition at a memorial site may detract from the memorial's design, historic setting and narrative. For these reasons and to promote fairness and parity in the process, we believe the CWA provision prohibiting donor recognition in a permanent manner has merit and changes to this provision should be undertaken thoughtfully.

However, the Department acknowledges the challenge of funding new memorials. Given the reliance of the Congressionally-authorized memorial sponsors on the generosity of the public in order to establish and construct memorials that Congress has authorized, the Department recognizes the importance of acknowledging large donations for effective fundraising, and believes that donor recognition may be appropriate with specific guidelines.

To promote a uniform process for all memorial sponsors and to ensure a strong design review, a change of guidance related to donor recognition should be carefully considered more broadly for all memorials under the CWA rather than by individual memorial exception. Any proposed changes should conform to all applicable guidelines for donor recognition, including but not limited to National Park Service Director's Order #21, the National Park Service Management Policies 2006, and the National Mall and Memorial Parks Donor Recognition Plan (Mall Donor Recognition Plan).

The Mall Donor Recognition Plan, adopted in 2011, applies only to structures and sites that are not covered by the CWA.The plan provides that donor recognition must be located on the interior of a facility, must be temporary and non-structural, must not detract from the visitor experience, and must not be affixed to historic structures or museum collections, benches, park furnishings, bricks or plantings.The plan currently sets a minimum $1 million donation for such recognition, although we anticipate that this minimum may need to be raised over time.

Should the committee consider legislation that permits recognition of large donations for the Vietnam Veterans Memorial Visitor Center and future commemorative works on lands under jurisdiction of the CWA, we recommend that the committee consult with the Department and the other agencies with responsibilities for commemorative works to develop appropriate guidelines for donor recognition.Other agencies to consult include the U.S. General Services Administration, the U.S. Commission of Fine Arts, and the National Capital Planning Commission.

We believe that the following should be considered in the development of the guidelines for donor recognition for commemorative works:

·appropriate location for the donor recognition;

·attributes of the display, whether physical or digital (such as a discreet statement or credit acknowledging the contribution, appropriately scaled for the setting and the commemorative work);

·a requirement that the donor recognition is temporary and is displayed for no more than five – ten years; and

·a requirement that the display does not include any advertising slogans or company logos.

Should the Congress move forward with a version of H.R. 588, the Department believes that certain specific provisions for approval of donor recognition in H.R. 588, in particular, subparagraphs (D), (E), (F) and (G) of amended section 40 U.S.C. 8905(b)(7) (from page 3, line 4 through page 4, line 8) are unnecessary. This approval process, as described, would be redundant to the approval process already required by the CWA for the approval of the design of a memorial, and specifies an approval time frame that is unworkable. The Department strongly supports the current process as required by the CWA by which the design of commemorative works and related support facilities are considered by the National Capital Memorial Advisory Commission, reviewed and approved by the Commission of Fine Arts, the National Capital Planning Commission and the Secretary of the Interior. The review and approval of donor recognition displays within the National Mall and Memorial Parks can be seamlessly integrated with the existing approval process for commemorative works because these displays would be part of the plan of the memorial and its site.

The Department would be happy to assist the committee working with the U.S. General Services Administration, the U.S. Commission of Fine Arts, and the National Capital Planning Commission, in drafting revisions to H.R. 588 in accordance with this statement.

Mr. Chairman, this concludes my testimony. I would be glad to answer any questions that you or other members of the subcommittee may have.