HR 2395 - 7.19.13



STATEMENT OF STEPHEN E. WHITESELL, REGIONAL DIRECTOR OF THE
NATIONAL CAPITAL REGION, 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. 2395, TO PROVIDE FOR DONOR
CONTRIBUTION ACKNOWLEDGEMENTS TO BE DISPLAYED AT PROJECTS
AUTHORIZED UNDER THE COMMEMORATIVE WORKS ACT, AND FOR OTHER PURPOSES.

July 19, 2013

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Mr. Chairman, thank you for the opportunity to present the views of the Department of the Interior regarding H.R. 2395, a bill to provide for donor contribution acknowledgement to be displayed at projects authorized under the Commemorative Works Act (CWA), and for other purposes.

The Department supports H.R. 2395 with amendments described in this statement.

H.R. 2395 would amend the CWA to allow a display of donors who contribute to commemorative works dedicated after January 1, 2010. The display would have to meet certain criteria and would require the approval of the Secretary of the Interior (Secretary) or the Administrator (Administrator) of General Services. The bill is necessary because the CWA prohibits donor acknowledgement in any manner as part of a commemorative work or its site.

Although the Department has supported the CWA ban on donor recognition; this ban has proven to be impractical, given the challenge of funding new memorials and the reliance of the memorial sponsors on the generosity of the public in order to establish and construct memorials that Congress has authorized. We recognize the importance of acknowledging large donations for effective fundraising and, therefore, support donor recognition with appropriate limitations as described below. We do not support permanent donor recognition.

The Department believes that by promoting a uniform process for donor recognition for all memorial sponsors and ensuring a strong design review of facilities displaying such recognition within the context of the existing memorial approval process, donor recognition can be an appropriate component at memorials and other commemorative works authorized under the CWA. The National Park Service currently has system-wide regulations and policies for donor recognition in National Parks across the country 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, currently applies only to structures and sites that are not part of memorials subject to the CWA. This bill would allow NPS to revise the Mall Donor Recognition Plan to be applicable to structures and sites covered under the CWA. The plan currently provides that donor recognition must be time-limited 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 also currently sets a minimum $1 million donation for such recognition, although we anticipate that this minimum may need to be raised over time through an update to the Mall Donor Recognition Plan. The CWA provides that the Secretary or the Administrator, and the U.S. Commission of Fine Arts (CFA), and the National Capital Planning Commission (NCPC) may develop design guidelines for commemorative works during the design review and approvals process. If donor recognition were to be allowed, we would like to work with you and these commissions on the issues of appropriate location and attributes of the display. We also believe that the timeline for donor recognition should not extend past 10 years.

Furthermore, we believe that the requirement to submit a plan and the notification and resubmittal process are unnecessary as a process for such review and approval currently exists in the CWA. In the current process, the design of commemorative works and related support facilities are considered by the National Capital Memorial Advisory Commission, and reviewed and approved by the CFA, the NCPC, and the Secretary or the Administrator. The review and approval of donor recognition displays 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 in working with the Administrator, the CFA, and the NCPC in drafting revisions to H.R. 2395 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.