By KEVIN NEVERS

For some years the Friends of the Dunes has generated thousands of dollars annually, for use by and at Indiana Dunes National Lakeshore (INDU), in the parking lot of the Dunes Harvest Festival during the third weekend of September, by soliciting donations from attendees as they enter with their vehicles.

The Friends has also supplemented those contributions to INDU by means of a donation box placed at its information booth at other festivals and events in the park.

But now the revision of an obscure document produced by the U.S. Department of Interior, entitled “Director’s Order No. 21: Donations and Fundraising,” has reduced a healthy stream of contributions to a trickle.

Not only have INDU officials, according to their interpretation of Director’s Order No. 21, instructed the Friends, beginning at last year’s Dunes Harvest Festival, to cease soliciting donations in the parking lot, they have asked the Friends as well to remove the donation box from its info booth.

INDU officials have allowed the Friends to retain a donation box at the contact station, located on the way to the Bailey Homestead, and another at the Chellberg Farm office. But those boxes, Friends Board of Directors Chair Don Mohar said when contacted by the Chesterton Tribune, only raise around $20 during events, compared to the $300 or $400 raised by the box at the info booth.

More troubling for Mohar is the “tremendous” loss of contributions during the Dunes Harvest Festival, the Friends’ major fundraiser of the year. Typically, he said, the Friends collected “thousands of dollars” in the parking lot over that weekend to be used for INDU programming. Now, Mohar projected, the Friends may only be able to collect a few hundred dollars annually on behalf of INDU.

Director’s Order No. 21

In instructing the Friends to cease soliciting donations in the parking lot, INDU officials cited Sec. 2.2 of Director’s Order No. 21: “It is (National Park Service) policy that its employees not solicit donations. The term ‘solicit’ means any request by an NPS employee to a non-federal entity, group, or individual for donations to be made directly or indirectly to the NPS in support of its programs.”

Mohar, though, disputes the relevance of Sec 2.2. For one thing, he said, the language specifically refers to NPS employees, which Friends volunteers are not. Sec. 5.2 of Director’s Order No. 21, moreover, specifically authorizes fundraising partners, such as the Friends, to “work with a park or other organizational unit to engage the public in philanthropy to benefit NPS programs.”

In any case, Mohar noted, in Sec. 1.2 Director’s Order No. 21 acknowledges “that each park and partner is unique and that a ‘one size fits all’ approach does not work.”

Mohar emphasized that the donations solicited in the parking lot of the Dunes Harvest Festival were in no way admission fees and that anyone who declined to make a donation for any reason was perfectly free to enter the festival site.

INDU officials, however, have reached an altogether different interpretation of Sec. 2.2, said Bruce Rowe, supervisor of interpretation at INDU. Under their reading of Director’s Order No. 21, “nobody, not the Park Service, not a partner, not anybody, can solicit for donations on park land. There is language allowing for donation boxes but not personal solicitations.”

Acting INDU Superintendent Gary Traynham subsequently confirmed that interpretation with the National Partnership Office in Washington, D.C., the arbiter of Director’s Order No. 21, Rowe added. Traynham was told that the document does in fact prohibit the collection of donations in the parking lot during a festival or event “so that people don’t feel like they’re being coerced to pay for entry.”

Sec. 6.3.1 of Director’s Order No. 21, on the other hand, clearly allows for the installation of donation boxes, provided that “100 percent of the donations or collections go to the NPS” and that the boxes “be placed only on NPS property.” But Sec. 6.3.1 is silent on the location of those boxes. Even so, Rowe said, Sec. 2.2 was interpreted as applying not only to the solicitation of donations in the parking lot but to the placement of a box at the info booth. INDU accordingly instructed the Friends to remove that box.

Rowe did note that the National Partnership Office could at some future point reinterpret Director’s Order No. 21—if a number of parks, like INDU, “have an issue” with the policy—but that at the moment matters stand where they stand.

The Visitor Center

Meanwhile, Mohar has one other bone to pick with INDU, namely, that the NPS is distributing materials produced with funds provided by the Friends at the Dorothy Buell Memorial Visitor Center, which INDU operates jointly with the Porter County Convention, Recreation, and Visitor Commission.

Under an agreement with the Friends, Mohar said, INDU is supposed to expend those funds “only to support programs and activities at the National Lakeshore.” But because the Visitor Center is located not on park property, but on land owned by Porter County, he feels that INDU is at the very least violating the spirit of its agreement with the Friends.

“I’ve heard that concern,” Rowe said in response. “The Visitor Center is obviously not on park land. But everything distributed by INDU at that facility is for visitors who can use the park itself. The materials are meant to assist people in using the park safely.”

“I can certainly see how it could be interpreted differently,” Rowe added. “But that’s our interpretation.”

The Friends of the Dunes is a private, not-for-profit organization established in 1982 to assist both INDU and Indiana Dunes State Park with their programs, activities, and research.

Posted 3/15/2007