MA Forest and Park Friends Network response to the draft "Volunteer Policy"

This letter was distributed by the Massachusetts Forest and Park Friends Network:

Dear Friend,

In November 2007, Governor Patrick signed into law a bill which was intended to provide insurance coverage for Friends groups' and other volunteers on properties managed by DCR. We think you will agree that the Draft Volunteer Policy presented by DCR lacks the support we anticipated with the passage of the Act Relative to Volunteers at State Parks. We've compiled some key points brought forward by Friends, which may help you form your own evaluation.

Volunteer Liability Draft Concerns

Part I Section C - Activities Volunteers May Not Perform
Volunteers often use power tools to help maintain trails. The draft policy prohibits 

“Operating personal or Nonprofit Organization owned power equipment such as chainsaws, unless expressly authorized by DCR in a Stewardship Agreement.”

• Will we need a special agreement to use vacuum cleaners, power drills, and leaf blowers?
• What conditions will the Stewardship Agreement set for the authorized use of power equipment by volunteers?
• How will authorization be accomplished? Who determines who may or may not use a power tool?
• Will this condition stop all volunteer use of power tools when the Volunteer Policy is adopted?
• If so, wouldn't it be best to determine how power tool authorization will happen before the Policy is adopted?
• It took over 3 years for DCR to write the Draft Volunteer Policy. How long will it take to draft out the authorization policy?

Part I Section D - Facility Staff Responsibility 

• Since park supervisors will be "responsible for assisting with the development of Volunteer Project Description Forms" and now "supervise, train, and coordinate Volunteer activities`", will DCR provide paid staff at Friends groups meetings to faciliate a closer collaboration?
• What does "Subject to available resources" mean when talking about DCR staff assisting friends groups?
• Parks are already underfunded and understaffed. Volunteers try to fill in the gaps between available resources and what's needed. Are we now to become a line-item subject to available resources?
• Volunteer leaders will have added paperwork. What can be done to reduce red tape? Can't DCR come up with online forms and databases?

Part I Section E -  Volunteer Recognition
"DCR shall develop a volunteer recognition program to honor volunteers based upon the number of hours of service to the Commonwealth"

• To be eligible for recognition, how will volunteers log in the hours they spend on projects other than on site work parties?
• Will organizers and volunteers who work at home have a mechanism for logging in?
• Is the recognition for groups only, or will DCR recognize individuals?
• Is the number of logged hours reflective of the quality, innovation or importance of a project? Or does that matter?

Part II Section A - Volunteer Project Description (VPD) Form

Describes three different Labor Union deadlines required to approve, amend or deny a project (Seriously, how many Union Members does it take to approve a project?)

Part II Section B - Volunteer Release Form
"To be considered a Volunteer under this Policy and to receive the liability coverage... associated with the Volunteer Project... a Volunteer Release Form must be signed and submitted to DCR prior to beginning the volunteer activity"

• If an individual wishes to maintain a trail can he or she do so without belonging to an affiliation?

"A Nonprofit Organization shall also be responsible for . . . delivering [the completed forms] to the Facility Supervisor prior to the commencement of the approved Volunteer Project."

• So, if a group is working six miles from the headquarters and someone shows up late, will the organizer have to deliver the forms to the supervisor or tell the volunteer to go home?

• Since the form(s) must be provided to the Facility Supervisor prior to commencement of the Project, will DCR prevent Friends groups from holding events unless all participants pre-register—no last minute volunteers allowed?

Part II Section C - Volunteer Services Documentation
"DCR facility shall maintain a Volunteer Services Log"

• This may do for work parties, but what kind of documentation is required for leading hikes? If a group leads hikes, or leads regular or spontaneous hikes are those considered  "Projects"?   
• The words "hike" and "walk" do not appear in the entire document. Does that mean volunteers can no longer partner with DCR for hikes?

Part II Section D -  Volunteer Services Reporting and Review
"The DCR Labor Relations Liaison shall meet with all relevant DCR labor union representatives to discuss past Volunteer Projects.

• Volunteers understand we cannot replace State Employees. We enjoy working with DCR staff and are not there to displace anyone. There will never be enough volunteers to deprive Union workers of jobs, but without volunteer help the parks feel neglected. Furthermore, volunteers develop a vested interest in parks and become strong advocates for DCR and their budget.  Isn't there enough to do without adding red tape? Why do we need additional reviews of past projects?

Part III Section B - Fundraising
 ". . . funds generated [must be used only for supporting or improving a DCR facility or program.."`

• Should DCR limit the use of all donations gathered at events to the support of the facility when Friends groups must incur significant expenses to advertise, provide snacks and beverages, educational materials and prizes, etc., in advance of the events?
• DCR's Special Use Permit requires the submission the Special Use Permit Application by May 1 for events that may take place months away. Isn't this too restrictive and doesn't this discourage spontaneous events?
• Why should a group with a Stewardship Agreement be held to the same process as groups without Agreements?
• Should Friends groups, partnering with DCR for public events be required to pay $35 for each permit? Shouldn't this fee be waived when a group partners with DCR?
• The Special Use Permit Application requires applicants to provide a Certificate of Insurance. When partnering, Friends groups are covered under DCR, aren't they? Why doesn't the Special Use Permit Application reflect this coverage?

"Nonprofit Organizations shall submit to DCR annually, by November 1, a record of all funds generated from co-sponsored fundraising activities or special events."

• Will DCR want a record of spending too?
• Again, what about the group's expenses?
• Is DCR aware that groups now pay around $850 a year for insurance (when they can get it)? That's a huge percentage if not more than what many groups bring in through donations. Does DCR understand the burden being placed on groups who need to hold events to raise funds?
• Legislation requires that money raised at events on DCR property is to be spent on the facility. Can DCR develop a reporting formula that will allow groups to deduct expenses and clarify that the profits will go to the park?

Part IV Section A - Memoranda of Agreement with Volunteer Organizations

• How long will it take, and what is the mechanism for developing a MOA with a non profit? Why isn't this spelled out in the Draft?
• What happens to groups that do not have a current MOA in the time between the adoption of the Volunteer Policy and their signing a MOA?