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B-202800 1 (1981-10-29)

handle is hein.gao/gaobabkgc0001 and id is 1 raw text is: 


                     SMP=ROLLER GENERAL OF THE UNITED STATES
                                 WASHINGTON D.C. 20548

   B-202800                                           October 29, 1981



   1he Honorable John D. Dingell
   Chairman, Subcormnitte on
     oversight and Investigations
   Committee on Energy and Commerce
   Bouse of Representatives

   Dear Mr. Chairman:

        This is in response to your request that we examine, in light of
   applicable laws, allegations that a group of non-Federal employees used
   the facilities of the Old Executive Office Building to solicit a number
   of corporations and individuals in the energy industry for contributions
   to the White House Historical Association to redecorate the White House.
   You specifically request that we determine whether solicitations were
   carried out consistent with Federal law and whether persons who used
   Federal facilities while soliciting funds violated any laws. You also
   questioned the closely intertwined relationship between the National
   Park Service, Department of the Interior and the White House Historical
   Association (Association).

        We requested information and comments from the White House, the
   Department of the Interior, and the Association. The response we received
   from the White House denied that the solicitation of funds took place
   as described in your letter. We have no basis to challenge this denial.
   As explained by the Executive Vice President of the Association, its
   role in this matter was limited to being the recipient of the donations.
   Laws and regulations which would be relevant if solicitations had been
   made from the Executive Office Building or by Federal employees are
   briefly discussed on page 3.

        The Association was incorporated in the District of Columbia in
   1961. Its charter provides that the National Park Service will be
   represented by at least two members of the 16 member Board of Directors,
   one of whom is to be the Executive Secretary.

        Responses from the Association and the Department of the Interior
   indicate that, in addition to its charter, the Association's relationship
•  with the National Park Service is based on an agreement that covers
   the responsibilities of the Association and the involvement of Park
   Service staff in the operation of the Association.

        Paragraph 2 of the agreement provides that the Association may
   use White House and other nearby Government facilities for the sale of
   educational and interpretive items. This paragraph particularly empha-
   sizes that Association employees are not Government employees and that

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