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We support the concept of a long-term strategic approach to 

 funding the requirements for recreation and conservation, espe- 

 cially involving the private sector and local and State level funding 

 measures. However, the "Teaming with Wildlife" proposal is ill- 

 timed and would, if implemented, place an undue hardship on 

 SIA's membership, and, more importantly, adversely affect the 15 

 million Americans who participate or otherwise might participate 

 in lifetime on-snow sports. 



Furthermore, these participants are already supportive of the 

 government's environment and wildlife programs through payment 

 of fees by ski area operators on public lands for downhill and cross 

 country skiing and snowboarding. 



At one time, the on-snow recreation industry in America enjoyed 

 tremendous growth. However, for the past decade, the number of 

 ski resort visits by skiers and snowboarders has remained con- 

 stant. During this period, however, product unit sales at the retail 

 level decreased 27 percent for alpine skis, 57 percent for cross 

 country skis, and 24 percent for alpine boots from the industry's 

 peak in 1987. 



Now, as costs for participating in our on-snow sport have esca- 

 lated, our sport is mature. It appears that the American public is 

 near a saturation point in the family budgeting process as to the 

 cost of recreation activities, which they can sustain. 



The proposed excise tax on ski equipment and other snow related 

 sporting goods will represent one more barrier for continued par- 

 ticipation or entry into our lifetime sport. The public's perception 

 is that our sport is already expensive. Therefore, any increase in 

 the costs associated with our sport would likely preempt participa- 

 tion and further growth. 



You should note that a significant majority of our members are 

 small businesses with sales not exceeding a million dollars. These 

 companies operate at an average profit before tax margin of less 

 than five percent. The impact in loss of any sales, as a direct result 

 of the proposed excise tax, would certainly cause a number of our 

 member businesses to fail, resulting in greater unemployment and 

 a decrease in the revenue base. This liability alone could outweigh 

 the revenue benefit that the imposition of such a tax might accrue 

 on the on-snow recreationists in America. 



The Teaming proposal calls itself a user fee. SIA does not oppose 

 a fee if it were equitable, cost effective, understandable to those as- 

 sessed, and dedicated to those areas for which fees were collected. 

 However, we believe that those who pay the fee must be provided 

 a direct and identifiable service. The "Teaming with Wildlife" pro- 

 posal fails far short of meeting this test. 



Unlike Wallop-Breaux, levying an excise tax on a loosely defined 

 list of outdoor recreation products is not compatible with the phi- 

 losophy of a fair and equitable user fee. Teaming's proposed mecha- 

 nism fails to meet the user-pays test. This proposal represents a 

 specialized tax if a substantial portion of users did not pay, or if 

 they pay a disproportionate share of the tax, and thereafter derive 

 no direct benefit. We believe this to be the case with the partici- 

 pants or potential participants in our sports. 



We share the concerns of others regarding the problems with in- 

 adequate administration of collected funds and certainly with the 



25-856 0-96 



