50 



As to operations and performance evaluations, the bill provides 

 for annual evaluations, and any concessioner who receives an an- 

 nual rating of unsatisfactory then becomes ineligible for the top 

 rating over the life of the agreement. 



We feel it would be in the best interest of both the agency and 

 the concessioner to have evaluations and ratings performed more 

 frequently than once a year so that the quality and performance 

 can be more closely tracked and corrections made more quickly. 



As to performance ratings and rating systems, there should be a 

 mechanism whereby a concessioner can earn back a previously held 

 higher rating because sometimes ratings may reflect the agency's 

 use of an inexperienced evaluator; sometimes ratings reflect a per- 

 sonality conflict with the concessioner; and sometimes ratings may 

 reflect an act or omission of an employee that was totally against 

 the concessioner's policies. 



A rating system that is usable and user friendly should have log- 

 ical positions. It should have a top, a middle, and a bottom. Letter 

 grades could be used and assigned numerical values. Periodic rat- 

 ings could be averaged to create grade point averages. The goal 

 could be as in food service establishments to have grade A conces- 

 sions operations; that is, anyone above a 3.0 average on a 4,0 

 would be a good concessioner. 



As to fees, we support the provision for establishing the mini- 

 mum acceptable fee in the solicitation. For areas where essentially 

 identical services are being bid, we feel that averaging all those fee 

 bids and taking the average of those bids is not desirable. In effect, 

 it would probably lower the actual fee of higher bidders and raise 

 the actual fee of lower bidders, and the amount would not even be 

 known until the bidding process had closed. 



NFRA would like to see the bill include a provision for recogniz- 

 ing and crediting to the concessioner the noncash and sometimes 

 nonfee compensation that concessioners provide the managing 

 agencies by performing work that the agencies can't or won't do. 

 Presently, these requirements are being imposed on concessioners 

 outside the authorizations and sometimes after the fact. 



As to the removal or retention of facilities, we would like to see 

 section ll[b] expanded to provide that as the end of a concession 

 authorization approaches, the Secretary concerned shall make a 

 finding as to whether the facilities or services are to be continued 

 in a subsequent concession agreement; that if they are to be contin- 

 ued and the existing concessioner is not selected as the new conces- 

 sioner, then the existing concessioner may either sell the business 

 to the new concessioner at fair market value as determined by an 

 independent valuation expert, or remove any improvement and re- 

 store the site. 



In summary, the goal of an interagency concessions policy, we be- 

 lieve, should be to identify those concessioners who deliver quality 

 service to the public and protect the natural and cultural resources 

 and deliver a fair return to the government, and also to retain 

 those concessioners as long as they meet those qualifications. 



H.R. 2028 contains provisions that go a long way toward creating 

 those incentives. However, the portion of section 2 that provides a 

 reasonable opportunity for the economic viability of the conces- 

 sioner needs to be strengthened to provide instead the reasonable 



