56 



authority for commercial use licenses. This shaky ground has led 

 to uncertainty. We have a high quality program, but it is never cer- 

 tain that if we do a good job we will have a reasonable chance of 

 maintaining our program in a given national park. 



To address these concerns and the very real concern of fair finan- 

 cial returns to the government, Congress has sought to reform con- 

 cession management. While H.R. 2028 contains innovative propos- 

 als that we do support, at this time NOLS does not endorse the 

 bill. But we do appreciate the constructive debate represented by 

 this hearing. 



NOLS has three main concerns. First, we oppose a one-size-fits- 

 all approach to permitting. There are significant differences in 

 agency missions and customary uses that need to be recognized in 

 the permitting process. There is a great deal of room for standard- 

 ization among agencies, but uniformity for its own sake does not 

 play to the strengths of an agency. 



Second, the language regarding the two-tiered system of permit 

 authorizations lacks clarity. The questions of frequency of use and 

 competitive interests differentiate among categories, but how will 

 frequency of use be defined? How broad or narrow will competitive 

 interests be construed? 



Third, we are concerned that small businesses and nonprofit or- 

 ganizations such as scouting groups, church groups, university out- 

 ing clubs, and backcountry education groups like NOLS will be af- 

 fected to a great degree by a system that may award permits to the 

 highest bidder. 



NOLS is not afraid of competition, evaluations, or reasonable 

 fees, but we are concerned that competition for competition's sake, 

 evaluations that weigh Federal revenue enhancement above quality 

 service, and the potential for fee wars jeopardize our ability to op- 

 erate. 



Beyond these three basic concerns, there are provisions that we 

 do support in H.R. 2028. Returning fees to the parks and forests 

 is a good idea. Resource protection as a factor in determining quali- 

 fied applicants and for evaluating concessions is appropriate. Also, 

 permit managers need to understand private enterprise, so setting 

 minimum qualifications for concession managers is critical. 



In conclusion, NOLS sees the potential for reform that recognizes 

 the full array of concessions including nonprofit educational groups 

 like NOLS, and the best reform will promote high quality conces- 

 sions with a fair and reliable system. 



Thank you, Mr. Chairman. This concludes my statement. I will 

 be happy to answer any questions. 



[The prepared statement of Mr. Henderson can be found at the 

 end of the hearing.] 



Mr. Hansen. Thank you, Mr. Henderson. We appreciate your 

 comments. We will recess for a short time to vote. Would the panel 

 mind staying with us? 



[Recess.] 



Mr. Hansen. Mr. Selengut, we will turn five minutes over to you, 

 sir. 



