20 



and less flexibility to modify the system to meet changing condi- 

 tions. 



But let me just mention the amendments that we would propose 

 if this legislation moved forward. First of all, it would include the 

 value of ancillary facilities on national forest system lands such as 

 restaurants or daycare centers and so forth. These revenues total 

 only 10 percent of the overall total, and we would suggest simplify- 

 ing the system even further and reducing paperwork by leaving 

 them out and adjusting the fee percentages accordingly in the for- 

 mula. 



Second, the system would produce about the same level of fees 

 as our existing GRFS system, and, therefore, we don't see a need 

 for a transition period which would be complex and time consum- 

 ing. And because the percentage of fees is relatively low compared 

 to overall revenues, we believe that there would not be a need for 

 such a transition period. 



Third, current laws and regulations under which we operate re- 

 quire advanced payments and periodic payments of fees. We believe 

 this is appropriate, and that the ski industry, like other users of 

 Federal property, should continue that practice of advanced pay- 

 ment rather than the system that is set forth in H.R. 1527. 



Fourth, we would recommend a process to update the formula 

 every five years to try to ensure that the fees paid truly do reflect 

 fair market value, and we have one other recommendation. Rather 

 than withdrawing ski areas from the mining laws immediately as 

 is proposed in the bill, we would suggest segregating those lands 

 for a two-year evaluation period to see whether there would be 

 other ways to moderate impacts on ski areas from mining activi- 

 ties; maybe underground mining, horizontal drilling, changes in the 

 boundaries of the areas and so forth before proceeding with with- 

 drawal. 



Let me now turn to H.R. 2028 on the concessions. We do object 

 to the enactment of H.R. 2028 in its present form. Recognizing the 

 extensive experience of the Park Service, we defer to the Depart- 

 ment of the Interior on sections 4 through 9, but we do have con- 

 cerns about three parts of the bill. 



First, Section 10[b] would return all fees to the agency which 

 sounds attractive to us, but under law, we return 25 percent of all 

 revenues that we collect for all national forest purposes to States 

 and counties for schools and roads. We believe strongly in the value 

 of that practice. We would want to continue it and would rec- 

 ommend that the legislation, if it would go forward, be modified to 

 direct that 25 percent to States and counties. 



Second, section 13 provides for compensation to concessioners if 

 the government breaches the contract. We certainly intend to meet 

 our commitments. We believe that this provision would unneces- 

 sarily expand the scope of litigation and management of the na- 

 tional forests. 



Finally, section 15 would allow sales of national forest lands to 

 concessioners. We already have authority for equal value ex- 

 changes. This provision would return only half the value to the 

 government, thereby diminishing the overall value of the national 

 forests. It also would, if used, sever the relationship between the 

 public and the entrepreneurs, and we believe that a purpose of 



