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Subcommittee on National Parks, Forests and Lands Page 3 



July 25, 1995 



1. The public values a range of recreational activities, including 

 organized recreational and educational pursuits. 



2. If the government desires this range of activities, it must provide 

 reliable and consistent permit mechanisms. 



3. The public expects safe and high quality recreational experiences 

 and the government has a duty to evaluate operators to ensure these 

 expectations. 



4. Recreation partners can provide real value to land management 

 through commitment to conservation, service projects and visitor 

 education. 



5. It is a privilege to operate on federal land and commercial operators 

 should provide a fair return to the government for this use. 



6. Businesses do not run one year at a time, and concession 

 authorizations must provide a reasonable term to justify the 

 development of an educational program or business. 



How does H.R. 2028 measure up to these principles? In some practical w^ays, this 

 bill makes progress towards business- and resource-friendly concessions. Resource 

 protection as part of concession applications and evaluations, inapplicability of NEPA 

 to permit renewals if sufficient analysis exists at the forest or park plan level, and a 

 standard for qualifications for concession managers, all make substantial contributions 

 to wise management. 



However, these issues affect only the margin of concession management. The 

 critical issues of guaranteeing quality concessions with an administratively efficient 

 system are met with unclear, and therefore dangerous, guidelines. Through the lack of a 

 reasonable weight given to the fee-bidding factor in applications, a high quality 

 program may be outbid by a well-financed but less capable concessioner. The 



