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Subcommittee on National Parks, Forests and Lands Page 5 



July 25, 1995 



The debate regarding reform can too easily focus on the large concession 

 contracts that provide hotels and similar services. The debate must recognize that most 

 commercial operations in national parks are currently authorized by a different type of 

 permit. A 1993 General Accounting Office report titled, "FEDERAL LANDS: 

 Improvements Needed in Managing Short-Term Concessioners" (GAO-RCED-93-177), 

 describes this use. The report states that in 1993 the National Park Service authorized 

 1,164 commercial use licences (CULs) that accounted for 80 percent of all concession 

 agreements. Outfitter and guide services accounted for 65 percent of all CULs issued. 

 CULs are problematic in their own right and deserve the attention of Congress. Clearly, 

 the impact on outfitted services is widespread if concession reform does not create a 

 workable authority for these types of recreational services. 



Comments on selected sections of HR 2028 



SEC. 2. PURPOSE. We agree that there is a need for greater uniformity and 

 consistency in the management of concessions by Federal land management agencies. 

 However, given that each of the six agencies encompassed by this bill has a different 

 mission, given that each has developed customary practices — not all of which are 

 inefficient or ineffective — we oppose a one-size-fits-all approach. Uniformity for its 

 own sake may not play to the strengths of an agency that has developed a permitting 

 procedure consistent with its statutory mandate. What should be sought is a modular 

 approach incorporating the best elements of the permitting process that these agencies 

 have in common, yet allowing for efficiencies based on each agency's unique strengths. 



The need for flexible concession management was underscored in a 1990 

 Department of the Interior report titled "Report of the Task Force on National Park 

 Service Concessions." It states very well the basic need in concession reform: "The great 



