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Subcommittee on National Parks, Forests and Lands Page 6 



July 25, 1995 



variety in the size, scope and nature of Park Service concessions operations underlines 

 the need for a flexible concessions management system." 



SEC. 3. DEFINflTIONS. We support the attempt to improve clarity by consistently 

 using the term "concession" to describe each tier of the statutory authorization — as in 

 "concession service agreement" or "concession license." Myriad terms meant to cover 

 this usage — "concession permit," "concession contract," "commercial use license" ~ 

 have sometimes led to confusion. 



SEC. 4. NATURE AND TYPES OF CONCESSION AUTHORIZATIONS. We support an 

 approach w^hich makes differentiation between types of usage and business operations. 

 Depending on how we are defined we may or may not have competition, depending on 

 how we are defined our use may or may not be infrequent. In areas where we operate 

 we welcome the opportunity to secure long-term concession authorizations. 



(a)(1) CONCESSION SERVICE AGREEMENT. Although agreements of this kind would 

 probably not be the norm for our operations, much of that would depend on whether 

 the Secretary concerned would make a "finding of competitive interest." The 

 requirement of substantial capital investment is discretionary, and it is not clear to 

 NOLS when this requirement might likely be applicable. 



(a)(2) CONCESSION LICENSE. The lion share of NOLS authorizations would probably 

 fall under this type of authorization ~ or so it seems. Without a definition of the term 

 "infrequent" and/or without a clearer understanding of the parameters of a 

 "competitive interest," it is difficult to know whether we would qualify for the 

 concession license or the concession service agreement. 



These uncertainties make us wonder what the practical effect of this legislation 

 will be. It is our experience that if management of small, outfitter-type, non-proprietary 

 operations becomes any more complicated than it currently is, some managers will 

 choose not to pursue the administrative headaches of this authorization and will only 



93-983 0-95-9 



