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Subcommittee on National Parks, Forests and Lands Page 9 



July 25, 1995 



plan level and the plan recognizes the type and scope of commercial services, there is no 

 need to duplicate the analysis with each permit renewal. 



The need for this language is real and practical, and in no way does it circumvent 

 the interests of proper environmental safeguards. We have experienced national forests 

 and national parks that have required environmental assessments before a permit is 

 issued while other forests and parks do not require these assessments even if faced with 

 the same type and scope of use. Environmental analysis consistent with the National 

 Environmental Policy Act (NEPA) is important, but needless duplication can be avoided 

 if cautious land managers are given direction to utilize analyses that have been 

 undertaken at broader levels of planning. 



SEC. 8. CONCESSIONER EVALUATIONS. 



(a)(1) "... [Rjesource protection (as applicable) . . . ." Again, like the same 

 provision for evaluating applications, this is appropriate, but the underlying vagueness 

 and ambiguity potentially neutralizes the value of the recognition. 



SEC. 9. FEES CHARGED BY UNITED STATES FOR CONCESSION AUTHORIZATIONS. NOLS 

 supports a fee regime which properly balances operator use with a reasonable charge 

 for services provided. We have a quality program and we are not afraid of a fair 

 competitive bidding structure. We have voiced our concern that the current CUL, with a 

 typical fee of $100, undersells the government's resources. However, fees alone do not 

 recognize the value of other services provided by concessions to the government. 

 Service projects such as trail maintenance and campsite clean-up, and educational 

 partnerships such as jointly-produced visitor brochures make dollar-for-dollar 

 contributions to land management. 



SEC. 10. DISPOSITION OF FEES. NOLS supports the special accounts into which fee 

 revenues will be deposited and from which the agencies will draw for services and 



