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Subcommittee on National Parks, Forests and Lands Page 10 



July 25, 1995 



facilities. We commend a process which gives the agencies greater responsibility over 

 the fees collected on their lands. 



SEC. 13. BREACH OF CONTRACT BY THE SECRETARY CONCERNED. Although the 

 definition of concession in Sec. 3(2) seems to cover this point, the breach of contract 

 provision should apply to both concession service agreements and concession licenses. 



SEC. 18. REGULATIONS. 



(b) QUALIFICATIONS OF AGENCY PERSONNEL ASSIGNED CONCESSION MANAGEMENT 

 DUTIES. NOLS supports this section. Concession permits outline in great detail the 

 qualifications of several aspects our operations, e.g., our instructors and our 

 performance history. However, the process has to date not established minimum 

 criteria for the agencies' concession managers. Consequently, in our experience, there is 

 a great deal of inconsistency in the application of policy in the acquisition and 

 maintenance of concession authorizations. 



Permit managers need to understand private enterprise. If the government sees a 

 benefit in allowing commercial use on public land to meet public needs, then the 

 government must work with commercial operators to ensure reasonably viable 

 operations. It is our sense that too many permit managers are naive about basic business 

 concepts such as lead-time needed with a permit guarantee to market and enroll 

 courses, and some managers do not veil their distaste for commercial operations on 

 "their" land. The establishment of minimum standards for concession managers would 

 go a long way to further uniform regulation and effective, efficient concession 

 management. 



^ NOLS operates on the following federal lands; 



National Parks: Big Bend National Park, Texas; Bighorn Canyon National Recreation Area, Montana; 

 Canyonlands National Park, Utah; Carlsbad Caverns National Park, New Mexico; Denali National Park 

 and Preserve, Alaska; Devils Tower National Monument, Wyoming; Dinosaur National Monument, 

 Colorado; Gates of the Arctic National Park and Preserve, Alaska; Glen Canyon National Recreation 



