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of thousands of jobs. These impressive figures and the 

 extraordinary growth of recreation on a national scale also 

 generate billions of dollars in tax revenue for Federal, state, and 

 local governments. 



We are submitting these comments, because many of our members 

 are small businesses which operate facilities on property owned by 

 the United Sates government. We are very concerned about any 

 change in current operating procedures, but we are particularly 

 concerned about the potential effects the changes to current 

 contract procedures offered by the key government agencies managing 

 waterfront properties and contained in H.R. 2028. 



MOAA's comments focus on three specific issues; 1) Emphasis 

 on satisfaction with current policies of the Corps of Engineers 

 and the National Park Service and differing agency missions, 2) The 

 changes proffered in H.R. 2028 regarding contract renewals and fee 

 structure, and 3) New policies for capital improvements and 

 property appraisals to determine "fair market value." 



It should be kept in mind that the large majority of marina 

 concessionaires are small businesses. Many are family owned. Most 

 are not large, sophisticated businesses involved in multi-million 

 dollar operations. Marina concessionaires cannot be compared to 

 concessionaires who operate large lodges in our national parks. 

 We must create a legislative policy that ensures the contributions 

 of small businesses, such as marina concessionaires, to job growth, 

 economic growth, tax revenue growth, and America's prosperity will 

 continue. 



In addition, MOAA strongly supports the efforts of the 

 Congress to reduce complexity in the Federal government. We 

 believe H.R. 2028 should support that Congressional goal to make 

 the leasing process less complicated. 



Satisfaction with Current Operating Policies 



Even though we understand the purpose of the bill is to 

 enhance the role of business in providing for recreation on Federal 

 lands, we are concerned the opposite will actually occur. We 

 believe new market restrictions contained in H.R. 2028 will place 

 small business with a life long commitment to customer satisfaction 

 at a distinct disadvantage with big business. Small businesses 

 will simply not be able to compete with big business due to the 

 restrictive financing associated with short term leases. Our 

 members ask that they be allowed to compete on a level playing 

 field with other business interests. 



A lease is a written agreement which conveys a possessory 

 interest in property for a specific period of time. However, the 

 lease may also contain express provisions restricting the usage of 

 the property. H.R. 2028 creates a "concession service agreement." 

 In many ways it is a lease, but it is not defined as such. 

 Concessionaires will propose capital improvements to property 



