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MOAA is seriously concerned that many recreational programs 

 will die if long term leases are discontinued, because the 

 financing will not be available to expand or improve a site. 

 Without consistent improvements to a property it will decay and 

 visitors will go elsewhere. 



Ten years is clearly not sufficient time for a concessioner 

 lease for a marina. It will not allow for sufficient time to 

 amortize the costs of projects. 



Lease terms for marina operations must be a minimum of 25 

 years. We recommend that the language of H.R. 2028 be amended to 

 specifically mention a minimum 25 year lease should be awarded to 

 a concessioner who has made a significant capital investment and 

 commitment to the recreation area. We do not want to leave 

 flexibility in the legislation to provide for a short lease term 

 to the rulemaking process. We are concerned of inconsistencies 

 among agencies regarding the treatment of lease term. 



In addition, banks need business plans and projections of 

 revenue and expense flows for several years into the future to base 

 a financial commitment to a project. It is important to project 

 fees into the future, but as fees go up, a variable is created that 

 the business and bank cannot foresee. We understand the interest 

 for the government to increase revenue. We may not agree with it, 

 but we understand it. The problem is that the costs will have to 

 passed onto the public. As the costs increase, the marina becomes 

 less stable and visitors may recreate somewhere else. The market 

 generally determines the cost of slip rental, not necessarily the 

 costs of operations. Just because costs increase does not mean 

 that a marina can charge more for slip rentals. 



We do not believe fees can be tied directly to inflation 

 rates. An understanding of operating costs, especially labor 

 costs, is most important. And market conditions must be considered 

 in any pricing structure. 



The actual fee structure is more complicated than a simple per 

 cent of gross revenue or a set annual fee. Many times the 

 government receives various types of compensation other than cash 

 fees. These types of services include concessioner repairs, 

 maintenance, improvements, or construction of government-owned 

 facilities. These fees are either in addition to or in lieu of 

 cash fees. Applicable government agencies must be given the 

 latitude to utilize this very important optional fee structure. 

 H.R. 2028 must be flexible enough to promote optional fee 

 structures. 



MOAA believes the annual evaluation language of H.R. 2028 in 

 inherently subjective by lease administrators. No criteria are 

 established in the bill. We strongly believe our members want to 

 know annually how they are doing, but we are very concerned that 

 an annual scorecard as described in the bill does not provide for 



