National Parks Conservation Association
Submitted to the
Subcommittee on National Parks and Public Lands
Senate Committee on Energy and Natural Resources
On S.2607 and S.2473 to permanently establish the Recreation Fee Program
June 19, 2002
The National Parks Conservation Association is our nation's only private, nonprofit citizens organization dedicated solely to protecting, preserving and enhancing the National Park System.
NPCA supports making the fee demonstration program permanent and appreciates the opportunity to submit testimony on S. 2607, the "Federal Lands Recreation Fee Authority Act" and S. 2473, the "Recreational Fee Authority Act of 2002". Since its initiation in 1996, the demonstration program has proven valuable in bringing much needed resources to our national parks. Today, according to our research at more than 40 national park units, the national parks receive only two thirds of the funding they need to accomplish their mission. The annual funding shortfall for the parks compounds an already enormous maintenance backlog that the General Accounting Office more than two years ago said amounted to $4.9 billion nationwide. Clearly the recreation fee program cannot and should not be used to fill this enormous funding gap. However, it can play an important, although small, role if the Park Service continues to implement it in a responsible way, and if the collected funds supplement rather than supplant needed appropriations.
The recreation fee demonstration program has brought more badly needed flexibility to many cash-strapped parks and has helped to educate park managers about public acceptance of entrance and use fees, options for fee collection, and collateral benefits and costs of increased fee collection. The program has been dynamic in raising a variety of issues that Congress should address once the program reaches its conclusion. Some of those issues include the appropriate method of interagency revenue sharing, the appropriateness of specific types of use fees, eventual fee caps, and distribution of revenues within the National Park Service.
Public Acceptance of the Demonstration Program: Entrance Fees
The fee demonstration program continues to have broad support among park visitors and the rest of the public. According to The National Park Service Comprehensive Survey of the American Public that was published by the Park Service in 2001 in conjunction with Northern Arizona University, 80 percent of respondents who could remember the amount they paid said the entrance fee was about right. Eleven percent said the fee was too high and six percent actually said the fee was too small. According to the same survey, however, 24 percent of recent visitors to national parks said people do not visit more often because entrance fees are too high.
The Park Service's findings are interesting when evaluated next to a survey NPCA conducted prior to initiation of the fee demonstration program. According to our survey, seventy nine percent of respondents were not opposed to an increase from an average (at that time) of $5 per carload for a visit of up to seven days. In 1996, NPCA again conducted a survey exploring the public's willingness to pay specific levels of fee increases. Based on per person, rather than per carload assessments, the 1996 survey showed that 56 percent of respondents would support an increase of $5 per person, with support gradually dropping to 20 percent as the increase rose to $10 per person.
Clearly, the public acceptance of fee increases has limits. The degree to which the Park Service has room to further increase fees beyond where they are set today is far from clear. At many units of the park system, entrance fees have been doubled and in some instances tripled since the demonstration program began. The fee at Yosemite National Park, for example, climbed from $5 per car before the initiation of the program to $20 per car. If the NPCA survey is any indicator, the current fee levels may be approaching or may have already reached the limit of what the public finds acceptable.
NPCA is pleased that both bills authorize entrance fee-free days or use at the national parks. However, we believe the bills should require more than one free fee day per year as is delineated in S. 2607. We suggest that a free fee day at least every two or three months is appropriate, and that such days should be sufficiently publicized, particularly in low income communities, to inform the public about their existence and to allow visitors to plan for them. We also believe that even more frequent "no-fee" days should be tested and informative surveys should be undertaken in order to gain a better understanding of how to serve the needs of low income visitors.
In addition, the Park Service should be required to take public opinion into account in evaluating the incremental increases the owners of our parks, the American people, will tolerate in the future. It is also important that the criteria reflect the difficulty that some of our citizens may have paying the admissions fees. S.2607 requires that the cost to the visitor be considered as a factor in the Park Service's fee-setting decisions, but S.2473 does not. We prefer the provision in S.2607, but believe it should be expanded to include the considerations described above.
In general, most of the other fee-setting criteria in both bills appear reasonable. However, we suggest eliminating line 2(c)(2)(D) in S. 2473, which calls for the Park Service to compare "comparable fees charged by nearby private sector operators". We do not believe such a comparison is appropriate. For example, it would not be appropriate to compare entrance fees at Everglades National Park with those at Disney World. Our national parks are national property and should not be treated as the equivalent of commercial enterprises. They are a public good and require different considerations where fees are concerned.
In fact, it is a credit to the national parks that so many Americans are willing to pay extra fees to help support them. It is important to note that the support for those fees would quickly evaporate if the proceeds did not remain with the parks, themselves. According to the Park Service's 2001 study, 93 percent of recent visitors thought all money should go to the unit where it was collected (41 percent) or to the Park Service with a percentage coming back to that unit and other units (52 percent). Only 6 percent said they would support fees that were transferred to the U.S. Treasury.
Public Acceptance: Use Fees
Depending on how they are designed and the amounts that are charged, both entrance and use fees may be problematic in certain circumstances. In one striking example, the National Park Service stepped some distance across the line of public acceptance for fee increases when it instituted sizeable fees at Grand Canyon National Park. At the Grand Canyon, private boaters must wait to get a slot on the Colorado River for as long as eight years. The Park Service instituted a place-holding fee of $25 per year and a $100 application fee so that, on average, private boaters would pay $300 before ever dipping an oar in the water.
This and other examples of excess have been important learning experiences for the Park Service as it has explored the boundaries of public acceptance of use fees. The demonstration program was well crafted, in that it has allowed NPS and the other land management agencies to explore different opportunities and occasionally fail without penalty. In many venues, use fees are a new concept both for the public and for the agency. As Congress evaluates the success of the program and considers making the program permanent, it should pay careful attention to examples like the Colorado River wait list fee and place limits on the Park Service's ability to levy such excessive fees.
We believe the Park Service should avoid multiple fees wherever possible. Multiple fees irritate the public and make the entire fee structure less understandable to park visitors. They have the potential to undermine public acceptance of the fee program over the long term and should not be undertaken lightly.
Broadening the Scope of Fee Collection
The National Park Service is authorized to collect fees under the demonstration program at 100 sites and currently collects at 97. Those 97 units include some that had previously prohibited fee collection, like Cape Canaveral NS which now charges a daily use fee. Other areas have discovered that, if appropriately applied, use fees can have collateral benefits unrelated to revenue generation. When Glen Canyon NRA established a fee at Lone Rock Campground, within one year assaults dropped by 71 percent, disorderly conduct violations dropped by 88 percent, quiet hours were enforced for the first time, littering decreased and family use of the campground increased. Although it is unfortunate that the parks experience any crime, clearly the fees assessed here have had a beneficial impact. In addition, smaller units, like Cape Canaveral were able to generate supplemental revenues that proved useful in addressing backlogged park needs.
Therefore, a carefully measured continuation and expansion of the program has potential benefits to the National Park System. However, we urge the subcommittee to require or incentivize the Park Service to continue do more to identify creative approaches to fee establishment and collection. Such a provision would encourage the Park Service to explore further both the opportunities and pitfalls of fee collection, building a more accurate record of where, what kind and what level fees are appropriate, while at the same time providing parks with badly needed supplemental revenue. Fee collection will not be practical at all units of the National Park System. Nor are fees appropriate at every unit, as S.2607 properly notes with regard to Great Smoky Mountains National Park. At the conclusion of an expanded program, Congress would have a more accurate record to guide future decisions on where, when, how and how much the public should be asked to contribute for use of its national parks.
While there is some question about whether fees should be institutionalized at parks that may no longer have programs they need, we believe the funding situation facing the parks renders such a debate somewhat academic. In the event a specific park has no need to establish fees or no specific program for which fees may provide a necessary infusion of resources, we agree that fees should not be charged. However, with a national park system that is 32 percent short of the annual funding needed to operate, we believe this issue could be dealt with in a future reauthorization of the program.
Facilitating Better Business Planning
Today the Park Service's lack of financial management capacity means that fee collection funds may not be spent in the most efficient and cost effective manner. Clearly, if the American people are asked to pay extra fees to visit their national parks, they have a right to know that fees are being collected and spent efficiently and effectively. In addition to the challenges of properly spending the funds that recreation fees generate, the park service has a variety of other business planning challenges that could, if approached strategically, provide important efficiencies within the national park system. As the subcommittee knows, NPCA, in partnership with the National Park Service, has developed the National Parks Business Plan Initiative which has been providing the park Service with valuable information about park resource needs. We have been working with the Park Service and the Appropriations Committee to extend that program in a way that institutionalizes additional capacity for sophisticated, long-term business management within the National Park System.
The primary impediment to raising the business management capacity of the Park Service is attracting high quality business students to careers in the Service. When NPCA has asked business students what the impediments are to their working with the Park Service, they repeatedly cite their enormous student loans. Consequently, we recommend that the bills incorporate language that would increase the current federal loan buy-down limit for the Park Service from a maximum of $6,000 per year to $10,000 per year for a total of as much as $40,000 over four years. There is a strong likelihood that the appropriations committee will fund a program expansion this year, but the program cannot be optimally effective without an amendment to federal loan buy-down authority.
Distribution of Revenues Among Agencies and Within NPS
NPCA has no position regarding whether the recreation fee program should include all land management agencies or only the Park Service. However, we believe the retention of the Golden Eagle passport is a worthy goal. As the subcommittee knows, one of the most contentious aspects of the demonstration program has been distribution of the revenues resulting from the Golden Eagle passport among federal land management agencies. Purchase of the Golden Eagle passport allows free entry to all fee areas across the land management agencies. Under the demonstration program, the price for the Golden Eagle passport was raised from $25 to $50 in 1997, resulting in an increase in total NPS revenues from $5.4 million to $9.6 million. Currently, revenue from the sale of the passport is retained by the agency making the sale. When sale of the passport is opened to third parties the calculus will become far more complex, as none of the agencies will be directly selling at least some portion of the passports. The fee demonstration program was specifically authorized to spend the resulting revenues on projects visible to the fee paying public. As a matter of equity, revenues should therefore be applied to the agencies based on their share of fee-generating visitation.
Within the Park Service, the level of revenues received at some of the "crown jewel" parks matches or exceeds the total annual operations budget for those units. Grand Canyon NP is the best example, generating $19.4 million in fee revenues in FY1997, compared with an operations budget for that year of $14.6 million. To advocates of a fee-funded National Park Service, this presents a tempting way to fund operations the few parks in this category. Those advocates, however, should realize that many of the most highly visited units also have the most substantial backlog of maintenance and infrastructure needs. Not surprisingly, visitation has a price. Grand Canyon NP alone has an infrastructure and maintenance backlog exceeding $154 million. Even with an annual contribution of an additional $15 million (the park currently retains 80 percent of the revenues), it will take Grand Canyon 10 years to address its outstanding maintenance project needs, assuming future maintenance budgets meet the needs of the park and the backlog does not grow. And Grand Canyon, like many other parks has substantial cultural and natural resource protection needs as well.
Nonetheless, as Congress considers the success of the demonstration program as it moves forward, it should consider the equity of high levels of supplemental revenues flowing into the high visitation, crown jewel parks. Units throughout the system suffer from similar problems of decaying infrastructure and delayed maintenance. The demonstration program currently distributes 80 percent revenues to the parks that collect the fees. The remaining 20 percent is distributed to the non-fee demonstration units and is used to support the management of the national fee program. As the need for additional studies (discussed below) emerges, Congress should consider evening the distribution so that the less visited and non-fee units do not, in effect, end up supporting the additional research and management of a program that generates revenues disproportionately benefiting the high-visitation crown jewels.
Revenue Sharing with States
We are concerned about establishing the revenue sharing agreements provided for in section 2(e) of S. 2473 without more research and experience. Given the controversy associated with apportioning Golden Eagle pass funds among federal agencies, it is not appropriate to institutionalize federal-state revenue sharing agreements in this legislation. Given the significant underfunding of the national parks, we are extremely concerned about any arrangements that, however well meaning, could drain sorely needed revenues from the national parks.
Additional Research Needs
When the National Park Service finished its plan for the demonstration fee program, the Service made relatively heavy use of parks that already charged fees and simply increased them. This avoided generating some of the controversy that the Forest Service has experienced, but it also provided a narrower scope for the demonstration program than could have been achieved. Therefore, ongoing research may be warranted to improve the agencies' level of understanding about the public's willingness to pay for entry to and use of parks supported by tax dollars.
In addition, little is known about the impact specific levels of fees have on the inclination of people to visit the parks from specific demographic and economic groups. The national parks are for all of us to enjoy and to learn from, no matter the individual's economic or social circumstance. Visitation figures since the initiation of the demonstration program indicate that the increases have had little or no impact on the public's overall willingness to visit the national parks. However, we are not convinced that enough is known to guarantee that the aggregate visitation numbers are not masking an impact based on socio-economic status.
As the Congress, the agency and the public become more comfortable with higher entrance and use fee levels, we must remain always cognizant of the impact that fee increases of any and all kinds have on Americans with limited means. Additional research would help delineate at what point fees become problematic for those visitors and begin to affect adversely the demographics of park visitation. For both issues—willingness to pay by the general public and impact of fee levels on economic and demographic groups—the National Park Service should understand the effect of its evolving actions before proposing changes, rather than proposing changes and evaluating the impacts after the fact. Acknowledging that research costs money, all such research could be covered by the revenues generated by the existing demonstration program.
Thus far, the fee demonstration program has proven to be a success by almost any metric. Fee revenues have increased 88 percent since FY1994; the application of fees has shown some collateral benefits; and the participating parks have begun to address their backlog of maintenance and infrastructure needs through the new revenues, albeit at a very slow pace. But making the program permanent requires caution. We suggest that the subcommittee include a sunset provision after five to seven years, to keep the Park Service honest with regard to the fees they set and to encourage a comprehensive evaluation of the program's successes or failures. We support the requirement in S. 2473 that the National Park Service issue a report on the program every three years. Such reports would be quite useful in future congressional debates about reauthorizing the program. We suggest that the subcommittee specify high priority items that should receive attention in such reports, including specific descriptions of how fees have been used in different parks; assessments of the demographic impacts of fees on park use, including socio-economic, ethnic and racial background; a description of emerging issues; and recommendations for future improvements to the program.
When fee proposals were discussed in the 104th Congress, many comparisons were made between the cost of a visit to the fee collecting parks and the cost of a variety of other forms of public entertainment. The comparisons provided an interesting diversion but avoided addressing the central question of what defines an appropriate fee for visiting the national parks and using resources that were set aside for public benefit. National parks are not entertainment outlets comparable to Disney World or the latest Hollywood blockbuster film. They serve a very different purpose, focused on education, inspiration and preservation for the future. We are somewhat more comfortable with using benchmarks for specific services like campgrounds. But even there, we do not believe campgrounds in national parks should necessarily cost as much as private facilities.
Given those differences, Congress should not grant permanent fee collection authority for the National Park Service without setting parameters and providing for the program's future re-evaluation and possible alteration. The National Park Service should be required to provide a coherent plan for the fee program, detailing where and when fees will be applied, at what level fees will be applied, how quickly and to what level fees will be increased over time, and if there are any program types or areas that NPS or the other agencies have learned from experience should remain free to the public.
We support extending the recreation fee program, which has proven extremely valuable to financially strained national parks. At the same time, we urge the subcommittee to reaffirm congressional intent that the resulting revenues be provided to the parks and public lands as supplemental revenues, in addition to the annual appropriations that the National Park Service and the other agencies currently receive. Despite the impressive revenue performance of a small collection of high visitation parks, the National Park System as a whole will never and should never be asked to support itself with fee revenues. Given the current operations and maintenance needs of the national parks, as well as the constraints within the Federal budget, it is essential that Congress maintain a bright line that assures fees do not replace current or sorely needed additional appropriations for the national parks.