NPCA submitted the following positions to members of the House Natural Resources Subcommittee on National Parks, Forests, and Public Lands ahead of a hearing scheduled for September 19, 2019.
NPCA is supportive of finding ways to create efficiencies in the recreation permitting process; we agree that there are some aspects that are cumbersome. But NPCA has some concerns with text in H.R. 3458, Recreation Not Red Tape and H.R. 3879, Simplifying Outdoor Access for Recreation:
Multi-jurisdictional trip permits: The bill text is unclear as to how activities that aren’t allowed on some federal lands will be taken into consideration in the permit process for a multi-jurisdictional trip. Moreover, the Park Service is tasked with protecting park resources in perpetuity, but other land management agencies have multiple use mandates. We are concerned that if a multi-jurisdiction trip permit, for activities on park land, is granted by another land management agency, park resource protection will not be the first priority for the lead agency. Finally, it is also possible that multi-jurisdictional trip permits offered by other agencies will create a loss in fee revenue for the Park Service. (Permits for Multi-Jurisdictional Trips: Sec. 106, H.R. 3458; Sec. 7, H.R. 3879)
Special Recreation Permits for ‘motorized recreational vehicle use’: The bills allow for the Department of Interior Secretary and Department of Agriculture Secretary to issue a special recreation permit for not only outfitting and guiding activities but also for “motorized recreational vehicle use.” The Park Service manages off-road vehicle use differently in each park unit, therefore instituting broad permit authority doesn’t reflect the need to adhere to specific regulations for each park unit. (Special Recreation Permit and Fee: Sec. 102 (b), H.R. 3458; Sec. 3(b), H.R. 3879)
Permit Flexibility and Substantially Similar Activities: NPCA is concerned with the allowance for the Secretaries to permit ‘substantially similar recreational activity.’ We are not supportive of this provision if the substantially similar recreational activity is not a pre-determined acceptable use in our national parks. (Permit Flexibility: Sec. 104, H.R. 3458; Sec. 5, H.R. 3879)
Additionally, NPCA is very supportive of Title II of H.R. 3458 and ensuring access to the outdoors for our servicemembers and veterans. We have a few concerns with other components of H.R. 3458:
Sec. 301-Extension of Seasonal Recreation Opportunities: In many parks across the country, increased visitation has already decreased any previous ‘shoulder’ seasons or ‘off-seasons.’ In addition to insufficient budgets for adequate staffing at many park units, the National Park Service has restrictions on the length of time that seasonal employees can work, adding further strain on adequate park management. Encouraging additional visitation in already high-use areas could strain park resources and wildlife depending on the time of year and must be considered before extended seasons are legislated.
Sec. 304-National Recreation Area System: Since the Park Service’s National Recreation Areas will not be included in this system, this provision could add confusion to an already complicated system of land management agencies managing areas with similar names but with different management priorities and policies. The National Park Service has its own set of National Recreation Areas that are managed differently than those that would be included in this system.
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