The essence of your proposal is to adjust the commercial and
private allocations to attain an equal wait in both sectors. I
won't quibble with your numbers (let's pin down the principles
first), but I will prod you to put some more detail into a
couple of areas.
First, you assume that there won't be an NPS wait list for
commercial customers; instead, each company would
maintain their own wait list. Here's my question--how would NPS
know, with reasonable certainty, how long the wait for
commercial customers is if the lists are maintained by the
concessionaires? How would you insure that the data given to
NPS are realistic. I know you're sensitive about how commercial
operators are portrayed, but I'll bet you that many of them
fudge on their income taxes--things like personal vehicles
claimed as business vehicles and the like. Is it possible
they'll fudge on their reporting requirements to the NPS? What
safeguards would be appropriate?
Second, comparable waits should be under comparable conditions.
Otherwise you're comparing apples and oranges. Any fees or
administrative requirements imposed by NPS on the private list
should be imposed on the commercial customers, collected by the
concessionaire and passed on to NPS. (This might be one way of
providing some accountability in the reporting process.) Fees
collected in this way could be offset against any commercial
license fees due from the company so the total cost of the trip
would remain the same. If current policies are a guide, these
fees would be non-refundable.
You seem to advocate that NPS should not increase overall use,
but should reallocate existing use. I fully agree with this.
But, use is not only allocated between private and commercial
sectors but within the commercial sector fixed amounts of use
have been granted to each company. My third question is how you
would re-allocate use within the commercial sector when you
adjust overall commercial use? (This is a big problem and one
reason why I think it very likely that NPS will expand overall
use in order to raise the private allocation.)
My fourth question is how often you would propose NPS should
revisit the allocation?
You are right that, properly done, your method would give close
to the same result as a demand-driven system (the "common pool
thing"). If you and others out there can work out the details on
how to make realistic adjustments, a system like this could be an
acceptable system.
Having said that, I still find it troublesome that with this
system concessionaires would still charge for access to a public
resource (as opposed to charging just for the services they
offer). This is contrary to the principles set out in the NPS
organic act and eventually may be challenged as part of a more
generic attack on all sorts of concessions. I also think that
insulating commercial passengers from NPS isolates NPS from good
information that it could use to improve management of the
river.
I'd like to see you flesh this proposal out (hopefully here or
on riveraccess). Do you plan to suggest it to NPS as part of
the CRMP process?
Ben
-- -------------------------------------------------- -- Ben Harding blh@hydrosphere.com -- -- Hydrosphere Resource Consultants -- -- Hydrosphere Data Products -- -- 1002 Walnut, Suite 200 -- -- Boulder CO 80302 -- -- -- -- 303-443-7839 voice 303-442-0616 fax -- -- -- -- Publishing Natural Resources Data on CD ROM -- -- Consultants in Natural Resources Planning -- -------------------------------------------------- ==================================================================== To subscribe, send email to majordomo@songbird.com, with "subscribe gcboaters" as the only line in the message body. To unsubscribe send "unsubscribe gcboaters". For further information send "info gcboaters", or see http://www.songbird.com/gcboaters ====================================================================