>Well, now we're cooking. This is a decent proposal.
>
>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.
>
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?
Guess I'm with Dave on this one. I don't think this info will be all that
hard to come by, and don't expect overwhelming dishonesty by the companies.
>
>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.
Not sure I'm understanding. Seems to me, if things are to be comparable,
then just as the commercials must pay what privates pay, the converse also
holds true. So, if commercials have to pay the private waitlist fee etc,
then they wouldn't ALSO be paying a licensing fee, or else the privates
would have to pay a licensing fee too. I have always thought that
commercials pay for a license which is their permit and it allows them to
take X number of people down; this is equivalent to the permit fee that a
private group pays, allowing them to take X number of people down. THe
outfitter's license fee is passed on to the customer in the cost of the
trip, so those passengers are laready, in effect, paying a permit fee. I
don't know how much those fees are for each commercial passenger. I imagine
before the new private fees commercial peeps paid much more in overall fees
to the Park than privates did. I don't know if that has changed now.
>
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.)
This is a big problem. I was basically thinking that market forces would
force the consolidation of companies so there would be fewer companies
serving the commercial pool. Since the pool would be smaller, it would be
harder to make money off it, and companies would buy each other out so
there would end up being a smaller number of companies but those that
survive still taking down about the number of passengers they do now. As I
mentioned, this would probably have both good and bad side effects. I'm
afraid I don't know enough still about how commercial permits are allocated
among comapnies to say anything particularly useful about that.
>
>My fourth question is how often you would propose NPS should
>revisit the allocation?
Good question. I wonder if you could do kind of a running thing. Probably
not. I dunno - pick a number - 10 years?
>
>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.
>
Well, I think as long as concessionaires are charged for access (through
licensing fees), their passengers will be charged for access. It's
impossible that they would not pass that cost on. It's the nature of doing
business. So, to remove the cost of access from commercial boating, the
permits would have to be free. Then someone would have to come up with a
new way of choosing who gets the commercial permits that is different than
the bid system or whatever they use now. This would probably generate a lot
of problems, nasty under-the-table politics (which may already go on), and
so on. But, maybe someone would come up with a good idea. The problem
though, with, say, trading off who gets the permits every few years, is
that no-one could build a decent business if they knew they would only have
it for 5 years. They would at least have to have to possibility of
maintaining a long-standing business or no-one would do it.
The other problem with getting rid of paid commercial permits, is that NPS
would lose money which they wouldn't tolerate. So they would take the money
from somewhere else, probably a good fraction from private boaters.
As it is, aren't we all paying for access, private and commercial? I feel
when I shell out 100's of dollars to NPS for a trip that I am decidedly
paying for access.
>
>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
>--
Well, like I said, it's kind of off the top of my head. I have a newfound
though short-lived freedom right now. I haven't had time to think about or
plan much of anything over the past few months, finishing up the old PhD.
So, I've been uninvolved in all of this so far, except letters to the
senators etc. I just reponded to your comments with what struck me then.
Maybe I can put some time into this now.
Sorry my fleshing out hasn't really added much. Your questions and points
are good ones. Let me think about it more. Also, some of my problem is not
quite understanding what you mean when you talk about charging for access
etc. Maybe you could spell that out for me 'cause I seem not to be getting
it.
Judy
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