# Presentation: 933205

## Christine Chui Lee
PRIZIM Inc. Consultant for the 
NPS Concession Program
June 2, 2008

**PRIZIM Inc. Consultant for the **
**NPS Concession Program**
**June 2, 2008**

**Advancing Executive Order 13423 Goals with Federal Agency Partners**

## Slide 2

**Notes:**
Who are NPS concessioners?  They are horse wranglers (BRCA002 – Bryce-Zion Trail Rides) . . . 

Skim through these photos.

## Slide 3

**Notes:**
Who are NPS concessioners?  Marinas (GATE003 – Marinas of the Future) . . .

Skim through these photos.

## Slide 4

**Notes:**
Who are NPS concessioners?  Retail stores (unknown park and concessioner)

Skim through these photos.

## Slide 5

**Notes:**
Who are NPS concessioners?  Food operations (ROMO001-under old Forever Resorts)

Skim through these photos.

## Slide 6

**Notes:**
Who are NPS concessioners?  Lodging (YELL077 – Xanterra Parks & Resorts, Old Faithful Inn)

Skim through these photos.

## [The National Park Service] ...shall promote and regulate the use of the...national parks...which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.

***[The National Park Service] ...shall promote and regulate the use of the...national parks...which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.***
***National Park Service Organic Act, 16 U.S.C.1.***

**Notes:**
What is the NPSCP?  It starts with the mission.

The NPS mission has two key parts.  One that talks to sustainability and preservation of resources.  The second part talks about providing for “quality visitor services” within national parks.

The Concessions Policies Act of 1965- Set forth the first official Law stipulating that the NPS was to provide for visitor services.  This legislation was updated in 1998.

## NPS Concession Program Mission

*2006 NPS Management Policies*

**NPS Concession Program Mission**

**Notes:**
In 1998, the National Omnibus Management Act (Public Law 105-391) was passed which substantially changed the manner in which the NPS awards concession contracts, as well as the terms and conditions for new contracts.  It also resulted in an opportunity for the NPS to emphasize resource protection and environmental management.

## NPSCP Responsibilities

**CONTRACT DEVELOPMENT**

**CONTRACT MANAGEMENT**

**Environmental Management**

**Asset Management**

**Financial Management**

**Professional Development & Training**

- Communications

- Policy, DOs & RMs

- Outreach

- Info. Technology

**NPSCP Responsibilities**

**Notes:**
NPSCP GOALS:
Timely prospectus development
Integrated information management system
Well-trained workforce
Determined possessory interest valuations
Responsible facility management
Quality visitor services
Sound fiduciary responsibility
Relevant guidance to stakeholders
Sound environmental management
Effective commercial services planning

## NPSCP At-A-Glance

- $885 million in concessioners’ gross receipts
- 23% in merchandise and retail
- 21% in lodging
- 19% in food and beverage
- 590 contracts
- 10% of contracts generate 82% of gross receipts
- 70% of contracts are under $500,000 in gross receipts annually
- Average of 3.4% franchise fee on all contracts
- About 6,000 commercial use authorizations
- 200 NPS and 23,000 concessioner employees

**Notes:**
More specifically, the NPSCP oversees:

590 contracts in 130 parks

$885m is 2005 gross receipts data.

10% of contracts = 55 (these contracts generate over $3 million annually)
70% of contracts = 382 (these contracts generate under $500,000 annually)

##   NPS Concession Program (NPSCP)

**Notes:**
Percentages based on 2004 gross receipts data.

 The contracts are grouped into eight key business types:
Lodging-a variety of overnight accommodation from cabins to full service hotels.
Food and beverage (F & B) - snack bars as well as full service restaurants and lounges.  
Marina - wet and dry storage and marina services.
Transportation - both ground and water transportation
Recreation - commercial recreational activities such as canoe and boat rentals, rafting and guide services and firewood sales.
Retail/ Merchandise - grocery and merchandise sales
Fuel and auto - gasoline sales as well as automobile services.
Other - non-typical concession operations including residential trailer villages and medical facilities.

## A Brief History of the NPSCP and Environmental Management

**1916:**  National Park Service Organic Act establishes the NPS

**1965:**  Concession Policy Act establishes the Concession Program

**1998:**  National Parks Omnibus Act reforms the Concession Program

**1999:**  Concession Program environmental management group established

**2000:  **Updated standard concession contract language released (65 FR 87)

**2004**:  Director’s Order 13A – Environmental Management Systems approved

**2006:**  NPS Management Policies finalized

**Notes:**
Why the NPS Concession Program and why environmental management?  It includes the laws, regulations, and policies that have been established over time.

## EO 13423:  Duties of Heads of Agencies (selected)

- Implement sustainable practices within agency
- Ensure integration of EO requirements within the EMS at all appropriate organizational levels
- Establish agency programs for environmental management training, audits, and leadership awards
- Ensure contracts for contractor operated government facilities or vehicles require compliance with the EO
- Ensure legally-binding obligations between the agency and concessioner require, to the extent determined by Director, that the concessioner take actions within the scope of the contract to facilitate the agency’s compliance with this order

**Notes:**
What are agency responsibilities with respect to EO 13423?  How do concessioners fit in? 

EMS – concessioner activities that affect an agency’s environmental, transportation, or energy
issues will be addressed in the development, implementation and maintenance of the concessioners EMS.  Concessioner EMSs can help support and enhance park goals/targets in their EMS

EO 13423 required if written into a concession contract; but the implementing instructions also say
that it's up to the Director to decide how applicable the EO is to concessioners - and that guidance
has not yet come out.

Now that we know how EO 13423 applies to concessioners – let’s see what the actual goals are.

## EO 13423 Goals

- Improve energy efficiency and reduce greenhouse gas emissions
- Use renewable energy and implement renewable energy projects
- Reduce water consumption

**Notes:**
What exactly does EO 13423 require of federal agencies?

For each – give examples of what concessioners are already doing.

Energy Efficiency:  Reduce energy intensity by 3% annually through 2015 OR 30% by end of FY 2015 (baseline is energy usage in FY03)
Water Efficiency:  Reduce water intensity by 2% annually or 16% total by FY2015 (baseline is water usage in FY07)
Fleet Vehicles:  Reduce total consumption of petroleum by 2% annually through end of FY2015; increase non-petroleum-based fuel consumption by 10% annually; use plug-in hybrid vehicles when commercially available at a comparable cost (baseline is FY05 and applies only to fleets of at least 20 motor vehicles)

Top:  non-concessioner photo of wind energy
Bottom:  non-concessioner photo of hotel room

## EO 13423 Goals

- Acquire environmentally preferable goods and services
- Reduce quantity of toxic and hazardous chemicals being acquired, used and disposed
- Maintain cost-effective waste prevention and recycling programs

**Notes:**
What exactly does EO 13423 require of federal agencies?

For each – give examples of what concessioners are already doing.

Energy Efficiency:  Reduce energy intensity by 3% annually through 2015 OR 30% by end of FY 2015 (baseline is energy usage in FY03)
Water Efficiency:  Reduce water intensity by 2% annually or 16% total by FY2015 (baseline is water usage in FY07)
Fleet Vehicles:  Reduce total consumption of petroleum by 2% annually through end of FY2015; increase non-petroleum-based fuel consumption by 10% annually; use plug-in hybrid vehicles when commercially available at a comparable cost (baseline is FY05 and applies only to fleets of at least 20 motor vehicles)

Top:  BIBE002 – NPCI (i.e., Forever Resorts) – recycling 200 miles away, have staff to assist NPS in recycling program
Bottom:  ZION003 – Xanterra Earth Composters

## EO 13423 Goals

- Comply with agency sustainable building principles
- Reduce consumption of petroleum products
- Acquires, manages, and disposes of electronics in an environmentally sound manner

**Notes:**
What exactly does EO 13423 require of federal agencies?

For each – give examples of what concessioners are already doing.

Energy Efficiency:  Reduce energy intensity by 3% annually through 2015 OR 30% by end of FY 2015 (baseline is energy usage in FY03)
Water Efficiency:  Reduce water intensity by 2% annually or 16% total by FY2015 (baseline is water usage in FY07)
Fleet Vehicles:  Reduce total consumption of petroleum by 2% annually through end of FY2015; increase non-petroleum-based fuel consumption by 10% annually; use plug-in hybrid vehicles when commercially available at a comparable cost (baseline is FY05 and applies only to fleets of at least 20 motor vehicles)

Left:  YELL077 – Xanterra – employee housing built on brownfield (LEED silver)
Right:  GLAC001 – Glacier Park Boat Company – worked with supplier on biodiesel boats in remote area

## Meeting EO 13423 Goals: Contractual

- Standard contract language
- EMS, BMPs, EPCRA reporting
- Customized operating and maintenance (O&M) plan language
- Training, energy & water management, design/renovation of structures, environmental purchasing
- Selection Process: Principal Selection Factor 1 (PSF1) and Secondary Selection Factor 1 (SSF1)
- Include issues important to park (e.g., alternative energy, waste reduction, other) & incorporate proposed activities into final O&M plans

**Notes:**
How does NPS work to incorporate EO 13423 goals into concession operations?

Ways that concessioners can help the NPS meet EO 13423 goals (note that concessioners are NOT subject to FAR).

NPS is unique in that we are one of the few agencies that have a Law and regulations that dictate how we will manage businesses operating in parks

## Meeting EO 13423 Goals: Outreach

- Samples
*GreenLine* Resources
- Newsletter
- CD
*Tech. Assist N*umber (303.987.6913)
- Email: _NPS_GreenLine@nps.gov_
- Website: _www.concessions.nps.gov/CoEMP.cfm_
- Training and conferences for superintendents and park staff
- On-site assistance during other tasks such as audits and evaluations

**Notes:**
We’ve implemented the EMP at concessioner locations through many means.  It involves educating concessioners AND park staff.

## Challenges: Administrative

- Accounting for environmental costs
- Internal communication
- Compliance assurance
- ISO 14001 certification
- Approve vs accept:  NPS liability
- Park EMS and concessioner EMP

**Notes:**
We’ve encountered a number of challenges, concerns, issues, and questions from Washington, DC management, regional staff, park staff, and concessioners, but we are working to address them as they arise.  Some administrative challenges that we have faced include:

Accounting for and Allocating Costs for EM. Need to consider EM as part of initial contract financial analysis, including both costs and overall potential savings to be achieved over the life of the contract.  Should also highlight issue of whether or not the “cost” of EM should/could be transferred to the visitor?  For example, should the rates for organic/sustainable foods be a premium?  Should concessioners be able to charge visitors more for “green rooms?”
Internal communication. Field and regional staff aren’t environmental experts; don’t always know that WASO can help.  But have created a central repository and technical assistance tool at national level for consistency and to support parks.  Also ensuring proposal information is transferred to contract to ensure the parks are getting what the concessioner committed to in their proposal. 
Compliance assurance.  Many assume that if a concessioner has an EMP, then this means they are compliant with all regulations, BMPs, etc. and that the park accepts/certifies that they are compliant with all regulations, etc.  This is not the case!  It just means they have a system in place to manage environmental concerns.
ISO 14001.  Many used to assume that the NPS favored concessioners who had ISO 14001 certification.  This is not the case!  ISO 14001 is expensive and the money could be used for other purposes; concessioners can have a fully functioning EMP without needing to get ISO 14001 certification.  Many of the larger concessioners have decided to get it anyhow, though.
NPS approving or accepting concessioner EMP.  Our language says we must approve – but perhaps we only want to accept.  Legal issue that we are working through now since “approval” may imply that we agree the concessioner is complying with regulations.
Park EMS and concessioner EMP.  Language is confusing between park and concessioner staff.  E.g., ECS vs policy; no facility interactions for EMP; documentation element – have 3 for EMP and only 1 for park EMS.

## Challenges: Implementation

- Buy-in
- Implementation oversight
- Tracking performance data (solid waste reduction, energy savings, etc.) – CDMS
- Tracking audit data
- Education

**Notes:**
We’ve encountered a number of implementation/monitoring challenges as well.  A few examples include:
 Buy-in. Demonstrating that Environmental Management is “part of doing business”:  Historically, environmental management was considered “another” program to add onto what folks were doing.  In order for it to be successful, need to integrate into and throughout all business practices/levels.  As concessioners realize there is cost savings, business efficiencies, and “marketing appeal” (e.g., guests are demanding green businesses), they are embracing a more comprehensive EM program.
Implementation oversight/Bureau monitoring.  Park staff not having either time/expertise to monitor the program to see whether concessioners have a (1) working EMP and (2) are adhering to that program.  This goes to, at a minimum, ensuring compliance by way of follow-up to NPS audits, ensuring that the concessioner is submitting the required environmental reports required under the contract, etc.  Concession specialists are “jack of all trades” and don’t have luxury of becoming an expert in a particular area b/c of time (i.e., resources limited at park level).  But have WASO-level expertise to assist those at the Park level.
Performance.  Tracking data to show progress – CDMS under development
Audit.  Challenge of tracking audit data follow-up – there needs to be follow-up and accountability.
Education:  Travel budget restriction – but it’s easier to train in person.  ISO 14001 favored or not?  No.
Top:  YELL – snowmobiles lined up at West entrance in the winter (no CONCID).  From YELL website.
Bottom:  YELL077 (Xanterra). From YELL website.

## Successes

- Improved awareness of environmental management
- Improved understanding of compliance
- Creativity and support for environmental best management practices
- Education of park visitors on environmental management
- Resource protection
- Models of sustainable tourism

**Notes:**
Despite challenges, lots of progress has been made since the beginning . . . 

Improved awareness by concessioners, park staff, stakeholders, third parties (awards) and hospitality industry
Improved understanding by concessioners of regulatory environmental requirements, and what they need to do in order to be considered in compliance with those regulations
 Larger (and even smaller) concessioners are now leading in pushing the envelope (ie., green rooms at some facilities) and have won a number of national/international awards recognizing these efforts

## Case Study:  Xanterra Parks & Resorts

- National company
- Hired full-time staff for environmental affairs
- Achieved ISO 14001-certified EMS at multiple sites – including those not in NPS
- Publish publicly-available sustainability report
- Won multiple environmental awards
- Implement multiple BMPs
- Green rooms

**Notes:**
Case study:  large concessioner

Some of the environmental ??  That Xanterra has implemented include:
ISO14001 certified EMS at parks (and other sites)
Publish annual sustainability report = transparency.  Emphasize importance of communicating programs (signage, visitor information, etc.)
They look at and abide by government requirements even though they are not required to do so.
There is an internal audit program in place, which helps to identify BMPs that are later implemented.
Hired full-time environmental staff soon after NPSCP started its environmental program.
Transfer of programs/technologies embraced within national parks to other state and private properties/locations.  For example, would show their solar array in Death Valley. 
New initiative to replace all guest room amenities (WEBE press release).  Highlight green rooms to illustrate point about cost for green programs and who should pay (e.g., visitors, NPS, concessioner)

## Case Study:  The Power of the GreenLine Newsletter

**Case Study:  The Power of the GreenLine Newsletter**

- Oli’s Trolley (Acadia NP)
- Reuse of park brochures
- Recycling container on-board
- Minimal cleaning chemicals used
- Katmailand, Inc. (Katmai NP & Preserve)
- Developed EMP, per contract requirements
- Set goals that could reach in a remote location

**Notes:**
Case study:  small concessioner.  EMP is not only for the big companies; needs to be tailored though.  Not one size fits all.

NEWSLETTER ARTICLE FOR BACKGROUND:
Katmailand, Inc. operates both Grosvenor Lodge and Brooks Lodge in the park, and was one of the first concessioners to sign a new NPS concession contract requiring a documented Environmental Management Program (EMP).
Guest accommodations at Brooks Lodge consist of 16 modern rooms with showers, private toilet facilities, heat, and electricity. Grosvenor Lodge can accommodate six guests at a time in three cabins, which have heat and electricity.  Another challenge facing Katmailand management is its remote location. The lodges are 300 miles away from Anchorage, and everything going in (such as food, supplies, and guests) and out (such as solid waste and recyclables) must be transported by small float planes.
Some environmental policies and standard operating procedures now in place because of the EMP include: 
1. Placing written materials about Katmailand’s environmental commitment in guestrooms. 
2. Installing low-flow water fixtures when replacing old fixtures. 
3. Replacing incandescent light with compact fluorescent lights. 
4. Converting ethylene glycol antifreeze systems to propylene glycol-based products. 
5. Recycling aluminum cans. 
6. Educating staff and guests on Leave No Trace and Tread Lightly! principles. 
7. Using green procurement principles when purchasing cleaning and office materials. 
8. Developing a hazard communication program. 
Since Katmailand only operates 3 1/2 months out of the year, the 2002 season will be its first year of EMP implementation. 

## Take Home Points	

- Collaborate to achieve goals
- Ensure contract language is consistent
- Communicate
- Standards
- Expectations
- Positives
- Offer assistance
- Be creative & flexible
- Manage data

**Notes:**
Collaborate.  Involve concessioners and other partners (cooperating associations, friends groups, permittees, leases, etc.) in helping you achieve EO 13423 goals, as well as in developing your facility’s EMS.  Help them to develop an understanding of your facility’s goals so that they can set appropriate goals and targets within their own facilities. Emphasize importance of parks/entities engaging concessioners/third parties at the beginning and in on-going “green team” meetings to make sure they are always engaged and providing their perspective.  

Language.  Ensure contract language is consistent with terminology used by your agency.  You may need to evolve the language/requirements as the program matures to help clarify language and/or include more current vocabulary/terms.

Communicate.  Always communicate with field staff, regional staff, and concessioners on what your expectations are and what contract language means.  Also, remember to communicate the positives – point out areas where they are excelling!!

Offer assistance!!  Even if they’ve heard it once doesn’t mean that its been retained.

Be creative and flexible.  Develop new and different methods of training/communication in order to get your points across.  This could include monthly conference calls (concession chats), an approach that has proven very effective for the NPSCP as a tool for communicating issues/trends on a national scale. Emphasize flexibility and understand that depending on size and complexity of operation the EMS could be 5 pages or 500; but it is also important to be flexible to allow concessioners to tie to/link with other documents they maintain as a business to advocate integration with the business model.  

Manage Data.  Figure out how to request and track data on a regular basis from your partners.  Consider as part of contract development, and clearly define reporting requirements in contracts.  How you will manage and track (esp follow-up).  Can talk in general about CDMS and how this will allow parks, eventually, to track environmental data in one system.  

## Standard Concession Contract

**Notes:**
Specifically, the EMS/EMP is written into the Standard Contract language.