GAO

United States General Accounting Office

Report to the Chairman, Subcommittee

on National Parks, Historic Preservation,

and Recreation, Committee on Energy

and Natural Resources, U.S. Senate

March 2000 PARK SERVICE

Need to Address

Management

Problems That Plague

the Concessions

Program

GAO/RCED-00-70

Page 1 GAO/RCED-00-70 Problems in Managing Park Concessioners

Contents

Letter 3

Executive Summary 4

Chapter 1

Introduction

12

Background 13

Condition of Lodging Facilities in National Parks Varies

Considerably 16

Scope and Methodology 20

Chapter 2

Long-Standing

Management Problems

Affect the Condition of

Lodging Facilities

23

More Qualified and Better-Trained Staff Would Improve the

Concessions Program 23

Management of the Concessions Program Lacks Accountability 35

Other Factors May Also Affect the Condition of Lodging Facilities 43

Conclusion 45

Agency and Industry Comments and Our Evaluation 46

Chapter 3

Options Are Available

to Address Problems in

Managing the

Concessions Program

47

Professionalize and Improve the Training of the Agency’s Workforce 48

Contract for Needed Business and Contracting Expertise 50

Improve Accountability for the Concessions Program 53

Conclusions 54

Recommendations to the Secretary of the Interior 55

Agency Comments and Our Evaluation 55

Appendixes Appendix I: Results of GAO’s Inspections of Lodging Facilities

in Two Parks 56

Appendix II: Comments From the Department of the Interior 75

Appendix III: Comments From the National Park Hospitality

Association 76

Appendix IV: GAO Contact and Staff Acknowledgments 78

Tables Table 1: Parks and Concessions Contractors Contacted 21
Contents

Page 2 GAO/RCED-00-70 Problems in Managing Park Concessioners

Table 2: Notable Reports and Memorandums That Raised

Concerns About the Qualifications and/or Training of Park Service

Concessions Staff 28

Table 3: Training and Experience Required to Execute the

Park Service’s Procurement and Concessions Contracts 31

Table 4: Notable Reports or Documents That Discussed the

Need for Accountability Within the Concessions Program 39

Table 5: Notable Task Force Reports or Documents That Raised

Concerns About the Use of Collateral Duty Staff in Managing

Concessions 43

Table 6: Poor Condition of Public Bathroom and Shower Facilities 66

Table 7: Results of GAO’s Room Inspections 70

Figures Figure 1: Examples of Lodging Facilities Found in the National

Park System 15

Figure 2: Typical Motel Rooms in Very Good Condition at Bryce

nd Zion National Parks 17

Figure 3: Needed Exterior Repairs at a Lodging Structure at Stovepipe

Wells in Death Valley National Park 18

Figure 4: Repair and Maintenance Problems in Rooms at Stovepipe

Wells 19

Figure 5: Abridged Organization of the National Park Service 36

Figure 6: Needed Exterior Repairs at Log Cabin Resort 58

Figure 7: Condition of Cliff Near Kalaloch Lodge in Olympic

National Park 59

Figure 8: Grounds at Grant Grove 65

Figure 9: Exposed Wiring in Public Bathroom and Shower Facilities 67

Abbreviations

FAR Federal Acquisition Regulation

GAO General Accounting Office

GPRA Government Performance and Results Act

NPS National Park Service

OMB Office of Management and Budget
United States General Accounting Office

Washington, D.C. 20548

Page 3 GAO/RCED-00-70 Problems in Managing Park Concessioners

Resources, Community, and

Economic Development Division

B-284573 Letr

March 31, 2000

The Honorable Craig Thomas

Chairman, Subcommittee on National Parks,

Historic Preservation, and Recreation

Committee on Energy and Natural Resources

United States Senate

Dear Mr. Chairman:

This report responds to your request that we review (1) factors affecting the condition of lodging

facilities in the National park system and (2) options available to address these factors.

As arranged with your office, unless you announce its contents earlier, we plan no further distribution

of this report until 14 days after the date of this letter. At that time, we will send copies to the

Secretary of the Interior and to the Director of the National Park Service. We will also make copies

available to others on request.

Please contact me on (202) 512-3841 if you or your staff have any questions.

Sincerely yours,

Barry T. Hill

Associate Director, Energy,

Resources, and Science Issues
Page 4 GAO/RCED-00-70 Problems in Managing Park Concessioners

Executive Summary

Purpose Concessioners play a significant role in providing services to many of the

over 270 million visitors to the national park system each year.

Concessioners are private businesses that operate under contracts with the

National Park Service to provide facilities and services, such as lodging,

food, merchandising, marinas, and various guided services. In August 1998,

GAO reported that the condition of lodging facilities varied considerably

from park to park and was at times quite poor.1 Concerned about these

varying conditions, the Chairman, Subcommittee on National Parks,

Historic Preservation, and Recreation, Senate Committee on Energy and

Natural Resources, asked GAO to identify (1) factors affecting the

condition of lodging facilities in the national park system and (2) options

available to address these factors.

Background The Department of the Interior’s National Park Service manages 379 park

units—such as national parks, national historic sites, and national

battlefields—located all across the nation. Concessioners provide services

to visitors in many of these units. In 1998, the latest year for which data are

available, 630 concessioners provided visitor services in park units that

grossed about $765 million in revenues. Of the $765 million in revenues

generated by concessioners, about $479 million (almost two-thirds) came

from the 73 concessioners that provided lodging accommodations.

For many years, concerns have been raised by the Congress, the Park

Service, and GAO about the need to reform existing concessions law and

the need for better management of the agency’s concessions program. In

November 1998, the Congress enacted a new concessions law as part of the

National Parks Omnibus Management Act of 1998. One of the intentions

and expectations of the new concessions law was that it would increase

competition in the awarding of new concessions contracts. In addition, the

law established an advisory board whose mission was to advise the

Secretary of the Interior on improvements the agency could make in

managing park concessioners. Since the passage of the law, the Park

Service has been working to issue new concessions regulations, which the

agency expects to finalize in April 2000.

1

National Park Service: The Condition of Lodging Facilities Varies Among Selected Parks

(GAO/RCED-98-238, Aug. 6, 1998).
Executive Summary

Page 5 GAO/RCED-00-70 Problems in Managing Park Concessioners

Results in Brief After considering numerous site-specific factors that could potentially

affect the condition of lodging facilities−such as whether the facilities were

used year-round or just seasonally, whether the facilities were owned by

the government or by the concessioner, whether the facilities were

designated as historic structures, and others−GAO found that the most

significant factors are those involving the agency’s overall approach to

managing the program. Specifically, the management problems center on

three areas: (1) inadequate qualifications and training of the agency’s

concessions specialists and concessions contracting staff, (2) the agency’s

out-of-date practices in handling its contracting workload and chronic

backlog of expired contracts, and (3) a lack of accountability within the

concessions program. For the most part, these problems are long-standing

and are consistent with similar concerns raised by the Department of the

Interior, its Office of the Inspector General, and Park Service concessions

staff. Because of these problems, the Park Service frequently has difficulty

managing the performance of its concessioners to ensure a consistent level

of quality in the services and facilities they provide.

The Park Service has two principal options for dealing with the problems

identified in its management of the concessions program: (1) using better

hiring and training practices to professionalize its workforce and thus

obtain better business and contracting expertise or (2) contracting out to

acquire the needed business and contracting expertise. These two options

are not mutually exclusive in that the agency could contract for expertise in

certain functions while developing expertise in-house for other functions.

Both options require that the agency better manage its human capital to

ensure that it selects, trains, develops, and manages concessions staff who

have the skills needed to bring about improvement in the concessions

program. Regardless of what options—or combination of options—it

selects, the agency needs to strengthen its accountability for and control of

the program. Unless this is done, the effectiveness of other changes to the

program will likely be diminished.
Executive Summary

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Principal Findings

Long-Standing Management

Problems Affect the

Condition of Lodging

Facilities

On several occasions, the Department of the Interior’s Office of the

Inspector General and the agency’s own staff have raised concerns about

the qualifications and training of the Park Service’s concessions staff. The

primary concern raised was that the agency’s concessions staff do not

normally have the business, financial, and contracting backgrounds needed

to successfully carry out the concessions program. However, the Park

Service has made only limited progress in addressing these concerns. It has

made few efforts to professionalize its workforce by hiring staff with

education or experience in business management or hospitality

management. Instead, it has filled concessions positions through internal

transfers—moving staff out of other career fields and into the concessions

program. Once transferred, these staff receive only limited training. A more

qualified and better-trained workforce would have a better understanding

of trends in the industry, best practices, and the tools needed to effectively

manage concessioners. Rather than seeking to professionalize the

concessions workforce, the agency has taken the view, expressed by the

chief concessions official in one regional office, that “anyone can do

concessions.” GAO’s work indicates that this comment typifies the agency’s

approach to managing its concessions program.

In addition to the problems with the qualifications and training of its

concessions staff, the Park Service’s concessions contracting practices are

out-of-date and do not reflect the best practices of the federal government,

the private sector, or other contracting practices within the agency. For

example, contracting staff in other agencies throughout the federal

government are encouraged to write contracts that are performance

based—meaning that the contracts contain incentives for good

performance and disincentives for performance that falls below

expectations. However, the agency’s concessions program is not using

performance-based contracts; and according to several senior Park Service

concessions program officials, the agency has no plans to do so.

Furthermore, for about 10 years, the agency has had difficulty addressing

its contracting workload in a timely manner, resulting in chronic backlogs

of expired concessions contracts. Many concessions contracts expired 5 to

10 years ago, and concessioners have since been operating on 1- to 3-year

contract extensions. These expired or extended contracts contribute to the

varying condition of lodging facilities because concessioners operating

under short-term contract extensions, or nearing the end of their contracts,
Executive Summary

Page 7 GAO/RCED-00-70 Problems in Managing Park Concessioners

are less likely to invest in their facilities to make needed capital

improvements.

The third major management issue affecting the concessions program is a

lack of accountability. While the Park Service, like other federal agencies,

is trying to improve accountability and program performance in response

to the Government Performance and Results Act of 1993 (GPRA) and other

related initiatives, the concessions program is an area where these efforts

need to be improved. Under the agency’s organizational structure, the head

of the program—the Chief of Concessions—has no direct authority over

those that implement the program in individual park units. Thus, the

organizational structure of the agency limits the impact that the head of the

program or other central offices can have on its ultimate success. This

structure relies on regional directors’ holding park superintendents

accountable for the results of their parks’ concessions programs. However,

concessions officials in the Park Service’s headquarters and two largest

regional offices indicated that this is not occurring. Specifically, they

acknowledged that superintendents are not being evaluated on the results

of their concessions programs. As a result, it is not surprising that this lack

of accountability exists. Further contributing to this lack of accountability

is the fact that there is no process in place for headquarters or regional staff

to ensure that park concessioners are meeting the agency’s minimum

acceptable standards or that these standards are being consistently

applied. In the private hotel/motel industry and the Department of

Defense—which manages similar activities—independent inspection teams

are used to determine the condition of the facilities and services being

provided to the public. The Park Service does not have such teams. As a

result, Park Service management has no systematic way of identifying

agencywide problems and determining whether corrective actions are

needed or new initiatives are warranted.

Options Are Available to

Address Problems in

Managing the Concessions

Program

Two options are available to deal with the problems identified in the

management of the concessions program: (1) professionalize the

workforce to obtain better business and contracting expertise or (2)

contract for the needed business and contracting expertise. To

professionalize its concessions workforce, the Park Service could change

its hiring practices and upgrade its training. Rather than filling positions in

the concessions program with staff transferred from other career fields, the

agency could hire staff with backgrounds or education in hospitality and/or

business management. Through this approach, the agency would gradually

develop greater in-house expertise in managing concessioners in a more
Executive Summary

Page 8 GAO/RCED-00-70 Problems in Managing Park Concessioners

businesslike manner. In addition, the agency could upgrade the training of

its concessions contracting staff so that they were as well qualified as the

agency staff involved with contracting outside the concessions program.

The benefit of pursuing this option would be that the agency would develop

a more qualified, better-trained, and professionalized concessions

workforce. However, the agency’s past record in taking action to address

these issues is not encouraging. Many of the concerns raised in this report

about the qualifications of the Park Service’s concessions staff have

surfaced repeatedly over the past 10 years in reports by the Department of

the Interior’s Inspector General and by several different departmental or

agency task forces. Several times over this period, the Park Service has

generally agreed that it needs to professionalize its concessions workforce,

but, as GAO’s work indicates, the agency has not made significant progress

in this area. Hence, the agency’s past experience suggests that there can be

little confidence that the agency will address these issues.

Instead of professionalizing its workforce, the Park Service could contract

for the expertise it needs to operate its concessions program. Contractors

could be hired to handle a number of financial and business-related tasks

such as planning, writing contract prospectuses, performing financial

analysis, assisting with contracting, and evaluating the performance of

concessioners.

Contracting for the business-related staff could have several benefits. For

example, through contracting, the agency could obtain a highly qualified

workforce in a short period of time. In addition, it would gain some

flexibility in staffing and could adjust the number of staff to fit the size of

its upcoming workload. Contracting could allow it to bring more staff on to

handle its backlog of expired and expiring concessions contracts and cut

back on its contractor staff when the workload is diminished.

Furthermore, contracting for certain functions has the potential to improve

performance as well as reduce some costs. For example, traditionally,

inspections of concessioners’ facilities and operations are a responsibility

of park concessions staff. These inspections can be subjective, and the

application of standards can vary from park to park. If the agency

centralized and contracted for this function, it could perhaps perform

inspections with fewer people and yet achieve greater consistency across

the agency.
Executive Summary

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While contracting has some potential to reduce costs in the concessions

program, it could also increase costs, particularly areas where the agency

would contract for larger numbers of highly skilled staff than it currently

maintains. However, some of the increased costs of contracting for more

qualified staff in the concessions program could be mitigated by

centralizing certain functions, such as inspections. In addition, the

increased costs could be mitigated by reducing the number of agency staff

in the concessions program.

These two options are not mutually exclusive, in that the agency could

contract for expertise in certain functions while developing the expertise

in-house for other functions. These options are principally focused on

improving the agency’s management of its largest concessioners—most of

which are lodging concessioners. In GAO’s view, once the agency has made

changes in the concessions program to address its largest concessioners,

the benefits of additional expertise−whether acquired through hiring,

training, contracting—are likely to cascade down to improve the agency’s

management of its smaller concessioners.

Finally, no matter which option or combination of options it selects, the

Park Service will need to strengthen its accountability for and control of

the concessions program. Unless changes are made to better link

concessions programs at the park-level with the agency’s leadership of the

concessions program, efforts to improve the program through the

suggested options are unlikely to succeed.

Recommendations GAO recommends that the Secretary of the Interior require the Director of

the National Park Service to increase the effectiveness of the concessions

management program by improving the qualifications of the concessions

staff (including improving their training in writing and administering

contracts), contracting for these services, or engaging in some combination

of the two.

GAO further recommends that the Secretary require the Director of the

Park Service to improve the accountability of park managers by

establishing a formal process for performing periodic independent

inspections of concessioners’ lodging operations throughout the park

system. These independent inspection teams should determine if the

services provided by concessioners meet the agency’s standards and report

these findings to the Director for corrective action.
Executive Summary

Page 10 GAO/RCED-00-70 Problems in Managing Park Concessioners

Agency and Industry

Comments and GAO’s

Evaluation

GAO provided a draft of this report to the Department of the Interior and

the National Parks Hospitality Association—an industry group

representing park concessioners—for their review and comment. The

Department of the Interior generally agreed with the findings and

recommendations in the report. The Department stated that the

recommendations offered an opportunity to strengthen and reform the

Park Service’s concessions program. The Department indicated that the

Park Service is already taking actions to address some of the concessions

program’s management problems that were discussed in the report, and is

actively considering other actions—such as moving toward more

performance-based contracting. GAO believes that the Department’s

actions are a positive step and, if implemented, will help improve the

program.

The National Park Hospitality Association believed that the backlog of

expired concessions contracts was the single most important factor

affecting the Park Service’s concessions program, including the condition

of concessions facilities. GAO agrees that this backlog is one of the key

management problems currently facing the concessions program. The

association also believed that ownership of facilities gives concessioners

incentives to keep the facilities in good condition. While there may be such

incentives, GAO’s work indicated that ownership of facilities did not

appear to be a key factor affecting their condition. Some governmentowned facilities were in very good condition, and some were in very poor

condition. The same was true for concessioner-owned facilities.

More detailed discussions of the comments from the Department of the

Interior and the National Park Hospitality Association are included in

chapters 2 and 3. The Department of the Interior’s comments appear in full

in appendix II, and the National Parks Hospitality Association’s comments

are included in appendix III.
Page 11 GAO/RCED-00-70 Problems in Managing Park Concessioners
Page 12 GAO/RCED-00-70 Problems in Managing Park Concessioners

Chapter 1

Introduction Chapte1r

The national park system comprises 379 units or areas that include some of

the nation’s most precious natural and cultural resources. These units

include a diverse mix of sites, from crown jewel natural parks such as

Yellowstone National Park and Yosemite National Park to historic parks

units such as Independence National Historical Park and Gettysburg

National Military Park. The National Park Service, an agency within the

Department of the Interior, is responsible for managing the more than 80

million acres that make up the national park system. The Park Service’s

mission in managing the park system is to provide for the public’s

enjoyment of the parks while at the same time protecting their resources so

that they will remain unimpaired for the enjoyment of future generations.

Concessioners play a significant role in providing services at the parks to

over 270 million visitors each year. Concessioners are private contractors

that operate facilities and provide services, such as lodging, food,

merchandising, marinas, and various guided services, at 132 park units.

Concessions operations are a key element in the operation of many parks,

and a major portion of visitor services nationwide are provided through

concessions. The history of concessions contracting dates back to the

establishment of the first national park—Yellowstone National Park in

1872—where private businesses provided diverse services, such as lodging,

transportation, and camping, to visitors. Today, concessioners operate the

ferry system that transports millions of visitors to the Statute of Liberty and

Ellis Island; conduct narrated shuttle tours to 18 major sites on the

National Mall and in Arlington National Cemetery; and manage six lodges,

guided mule service, and bus tours for visitors to Grand Canyon National

Park.

In August 1998, we issued a report on the condition of concessioneroperated lodging facilities in the national park system.1 That report

demonstrated that the condition of lodging facilities, and therefore the

performance of the concessioners managing them, varied considerably

from park to park and was at times quite poor. This report discusses the

management factors that allow such widely varying conditions to exist and

suggests options to improve the management of the concessions program.

1

National Park Service: The Condition of Lodging Facilities Varies Among Selected Parks

(GAO/RCED-98-238, Aug. 6, 1998).
Chapter 1

Introduction

Page 13 GAO/RCED-00-70 Problems in Managing Park Concessioners

Background The 1916 Organic Act that created the Park Service authorized the

Secretary of the Interior to grant privileges to private businesses for the

accommodation of visitors within the national park system. To do so, the

Park Service issues contracts and permits to concessioners to provide

services in the parks. Until the passage of the National Parks Omnibus

Management Act of 1998 (1998 act), concessions contracts could be

awarded up to 30 years. However, the 1998 act provides that such contracts

shall be awarded generally for 10 years or less, unless a longer term (up to

20 years) is warranted. On June 30, 1999, the Park Service published in the

Federal Register a proposed rule to amend its regulations on concessions

contracts to comply with the requirements of the 1998 act, which provides

new legislative authorities, policies, and requirements for the solicitation,

award and administration of the Park Service’s concessions contracts. The

Park Service expects to issue final regulations in April 2000.

Within the Park Service, the Washington Concessions Division is

responsible for developing regulations, policies, and guidelines governing

the administration of the concessions program throughout the national

park system. Individual parks have the primary responsibility for

administering and implementing all aspects of the concessions program,

including planning and contracting, administering the provisions of the

contracts, approving the rates that concessioners can charge the public,

and evaluating concessioners’ operations. This responsibility includes

ensuring that the parks and visitors receive satisfactory services and

facilities from concessioners. To do this, park staff perform periodic and

annual evaluations of concessioners’ services and facilities to ensure that

park visitors receive safe, sanitary, and attractive services, equal in quality

to those that visitors would expect from the private sector operating

outside national park areas. The Concessions Program Center, located in

Denver, provides technical support servicewide in areas such as planning

for concessions operations, concessions contracting, conducting

appraisals, and conducting financial and feasibility studies relating to

concessions. In addition, each of the Park Service’s seven regional offices

has one or two support offices that provide direct assistance to parks in

such activities as planning, contracting, and reviewing concessions

operations.

The activities that concessioners conduct throughout the national park

system are quite broad in nature and size. Concessions operations range

from large lodging, food, and retail establishments generating more than

$50 million each year to very small outfitters that generate less than $5,000
Chapter 1

Introduction

Page 14 GAO/RCED-00-70 Problems in Managing Park Concessioners

per year. Most concessioners are relatively small businesses that generate

less than $100,000 in revenues per year. However, the relatively few

concessioners that provide lodging are among the largest concessioners in

the park system. In 1998, about 630 concessioners provided visitor services

grossing about $765 million in revenues. Of that amount, about $479 million

(almost two-thirds) came from 73 concessioners that provide lodging

accommodations. Thus, most of the revenues generated by park

concessioners come from the few concessioners—about 12 percent—that

provide lodging to park visitors. While this report specifically addresses

lodging concessioners in national parks, its findings can also apply to other

large concessioners throughout the parks.

Lodging in the national park system consists of a variety of facilities,

including rustic lodging (lodging not accessible by automotive vehicles),

tents, cabins, motels, and hotels. Forty-five of the national parks provide

lodging facilities, including hotel- or motel-type facilities, dude ranches,

hostels, and rustic and tent cabins. Thirty of these parks offer visitors

overnight lodging accommodations in hotel- or motel-type facilities. The

lodging accommodations range from economy rooms with few amenities,

to mid-scale rooms, to deluxe historic and elegant hotels, such as the

Ahwahnee Hotel in Yosemite National Park and the El Tovar Hotel in Grand

Canyon National Park. Annually, nearly 4 million visitors stay in lodging

provided by concessioners. Figure 1 illustrates various types of lodging

facilities in the national park system
Chapter 1

Introduction

Page 15 GAO/RCED-00-70 Problems in Managing Park Concessioners

Figure 1: Examples of Lodging Facilities Found in the National Park System

Cabins in Sequoia-Kings Canyon National Park Curry Village Cabin in Yosemite National Park

Lake Crescent Lodge in Olympic National Park Wuksachi Lodge in Sequoia-Kings Canyon National Park
Chapter 1

Introduction

Page 16 GAO/RCED-00-70 Problems in Managing Park Concessioners

Condition of Lodging

Facilities in National

Parks Varies

Considerably

In our prior review of the condition of lodging facilities, we judgmentally

selected a sample of 10 parks—about one-third of all parks having hoteland motel-type lodging operated by concessioners—to evaluate the

condition of these facilities. Using commonly accepted hospitality industry

standards, we found that the condition of lodging facilities−and, thus, the

performance of the concessioners managing them−varied considerably

among and within parks. For example, as shown in figure 2, lodging

facilities like those at Bryce Canyon and Zion in Utah were in very good

condition.

The El Tovar Hotel in Grand Canyon National Park The Ahwahnee Hotel in Yosemite National Park
Chapter 1

Introduction

Page 17 GAO/RCED-00-70 Problems in Managing Park Concessioners

Figure 2: Typical Motel Rooms in Very Good Condition at Bryce and Zion National Parks

However, other facilities, such as those at Stovepipe Wells in Death Valley

National Park in California, needed substantial renovation. Figures 3 and 4

illustrate the poor conditions we found in these facilities. 2

Room in Bryce National Park Room in Zion National Park

2

We visited Death Valley in May 1999 and found that all of the poor lodging conditions we

found during our Apr. 1998 visit had been corrected.
Chapter 1

Introduction

Page 18 GAO/RCED-00-70 Problems in Managing Park Concessioners

Figure 3: Needed Exterior Repairs at a Lodging Structure at Stovepipe Wells in

Death Valley National Park

Duct tape on broken window Broken handle and screen on back door
Chapter 1

Introduction

Page 19 GAO/RCED-00-70 Problems in Managing Park Concessioners

Figure 4: Repair and Maintenance Problems in Rooms at Stovepipe Wells

We also found that lodging facilities in 4 of the 10 parks we reviewed in

1998 did not have functioning smoke detectors; those in 2 parks had a large

number of housekeeping problems, such as dirty and/or stained carpets

and unclean windows; and those in 5 parks had a substantial number of

repair and maintenance problems, such as cracks, holes, or stains in

bathroom walls and/or ceilings.

In addition to the condition of lodging facilities at the 10 parks we reviewed

in our prior report, we assessed the condition of lodging facilities at two

other parks during this review—Sequoia-Kings Canyon National Park in

California and Olympic National Park in Washington. Appendix I of this

report summarizes the condition of the lodging facilities in these two parks.

Corroded drinking water facility and damaged Plastic bag holding broken shower facility Holes in bedspread

wall
Chapter 1

Introduction

Page 20 GAO/RCED-00-70 Problems in Managing Park Concessioners

Scope and

Methodology

Concerned about the widely varying conditions of park lodging facilities

and the performance of the concessioners contracted to manage them, the

Chairman, Subcommittee on National Parks, Historic Preservation, and

Recreation, Senate Committee on Energy and Natural Resources, asked us

to review factors affecting the condition of lodging facilities in the national

park system and options available to address these factors. Accordingly, we

reviewed the factors affecting the condition of lodging facilities at seven

national parks. The parks selected included 5 of the 10 parks we visited

during our prior review. These were Bryce Canyon and Zion national

parks—where we found some of the best lodging conditions−and Death

Valley, Mammoth Cave, and Shenandoah national parks—where we found

lodging facilities needing significant repair. In addition, for this review, we

selected two other parks. We chose these parks because they have multiple

concessioners operating lodging facilities in each park—Sequoia-Kings

Canyon National Park has two concessioners that each provide lodging,

and Olympic National Park has four concessioners that each operate

lodging facilities.3 We selected these two parks to determine whether

lodging conditions and the performance of concessioners varied among

different concessioners in the same park. Table 1 shows the parks and

concessioners that we contacted.

3

We treated Sequoia National Park and Kings Canyon National Park as one park unit

because the Park Service administers them as one unit. Two concessioners manage lodging

facilities in the park unit.
Chapter 1

Introduction

Page 21 GAO/RCED-00-70 Problems in Managing Park Concessioners

Table 1: Parks and Concessions Contractors Contacted

We identified multiple factors that may affect the condition of lodging

facilities and the performance of concessioners through discussions with

park officials and concessioners at the seven parks visited; Park Service

officials at headquarters; two regional offices; and the Concessions

Program Center in Denver; officials in the hotel and motel industry; and the

National Park Hospitality Association, which represents the major

concessioners in the national park system. These factors included the

concessioner’s management, the relationship between the concessioner

and the park, the extent of the reserve or special account in which funds

are set aside for improving facilities, the park’s oversight and evaluation of

the concessioner’s operations, the park’s use of specialists in concessions

management that carried out concessions-related activities full-time or as a

collateral duty, the process for approving reasonable rates that

concessioners can charge the public, the operation of lodging facilities on a

seasonal or year-round basis as well as the extent of the operating

revenues, the ownership of the facilities (i.e., whether they were owned by

the government or the concessioner), and the designation of facilities as

historic structures requiring higher maintenance and repair costs. We also

reviewed various documents relating to concessioners’ operations in the

parks, including the concessions contracts, maintenance and operating

plans, parks’ evaluations of concessioners’ operations for 1997 and 1998,

and concessioners’ annual reports.

Park unit Concessioners

Bryce Canyon National Park AmFac Parks & Resorts

Death Valley National Park AmFac Parks & Resorts

Mammoth Cave National Park National Park Concessions, Inc.

Olympic National Park Aramark Corp.

Log Cabin Resort

National Park Concessions, Inc.

Sol Duc Hot Springs Resort

Sequoia-Kings Canyon National Park Delaware North Parks Services

Kings Canyon Park Services Company

Shenandoah National Park Aramark Corp.

Zion National Park AmFac Parks & Resorts
Chapter 1

Introduction

Page 22 GAO/RCED-00-70 Problems in Managing Park Concessioners

Information on the condition of the lodging facilities in the five parks we

previously visited is contained in the prior lodging report. In that report, we

developed a checklist to evaluate the condition of lodging facilities. That

checklist was based on common industry standards for inspecting lodging

facilities. We used the same checklist to evaluate the condition of the

lodging facilities in Sequoia-Kings Canyon and Olympic national parks.

That checklist, and the results of our inspection of those two parks, are

found in appendix I.

To develop options for addressing the management of park concessions,

we considered what would resolve long-standing issues related to concerns

about the (1) qualifications and training of concessions staff, (2) chronic

backlogs of concessions contracts, and (3) lack of accountability within the

concessions program. In addition, we compared the Park Service’s

concessions contracting requirements and practices with the contracting

requirements and best contracting practices prescribed by the Federal

Acquisition Regulation and implemented by the Department of the Interior.

We also reviewed reports by the Department of the Interior’s Inspector

General, Park Service task forces, and GAO that evaluated the concessions

management program.

Because our study focused on a judgmental sample of seven national parks,

our findings may not be representative of the entire national park system.

However, the Park Service and other units within the Department of the

Interior have prepared at least seven other reports and analyses that

evaluate concessions management activities within the agency and support

our analysis in many respects. These other analyses are cited throughout

this report where appropriate. We conducted our review from April 1999

through February 2000 in accordance with generally accepted government

auditing standards.
Page 23 GAO/RCED-00-70 Problems in Managing Park Concessioners

Chapter 2

Long-Standing Management Problems Affect

the Condition of Lodging Facilities Chapte2r

Our work indicated that problems with the Park Service’s overall approach

to managing the concessions program are the primary reason that the

condition of park lodging facilities varies—ranging from very good at some

parks to needing substantial repairs at others. After considering numerous

site-specific factors that could potentially affect conditions−such as

whether the facilities were used year-round or just seasonally, whether the

facilities were owned by the government or by the concessioner, whether

the facilities were designated as historic structures, and others−our

analysis indicated that the most significant factors are those involving the

agency’s overall approach to managing the program. Specifically, the

management problems center on three areas: (1) inadequate qualifications

and training of the agency’s concessions specialists and concessions

contracting staff, (2) the agency’s out-of-date practices in handling its

contracting workload and chronic backlog of expired contracts, and (3) a

lack of accountability within the concessions program.

For the most part, these problems are not new. For many years, similar

concerns about the concessions program’s management have been raised

by the Department of the Interior, its Office of the Inspector General, and

Park Service concessions staff. Because of these problems, the Park

Service frequently has difficulty managing the performance of its

concessioners, including the quality of the services and facilities that they

provide.

More Qualified and

Better-Trained Staff

Would Improve the

Concessions Program

Several times since 1990, the Department of the Interior’s Office of the

Inspector General and the Park Service’s own staff have raised concerns

about the qualifications and training of the agency’s concessions staff. The

primary concern was that Park Service concessions staff do not normally

have the business, financial, and contracting backgrounds needed to

successfully carry out the concessions program. However, the agency has

made only limited progress in addressing these issues. It has made few

efforts to hire staff with education or experience in business management

or hospitality management. Instead, the agency typically fills concessions

staffing needs by transferring staff from other career fields within the

agency. Once transferred to the concessions program, these staff receive

only limited training. The chief concessions official in one regional office

indicated to us that there is a view within the agency that “anyone can do

concessions.” Our work indicates that this comment typifies the agency’s

approach to managing its concessions program.
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Page 24 GAO/RCED-00-70 Problems in Managing Park Concessioners

The Agency Has Not

Emphasized Business Skills

When Hiring Concessions

Staff

Traditionally, to meet the concessions program’s staffing needs, the Park

Service transfers staff from other career fields within the agency, such as

interpretive or law enforcement rangers and administrative staff. With very

few exceptions, the concessions staff we spoke with were hired by the

Park Service to serve in some other career field and were subsequently

transferred to the concessions field. This was prevalent at all levels within

the program, including the head of the program, and most headquarters,

regional, and park concessions officials. For example, the chief of the

concessions program was a park superintendent before assuming her

current position. She was hired initially into the agency’s finance office and

later worked in cultural resources and interpretation before becoming a

concessions analyst and later a park superintendent. The principal

concessions staff, at Bryce Canyon, Mammoth Cave, Sequoia-Kings

Canyon, and Death Valley national parks were all hired as law enforcement

or interpretative rangers and were later transferred into the concessions

program. The principal concessions staff at Shenandoah National Park and

the senior operations and contracting officials in the agency’s concessions

headquarters office were first hired to fill administrative positions. In total,

of the about 20 agency concessions staff we spoke with, only 4 were hired

into the agency’s concessions program with experience or backgrounds in

business or hospitality management, and 1 of these 4 staff has since retired.

Our review suggests that the practice of hiring concessions staff from other

career fields is likely to continue. Two of the seven parks we visited—

Mammoth Cave and Shenandoah national parks—indicated they were

looking to hire concessions staff. Mammoth Cave National Park was trying

to expand its concessions staff, while Shenandoah National Park was

trying to replace a departing staff person. In both cases, park managers

indicated they were looking to fill the position from within the agency

because (1) either they did not think they could pay enough to hire

someone with a background or education in business or hospitality

management or (2) they were concerned about how long it would take an

outside hire to learn how the parks operate.
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Since 1990, several Department of the Interior or Park Service task forces

have recommended that the agency “professionalize” the concessions

workforce through better training and/or hiring staff with education or

experience in hotel or business management. For example, in 1990, a Park

Service task force found that concessions staff do not normally have the

business, financial, and contracting backgrounds needed to successfully

carry out the concessions program. In addition, a 1990 report from the

Department of the Interior’s Inspector General recommended upgrading

the qualifications of staff working in the concessions field. This report

stated that the staff working in concessions “did not have sufficient

educational backgrounds” to perform their work well.1 In 1991, a

Department of the Interior task force recommended that all agencies

within the Department—including the Park Service—recruit staff for their

concessions programs that “have a basic knowledge of business including

such subjects as contract law, contract administration, hotel and restaurant

management, accounting, and financial management . . . . Furthermore, a

1994 memorandum from the Director of the Park Service to the agency’s

regional directors stated that the agency needed more concessions staff

“with education or experience in business, accounting, business law or the

hospitality industry.” The Director indicated that the agency did not have

enough staff with these backgrounds and that a wide recruitment effort

was needed. The Director suggested that to recruit qualified staff, the

agency should look for candidates from outside the government.

Nonetheless, the Park Service is continuing to fill positions in the

concessions program by transferring staff from other career fields. The

agency has yet to make significant improvements in professionalizing its

concessions workforce.

These concerns about why the agency has not hired more staff with

business-related skills were echoed by headquarters officials. They

indicated there were several reasons why the agency has not hired staff

with backgrounds or education in business or hospitality management. The

concessions program’s senior operations official in headquarters said that

most college graduates with a background in business or hospitality

management do not want to work for the government or in isolated areas of

the country where many parks are located. In addition, according to this

official, the Office of Personnel Management’s (OPM) regulations slow the

hiring process so much that by the time the Park Service can make an offer,

1

Follow-up Review of Concessions Management, National Park Service, U.S. Department of

the Interior Office of the Inspector General (Report No. 90-62, Apr. 16, 1990).
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an applicant is likely to have taken another job. These comments are

consistent with the views expressed in a 1997 report by a Park Service task

force on concessions. The report indicated that the procedures set up by

OPM for hiring qualified staff in federal agencies are somewhat

cumbersome. According to the report, “instead of assisting the agency in

finding the most qualified candidate for any specific position, these

procedures may serve to deter some qualified candidates from applying.”

However, this same headquarters concessions official acknowledged that it

has been about 5 to 10 years since the agency has made any real effort to

hire from colleges. When it made such an effort, it was focused only on

universities with large minority populations—as part of an effort to

increase the diversity of the agency workforce—and not on colleges and

universities known for their business or hospitality management programs.

Concessions Program Staff

Receive Little Training

Given the Park Service’s approach to staffing these positions, providing

sufficient training is especially critical. However, once staff begin working

in concessions, they are provided with only limited formal training. For

example, the primary training is a 40-hour course on reviewing

concessioners’ pricing and evaluating their performance. In addition, there

is a 40-hour course on concessions contracting, as well as some other

periodic training. A grant program also provides funding for a limited

number of staff to do such things as take professional development classes

or take short-term fact-finding trips to other agencies or private

corporations to learn from their operations.

In 1995, a Park Service task force on concessions reported that for many

years, the agency’s concessions training has been reactive in both its

content and timing—the result of current initiatives and influences rather

than long-term planning. As a result, according to the report, “the program

has failed to give its employees the training they need to manage the

complex concessions program.” This task force recommended a multiyear

strategy for developing a comprehensive training curriculum for

concessions staff. However, according to the senior headquarters

concessions official who coordinates concessions training, because of

limited funding for training, this strategy has not been implemented. This

official indicated that the budget for the concessions program is generally

sufficient to fund one programwide training class each year. While other

funding for training is available in the agency, all programs and career fields

compete for this money. Because training for other programs is given

higher priority, the concessions program does not usually receive

additional funding for training. As a result, according to this official, the
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agency is not providing its concessions employees with the training they

need to succeed in managing the concessions program. With limited money

for formal training, most of the training is done on the job or through

mentoring by more senior concessions staff. This has been the agency’s

practice for many years.

Several internal studies and other documents have addressed the

qualifications and training of concessions staff. Table 2 summarizes the key

points made in these studies and documents on this issue.
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Table 2: Notable Reports and Memorandums That Raised Concerns About the

Qualifications and/or Training of Park Service Concessions Staff

Source: GAO’s compilation of agency documents.

Contracting Practices Are

Out of Date, and Many

Contracts Have Expired

The concessions contracting practices of the Park Service are out of date

and do not reflect the best practices of the federal government, private

sector, or other contracting programs within the agency. In addition, the

agency has had difficulty addressing its concessions contracting workload

Source and date of report/memorandum Concerns raised by report/memorandum

Report of the Task Force on National Park

Service Concessions, U.S. Department of

the Interior, Apr. 9, 1990

Concessions staff do not normally have the

business, financial, and contracting

backgrounds needed to successfully carry

out the concessions program.

Follow-up Review of Concessions

Management, National Park Service,

Report No. 90-62, Office of the Inspector

General, U.S. Department of the Interior,

Apr. 1990

Agency staff working in concessions do not

have sufficient educational backgrounds to

perform their work well. The report

recommends improving the qualifications of

staff working in the concessions field.

Report of the Concessions Management

Task Force, U.S. Department of the

Interior, Nov. 4, 1991

This report recommends that all agencies

within the Department recruit staff for their

concessions programs with a basic

knowledge of business, including such

subjects as contract law and administration,

hotel/restaurant management, and financial

management.

Memorandum from the Director of the Park

Service on Personnel Staffing for National

Park Service Concessions, Jan. 12, 1994

The agency needs more concessions staff

with education or experience in business,

accounting, business law or the hospitality

industry. To recruit qualified staff, the

Director suggests that the agency look for

candidates outside of the government.

Park Service concessions work group,

June 1994—findings reported in

Concession Careers Future Task Force

Report, National Park Service, Oct. 97

The agency needs to develop a recruitment

program, enhance training and development,

and improve career development.

Concessions Management Curriculum

Task Force Report, National Park Service,

Sept. 1995

The concessions management program has

failed to give its employees the training they

need to manage the complex concessions

program. A systematic, comprehensive

employment development program is

needed.

Concession Careers Future Task Force

Report, National Park Service, Oct. 1997

This report outlines a series of human

resource management processes and

recommendations to strengthen and

professionalize the staff needed to effectively

manage concessions.
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Page 29 GAO/RCED-00-70 Problems in Managing Park Concessioners

in a timely manner and has experienced chronic backlogs of expired

contracts for nearly 10 years. This backlog of contracts has created a

disincentive for concessioners to invest in facilities. As contracts have

expired, most concessioners have been put under short-term contract

extensions lasting between 1 and 3 years. According to several

concessioners, such short-term extensions discourage investment because

they give concessioners little time to earn a return on their investment.

When concessioners invest less in facilities or capital improvements, the

condition of lodging facilities is affected. Thus, the backlog of expired

contracts contributes to the varying condition of the parks’ lodging

facilities.

Park Service’s Contracting

Practices Need Updating

The agency’s concessions contracting practices do not reflect the best

practices of the federal government or of other contracting programs

within the agency. The Park Service uses two major types of contracts:

concessions contracts and acquisition, or procurement, contracts.

Procurement contracts are subject to the Federal Acquisition Regulation

(known as the FAR). Among other things, the FAR prescribes a contracting

process that reflects many of the best contracting practices of both the

public and the private sectors. Because concessions contracts are not

funded by federal appropriations, they are not subject to the FAR. As a

result, according to agency officials, the agency has made no attempt to

learn how best practices prescribed by the FAR could be applied to the

contracting practices of the concessions program.

Concessions contracts and procurement contracts are managed separately

in the agency, with little or no communication between the two contracting

staffs or sharing of information on best practices. The value of concessions

contracts in 1998 was about $765 million, while the value of procurement

contracts in the agency was about $167 million. Yet despite the lower dollar

value of the procurement contracts, the training and qualification

standards prescribed by the FAR for the agency’s procurement contracting

staff are much higher than the Park Service’s standards for the concessions

contracting staff.
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For example, procurement contracting staff must meet specific training

requirements in order to qualify to write contracts of varying values.2 The

greater the value of the contract, the more training is required for

contracting staff to execute the contract. Procurement contracting staff

must also update their training to keep their skills current. If they do not

meet these requirements, they lose their authority to sign contracts. By

contrast, concessions contracting staff have no such requirements,

although the agency does suggest some limited training. As a result, there is

a lower standard for the qualifications of staff executing concessions

contracts. As shown in table 3, the qualifications required for concessions

staff to write a contract worth $1 million per year—or even $10 million per

year—are significantly less rigorous than the qualifications required for

procurement staff to write a contract worth $1 million per year.

2

The Park Service’s procurement standards are prescribed by the Department of the

Interior’s Acquisition Regulations (DIAR), which are consistent with the Federal Acquisition

Regulation (FAR).
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Table 3: Training and Experience Required to Execute the Park Service’s

Procurement and Concessions Contracts

Source: Park Service concessions officials and the Department of the Interior’s acquisition regulations.

In addition, for procurement contracts, a Park Service official in

headquarters is responsible for enforcing compliance with these

requirements. If procurement contracting staff are not in compliance with

these requirements, they lose their authority to write contracts. In contrast,

for concessions contracting, there are no comparable requirements.

Park Service’s procurement

contracts

Park Service’s concessions

contracts

Annual value of

contracts (1998)

$167,000,000 $765,000,000

Training required to

write contracts of

more than

$1,000,000

400 hours of training in

advanced contract law,

negotiation techniques,

advanced contract

administration, source selection,

planning, cost and price

analysis, and others.

None. However a 40-hour

training course is suggested.

The core training relies on

mentoring and on-the-job

training from other concessions

staff.

Experience required

to write $1,000,000

contracts

At a minimum, 4 years

experience in writing

progressively more complex

contracts. Contracting officers

working on complex, largedollar-value contracts must have

additional specialized training

and experience commensurate

with their duties.

None.

Continuing education

requirement

40 hours of training every 2

years.

None, although various training

is suggested.

Consequence of not

meeting continuing

education

requirement

Loss of the authority to sign

contracts.

None
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The notion of the concessions contracting program learning from the

agency’s procurement contracting program is not new. A 1990 Park Service

task force on concessions management recommended that the agency

explore the development of contracting procedures and training

requirements similar to those required for the agency’s procurement staff.

However, this was never done. According to Park Service concessions

contracting officials, because they are exempt from the FAR, there has

never been an effort made to align the contracting practices of the

concessions program with the practices of the agency’s procurement

contracting program.

Furthermore, according to a Deputy Associate Administrator in the Office

of Management and Budget’s (OMB) Office of Federal Procurement

Policy—the highest contracting policy office in the federal government—

there is no reason why any agency or any program activity within an agency

cannot apply good contract management principles and practice good

contract management as prescribed by the FAR—regardless of whether

they are subject to the FAR. This official indicated that the FAR includes

many of the best contracting practices of both the public and the private

sectors. For example, under the FAR, procurement contracting staff are

encouraged to write performance-based contracts—meaning contracts that

contain incentives for good performance and disincentives for

performance that falls below expectations. However, the concessions

program has not used performance-based contracts. Several Park Service

concessions program officials, including the senior contracting official in

headquarters, have indicated that the agency has no plans for moving

toward more performance-based contracts. According to the official from

OMB’s Office of Federal Procurement Policy, performance-based contracts

are considered a best practice in the federal government and private

industry and should be used wherever possible to provide incentives for

better performance from contractors, including concessioners. Moving to

more performance-based contracts could help the Park Service better

manage concessioners’ performance—including their performance in

maintaining the condition of lodging facilities.

According to this senior OMB official, an agency can adopt the FAR’s

principles and practices to help address whatever goal the agency is trying

to achieve. As a result, programs that are exempt from the FAR, such as the

Park Service’s concessions program, have an opportunity to (1) use the

best practices prescribed by the FAR in their contracting programs and (2)

be more innovative in their contracting, since their contracting authorities

provide a great deal of discretion.
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Nonetheless, when we discussed this issue with several park and

concessions officials, they said the incentives and disincentives that are

typically part of performance-based contracts could help to ensure that

facilities were adequately maintained. For example, following practices in

the hospitality industry, a long-term concessions contract could contain

performance-based provisions linking incentives and disincentives to

concessioners with how well they maintained their facilities and provided

contracted services. In this regard, the long-term contracts for the seven

parks included in our review do not contain provisions for investing in

facilities during the latter stages of the contracts. As a result, concessioners

have less incentive to invest funds to improve or maintain facilities during

this period. While most of these contracts were awarded for about 20 years

or longer, facility improvements were usually required only during the first

5 years of the contracts.

The Park Service’s concessions staff has made no effort to learn what

practices prescribed by the FAR would benefit concessions contracting.

The senior concessions contracting staff in both headquarters and the

Concessions Program Center—the agency’s technical support center—

were not familiar with the contracting practices prescribed in the FAR. In

addition, when the concessions staff were developing regulations and

standard contract language to implement the new concessions law passed

in 1998, they did not consult with or seek advice from the agency’s

procurement staff, contracting consultants, or any other outside

contracting experts. In fact, the senior concessions contracting official in

headquarters indicated to us that the agency made no attempt to include

any best contracting practices of either the public or the private sector in

the agency’s concessions program. Instead, they relied on the staff who

were most familiar with the agency’s past concessions contracting

practices to develop the new regulations. As a result, the Park Service’s

concessions contracting practices are out of date and are an obstacle to

better managing concessioners’ activities and performance. In our view,

using the best available contracting practices would enhance the agency’s

ability to improve the performance of concessioners and the facilities and

services they provide.

Contracting Backlog Limits

the Agency’s Ability to

Manage Concessioners

In addition to not using the most up-to-date contracting practices, the Park

Service has carried backlogs of expired concessions contracts for nearly 10

years. As contracts expire, the agency has put many concessioners under 1-

to 3-year contract extensions. This is significant because several of the

concessioners we spoke with indicated that there was a disincentive to
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invest in facilities when they were operating under extensions because

there was such a short time available for them to earn a sufficient return on

their investment. As of December 31, 1999, 283 of the 630 concessions

contracts and permits had expired. In addition, another 195 contracts or

permits will expire by the end of 2001. In total, 478−or about 75 percent−of

the agency’s 630 concessions contracts and permits either have expired or

will expire by December 31, 2001.

Much of the backlog dates from 1990, when the Secretary of the Interior

placed a moratorium on concessions contracting because of his concerns

about the management of the Park Service’s concessions program. To

address these concerns, the agency issued new concessions regulations in

1992 and revised its standard concessions contract language in 1993.

However, by 1995, only limited contracting had occurred, and 95 percent of

the agency’s concessions contracts had expired. From 1995 to 1998, the

agency focused on extending expired contracts for short terms—generally

1 to 3 years. Little contracting was done during this period, according to

agency officials, because of uncertainty created by pending legislation

proposing changes to the agency’s concessions law. In November 1998, the

National Parks Omnibus Management Act of 1998 became law. Title IV of

this act included a new concessions law for the agency. No contracts have

been written since the new law was passed because the agency has been

promulgating regulations and developing standard contract language to

begin contracting under its new authority.

This backlog of contracts presents a tremendous workload for the Park

Service. Some program officials are concerned that the agency may not

have enough experienced staff to address its contracting needs in a timely

manner. For example, the Chief of Concessions indicated that one of her

top priorities is expanding the capacity of the agency to write contracts.

This concern about capacity suggests that the agency may need several

more years to eliminate its backlog of concessions contracts.

Other factors could also affect the agency’s ability to address its

contracting backlog. The Chief of Concessions indicated that delays in

finalizing the agency’s concessions contracting regulations—which

implement the new concessions law—have further increased the backlog.

The agency cannot begin writing contracts until the regulations are

finalized. The new concessions law was passed in November 1998, and the

regulations implementing this law were published for comment in June

1999. The comment period ended in October 1999, and the agency has since
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been reviewing comments and finalizing the regulations. However, as of

March 23, 2000, the regulations had yet to be made final.

Concerns about addressing the backlog of contracts are significant because

this backlog affects the condition of lodging facilities. Several of the

concessioners we spoke with during this review were operating under 1- to

3-year extensions of expired contracts. They indicated that there is a

disincentive for them to invest in facilities when they are under such

extensions because 1 to 3 years may not be enough time for them to

generate a sufficient return on their investments. Furthermore, several

Park Service and concessioner officials told us that these short-term

extensions create uncertainty about how long a concessioner will be

operating at a park. This uncertainty makes it difficult for concessioners to

justify any major upgrading of their facilities. If this backlog of contracts

continues for several more years, it could further affect both the level of

investment in concessions facilities and the condition of these facilities. In

fact, in commenting on a draft of this report, the National Park Hospitality

Association—an industry association that represents park concessioners—

stated that the backlog of concessions contracts has had a devastating

effect on the concessions programs in many parks and has contributed to

both a loss of capital investments and delays in moving forward on many

facility improvements.

Management of the

Concessions Program

Lacks Accountability

The Park Service’s approach to managing the concessions program lacks

accountability. Under the agency’s organizational structure, the head of the

program—the Chief of Concessions—has no direct authority over those

that implement the program in individual park units. Thus, the

organizational structure of the agency limits the impact that the head of the

program or other central offices can have on its ultimate success. In

addition, individual park superintendents are given broad discretion in

managing their parks’ concessions programs. However, according to

agency officials, the superintendents are not held accountable for the

results of their parks’ concessions programs.

Organizational Structure of

the Program Impedes

Accountability

Managing a park’s concessions program is one of the many responsibilities

of a park superintendent. The superintendent and the park staff implement

the agency’s concessions program and make decisions about how the

program will be run. The superintendent makes or approves decisions on

such matters as hiring agency staff for the park’s concessions program,

determining how much of a park’s budget and staff will be dedicated to
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concessions, and rating a concessioner’s performance during required

annual evaluations. However, there is no direct reporting relationship

between the park superintendents and their staff and those who lead the

program in the agency’s regional and headquarters offices. As illustrated in

figure 5, each park superintendent reports to one of seven regional

directors, who in turn report to the Director of the National Park Service.

While there is a Chief of Concessions in the agency’s headquarters office,

this position reports to an associate director—who is part of the agency’s

senior management team−who in turn reports to the Director. This

situation results in a lack of accountability that undermines the

effectiveness of the concessions program’s overall management.

Figure 5: Abridged Organization of the National Park Service

Source: National Park Service.

One example of how this condition impedes accountability between the

Chief of Concessions and the individual park concessions staff is the lack

of meaningful data available to the Chief of Concessions on the

performance of park concessioners. For instance, the former Chief of

Concessions (who retired during the course of our review) told us he did

not have information on the condition of lodging facilities in the parks. He

indicated that our review would provide him with valuable information

about the condition of these facilities. He did not have such information

Seven

Regional

Directors

379

park units

Director

Deputy Director

Associate Director,

Park Operations

and Education

Chief of Consessions

Concessions Program Center

(technical support)

Several other

Associate

Directors
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because, although the condition of facilities is generally known by local

park managers, it is not generally known or reported to higher levels within

the agency. Agency officials indicated that this is the case because the

agency’s organizational structure is highly decentralized. The lack of

information on the conditions of facilities contrasts with the best practices

of other organizations with similar responsibilities. For instance, in the

private sector, the hotel and motel industry uses quality assurance

inspection teams to periodically inspect local hotel operators to ensure that

they are meeting corporate quality standards for the condition of services

and facilities. Typically, these teams operate out of an organization’s central

offices and report to the top management of the organization. Similarly,

within the federal government, the Department of Defense uses inspection

teams to ensure the quality of many of the hospitality assets it manages,

such as officers’ clubs and lodging facilities available to military staff. Both

the private industry and the Department of Defense use the independent

inspection process to (1) evaluate performance and (2) identify possible

trends or problem areas that need to be addressed on a broader basis.

In addition to its headquarters and regional offices, the Park Service has a

technical assistance group for concessions issues, called the Concessions

Program Center, located in Denver, Colorado. This center was created in

1994 as a resource available to all park managers and concessions staff in

running their concessions programs. The center has staff with expertise in

accounting, appraisal, financial analysis, planning, and concessions

contracting. This center is considered by agency staff to be an extension of

the headquarters concessions office. While the Concessions Program

Center has technical expertise, it serves principally in an advisory capacity

to the parks implementing the concessions program. Park managers are

not required to use the resources available at the center. Hence, even

though the Concessions Program Center retains many of the technical

experts within the agency’s concessions program, their advice and counsel

may not be sought or fully considered by parks in managing or contracting

with concessioners. Thus, the organizational structure of the concessions

program limits the impact that the head of the program or the Concessions

Program Center can have on its ultimate success.

Parks Are Not Held

Accountable for the Success

of Their Concessions

Programs

In the absence of line authority from the head of the concessions program

to park superintendents, the Park Service relies on regional directors to

hold the superintendents accountable for the success of their parks’

concessions programs. This policy was detailed in an agency directive in

1995, which stated that superintendents and regional directors are
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accountable for the proper management of their concessions programs and

that the results achieved will be taken into consideration during annual

performance reviews. However, officials in the headquarters concessions

program office and in the two largest regional offices indicated that this is

not happening. (These two regions—the Intermountain Region and the

Pacific West Region—account for 52 percent of the agency’s concessions

contracts and over 75 percent of the concessions revenues.) According to

these officials, the regional directors place little emphasis on the

concessions program because they rarely consider the parks’ performance

in managing concessioners when rating the performance of park

superintendents. Thus, superintendents are not held accountable for either

(1) the performance of their parks’ concessions programs, or (2) the

performance of concessioners operating in their parks. Moreover, because

neither the Chief of Concessions in headquarters nor officials in the

agency’s Concessions Program Center have direct authority to change or

improve this situation, it has not changed. Furthermore, even if the regional

officials did place more emphasis on assessing the performance of park

officials in managing concessioners, there is currently no mechanism, like

inspection teams, for doing so.

This lack of accountability is not consistent with recent efforts to improve

accountability and program performance as the Park Service, like other

federal agencies, implements the requirements of the Government

Performance and Results Act of 1993 (GPRA) and other related initiatives.

GPRA was designed to hold federal agencies, and the programs they

manage, more accountable for achieving improved performance and

results. Under GPRA, federal agencies are to develop annual performance

plans that, among other things, establish (1) performance goals and (2) a

means to measure progress towards attaining these goals. However, even

though the performance of concessioners is a key ingredient in providing

services to millions of park visitors annually, the Park Service has not

identified any annual performance goals specifically related to improving

its long-standing concessions management problems. The only

concessions-related goal mentioned is directed at increasing the rate of

return to the government generated from concessions contracts.

Like many of the other issues involving concessions management,

concerns about accountability in the concessions program have been

raised several times since 1990 by task forces, the Inspector General, and

others within the agency. Table 4 provides a chronology of various reports

and documents that discussed the need for accountability within the

concessions program.
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Table 4: Notable Reports or Documents That Discussed the Need for Accountability

Within the Concessions Program

Source: GAO’s compilation of agency documents.

As these analyses show, these issues related to accountability have led to

confusion among the concessions staff about their roles and

responsibilities. For example, the October 1997 Park Service task force

report noted that there was uncertainty about the roles and responsibilities

of concessions staff at headquarters, regional offices, and parks. That

report raised questions about who is ultimately responsible for (1)

managing the agency’s concessions program staff and (2) ensuring

accountability in the concessions program, given the agency’s

decentralized organizational structure. Similarly, the 1999 report from the

Department of the Interior’s Office of the Inspector General indicated that

the lack of accountability created confusion within the program because

staff were uncertain about “who does what” and “who works for whom.”

Source and date of report or document Concerns raised by report or document

Report of the Task Force on National Park

Service Concessions, U.S. Department of

the Interior, Apr. 9, 1990

The Park Service needs to raise the level of

responsibility for negotiating contracts,

create professional teams to inspect

concessions operations, and improve

accountability for managing activities.

Special Directive 95-9 on Revised

Delegation of Authority for Concessions

Contracting, National Park Service, U.S.

Department of the Interior, July 11, 1995

Since the concessions program involves the

long-term commitment of significant

resources and could lead to a perceived

loss of revenues, each park manager and

field director will be accountable for the

proper management of concessions under

his/her authority.

Concession Careers Future Task Force

Report, National Park Service, Oct. 1997

Uncertainty exists about the roles and

responsibilities of concessions staff at

headquarters, regional and support offices,

and parks. Given the agency’s

organizational structure, the report raised

questions as to who is ultimately

responsible and accountable for managing

concessions staff in the concessions

program.

Concession Contracting Procedures,

National Park Service, Report No. 99-I-626,

Office of the Inspector General, U.S.

Department of the Interior, June 1999

The lack of accountability in managing

concessions created confusion within the

program because staff were uncertain

about who does what and who works for

whom. The report indicated that this

confusion contributed to delays in

processing concessions contracts.
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This report indicated that this confusion contributed to delays in writing

concessions contracts.

The Park Service has made an effort to resolve this confusion. In February

1999, the agency sent a memorandum to its regional directors outlining

what levels of the agency have responsibilities for completing various

concessions tasks, such as planning, contracting, and financial analysis.

This memo was distributed in response to concerns raised during the

Inspector General’s review about confusion over responsibilities. However,

our work, which we conducted after the memorandum was issued,

suggests that some confusion remains about responsibilities for key

aspects of the concessions program. For example, the Chief of Concessions

indicated that for most parks, staff in regional offices will take the lead in

issuing new concessions contracts as the previous ones expire. However,

according to staff in several of the parks we visited, there are no longer

enough staff in the regional offices to meet their contracting needs, and the

parks may take the lead in contracting. In addition, at Olympic National

Park in Washington, the concessions specialist indicated that with a recent

retirement, the regional office would have only two people to meet the

needs of all the parks in that region. Consequently, he did not think the

regional office would be able to keep up with the parks’ contracting

workload. This official believes he will be responsible for taking the lead in

planning and writing new contracts for the four different lodging

concessioners in that park. He was concerned about writing the contracts

because, although he viewed himself as knowledgeable in overseeing park

concessioners, he considered himself “a novice” at writing contracts.

Aside from the confusion over responsibilities, other significant problems

within the concessions program reflect the need for better accountability.

These include (1) a lack of consistent and effective oversight of

concessioners’ performance, and (2) wide variation in the priority given to

concessions management by park managers.

We asked park officials and concessioners whether sufficient enforcement

tools exist to hold concessioners accountable for how they perform. Most

of these officials believed that sufficient enforcement tools exist. They

indicated that the main enforcement tools are the periodic park inspections

and/or annual evaluations of concessioners’ operations because these

serve as a basis for park managers to assess concessioners’ performance. If

a concessioner’s performance is poor, park officials may give a marginal or

unsatisfactory rating. An unsatisfactory rating in the annual evaluation for

any year, or a marginal rating for 2 consecutive years, constitutes grounds
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for terminating a contract. However, we found that these tools were being

used inconsistently across the agency.

Our review of the Park Service’s annual evaluations of concessioners for

1997 and 1998, as well as other reviews of concessioners’ operations,

indicated that virtually all concessioners received a satisfactory rating.

Concessioners generally received such a rating regardless of the condition

of their facilities. For example, at Death Valley, Mammoth Cave, and

Shenandoah national parks, we found obvious problems with the condition

of the lodging facilities, but the concessioners at these parks all received

satisfactory ratings from the local park managers.3 The park managers at

these locations were not held accountable for these deteriorating

conditions.

Another sign of the concessions program’s lack of accountability is that the

parks in our review gave widely varying priorities to overseeing

concessioners. For example, the seven parks we visited each manage

concessioners that are among the largest in the agency. Five of the seven

parks we visited had between one and three staff working full-time on

concessions, and two parks (Mammoth Cave and Death Valley) each had

one person working less than one-quarter time on concessions as a

collateral duty. While, collateral duty staff work part-time on concessions,

their principal duties are generally in other areas, working, for example, as

park rangers or administrative staff. Officials at the two parks with

collateral duty concessions staff indicated that the parks could do a much

better job with their concessions program if they had a person responsible

full-time for concessions issues at the park. At Mammoth Cave, a park

official indicated that the park was doing the “bare minimum” by running

the program as a collateral duty for one park staff member. The person

responsible for concessions was spending 10 to 20 percent of his time on

concessions. Similarly, at Death Valley, the park official responsible for

concessions indicated that he spent about 20 percent of his time on

concessions. He said that he thought a full-time person handling these

responsibilities would do a better job. In his view, one of the reasons the

facilities had deteriorated at Death Valley was a lack of oversight by the

park.

3

Shenandoah National Park rated its lodging concessioner as satisfactory in 1997 and

marginal in 1998. Park officials indicated that the marginal rating was principally the result

of recurring health and safety problems in this concessioner’s food service program—not

the condition of its lodging facilities.
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The decisions made by park managers at Death Valley and Mammoth Cave

to handle concessions management as a collateral duty is indicative of the

relatively low priority assigned to these activities. Both of these parks have

over 100 full-time staff yet do not have one staff person dedicated to

concessions.4 According to the head of the Concessions Program Center, “if

[having a full-time person handle concessions were] a high enough priority

for the Superintendent, then a position would currently be funded.” In our

view, these widely varying approaches to managing the performance of

concessioners is another reflection of the lack of accountability within the

program. Perhaps the most concrete example of the impact of this situation

occurred at Death Valley, where park managers put such a low priority on

managing concessions that basic aspects of oversight—conducting an

inspection and preparing an annual evaluation of the concessioner’s

performance—were not performed in 1998. In addition, there do not appear

to have been any consequences to the park for not carrying out these

responsibilities. In fact, concessions staff at the region and headquarters

were not aware that these required tasks had not been performed until we

told them.

Once again, concerns about the use of collateral duty concessions staff are

not new. Since 1990, as shown in table 5, a number of task force reports and

other documents have raised concerns about the use of collateral duty

concessions staff. For example, the 1990 Park Service task force on

concessions raised concerns about the use of collateral duty concessions

staff. The task force report recommended that the agency cut back on

assigning concessions management responsibilities as secondary duties to

employees who work primarily as rangers, administrative staff, or other

park staff. In addition, a 1997 task force report indicated that the increasing

level of complexity and depth of expertise required to manage

concessioners is such that “collateral duty employees are generally not able

to master the skills needed to perform the full scope of their

responsibilities.”

4

In fiscal year 1998, Mammoth Cave had 131 full-time-equivalent staff while Death Valley had

101.
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Table 5: Notable Task Force Reports or Documents That Raised Concerns About the

Use of Collateral Duty Staff in Managing Concessions

Source: GAO’s compilation of agency documents.

Other Factors May

Also Affect the

Condition of Lodging

Facilities

While our analysis indicates that the Park Service’s overall approach to

managing the concessions program is the most significant factor affecting

the condition of the parks’ lodging facilities, several other factors can affect

the condition of these facilities to varying degrees. During our visits to each

of the seven parks in our sample, we asked park officials and

concessioners what they thought were the most significant factors

affecting the condition of the lodging facilities. We discussed such factors

as the use of historic structures, the Park Service’s rate approval process,

the extent of revenues going back into maintaining or improving facilities,

whether the facilities were owned by the concessioner or by the

Source and date of report or document Concerns raised by report or document

Report of the Task Force on National Park

Service Concessions, U.S. Department of

the Interior, Apr. 9, 1990

The report recommended that the agency

cut back on assigning concessions

management responsibilities as a

secondary duty to employees who work

primarily as rangers, administrative staff, or

other park staff.

Report of the Concessions Management

Task Force, U.S. Department of the Interior,

Nov. 4, 1991

Many collateral duty staff have little

formalized training in concessions

management. The report recommended

that the agency limit the practice of having

staff manage concessions as a collateral

duty.

Memorandum from the Director of the Park

Service on Personnel Staffing for National

Park Service Concessions, Jan. 12, 1994

The agency needs to increase the numbers

and improve the quality of concessions

staff. Additional or secondary duties must

be held to a minimum.

Park Service concessions work group, June

1994—findings reported in Concession

Careers Future Task Force Report, National

Park Service, Oct. 1997

The agency should provide for less

dependence on collateral positions.

Concession Careers Future Task Force

Report, National Park Service, Oct. 1997

This report indicated that the increasing

level of complexity and depth of expertise

required to manage concessioners is such

that collateral duty employees are generally

not able to master the skills needed to

perform the full scope of their

responsibilities.
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government, whether the concessioner was operated seasonally or yearround, the management of the concessioner, and others.

At these seven parks, the views of park and concessions staff on what

factors significantly affected the condition of the parks’ lodging facilities

were mixed and could not necessarily be correlated to the conditions we

found at the parks. For example, views varied on whether the ownership of

lodging facilities was a factor affecting their condition. In some parks, such

as Shenandoah, and Sequoia-Kings Canyon, concessions facilities are

largely owned by the concessioners. In other parks, such as Bryce Canyon,

Zion, and Death Valley, the concessions facilities are mostly governmentowned. In still other parks, such as Mammoth Cave and Olympic, the

ownership of the facilities is mixed, with some owned by the government

and others owned by the concessioners. In commenting on whether the

ownership of facilities affected their condition, some park officials thought

that facilities owned by the government would generally be in better

condition than facilities owned by concessioners. Other park officials did

not feel strongly about this. Similarly, some park concessioners thought

that facilities owned by concessioners would generally be in better

condition. However, other concessioners did not agree with this or did not

feel strongly either way. At parks with a mix of government- and

concessioner-owned facilities, park and concessions officials generally

agreed that there was no discernable difference in the condition of the two

types of facilities. On the basis of our observations, the ownership of

facilities did not appear to be a factor affecting their condition. Some

government-owned facilities were in very good condition, and some were

in very poor condition. We found the same was true for concessionerowned facilities.

Views were similarly mixed on a number of other factors that may affect

the condition of lodging facilities, including their designation as historic

structures, seasonal versus year-round operations, the Park Service’s rate

approval process, and others. However, there were a few factors on which

park and concessioner officials widely agreed. One factor was the extent of

revenues that concessioners were required by their contract to put into a

special set-aside account. Funds from this special account would later be

used by the concessioner to repair and/or improve concessions facilities.

Most, if not all, of the park and concessioner officials we spoke with

indicated that the extent and use of special accounts to repair and/or

improve concessions facilities was a very positive factor affecting the

condition of lodging facilities. The National Parks Hospitality Association

also noted that special accounts are very important for repairing and
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maintaining government-owned concessions facilities. While the views

were largely consistent on the positive effects of using special accounts to

repair and improve concessions facilities, the use of special accounts did

not necessarily ensure that lodging facilities would be kept in good repair.

For example, our work showed that some of the parks with the best

lodging conditions, such as Bryce Canyon and Zion, used special accounts

to keep facilities in good shape, but one of the parks where the lodging

facilities were most in need of repair−Death Valley−also used a special

account.

Similarly, although park and concessioner officials viewed the parks’

evaluation and oversight of concessioners’ operations as significant factors

affecting the condition of facilities, these factors did not necessarily ensure

that concessioners maintained facilities in a satisfactory condition. For

example, we found that the lack of oversight in Death Valley National Park

contributed to the run-down condition of its lodging facilities. On the other

hand, continuous monitoring, oversight, and documentation of repair and

maintenance problems at Shenandoah National Park have not led to the

correction of repair and maintenance problems at facilities in the park.

One factor on which there was widespread agreement among park and

concessioner officials was the concessioner’s management. The officials

told us the commitment and capabilities of the concessioner’s management

significantly affect the condition of the facilities. For example, at Bryce

Canyon National Park—where the facilities are in very good condition—

park officials told us that the concessioner had a strong general manager

who was committed to operating high quality facilities. In several other

parks—Death Valley, Mammoth Cave, Sequoia-Kings Canyon, and

Shenandoah—the condition of lodging facilities has suffered somewhat

because of the management performance of the concessioner. At Death

Valley and Mammoth Cave, park and concessioner officials told us, the

former concessions managers did not want to improve facilities. At

Sequoia-Kings Canyon, the former concessioner let facilities deteriorate

over a number of years, and at Shenandoah, the concessions manager has

allowed repair and maintenance problems to persist for several years.

Conclusion While the Park Service’s concessions program affects millions of park

visitors each year, the management of the program continues to be plagued

by some of the same problems that were identified 10 years ago. The

consequence of not hiring more qualified staff, not training them well, and

having limited accountability within the concessions program is a
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reflection of the relatively low priority the agency has given the program.

Now, a number of obstacles must be overcome to improve the agency’s

ability to manage the performance of concessioners operating in the parks.

Because the Park Service has not managed concessioners effectively, there

is wide variation in their performance—including, among other things, the

condition of park lodging facilities.

Agency and Industry

Comments and Our

Evaluation

The Department of the Interior generally agreed with the findings in the

report. The National Park Hospitality Association raised three main points

in its comments. First, the association suggested that the backlog of

expired concessions contracts was the single most important factor

affecting the Park Service’s concessions program, including the condition

of concessions facilities. We agree that this backlog is one of the key

management problems currently facing the concessions program. Second,

the association indicated that ownership provides concessioners with

incentives to keep facilities in good condition. While there may be such

incentives, our work indicated that ownership of facilities did not appear to

be a key factor affecting their condition. We found that some governmentowned facilities were in very good condition and some were in very poor

condition. The same was true for concessioner-owned facilities. Third, the

association indicated that special accounts are very important for repairing

and maintaining government-owned concessions facilities. However, our

work showed that while special accounts contribute to the upkeep of

government-owned facilities, the use of special accounts does not ensure

that these facilities will be in good condition. We found that special

accounts were used to maintain government-owned concessions facilities

both at parks whose facilities were among the best maintained and at parks

whose facilities were most in need of repair.
Page 47 GAO/RCED-00-70 Problems in Managing Park Concessioners

Chapter 3

Options Are Available to Address Problems in

Managing the Concessions Program Chapte3r

The problems facing the Park Service’s concessions program are not new.

In fact, many of them have been issues for the agency for 10 years or more.

With the new concessions law and subsequent new regulations, the agency

has an opportunity to take a new approach to managing this program, and

our work shows that a new approach is needed. The choices available to

deal with the problems identified in the management of the concessions

program center on two options: (1) professionalizing the workforce to

obtain better business and contracting expertise or (2) contracting for the

needed business and contracting expertise. These two options are not

mutually exclusive in that the agency could contract for expertise in certain

functions while developing the expertise in-house for other functions. Both

options require that the agency better manage its human capital to ensure

that it selects, trains, develops, and manages concessions staff who have

the skills needed to bring about improvement in the concessions program.

However, regardless of which option—or combination of options—is

selected, the agency needs to strengthen its accountability for and control

over the program. Unless this is done, the effectiveness of other changes

will be diminished.

In considering what actions to take, the agency needs to make changes

soon, since most concessions contracts have expired, are operating under

short-term extensions, or will expire in the next few years. Because

contracts can be written with terms of up to 20 years, the commitments

made in any new contracts over the next few years will affect the

concessions program for a long time. If the agency acts fast, these

contracts can include the potential benefits of upgrading the concessions

program. However, if changes are slow in coming, then the identified

problems are likely to be perpetuated by a whole series of new concessions

contracts.

The options we are providing are principally focused on improving the

agency’s management of its largest concessioners—many of which provide

lodging. In our view, once the agency has made changes in the concessions

program to address the management of its largest concessioners, the

benefits of additional expertise−whether acquired through hiring, training,

or contracting—are likely to cascade down to improve the agency’s

management of its smaller concessioners.
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Professionalize and

Improve the Training of

the Agency’s

Workforce

One option available to the Park Service concessions program is to change

its hiring practices and upgrade its training. Rather than filling positions in

the concessions program with staff from other career fields, the agency

could encourage the hiring of staff with backgrounds or education in

hospitality and/or business management. Through this approach, the

agency would gradually develop greater in-house expertise in managing

concessioners. In addition, the agency could upgrade the training of its

concessions contracting staff so that their qualifications are similar to

those of the agency’s procurement contracting staff.

Furthermore, the demographic profile of the current concessions staff

would suggest that now would be a particularly good time to begin hiring

more qualified staff. According to the agency, about 33 percent of its

concessions staff are over 50. With such a large percentage of the

workforce in this age bracket, the agency is already in the position of

needing to recruit additional staff into the program to backfill for staff that

may be retiring. In fact, the Chief of Concessions indicated that succession

planning is one of her top priorities.

By changing its hiring practices to recruit staff with backgrounds in

hospitality or business management, the agency would be applying the

same approach to recruiting that it applies to recruiting for many other

career fields−hiring staff with education and/or experience appropriate for

the work they will be doing. For example, many staff in the interpretive

ranger career field have backgrounds in history, education, science,

recreation, or other related fields. The staff managing natural resources

frequently have backgrounds in biology, botany, ecology, agronomy or

other resource related fields. By hiring staff with backgrounds appropriate

for concessions, the agency would both align its hiring practices for

concessions with its hiring practices for other career fields and improve the

qualifications of its concessions staff.

In addition to changing its hiring practices, the agency could upgrade the

training and qualifications of its concessions contracting staff to be similar

to those of its procurement staff. To assist with this, there may be a role for

officials from the Department of the Interior. Under the FAR, the

Department’s Office of the Procurement Executive is responsible for

ensuring that all procurement staff are sufficiently qualified to write

procurement contracts. This office could also be responsible for ensuring a

similar competency for the Park Service’s concessions contracting staff. In

fact, officials from this office agreed that they could provide some
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assistance in this area to the concessions program. If the standards on

training and qualifications for procurement contracting staff were applied

to concessions contracting staff, there would be a significant improvement

in the training and qualifications of the concessions contracting staff.

The benefit of selecting this option would be a more qualified, bettertrained, and professional workforce. This staff would be in a position to

make better business-related decisions and write contracts that

incorporate the best practices of the private and the public sectors. The

agency would not need to rely on staff who consider themselves “novices”

in contracting to write and execute multimillion-dollar concessions

contracts. A more qualified concessions contracting staff would be an asset

to the agency as it seeks to reduce its backlog of expired and expiring

concessions contracts.

However, there are also some costs and risks in pursuing the option of

professionalizing the workforce. Because of the backlog of expired,

expiring, and extended contracts, the agency has an immediate and

substantial workload that needs to be addressed. The process of

professionalizing its staff will take time, since staff need to be hired and

training needs to be conducted. As a result, if the agency chooses to

professionalize its workforce, it may further delay its contracting workload

while it pursues this effort, thereby increasing the backlog and potentially

affecting the condition of concessions facilities.

Providing additional training to concessions staff would also cost money.

According to concessions staff, there is generally only enough training

funding available to the concessions program to pay for one programwide

40-hour class each year. Providing a level of training comparable to that

received by procurement contracting staff would require much more than a

single week-long class. To fund such a training curriculum, the parks,

concessions program, or agency would have to shift its funding priorities,

obtain more money via appropriations, or find other funding sources.

Because increased appropriations are unlikely, the agency may have to

reconsider the relative priorities of all training and other activities within

the agency. This could mean that if additional concessions contracting

training were provided, some other training or activities within the agency

would receive less funding.

Instead of shifting priorities from other training or activities, the agency

could tap one other potential source of funding for additional concessions

training. Under the new concessions law, 80 percent of concessions fees
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stay at the parks where they are generated and 20 percent are available for

use at the discretion of the agency. In 1998, the Park Service collected

about $16.5 million in concessions fees. Twenty percent of these fees would

be about $3.3 million. Using this money, the Park Service could fund many,

or perhaps all, of its additional training needs. If it chose to do so, however,

the trade-off would be that this $3.3 million would not be available to fund

various improvements in the parks.

Finally, while there are benefits and risks in pursuing this option, the

agency’s past record in taking action to change its hiring practices and

upgrade its training is not encouraging. Many of the concerns we have

raised in this report about the qualifications of its concessions staff have

been raised repeatedly over the past 10 years by the Department of the

Interior’s Inspector General and by several different departmental or

agency task forces. Several times over this period, the Park Service has

generally agreed that it needs to professionalize its concessions workforce.

However, our work indicates that there has not been significant progress in

this area. Hence, the agency’s past performance suggests to us that there

can be little confidence that the agency will address these issues.

A 1997 Park Service task force report also expressed concern about the

agency’s not making needed improvements in its management of the

concessions program. The report indicated that the greatest single barrier

to the effective management of human resources within the concessions

program was the potential lack of commitment from agency management.

According to the report, “[t]here is only one scenario that may be more

harmful to the Concessions Management Program than management’s

withholding its commitment to [professionalizing the workforce]. That

scenario would involve management saying that it is committed when in

fact it is unwilling or unable to be.”

Contract for Needed

Business and

Contracting Expertise

Instead of professionalizing its workforce, the Park Service could contract

for the expertise it needs to operate a more businesslike concessions

program. Contractors could be hired to handle a number of financial and

business related tasks, such as planning, writing prospectuses, performing

financial analysis, assisting with contracting, and evaluating the

performance of concessioners. This concept is consistent with the

guidance provided in OMB Circular A-76, which encourages federal

agencies to perform only those activities that are governmental in nature—

such as managing resources—and let private firms handle business related

activities. In fact, OMB Circular A-76 specifically mentions several
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activities that could appropriately be handled by private firms under

contract with federal agencies. These activities include (1) providing

assistance to contract management, (2) providing technical evaluation of

contractors’ proposals, (3) providing inspection services, and (4) assisting

with evaluating contractors’ performance. Each of these areas is a critical

component of the Park Service’s concessions activities. In addition, the

concept of contracting with private entities to conduct or assist with

elements of managing concessioners was encouraged in the agency’s

concessions law—the National Parks Omnibus Management Act of 1998.

There would be several benefits of contracting for business-related staff.

For example, through contracting, the agency could obtain a highly

qualified workforce in a short period of time. In addition, the agency would

gain some workforce flexibility because it could adjust its staffing in

accordance with its upcoming workload. For example, it could bring

contractor staff on to handle its backlog of expired and expiring

concessions contracts and then release these staff when the backlog is

eliminated. By contracting for additional staff, the agency would not have

to spend money to train its own staff. Instead it would essentially purchase

the expertise it needs by using contractor personnel who are already

trained and knowledgeable about current industry practices and trends.

Furthermore, contracting for certain functions could improve performance

as well as reduce some of the agency’s costs. For example, park

concessions staff traditionally inspect concessioners’ facilities and

operations. These inspections can be subjective, and standards can be

applied differently from park to park. If the agency centralized and

contracted for this function, it could perhaps perform inspections with

fewer people and yet achieve greater consistency across the agency. With

this function handled by contractors, park staff could then focus on other

mission-related activities, such as managing park resources and serving

park visitors.

Hiring contractors to help the agency oversee other contractors

(concessioners) would be consistent with recent reforms the Park Service

made in its construction program. Because of congressional concerns

about the cost of its construction projects, the Park Service has changed

how it supervises most of its construction projects. Instead of maintaining

a skilled in-house workforce of engineers and architects who travel across

the country to park units to supervise the construction of visitor centers,

administrative buildings, and other park facilities, it now contracts for this

function with a number of architectural and engineering firms across the
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country. By doing so, the agency is saving money, since it pays only for the

number of skilled staff it needs to meet its current construction oversight

needs.

While contracting could reduce some costs in the concessions program, it

could also increase other costs. In particular, costs would increase if the

agency were to contract for larger numbers of highly skilled staff than it

currently maintains. However, some of these increased costs could be

mitigated by savings resulting from centralizing certain functions, such as

inspections, as previously discussed. In addition, increased costs could be

mitigated by (1) reducing the number of agency staff in the concessions

program or (2) potentially obtaining greater returns to the government

from concessions contracts through the use of a more qualified workforce

for contracting and overseeing concessioners.

If the agency were to hire contractors to handle much of its businessrelated concessions workload, then some portion of the current

concessions workforce might no longer be needed to perform these

functions. As discussed, a significant percentage of the current concessions

workforce is near retirement. Thus, some desired reduction in the agency’s

concessions staff could be handled through attrition, as staff retire. In

addition, since most concessions staff came into the concessions program

from some other career field within the agency, they have a variety of skills

in park or administrative-related fields. If any further reduction in the

concessions staff were desired, these staff could be transferred to other

career fields in the agency for which they are qualified.

Finally, another benefit of gaining expertise through contracting is the

expectation that better business practices and better concessions contracts

may produce greater returns to the government from concessions. One of

the intentions of the new concessions law was that it would increase

competition in the award of new concessions contracts. Under the

previous concessions law, most concessioners had a preferential right of

renewal when their contract expired. This preference tended to have a

chilling effect on competition because qualified businesses were reluctant

to spend time and money preparing bids when the award was most likely

going to the incumbent concessioner. As competition for concessions

contracts increases, concessioners may bid more for the rights to operate

park concessions than they previously paid. (Greater competition may also

increase the number or quality of services concessioners provide to park

visitors.) This same law also allows the agency to retain all fees generated

from concessions contracts. Therefore, any additional returns from
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concessioners could offset some portion of the costs of contracting for

more qualified staff in the concessions program.

Improve

Accountability for the

Concessions Program

Regardless of the option or combination of options selected, it is important

that changes be made to strengthen the Park Service’s accountability for

and control of the concessions program. Unless changes are made to better

link the concessions programs at individual parks with the agency’s

leadership of the concessions program, efforts to improve the program

through the suggested options are unlikely to succeed.

For example, if the Chief of Concessions decides to improve the program

by hiring staff with backgrounds or education in business or hospitality

management, then park superintendents would implement this decision,

since they are responsible for hiring staff in parks. However, if the

superintendents were not held accountable for their concessions-related

hiring practices, then the efforts of the Chief of Concessions to improve the

qualifications of concessions staff would not likely be implemented. This

concern was discussed in a 1997 agency task force report on concessions,

which listed several barriers to hiring highly qualified staff for concessions

positions. One such barrier was that officials making hiring decisions, such

as park superintendents, “may not share a Servicewide programmatic

perspective and instead may make personnel decisions based on factors

other than what may be in the best long-term interest of the agency. . . .”

This is cause for concern because, as the report indicates, (1) the Park

Service “is a decentralized organization whose various parts function with

considerable autonomy” and (2) individual hiring decisions made by park

superintendents can have a “substantial long-term effect on the Service’s

Concessions Management Program as a whole.”

Similarly, the considerable autonomy of park superintendents and the

agency’s accountability structure could be an obstacle if the Chief of

Concessions sought to gain expertise by contracting for certain functions

of the concessions program. In order for contracted expertise to be able to

improve the performance of the concessions program, the current

accountability structure of the agency would need to be changed to ensure

that the work and advice of the contractors were fully considered when

park superintendents made concessions decisions.
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In a recent report, the Department of the Interior’s Office of the Inspector

General raised concerns about how the concessions program fits into the

Park Service’s accountability structure.1 The report made several

recommendations to the Park Service including, (1) adding a critical

element for the successful completion of concessions duties in the

performance standards of officials, such as superintendents, who are

involved in concessions activities; and (2) making a senior management

official, such as the agency’s Deputy Director, responsible for ensuring that

park superintendents and regional directors successfully perform their

concessions responsibilities. In August 1999, the Director of the Park

Service sent a memorandum to each regional director stating that the

performance of park concessions programs will be considered during

annual performance reviews for each park superintendent with a

concessions program. However, according to the Chief of Concessions, she

is not sure if this direction has been implemented. In addition, according to

our review, the agency does not appear to be making a senior management

official, such as the agency’s Deputy Director, responsible for ensuring that

park superintendents and regional directors successfully perform their

concessions responsibilities. Hence, significant changes have yet to be

made to the accountability structure of the concessions program.

Conclusions While the Park Service has recognized many of the problems facing the

management of its concessions program, it has not yet been able to make

significant progress in addressing them. The extent of these problems

requires the agency to make difficult choices on how best to manage the

performance of its concessioners in order to ensure that high-quality

facilities and services are provided to the hundreds of millions of people

who visit the parks each year. Unless the agency takes action, its

concessions program will continue to provide facilities and services whose

quality varies considerably from park to park. In our view, the agency can

do more to strengthen the accountability of the concessions program.

While the agency indicated in August 1999 that the performance of park

concessions operations will be considered during superintendents’

performance reviews, it provided similar emphasis on concessions in 1995,

which did not result in superintendents being more accountable for their

concessions programs. Thus, in our view, it is unlikely that the emphasis

provided in the August 1999 memorandum will significantly improve the

1

Concessions Contracting Procedures: National Park Service, U.S. Department of the

Interior, Office of the Inspector General (Report No. 99-I-626, June 30, 1999).
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program’s accountability. Hence, further actions are needed to better align

the concessions program so that those implementing the program in

individual parks are more accountable to those managing and leading the

concessions program agencywide.

Recommendations to

the Secretary of the

Interior

We recommend that the Secretary of the Interior require the Director of the

Park Service to increase the effectiveness of the concessions management

program by improving the qualifications of the concessions staff (including

improving their training in writing and administering contracts),

contracting for these services, or using some combination of the two

approaches.

We further recommend that the Secretary require the Director of the Park

Service to improve the accountability of park managers by establishing a

formal process for performing periodic independent inspections of

concessioners’ lodging operations throughout the park system. These

inspection teams should determine if the facilities and services being

provided meet the agency’s standards and report identified deficiencies to

the head of the agency for corrective action.

Agency Comments and

Our Evaluation

The Department of the Interior generally agreed with the findings and

recommendations in the report. The Department stated that the

recommendations offered an opportunity to strengthen and reform the

Park Service’s concessions program. The Department also indicated that

the Park Service is already taking actions to address some of the problems

with the concessions management program that were discussed in the

report and is actively considering other actions, such as moving toward

more performance-based contracting. We believe that the Department’s

comments are a positive step and will help improve the program if they are

implemented.
Page 56 GAO/RCED-00-70 Problems in Managing Park Concessioners

Appendix I

Results of GAO’s Inspections of Lodging Apendxies

Facilities in Two Parks ApendxiI

This appendix summarizes the results of our inspections of the lodging

facilities at Olympic and Sequoia-Kings Canyon national parks. To

determine the condition of lodging facilities at these parks, we used

common industry standards for inspecting lodging facilities to develop an

evaluation checklist. The checklist included criteria for the condition of

both the exterior of the facilities and the rooms. Specifically, to assess the

condition of the facilities’ exteriors, we examined lodging structures,

grounds, public rest rooms, and public signs. To assess the condition of the

rooms, we examined (1) safety and security features, (2) the availability of

furnishings, (3) the quality of the housekeeping, and (4) the repair and

maintenance of these rooms.

Olympic National Park Olympic National Park, located in northwest Washington State, consists of

about 900,000 acres of diverse resources, including glaciers, valleys, lakes,

ocean beaches, and a temperate rain forest. Nearly 96 percent of the park is

designated as wilderness.

Within the park, four different concessioners operate both governmentowned and concession-owned lodging facilities, including lodges, cabins,

cottages, and hotel-/motel-type facilities. The four concessioners are as

much as 80 miles from each other. The facilities are Kalaloch Lodge with 64

rooms, operated by ARAMARK; Lake Crescent Lodge with 52 rooms,

operated by National Park Concessioners, Inc.; Log Cabin Resort with 28

rooms, operated by a private partnership; and Sol Duc Hot Springs Resort

with 32 rooms, also operated by a private partnership. Only Kalaloch Lodge

is open year-round; the other three facilities are open approximately from

late spring to fall. The facilities were built as early as 1916 (the lodge at

Lake Crescent resort) and as recently as 1998. Most of the units were built

during the 1950s, 1960s, and 1980s. At each of the four facilities, the Park

Service owns some of the lodging, but at each site, the government owns

less than a majority of the lodging units. None of the lodging facilities have

telephones or televisions in the guest rooms in accordance with a policy

established by the park. We inspected 9 rooms at three locations and 10 at

the fourth site.

At Kalaloch Lodge, the room rates during the peak season (early June to

early October) are $73 to $208 per night in the lodge, $152 to $211 in the

bluff cabins, $127 to $155 in the log cabins, and $119 to $130 for nine other

units. The rates at Lake Crescent Lodge range from $104 to $140 per night

for the cottages, $100 to $116 per night for the motor lodge and nonhistoric

lodge, and $65 per night for a room in the historic lodge with a central
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bathroom. The rates at Log Cabin Resort range are $49 per night for

camping log cabins (no indoor plumbing), $75 for rustic cabins, $90 for

rustic cabin with a kitchenette, $106 for a lodge room, and $122 for chalet

rooms. The rates at Sol Duc Hot Springs are $92 per night for one or two

persons in a noncooking cabin and $112 for a kitchen cabin.

Condition of the Exterior

and Grounds at Olympic

National Park

The lodging buildings and grounds at the four facilities we visited at

Olympic National Park were generally in good condition and well

maintained. Specifically, we found the following:

Structures The lodging facilities at these four facilities were generally in good repair,

although several facilities needed some repairs. Figure 6 shows needed

repairs to a roof and porch at Log Cabin Resort.
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Figure 6: Needed Exterior Repairs at Log Cabin Resort

At Kalaloch Lodge, the lodge, cabins, and other facilities were in generally

good condition. However, according to a Park Service official, the lodge
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and several of the cabins are in danger of falling into the ocean because of

severe erosion on the bluff near the facilities (see fig. 7).

Figure 7: Condition of Cliff Near Kalaloch Lodge in Olympic National Park

Proposals have been formulated to relocate and rebuild the concessionerowned lodge and several government-owned cabins. A final decision has

not been made because the concessioner wants to build a larger lodge and

the Park Service wants to replace the current lodge with one of about the

same capacity.

At Lake Crescent Lodge, some of the exterior paint had peeled and

chipped. Moss was growing on the roofs of the four fireplace cottages, and

for several of the units, the stone masonry chimneys were cracked. At Log

Cabin Resort, we noted some exterior wood rot and excessive moss

buildup on the roofs of eight rustic cabins. At Sol Duc Hot Springs Resort,

all buildings were well maintained; however, the exterior doors of some

cabins needed refinishing. A concessioner’s representative told us that

some of the exterior doors are scheduled to be refinished.

Grounds The grounds at all four facilities, which consisted mainly of lawns and

landscaping, were in generally good condition. The grounds at Kalaloch

Lodge were well maintained and free of debris and litter. At Lake Crescent
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Lodge, the grounds were well maintained, and exterior lighting had

recently been installed near the walkways. We found that at Log Cabin

Resort, the area in front of the 12 A-frame units needed a general cleanup

and weeding. In addition, about 10 picnic tables in the camping area were

in disrepair or had rotting or warped tabletops and benches. At Sol Duc, the

grounds were well maintained and had adequate lighting in the common

areas.

Public Rest Rooms The public rest rooms that we observed at Olympic National Park were

generally clean and well maintained. The public rest rooms at Kalaloch

Lodge were clean and well maintained. At Lake Crescent Lodge, a valve

was leaking in a urinal in the men’s rest room in the lodge. At Log Cabin

Resort, a hot air blower to dry hands in a women’s rest room was not

working because of a tripped circuit breaker. In addition, three of the six

light bulbs in the rest room were burned out. At Sol Duc, the public rest

rooms in the lodge were clean and well supplied.

Public Signs We did not observe any problems with the signs at the four facilities. They

were sufficient, accurate, appropriately placed, and generally well

maintained.

Condition of Rooms at

Olympic National Park

The 37 rooms that we inspected at Olympic National Park were generally in

good condition. In accordance with the park’s policy, none of the facilities

had telephones or televisions in the guest rooms.

Safety and Security Four rooms we inspected at Kalaloch Lodge presented safety and security

concerns. Three rooms had a window without a functioning lock, and the

primary lock on the door to the deck of another unit was not working.

According to a concessioner official at Kalaloch, about 50 window frames

throughout the complex were being replaced, including at least one of the

windows we found with a lock problem. Two units at Lake Crescent Lodge

had safety or security problems. One unit did not have a viewport or

window next to the entrance, and the other unit had a nonfunctioning

window lock.

At Log Cabin Resort, four of the nine units we inspected had safety or

security problems. Three units had nonworking window locks, and two

units had nonfunctioning smoke detectors. In one unit, the primary door

lock did not work. None of the nine cabins we inspected at Sol Duc were

equipped with deadbolt locks; only primary locks were found on the
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entrance doors to the cabins. The lock on a window in one cabin was not

working. We found that all units with kitchens were equipped with fire

extinguishers and every third unit without a kitchen had a fire extinguisher.

Furnishings None of the rooms we inspected had all of the furnishings required by

industry standards. For example, telephones, televisions, pencils/pens and

notepads, which are required by industry standards, are generally not made

available to guests at any of the park’s concessioner-operated facilities as a

general policy. Olympic National Park prohibits televisions and telephones

in guest rooms. Furthermore, none of the units had air-conditioning.

At Log Cabin Resort, the reading lights in all the inspected units had bulbs

of less than 75 watts—a common industry standard—and none of the units

had a notepad or pen/pencil. Five units did not have an ice bucket or alarm

clock or radio. Three units were not color coordinated, and three had no

nightstand. One or two units lacked at least one chair, an available writing

surface, shades or draperies, nonskid pads/strips in the shower/tub, or

electrical outlets in the bathroom.

At Lake Crescent Lodge, six units did not have nonskid pads or strips in the

shower/tub area, and in three units, the light fixtures had bulbs of less than

75 watts. Other deficiencies noted were no ice bucket in one room and an

unclean blanket in another room. The main lodge has five rooms that share

one bathroom for men and one for women.

At Kalaloch Lodge, all nine of the units we inspected lacked a skid pad or

mat in the shower/bathtub. Other furnishings issues were no wastebasket

in one room, no ice bucket in two rooms, no electrical outlet in the

bathroom and a bedroom in one cabin, no alarm or clock radio in one

room, and no pencil/pen or note pad in eight and nine rooms, respectively.

None of the nine cabins we inspected at Sol Duc were equipped with a note

pad, pen or pencil. Eight of the nine cabins had a reading light of less than

75 watts on the nightstand, and two units had a reading light of only 25

watts. Seven units were not furnished with an ice bucket or alarm clock or

radio. Five units had no wastebasket. Other furnishings issues were an

unclean mattress pad and an unclean or unsuitable bedspread in separate

cabins.

Housekeeping Five of the nine rooms we inspected at Kalaloch Lodge had housekeeping

deficiencies. These included mildew in a shower area; cracked caulking
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near a bathroom vanity; a dirty and stained carpet; dirty window shades;

dirty and stained walls and ceilings; and a chipped/dirty door frame.

At Lake Crescent Lodge, the shared bathrooms in the main lodge had

several housekeeping and other items needing attention. For example, an

outside vent had no fan, a toilet was not working properly, a bathtub lacked

nonskid pads/strips, a knob on a baseboard heater was missing, and paint

was peeling. Items needing housekeeping attention in the individual rooms

were dusty conditions, an unclean tub enclosure, and an unclean vanity.

Other than a torn pillowcase in one unit, none of the units we inspected at

the Log Cabin Resort had any major housekeeping problems. At Sol Duc,

one cabin with a kitchen did not have any soap in the kitchen sink soap

dispenser.

Repairs and Maintenance Three of the rooms we inspected at Kalaloch needed repairs. One room in

the main lodge had two window blinds that failed to completely lower to

block outside light, and the room also had cracks in the shower/tub area.

Two other units had drapes that did not operate correctly. One of these

units also had worn and torn carpet, and the other unit had the hot and cold

shower faucets reversed.

At Lake Crescent Lodge, four separate cabins had excessive moss growth

on the roof and severe cracks in the stone chimney. Five units needed at

least some repairs or improved maintenance. In one unit, we found a

broken window, a sagging drapery rod and a sagging drapery cord, burned

out lights, and loose drawer pulls. In other units, we found a burned out

porch light, a poorly patched carpet, inadequate water pressure in two

showers, and broken window screens.

Seven of the nine units we inspected at Log Cabin Resort had repair and

maintenance problems. These included rooms where shades or drapes did

not block outside light, an extension cord in use, peeling paint, and duct

tape over a small hole in a wall.

Four of the nine cabins at Sol Duc had items needing repair, including a

nightstand with mildew and a burn spot; one window drapery that did not

close properly; a cracking window sill in one bathroom, and reversed hot

and cold faucets in a bathroom. One cabin, located on a low site, had

excessive moisture problems, including mildew in the bathroom near the

toilet and vanity.
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Sequoia-Kings Canyon

National Park

Sequoia-Kings Canyon National Park, located in central California east of

the city of Fresno, consists of about 864,000 acres of deep canyons and high

alpine peaks in the Sierra Nevada mountains, and some 75 groves of giant

sequoia trees.1 The park also is home to the 14,494-foot Mt. Whitney—the

highest peak in the contiguous United States.

Within the park, two different concessioners operate overnight

accommodations, including lodges, cabins, and hotel-/motel-type facilities.

Accommodations in Kings Canyon include Cedar Grove Lodge with 21

motel-type rooms, Grant Grove with 51 cabins, and John Muir Lodge with

36 hotel-type rooms, all operated by Kings Canyon Park Services.

Accommodations in Sequoia include the Wuksachi Village and Lodge,

operated by Delaware North Parks Services. This facility, which has 102-

motel-type rooms, opened in May 1999.

While Wuksachi Village and Lodge and Grant Grove are open year-round,

Cedar Grove is open from late spring to fall. As of May 1999, facilities in the

park ranged in age from 8 months to over 60 years. The concessioners own

all lodging facilities in the park. Except for rooms at Wuksachi Village and

Lodge, which have telephones, none of the lodging facilities we inspected

had telephones or televisions in the guest rooms, in accordance with park

policy. We inspected a total of 27 rooms—9 at each of the three facilities;

however, we did not inspect rooms at John Muir Lodge because it did not

open until late May 1999—after our visit.

Rates at Grant Grove were $35 per night for a tent cabin, $45 to $55 for a

rustic cabin, and $85 to $90 for a bath cabin. Rates at the John Muir Lodge

ranged from $125 per night for a lodge room to $210 for a suite. At Cedar

Grove, the rates were $85 per night for a lodge room. Neither Grant Grove

nor Cedar Grove has off-peak rates. At Wuksachi Village and Lodge, peak

season rates per night were $110 for a standard room, $125 for a deluxe

room, and $155 for a superior room. Off-peak rates at Wuksachi were $75,

$90, and $105 per night, respectively, for the three types of accommodation.

1

We treated Sequoia National Park and Kings Canyon National Park as one park unit

because they are jointly administered.
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Condition of the Exterior

and Grounds at SequoiaKings Canyon National Park

With the exception of several public bathrooms/showers and the grounds

at Grant Grove, the lodging buildings and grounds at the three facilities we

visited at Sequoia-Kings Canyon National Park were generally in good

condition and well maintained.

Structures The lodging buildings at these three facilities were generally in good repair,

although several buildings needed refinishing at Grant Grove. At Grant

Grove, many structures were well maintained but the exterior paint/stain

on others was only in fair condition. Some cabins had exterior doors and

siding that were worn and needed refinishing. By contrast, at Cedar Grove,

the structures were well maintained, having been repainted in 1998. At

Wuksachi Lodge, which opened for business in May 1999, the structures

were in excellent condition, with fresh paint and stain.

Grounds The grounds at these facilities, which consisted mainly of natural

landscaping, were in generally good condition; however, at two locations,

some debris and surplus room furnishings were piled on the ground

adjacent to the guest accommodations.

At Cedar Grove, we found some debris (bricks and some trash) around

heating equipment at the rear of the facility and some partly rolled up

chicken wire in a landscaped area. At Grant Grove, adjacent to the public

bath facility in Tent City, surplus or broken cabin furnishings, such as

cabinets, screens, and chairs, were stacked together awaiting disposal, as

shown in figure 8.
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Figure 8: Grounds at Grant Grove

According to the park concessions specialist, this was unattractive and the

concessioner was to remove it immediately. At all three areas, there were

sufficient trash receptacles spread throughout the grounds, and apart from

the previously mentioned items, there was no trash or debris on the

premises. Exterior lighting was sufficient at Grant Grove and Wuksachi;

however at Cedar Grove, the walkup ramp on one side of the building had

poor illumination at night, two exterior light fixtures had missing or broken

plexiglass, and there was only one light for the parking area.

Public Rest Rooms We found major deficiencies with the public bathroom and shower

facilities at Grant Grove—specifically, the unsanitary and dirty conditions

of the public showers at Meadow Camp. The shower area, shown in figure

9, had considerable mildew on several walls, ants crawling on the floor, a

stained shower pan, a very rusty heater fixture, a dirty linoleum floor with

holes in the linoleum, light fixtures that contained bugs, a leaky shower

faucet, and considerable graffiti.
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Figure 9: Poor Condition of Public Bathroom and Shower Facilities

In the men’s rest room, one of three toilets was out of order, and another

stall was locked from the inside. Toilet stalls had considerable graffiti—

some written and some carved into wooden partitions. Other deficiencies

included excessively hot water in the vanity faucet, water on the floor due

to an overflowing toilet, a dirty and stained entrance door, chipped paint on

the walls and heater, a missing light bulb and a light fixture with a broken

cover, and some missing ceramic tiles in the vanity sink area.

Deficiencies were also noted in the bathroom and shower facilities in the

Tent City portion of Grant Grove. For example, there was no ventilation in

the men and women’s bathroom because the windows were nailed shut. In

the women’s bathroom, the hot water faucet fixtures were loose, a toilet lid

was loosely secured, there were spitwads on the ceiling, the walls were

rusty and the floor worn, and the bath light cover was missing, exposing

electrical components, as shown in figure 10.

Mildew on shower wall Rusty heater fixture
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Figure 10: Exposed Wiring in Public Bathroom and Shower Facilities

In the men’s bathroom, two of four light bulbs were burned out, the toilet

stalls contained some graffiti, one of four sinks had no hot water, the walls

were dirty in spots, and there was excessive dirt in the corners. In the

common shower area, one shower was not operating because the light

fixture was missing, and the two operating showers were each missing a

light bulb, and one shower had no operational fan for ventilation.

The public bathroom facilities in the Wuksachi Lodge were new, well

maintained, and accessible to the handicapped. At Cedar Grove, the lodge’s

public rest room facilities were generally well maintained and clean,

although they lacked electrical outlets.
Appendix I

Results of GAO’s Inspections of Lodging

Facilities in Two Parks

Page 68 GAO/RCED-00-70 Problems in Managing Park Concessioners

Public Signs We did not observe any problems with the signs at the three facilities,

although at Wuksachi, directional signs on the access road off the main

highway and in the parking lots had not been installed at the time of our

visit. The signs we did observe at all three locations were sufficient,

accurate, appropriately placed, and generally well maintained.

Condition of Rooms at

Sequoia-Kings Canyon

National Park

The 27 rooms that we inspected at Sequoia-Kings Canyon National Park

were generally in good condition. While the rooms lacked some furnishings

required by industry standards and had some housekeeping problems, they

were largely in good repair.

Safety and Security All nine rooms we inspected at Grant Grove had safety and security

concerns. Eight rooms had no dead bolt lock, and three rooms had

windows without functioning locks. Two rooms did not have a smoke

detector, and in two other rooms, the smoke detector was not functioning.

Four rooms also did not have an interior light switch.

At Cedar Grove, the doors to all nine rooms lacked a dead bolt lock, and

two rooms had no window adjacent to the door or no viewport. At

Wuksachi Lodge, no safety or security concerns were identified.

Furnishings None of the rooms we inspected had all of the furnishings required by

industry standards. For example, telephones, televisions, pencils/pens and

notepads, which are required by industry standards, are generally not made

available to guests at any of the park’s lodging facilities. At these three

locations, none of the rooms had televisions, pencils/pens and notepads;

only Wuksachi had telephones; and only Cedar Grove had air-conditioning.

While the rooms at Cedar Grove and Wuksachi Lodge were adequately

furnished, at Grant Grove, six rooms had no writing surface, nine rooms

had no ice bucket and five rooms had no electrical outlets. Four rooms

lacked sufficient light, and seven rooms had light bulbs of less that 75

watts. Seven rooms had no private bath.

Housekeeping We did find some housekeeping problems at Grant Grove and Cedar Grove.

At Grant Grove, four of the nine rooms inspected had cobwebs or bugs

and/or dirt on the windows. At Cedar Grove, seven of the nine rooms

inspected had dirt or dust on the edges of the carpet or on the drapery,

while several other rooms had cobwebs or dirty walls. At Wuksachi Lodge,

all rooms inspected were very clean.
Appendix I

Results of GAO’s Inspections of Lodging

Facilities in Two Parks

Page 69 GAO/RCED-00-70 Problems in Managing Park Concessioners

Repairs and Maintenance Overall, the rooms at Sequoia-Kings Canyon were in good repair except for

some deficiencies at Grant Grove. At Grant Grove, two rooms had smoke

detectors that were not functioning; three rooms had draperies that did not

close all the way; and three rooms had walls with holes, cracks, or graffiti.

The bathrooms in two rooms had peeling paint, and one had cracks or

holes in the wall.

Table 6 presents the detailed results of our room inspections in Olympic

and Sequoia-Kings Canyon national parks. To obtain our sample of rooms,

we generally requested a list of vacant and just cleaned but not yet

occupied rooms from the concessioner and randomly selected rooms to

inspect. We made our inspections with representatives of both the park and

the concessioner present.
Appendix I

Results of GAO’s Inspections of Lodging

Facilities in Two Parks

Page 70 GAO/RCED-00-70 Problems in Managing Park Concessioners

Table 6: Results of GAO’s Room Inspections

Number of problems found

Category/problem Olympic National Park Sequoia-Kings Canyon National Park

Number of rooms inspected 37 27

Room’s general safety and security

No/not functioning primary locks 2 1

No/not functioning dead bolt 9 17

No viewport or window 1 2

No functioning window locks 8 3

No smoke detector 2

Not functioning 2 2

No active light switch 4 4

Subtotal 26 31

Illumination

Lamps not sufficient 5

Wattage−less than 75 watts 20 8

Subtotal 20 13

Furnishings

No chair available 2 3

Not in good condition

No writing surface 2 6

Not in good condition

No nightstand 3 1

Not in good condition 2 1

No clothes facility

Not in good condition 1

No television 37 27

Not functioning

No telephone 37 18

Not functioning

No direct-dial/24-hour switchboard

Subtotal 83 57

Other

No wastebasket 6 1

No ice bucket 15 9

No electrical outlets 1 5

Continued
Appendix I

Results of GAO’s Inspections of Lodging

Facilities in Two Parks

Page 71 GAO/RCED-00-70 Problems in Managing Park Concessioners

Not functioning 1

No alarm clock/radio 14 10

No note pad 29 27

No pen or pencil 35 27

Extension cord used 2

Subtotal 102 80

General

Room not quiet 2

No luggage space

No shades/draperies 2 1

Outside light not blocked 9 3

No heating system

Not functioning 1

Not reasonably quiet

No air-conditioning 37 18

Not functioning

Not reasonably quiet

Room not color coordinated 3 1

Inadequate floor space

Subtotal 51 26

Room’s overall cleanliness

Not free of insects/rodents 3

Not free of dust/dirt/litter 1 8

Not free of cobwebs 6

Not free of stains 2 2

Not free of odors

Unclean windows 1

Subtotal 3 20

Carpeting

Dirty/stained 1 3

Worn/torn 2 1

Subtotal 3 4

Walls/ceiling

Unclean 2 2

Peeling paint 1

Defects 4

Subtotal 2 7

Bedding

Continued from Previous Page
Appendix I

Results of GAO’s Inspections of Lodging

Facilities in Two Parks

Page 72 GAO/RCED-00-70 Problems in Managing Park Concessioners

Mattress

Sagging

Not free of odors

Not sized to fit frame

Lumps/protrusions

Subtotal

Box springs

Protruding

Not quiet

Broken 1

Subtotal 1

Other

Unclean pillow 3

Two clean sheets not available 1

One clean mattress pad not available 1

Unclean pillowcase(s) 1

Unsuitable, unclean bedspread 1

Unsuitable, unclean blanket 1 1

Bed linens not changed daily 19 9

Subtotal 22 15

Bath area

General

No private bath 2 7

Inadequate ventilation 1

Inadequate lighting

Subtotal 2 8

Toilet

Not functioning 1

Unclean

Subtotal 1

Shower/tub

Not available

Not functioning 1

Unclean

Grout problems 1

Inadequate water pressure 2

Nonskid pad/strips not available 17

Inadequate hot water

Continued from Previous Page
Appendix I

Results of GAO’s Inspections of Lodging

Facilities in Two Parks

Page 73 GAO/RCED-00-70 Problems in Managing Park Concessioners

Cracks 1 2

Shower curtain/tub enclosure

Unclean and torn/mildew 3 2

Subtotal 24 5

Vanity/sink

Not available

Not functioning 1

Unclean 2

No mirror

Inadequate water pressure

Inadequate hot water 1

No or inadequate light above vanity 1

No electrical outlet convenient to sink 3

Not functioning 1

Subtotal 6 3

Towels

Not one quality bath towel/person 1

Not one quality hand towel/person

Not one quality wash cloth/person

No towel rack 2

Towels not changed daily

Subtotal 3

Other

No cloth bath mat

No spare toilet tissue

No wrapped drinking glass/person

No wastebasket 1

No wrapped soap bar/person

No facial tissue

Subtotal 1

Bath’s overall cleanliness

Not free of hair

Not free of stains

Subtotal

Bath walls/ceiling

Unclean 1 2

Peeling paint 2 2

Defects−cracks, holes, stains 1 2

Continued from Previous Page
Appendix I

Results of GAO’s Inspections of Lodging

Facilities in Two Parks

Page 74 GAO/RCED-00-70 Problems in Managing Park Concessioners

Subtotal 4 6

Total 351 278

Continued from Previous Page
Page 75 GAO/RCED-00-70 Problems in Managing Park Concessioners

Appendix II

Comments From the Department of the

Interior ApendxiI
Page 76 GAO/RCED-00-70 Problems in Managing Park Concessioners

Appendix III

Comments From the National Park Hospitality

Association ApendxiI
Appendix III

Comments From the National Park

Hospitality Association

Page 77 GAO/RCED-00-70 Problems in Managing Park Concessioners
Page 78 GAO/RCED-00-70 Problems in Managing Park Concessioners

Appendix IV

GAO Contact and Staff Acknowledgments ApendxiIV

GAO Contact Cliff Fowler, (202) 512-8029

Acknowledgments Robert Antonio, Brian Estes, Frank Kovalak, Paul E. Staley Jr, and Ned

Woodward made key contributions to this report.

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GAO Contact and Staff Acknowledgments

Page 80 GAO/RCED-00-70 Problems in Managing Park Concessioners

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