a

GAO

United States Government Accountability Office

Report to Congressional Requesters

May 2006 NATIONAL PARKS 

AIR TOUR FEES

Effective Verification 

and Enforcement Are 

Needed to Improve 

Compliance

GAO-06-468
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 2006

NATIONAL PARKS AIR TOUR FEES

Effective Verification and Enforcement 

Highlights of GAO-06-468, a report to Are Needed to Improve Compliance 

congressional requesters 

The Omnibus Budget 

Reconciliation Act of 1993 (the fees

legislation) required the National

Park Service to begin collecting 

fees from operators that conduct 

air tours over national park units 

that meet certain criteria. 

Currently, only Grand Canyon,

Haleakala, and Hawaii Volcanoes 

National Parks meet the criteria to 

charge air tour fees. The Federal

Aviation Administration (FAA), in 

cooperation with the Park Service,

also regulates air tours over park 

units pursuant to the National 

Parks Overflights Act of 1987 and 

the National Parks Air Tour

Management Act of 2000. 

GAO was asked to (1) assess the 

Park Service’s collection of air tour 

fees and (2) identify what factors, if 

any, hinder the collection of air 

tour fees. GAO is also providing 

information on the possible 

expansion of air tour fees to 

additional park units. 

Relying largely on voluntary compliance, the Park Service has collected 

some, but not all, fees from air tour operators at Grand Canyon, Haleakala, 

and Hawaii Volcanoes National Parks. After passage of the fees legislation, 

these three park units instituted air tour fees in 1994 by requesting operators 

to voluntarily report their air tours and pay appropriate fees monthly. Since 

then, the Park Service has collected about $19 million at the three park units

(in inflation-adjusted 2005 dollars). However, voluntary compliance with the 

air tour fee requirement has been inconsistent, and several operators are not 

paying the required fees. For example, GAO found that 13 of the 21 

operators conducting air tours over Grand Canyon underpaid their air tour 

fees for calendar years 2000 through 2003 by more than $1.5 million. 

The Park Service’s ability to collect air tour fees is hindered by several 

factors, as follows: 

• The Park Service cannot verify air tour activity over the three park 

units. Air tour operators are not required to record and report to either 

the Park Service or FAA their number of air tours over park units, except 

for Grand Canyon. Operators at Grand Canyon are required to report 

their air tours only to FAA. Consequently, the Park Service relies on 

operators to voluntarily report their air tours and pay the required fees. 

A GAO January 2006 report recommended that FAA take steps to require

operators to report to both agencies their air tours over park units under 

the 2000 air tour act, including Haleakala and Hawaii Volcanoes.

• The Park Service cannot effectively enforce compliance due to the lack

of air tour data. The Park Service has limited ability to enforce 

compliance because it does not have jurisdiction over airspace and lacks 

sufficient air tour data. Conversely, FAA is not required to assist with 

collecting, or enforcing the collection of, air tour fees. As a result, both 

Park Service and FAA officials told GAO, the agencies have little or no 

ability to take enforcement action against noncompliant operators. 

• Different geographic applicability of two laws complicates efforts to 

collect air tour fees. The fees legislation and the 2000 air tour act have

different geographic applicability, which has complicated the Park

Service’s collection efforts. 

Air tour fees are currently charged at only 3 of the 86 park units with air 

tours, based on the criteria established in the fees legislation. Expanding air 

tour fees to other park units could generate additional funding for the Park 

Service, but such an expansion would require a legislative change and 

should be balanced against potential impacts on air tour operators. 

Legislation could explicitly provide that the additional funding may be used 

to develop the air tour management plans required by the 2000 air tour act. 

Regarding the potential impacts on air tour operators, the 2000 air tour act 

directed FAA to prepare a report to Congress on this subject by October 

2000. FAA has drafted the report but has not submitted it to Congress. 

What GAO Recommends

Congress should consider 

amending the fees legislation or the 

2000 air tour act to reconcile their 

geographic applicability. In 

addition, GAO recommends that

FAA (1) ensure the Park Service 

receives data on air tours at Grand 

Canyon and (2) report to Congress

on the effects that fees are likely to 

have on operators. 

The Departments of the Interior

and Transportation generally 

agreed with our findings and 

recommendations, as revised. 

www.gao.gov/cgi-bin/getrpt?GAO-06-468.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robin M. 

Nazzaro at (202) 512-3841 or 

nazzaror@gao.gov. 
Page i GAO-06-468 National Parks Air Tour Fees

Contents

Letter 1

Results in Brief 5

Background 8

Largely through Voluntary Compliance, the Park Service Has 

Collected Some, but Not All, Air Tour Fees at Three Park

Units 12

Collections of Air Tour Fees Are Hindered by Several Factors 15

Expanding Air Tour Fees to Additional Park Units Should Be 

Balanced against Potential Impacts on Air Tour Operators 19

Conclusions 21

Matter for Congressional Consideration 22

Recommendations for Executive Action 22

Agency Comments and Our Evaluation 23

Appendixes

Appendix I: Scope and Methodology 26

Appendix II: Number of Authorized Air Tours over National Park Units 

and Admission Fee Information 30

Appendix III: Comments from the Department of the Interior 33

GAO Comments 36

Appendix IV: GAO Contact and Staff Acknowledgments 37

Tables Table 1: Differences in Flight Information Air Tour Operators at 

Grand Canyon National Park Reported to FAA and to the 

Park Service, Calendar Years 2000-2003 14

Table 2: Park Units with Authorized Air Tours, Grouped by Types of 

Admission Fees 20

Table 3: Air Tour Operators We Interviewed, and the Total Number 

of Operators, at the Three Park Units that Charge Air Tour 

Fees 28

Figure Figure 1: Geographic Applicability of the Fees Legislation and the 

Air Tour Management Act at Haleakala National Park 18
Contents

Page ii GAO-06-468 National Parks Air Tour Fees

Abbreviations

FAA Federal Aviation Administration

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-06-468 National Parks Air Tour Fees

United States Government Accountability Office

Washington, D.C. 20548

A

May 11, 2006 Letr

Congressional Requesters

Millions of visitors each year enjoy our national parks, monuments, historic 

sites, and other units of the national park system (national park units).1

While most visitors experience the park units on land by walking, driving, 

or as part of a bus tour, some visitors view the park units through 

commercial, sightseeing air tours (air tours). The Department of the 

Interior’s (Interior) National Park Service (Park Service) is responsible for 

managing the 390 national park units and for collecting applicable fees 

associated with their use. Collecting applicable admission and commercial 

tour use fees from individuals, private vehicles, and tour buses that enter 

the park units on land is generally a simple process. At those park units that 

charge fees, the Park Service typically collects the fees at entrance gates, 

and visitors can be denied entry if they do not pay the required fees. To 

verify that these visitors and tour buses have paid the fees, the Park Service 

periodically checks their receipts, and some park units compare visitation 

and vehicle statistics with the fees collected. In contrast, collecting 

commercial tour use fees for air tours (air tour fees) has posed some 

unique challenges for the Park Service.

As part of legislation giving the Park Service recreation fee authority, the 

Omnibus Budget Reconciliation Act of 1993 (the fees legislation) required 

the Park Service to begin collecting a commercial tour use fee for all 

aircraft conducting tours in the airspace over two park units—Grand 

Canyon and Haleakala National Parks (Grand Canyon, Haleakala)—after 

October 1, 1993.2

 The air tour fee requirement also applies to any other 

park unit that charges an admission fee and for which the Park Service 

determines the level of air tour activity over the park unit is equal to or 

greater than the level at Grand Canyon or Haleakala.3

 In December 1993, 

the Park Service determined that the level of air tour activity over Hawaii 

Volcanoes National Park (Hawaii Volcanoes) was equivalent to Haleakala 

1

In this report, we use the phrase “national park units” or simply “park units” to refer to all 

units in the national park system, including national historic sites, memorials, monuments, 

parks, recreation areas, and other designations.

2

Pub. L. No. 103-66, title X, § 10002(c), 107 Stat. 404 (1993).

3

The Omnibus Budget Reconciliation Act of 1993 uses the term “admission fees” to refer to 

the fees charged at some park units’ entrances, which the Park Service also calls “entrance 

fees.”
Page 2 GAO-06-468 National Parks Air Tour Fees

and that air tour fees would be charged for this park unit as well. The air 

tour fee per entry into the airspace of these three park units is $25 per 

aircraft with a capacity of 25 or fewer passengers or $50 per aircraft with a 

capacity of more than 25 passengers. The fees legislation also allows the 

Park Service to periodically make reasonable adjustments to the air tour 

fee. At the time of our review, all air tour aircraft at the three relevant park 

units carried fewer than 25 passengers, and since the Park Service has not 

made any adjustments since 1993 to air tour fees, only the $25 fee has 

applied. 

While the Park Service is charged with collecting air tour fees, it is the sole 

jurisdiction of the Department of Transportation’s Federal Aviation 

Administration (FAA) to regulate or control the airspace over national park 

units. As part of its aviation responsibilities, FAA issues certificates to 

pilots who conduct air tours, monitors the safety and maintenance of air 

tour aircraft, issues applicable air carrier certificates, and takes necessary 

enforcement actions. The Park Service does not issue certificates or 

business permits to air tour operators.

Congress directed FAA, in cooperation with the Park Service, to regulate 

air tours over park units in legislation commonly referred to as the National 

Parks Overflights Act of 1987 (Grand Canyon Act)4

 and the National Parks 

Air Tour Management Act of 2000 (Air Tour Management Act).5 The Grand 

Canyon Act, among other things, requires FAA to prepare and issue a plan 

to manage air traffic above Grand Canyon. FAA and the Park Service are 

jointly conducting the environmental work necessary to prepare such a 

plan, but in the meantime, FAA has issued special federal aviation 

regulations that, in part, require operators to record and report their air 

tours over Grand Canyon to FAA.6

 The Air Tour Management Act, among 

other things, requires FAA, in cooperation with the Park Service, to develop 

air tour management plans for national park units and abutting tribal lands 

4

Pub. L. No. 100-91, 101 Stat. 676 (1987).

5

Pub. L. No. 106-181, title VII, 114 Stat. 185 (2000). The Air Tour Management Act does not 

apply to (1) Grand Canyon National Park or tribal lands within or abutting that park unit; (2) 

any air tour operator while flying over or near Lake Mead National Recreation Area solely as 

a transportation route to conduct an air tour over Grand Canyon National Park; and (3) any 

land or waters in Alaska. The Air Tour Management Act also prohibits any air tours over 

Rocky Mountain National Park.

6

Special Flight Rules in the Vicinity of Grand Canyon National Park (14 C.F.R. Part 93, 

Subpart U).
Page 3 GAO-06-468 National Parks Air Tour Fees

where commercial air tour companies (air tour operators) apply for 

authority to conduct air tours.7

 As of April 2006, the agencies had not 

completed any air tour management plans, although plans are in 

development for Grand Canyon and six other national park units.8

 Under 

the regulations implementing the Grand Canyon Act, FAA has authorized 

14 air tour operators to conduct a combined total of 91,250 air tours 

annually as of March 2006.9

 Similarly, under the Air Tour Management Act, 

FAA has authorized 77 air tour operators at 85 park units to conduct a 

combined total of 262,857 air tours annually. Of that amount, 14 operators 

are authorized to conduct a combined 28,441 air tours annually at Hawaii 

Volcanoes, and 10 operators are authorized for a combined 26,325 air tours 

annually at Haleakala. 

Although legislation directs the agencies to work together in developing 

plans to manage air tours over national park units—and the agencies 

anticipate that local FAA district offices will have the lead role in 

monitoring and enforcing the plans—no law specifically assigns FAA the 

responsibility to carry out enforcement actions against air tour operators 

that do not pay their fees. Neither the Grand Canyon Act nor the Air Tour 

Management Act establish specific mechanisms for air tour fee collection 

and enforcement, except that the Air Tour Management Act required FAA 

to report to Congress by October 2000 on the effects that air tour fees are 

likely to have on the air tour industry, including (1) the viability of a tax 

credit for air tour operators and (2) the financial effects that any proposed 

offsets are likely to have on FAA.

7

A “commercial air tour operator” is any person who conducts a commercial air tour 

operation, including individuals, companies, and corporations.

8

The Grand Canyon Act requires FAA to “... prepare and issue a final plan for the 

management of air traffic in the air space above the Grand Canyon.” While the air traffic 

management plan required by the Grand Canyon Act must meet different legislative 

requirements than the air tour management plans required by the Air Tour Management Act, 

to simplify the presentation of information in this report, we will refer to all the plans simply 

as “air tour management plans.” 

9

During calendar years 2000 to 2003, 21 operators had authority from FAA to conduct air 

tours over Grand Canyon, but as of March 2006, that number had dropped to 14. In addition 

to the 91,250 total annual air tours authorized over Grand Canyon, FAA was retaining 2,721 

allocations (from operators that had gone out of business) for potential future distribution, 

as of March 2006.
Page 4 GAO-06-468 National Parks Air Tour Fees

In January 2006, we reported on the status of the Air Tour Management 

Act’s implementation.10 We found, among other things, that FAA and the 

Park Service lack data to verify air tour activity over park units regulated 

by the Air Tour Management Act because FAA and existing laws and 

regulations do not require operators to record and report such information. 

Consequently, we recommended that FAA establish a procedure for 

operators to record and report to both agencies the number of air tours 

they conduct over national park units in order to improve enforcement of 

that act. The Department of Transportation agreed with our findings in that 

report and agreed to consider our recommendations as FAA moves forward 

with the air tour management program. As part of our review of the Air 

Tour Management Act, we were also asked to review operators’ compliance 

with the payment of air tour fees. We chose to report separately on the fees 

issue because the fees legislation is distinct from the Air Tour Management 

Act, and air tour fees currently apply to only three park units.

In congressional oversight hearings in 2002 and 2004, Interior, a large air 

tour operator in Hawaii, and nonprofit conservation organizations raised 

concern that some air tour operators have not paid all fees owed to the 

national park units as required by the fees legislation.11 In this context, you 

asked us to (1) assess the Park Service’s collection of air tour fees and 

operators’ compliance in paying fees and (2) identify what factors, if any, 

hinder the collection of air tour fees. We are also providing information on 

the possible expansion of air tour fees to additional park units.

In conducting our work, we analyzed Park Service and FAA policies, 

guidance, and other relevant documents, as well as applicable laws and 

regulations. In addition, we reviewed the Park Service’s data on the 

collection of air tour fee payments at the three relevant park units and 

FAA’s data on the number of air tours over Grand Canyon, which operators 

are required to record and report to FAA. We determined that both 

agencies’ data were sufficiently reliable for the purposes of this report. We 

also interviewed Park Service officials at headquarters and at the three 

10GAO, National Parks Air Tour Management Act: More Flexibility and Better 

Enforcement Needed, GAO-06-263 (Washington, D.C.: Jan. 27, 2006).

11U.S. Senate, Committee on Commerce, Science, and Transportation, Hearing on National 

Park Overflights, October 3, 2002, S. Hrg. No. 107-1123, at 27, 34, and 36 (2002); and U.S. 

Senate, Committee on Energy and Natural Resources, Subcommittee on National Parks, 

Hearing on the National Parks Air Tour Management Act, July 22, 2004, S. Hrg. No. 108-731, 

at 21 and 25-27 (2004).
Page 5 GAO-06-468 National Parks Air Tour Fees

park units that have established air tour fees, FAA officials at headquarters 

and at the two relevant district offices, and a sample of 18 operators of the 

33 that had authority to conduct air tours at the three relevant park units. 

This sample included different sizes of air tour operators, as measured by 

the number of air tours they are authorized to conduct annually. A more 

detailed description of our scope and methodology is presented in 

appendix I. We performed our work from January 2005 through April 2006 

in accordance with generally accepted government auditing standards. 

Results in Brief Relying largely on voluntary compliance, the Park Service has collected 

some, but not all, air tour fees from operators at Grand Canyon, Haleakala, 

and Hawaii Volcanoes. After passage of the fees legislation, these three 

park units instituted air tour fees in 1994 by requesting air tour operators to 

voluntarily report their air tours and pay the appropriate fees on a monthly 

basis. Since then, the Park Service has collected about $19 million in air 

tour fees at the three park units (in inflation-adjusted 2005 dollars): at 

Grand Canyon, over $16 million; at Haleakala, about $970,000; and at 

Hawaii Volcanoes, about $1.9 million. However, voluntary compliance with 

the air tour fee requirement has been inconsistent, and several operators 

are not paying the required fees. For example, we compared the data that 

air tour operators at Grand Canyon reported to FAA with the data they 

voluntarily supplied the Park Service and found that 13 of the 21 operators 

underpaid their air tour fees for calendar years 2000 through 2003 by more 

than $1.5 million. Furthermore, at Hawaii Volcanoes, one operator, who 

owed more than $360,000 as of January 2005, has publicly stated that it 

stopped paying fees because other operators were not paying. Over the 

past 12 years, the Park Service’s efforts to collect unpaid fees have been 

uneven. For example, at Hawaii Volcanoes, Park Service officials sent 

letters to air tour operators in 1994, 1997, 2004, and 2005, encouraging the 

payment of fees, and the Park Service filed lawsuits against three operators 

at Grand Canyon. The lawsuits resulted in settlements in July 2000 in which 

the three operators agreed to make back payments totaling about $800,000, 

but Park Service officials told us the operators have stopped making such 

payments, and the park unit has taken no further action. 

The Park Service’s ability to collect air tour fees is hindered by several 

factors, as follows:

• The Park Service cannot verify air tour activity over the three park 

units. Except for Grand Canyon, air tour operators are not required to 

record and report to either the Park Service or FAA their number of air 
Page 6 GAO-06-468 National Parks Air Tour Fees

tours over national park units. At Grand Canyon, operators are required 

to report their flights to FAA, and the Park Service has requested this 

information, but the relevant FAA district office has generally been 

unwilling to share the flight data because of concerns that FAA’s 

involvement with fees could cause operators to underreport their air 

tour activity. Consequently, the Park Service relies on air tour operators 

to voluntarily and accurately report their air tours and pay the required 

fees. Without the ability to verify operators’ air tour activity, the Park 

Service cannot ensure that operators are making all the required 

payments. As previously noted, our January 2006 report recommends 

that FAA establish a procedure for operators to record and report to 

both agencies the number of air tours they conduct over national park 

units regulated by the Air Tour Management Act, which includes 

Haleakala and Hawaii Volcanoes.

• The Park Service cannot effectively enforce compliance due to the lack 

of air tour data. The agency charged with collecting air tour fees—the 

Park Service—has limited ability to enforce compliance because it does 

not have jurisdiction over the airspace or air tour operators and lacks 

sufficient air tour data. Conversely, the agency with the authority over 

the airspace and air tour operators—FAA—is not required to assist with 

collecting, or enforcing the collection of, air tour fees. Neither the Grand 

Canyon Act nor the Air Tour Management Act requires air tour 

management plans to contain provisions specifically addressing fee 

compliance. Furthermore, neither act requires that operators’ authority 

to conduct air tours over park units be conditioned on payment of air 

tour fees. While the Park Service could go to court seeking fees owed 

from noncompliant operators or refer outstanding fees to the 

Department of the Treasury for debt collection, the agency generally 

lacks the evidence necessary to prove that air tour operators have not 

paid all the fees owed. As a result, both Park Service and FAA officials 

told us the agencies have little or no ability to take enforcement action 

against noncompliant operators.

• Different geographic applicability of two laws complicates efforts to 

collect air tour fees. The fees legislation and the Air Tour Management 

Act and/or their respective implementing guidelines or regulations have 

different geographic applicability. Under the fees legislation, an air tour 

operator is required to pay a fee when a tour enters the airspace over the 

park unit, whereas the Air Tour Management Act defines air tours as 

flights over a national park unit or within a half-mile outside its 

boundary. The different geographic applicability of the two laws has 
Page 7 GAO-06-468 National Parks Air Tour Fees

complicated the Park Service’s efforts to collect air tour fees by 

providing some air tour operators with a plausible explanation for why 

they are not paying fees. Under the existing system, air tour operators 

can assert that they fly only within a half-mile of a park unit boundary 

but do not cross it; therefore, their air tours are covered by the Air Tour 

Management Act but not by the fees legislation. To enable the Park 

Service to verify air tour activity under both laws and determine the 

appropriate level of fees owed under the fees legislation, air tour 

operators would have to record and report two sets of data: one for air 

tours that cross the park unit boundary for fee collection, and another 

for air tours that fly over or within a half-mile of a park unit boundary 

for the Air Tour Management Act. Alternatively, the fees legislation and 

the Air Tour Management Act would have to be reconciled to have 

consistent geographic applicability. 

Air tour fees are currently charged at only 3 of the 86 park units with air 

tours, based on the criteria established in the fees legislation. Expanding 

air tour fees to other park units could generate additional funding for the 

Park Service, but such an expansion would require a legislative change. 

The legislation could explicitly provide that the additional funding may be 

used to develop the air tour management plans required by the Air Tour 

Management Act. In January 2006, we reported that the Park Service had 

not funded its share of the development costs for air tour management 

plans. However, any possible expansion of air tour fees should be balanced 

against potential impacts on air tour operators. FAA’s report on potential 

impacts, which the Air Tour Management Act required by October 2000, 

was drafted in January 2001 but has not been submitted to Congress. Once 

FAA submits its report, Congress, the Park Service, and other stakeholders 

will have additional information to evaluate whether air tour fees should be 

expanded to other park units.

To enhance the collection of air tour fees, Congress should consider 

amending the fees legislation or the Air Tour Management Act to reconcile 

the geographic applicability of the two laws. Once these two acts are 

reconciled, reporting by air tour operators under the Air Tour Management 

Act could also be used to monitor and enforce air tour fee collections. In 

our January 2006 report, we recommended that FAA establish a procedure 

for operators to record and report to both agencies the number of air tours 

they conduct over national park units regulated by the Air Tour 

Management Act, which includes Haleakala and Hawaii Volcanoes but not 

Grand Canyon. In order to improve compliance and enforcement of air tour 

fees at Grand Canyon, we are recommending that FAA take steps to ensure 
Page 8 GAO-06-468 National Parks Air Tour Fees

that the Park Service receives the information it needs on air tours at Grand 

Canyon. We are also recommending that FAA submit to Congress the 

report required under the Air Tour Management Act on the effects that air 

tour fees are likely to have on air tour operators. In commenting on a draft 

of this report, Interior, representing the Park Service, agreed with our 

findings, conclusions and recommendations, particularly those that 

address the need for more accurate and reliable air tour data. The 

Department of Transportation, representing FAA, generally agreed with our 

findings, conclusions, and recommendations, as revised. FAA disagreed 

with a Matter for Congressional Consideration, which we have since 

removed from the report, to amend the Grand Canyon Act and the Air Tour 

Management Act to require compliance with air tour fee payments as a 

condition for operating authority to conduct air tours over national parks 

units. We agreed with FAA that much of the administrative burden for 

making operators’ air tour operating authority conditioned on fee 

compliance could unduly fall on FAA. FAA also expressed concern that it 

would distract from FAA’s primary focus of aviation safety. As a result, we 

have removed that matter from the report. We now emphasize in the report 

that the Park Service could take more aggressive enforcement actions once 

it has the necessary air tour flight data. See the “agency comments and our 

evaluation” section and appendix III for Interior’s comment letter and our 

evaluation of these comments. 

Background The Park Service is responsible for conserving the scenery, the natural and 

historic objects, and the plants and wildlife in national park units, and for 

providing for the enjoyment of national park units in ways that leave them 

unimpaired for future generations. To accomplish its mission, the Park 

Service has a budget of about $1.7 billion for fiscal year 2006. The Park 

Service also has authority to collect and retain recreation fees from 

visitors, including entrance fees, amenity fees, and special permit fees, to 

be used primarily at the site where the fee was collected.12 In fiscal year 

2005, the Park Service collected $146.8 million in visitor use fees.

The Omnibus Budget Reconciliation Act of 1993 (the fees legislation) 

directed the Park Service to establish air tour fees by October 1, 1993.13 In 

12Federal Lands Recreation Enhancement Act, Pub. L. No. 108-447, Div. J, title VIII, 118 Stat. 

3377 (2004). 

13Pub. L. No. 103-66, title X, § 10002(c), 107 Stat. 404 (1993). 
Page 9 GAO-06-468 National Parks Air Tour Fees

the House Budget Committee’s report accompanying the fees legislation, 

the committee stated that tour operators generate their revenues by selling 

national park units as a destination and, therefore, a modest fee is a 

reasonable and justifiable means of addressing impacts they have on park 

unit resources and personnel.14 Under the fees legislation, the Park Service 

considers an air tour to be a flight that consists of one or more persons 

traveling on an itinerary that has been packaged, priced, or sold for leisure 

or recreational purposes by an organization that realizes financial gain 

through the provision of the service. The Park Service specifically excludes 

flights that are conducted solely as transportation between two points. The 

Park Service also determined that air tours that enter and exit the airspace 

over any of the applicable park units more than once during a single flight 

have to pay only one fee for that air tour. The Park Service implemented the 

fee requirement to apply whenever an air tour crosses the boundary of a 

qualifying park unit below specified altitudes at each of the park units: 

12,000 feet above mean sea level at Haleakala and 5,000 feet above ground 

level at Hawaii Volcanoes. At Grand Canyon, the special federal aviation 

regulations establish altitude levels that vary with flight patterns. 

While the Park Service is the sole agency charged with collecting air tour 

fees, it has no authority to regulate or control the airspace over the park 

units; that is the sole jurisdiction of FAA. Congress directed FAA and the 

Park Service to work together to regulate air tours over park units in the 

National Parks Overflights Act of 1987 (Grand Canyon Act)15 and the 

National Parks Air Tour Management Act of 2000 (Air Tour Management 

Act).16 FAA’s mission is to provide the safest, most efficient aerospace 

system in the world. FAA is pursuing its mission with an annual budget of 

more than $13.8 billion in fiscal year 2006, of which about $7.7 million is 

estimated to be spent on air tour management. FAA has tasked its 

Western-Pacific Regional Office with working with the Park Service to 

implement these two acts. The Park Service established the Soundscapes 

Program Center in 2000 (now the Natural Sounds Program) primarily to 

work with FAA’s Western-Pacific Regional Office to develop air tour 

management plans under the two acts. The Natural Sounds Program’s 

budget for fiscal year 2006 is about $1.4 million, according to a program 

official. 

14H.R. Rep. No. 103-111, at 371 (1993).

15Pub. L. No. 100-91, 101 Stat. 676 (1987).

16Pub. L. No. 106-181, title VII, 114 Stat. 185 (2000). 
Page 10 GAO-06-468 National Parks Air Tour Fees

The Grand Canyon Act, which was enacted 6 years before the fees 

legislation, instructed FAA and the Park Service to prepare a management 

plan for air traffic over Grand Canyon. Due to the unusually high level of air 

tour activity over the canyon and some aircraft accidents in its 

vicinity—including a collision in June 1986 between an air tour airplane 

and a tour helicopter resulting in 25 deaths—the act directed the Park 

Service to submit recommendations to FAA concerning the actions 

necessary for the protection of resources and “... substantial restoration of 

the natural quiet and experience of the park [Grand Canyon] and protection 

of public health and safety from adverse effects associated with aircraft 

overflight.” The act authorized FAA to issue regulations to implement the 

plan and authorized the Park Service to enforce the plan’s requirements 

under that agency’s own rules and regulations. To date, the two agencies 

have not developed an air tour management plan for Grand Canyon and are 

currently engaged in an alternative dispute resolution process with other 

stakeholders to develop the plan. However, after receiving 

recommendations from the Secretary of the Interior, as the Grand Canyon 

Act required, FAA revised special federal aviation regulations in June 1988 

to regulate air traffic over Grand Canyon.17 These regulations, among other 

things, created flight-free zones, minimum flight altitudes, and specific 

flight paths for air tours; required air tour operators to report their air tours 

over Grand Canyon to FAA; and established procedures for setting a limit 

on the number of air tours allocated to operators over Grand Canyon. 

Subsequently, FAA issued a final rule in December 1996 to codify the 

special regulations and, in 2000, FAA set the allocations and issued special 

authority to the operators based on their level of air tour activity over 

Grand Canyon from May 1, 1997, to April 30, 1998.18 Since then, some air 

tour operators have transferred or sold their air tour allocations with FAA’s 

knowledge. FAA has changed the total number of allocations only once, in 

accordance with a recommendation from Interior to raise the regulated 

airspace “ceiling” above Grand Canyon from 14,500 feet to 18,000 feet 

above sea level; in February 2005, FAA granted 3,711 air tour allocations to 

one operator that had previously been unregulated, which increased the 

total number of air tour allocations for Grand Canyon to 93,971.

1753 Fed. Reg. 20264 (June 2, 1988).

18Special Flight Rules in the Vicinity of Grand Canyon National Park (14 C.F.R. Part 93, 

Subpart U).
Page 11 GAO-06-468 National Parks Air Tour Fees

The Air Tour Management Act, which was enacted 7 years after the fees 

legislation, arose from noise and safety concerns, like the Grand Canyon 

Act, but applies to all park units, with the exceptions of (1) Grand Canyon 

or tribal lands within or abutting that park unit, (2) any air tour operator 

flying over or near Lake Mead National Recreation Area solely as a 

transportation route to conduct an air tour over Grand Canyon, and (3) any 

land or waters in Alaska. The Air Tour Management Act also prohibits any 

air tours over Rocky Mountain National Park. This act directed FAA, in 

cooperation with the Park Service, to develop air tour management plans 

for national park units and abutting tribal lands where air tour operators 

apply for authority to conduct air tours. The Air Tour Management Act 

defines a “commercial air tour operation” (air tour) as any flight conducted 

for compensation or hire in a powered aircraft where a purpose of the flight 

is sightseeing over a national park unit, within one-half mile outside its 

boundary, or over an abutting tribal land. In the regulations implementing 

the Air Tour Management Act, FAA further defined air tours regulated 

under that act to include only flights below 5,000 feet above ground level.19

To implement the Air Tour Management Act, FAA and the Park Service 

signed an interagency memorandum of understanding that established 

procedures the two agencies would follow in coordinating the development 

of air tour management plans, including a provision that FAA would fund 

60 percent of the cost of developing the plans, and the Park Service would 

fund 40 percent. This agreement describes the qualifying costs as external 

contractor costs required to produce the plans. These qualifying costs 

exclude staff salaries, benefits, and travel for agency personnel; agency 

equipment and supplies; and any costs for in-house contractors hired by 

either agency.

In our January 2006 report on the Air Tour Management Act, we found, 

among other things, that the Park Service has not fulfilled its agreement 

with FAA to fund 40 percent of the cost of developing the air tour 

management plans. The Park Service had not requested or received any 

dedicated funding for the program until fiscal year 2006, when Congress 

provided $500,000 toward air tour management. For fiscal year 2007, the 

Park Service has requested $2.4 million for air tour management. 

Meanwhile, from fiscal years 2001 through 2005, FAA has funded 100 

percent of the initial plans’ development through distinct budget 

appropriations totaling $27 million. Although the Park Service has, like 

FAA, contributed staff time to work on the development of air tour 

1967 Fed. Reg. 65662 (Oct. 25, 2002).
Page 12 GAO-06-468 National Parks Air Tour Fees

management plans, the cost of doing so does not count toward its 40 

percent obligation, according to the agreement. Officials from both 

agencies told us that if the Park Service does not meet its obligation within 

the next 2 years, development of future air tour management plans may be 

hindered. 

Largely through 

Voluntary Compliance, 

the Park Service Has 

Collected Some, but 

Not All, Air Tour Fees 

at Three Park Units

The Park Service, relying largely on voluntary compliance, has collected 

some, but not all, air tour fees from air tour operators at Grand Canyon, 

Haleakala, and Hawaii Volcanoes. The Park Service established air tour 

fees at Grand Canyon, Haleakala, and Hawaii Volcanoes in March 1994. In 

order to collect payments from air tour operators, Park Service officials 

sent notice letters to relevant operators that air tours over these three park 

units would be subject to the fees beginning in March 1994. However, 

officials at Haleakala reached an informal agreement with air tour 

operators to not pay fees from 1994 through 2001 if operators followed a 

specific flight path. The voluntary agreement established terms such as air 

tour routes and no-fly areas and was signed by a group of operators and 

Park Service officials at Haleakala; it kept air tours out of the park unit’s 

boundary, except for one small corner of the park unit. However, when 

Haleakala acquired more land where the air tours were conducted, it 

negotiated a new voluntary agreement with operators, which included 

paying the $25 air tour fee. Thus, Haleakala did not begin charging air tour 

fees until January 2002. Haleakala officials believe that operators have 

been mostly compliant with the air tour fee as a result of the voluntary 

agreement. Grand Canyon and Hawaii Volcanoes requested each air tour 

operator to voluntarily report monthly to the appropriate park unit the 

number of air tours conducted, as well as to send a payment covering all 

appropriate $25 fees for that month. Under the fees legislation, only park 

units charging an admission fee—which could include per-person 

admission fees—may charge air tour fees. The Park Service has chosen to 

charge air tour fees only at park units that charge a per-vehicle admission 

fee.

Since the Park Service began collecting air tour fees 12 years ago, it has 

collected about $19 million at the three park units:20 more than $16 million 

at Grand Canyon; about $970,000 at Haleakala; and about $1.9 million at 

Hawaii Volcanoes. In general, at least 80 percent of recreation fees, 

20These dollar values are in inflation-adjusted 2005 dollars; other dollar values in this report 

have not been adjusted.
Page 13 GAO-06-468 National Parks Air Tour Fees

including air tour fees, collected at a specific park unit remain available for 

expenditure, without further appropriation, at that park unit.21 The fees 

must be used for repair, maintenance, and facility enhancement directly 

related to visitor enjoyment and access; interpretive and visitor 

information; certain habitat restoration and law enforcement; direct costs 

associated with the recreation fee program; and other qualifying costs. For 

example, at Haleakala, these “80 percent funds” are being used to build new 

restrooms for visitors, complete deferred maintenance projects, 

rehabilitate exhibits, maintain trails, remove alien and invasive species, and 

construct a new entrance station. The balance (generally 20 percent) of 

recreation fees collected, including air tour fees, is available to the Park 

Service on an agency-wide basis for the same types of projects as the 80 

percent funds. 

However, voluntary compliance with the air tour fee requirement has been 

inconsistent across the three park units, and several operators are not 

paying the required fees. For example, we found that 13 of the 21 air tour 

operators that conducted air tours over Grand Canyon from May 2000 

through December 2003, underpaid their air tour fees by more than $1.5 

million. Specifically, in comparing the data that air tour operators reported 

to FAA with the data they voluntarily supplied the Park Service, we found 

that 6 operators underreported their tours to the Park Service and 

underpaid their fees, while 7 operators reported no tours to the Park 

Service and paid no fees. Table 1 shows the data that air tour operators at 

Grand Canyon reported to FAA and the data the operators voluntarily 

supplied the Park Service for paying air tour fees over those 4 years. 

Similarly, at Hawaii Volcanoes, one operator, who owed more than $360,000 

as of January 2005,22 has publicly stated that it stopped paying air tour fees 

in July 2003 because other operators were not paying—although this 

operator resumed paying fees in November 2005 and has consistently paid 

fees at Haleakala. One operator at Haleakala also told us it has not been 

paying air tour fees. 

21The Park Service may reduce the amount of fees retained by a park unit, but not below 60 

percent, for a fiscal year if the Secretary of the Interior determines that the revenues 

collected exceed the reasonable needs of a particular park unit for which expenditures may 

be made that fiscal year.

22In March 2006, Interior’s Office of Inspector General reported, among other things, that 

Hawaii Volcanoes had not been able to collect millions of dollars’ worth of air tour fees due 

to insufficient air tour data. U.S. Department of the Interior, Office of Inspector General, 

Hawaii Volcanoes National Park: Improved Operations Should Enhance Stewardship and 

Visitor Experience, P-IN-NPS-0074-2004 (Washington, D.C.: March 2006).
Page 14 GAO-06-468 National Parks Air Tour Fees

Table 1: Differences in Flight Information Air Tour Operators at Grand Canyon 

National Park Reported to FAA and to the Park Service, Calendar Years 2000-2003

Sources: GAO analysis of FAA and Park Service information (not adjusted for inflation).

a

Data for 2000 covers May through December 2000.

Since 1994, the Park Service’s efforts to collect unpaid fees have been 

uneven. All three of the park units that assess an air tour fee have sent 

letters to air tour operators encouraging the payment of fees at various 

times from 1994 through today. For example, officials at Hawaii Volcanoes 

sent letters in 1994, 1997, 2004, and 2005 to encourage air tour operators 

that they believe fly over that park unit to pay the fee. These letters also 

sought payment for past fees that were unpaid, or evidence from the 

operators that they did not fly over the park unit. In response, some air tour 

operators supplied the requested evidence and/or started paying fees for 

current air tours. At Grand Canyon, the Park Service filed lawsuits against 

three operators that had conducted air tours over that park unit but had not 

paid all appropriate fees. The lawsuits resulted in settlements in July 2000 

in which each operator agreed to make back payments and continue to 

conduct air tours by paying $50 per air tour—$25 for the current tour and 

$25 for a past tour—until the settlement amounts were paid, which totaled 

about $800,000 from all three operators. However, Park Service officials 

stated that all three operators have stopped making back payments: two of 

the operators are still conducting air tours but report that they are unable 

to afford the payment, and the third operator is no longer in business over 

Grand Canyon. Although the officials say that the operators are required to 

continue making payments under these settlements, the Park Service has 

not pursued their compliance. 

Calendar 

year

Air tours

 reported to the 

Park Service

Air tours 

reported 

to FAA

Number of air tours 

not reported to the 

Park Service

Fees owed from 

unreported air 

tours

2000a 36,282 51,112 15,438 $385,950

2001 30,739 48,915 18,632 465,800

2002 20,402 39,415 19,296 482,400

2003 35,902 43,728 7,827 195,675

Total 123,325 183,170 61,193 $1,529,825
Page 15 GAO-06-468 National Parks Air Tour Fees

Collections of Air Tour 

Fees Are Hindered by 

Several Factors

The Park Service’s ability to collect air tour fees is hindered by several 

factors: the agency cannot verify air tour activity over the three park units, 

it cannot effectively enforce compliance, and two key laws have different 

geographic applicability.

The Park Service Cannot 

Verify Air Tour Activity Over 

the Three Park Units

The Park Service is unable to verify the number of air tours that operators 

conduct over Grand Canyon, Haleakala, and Hawaii Volcanoes, thus 

limiting the agency’s ability to ensure that operators are making all the 

required payments. Except for Grand Canyon, current laws and regulations 

do not require air tour operators to record and report their air tour activity 

over national park units to either the Park Service or FAA. At Grand 

Canyon, FAA regulations require air tour operators to report all their air 

tours to FAA under the special federal aviation regulations implementing 

the Grand Canyon Act, although in practice, the operators report all their 

flights (not just air tours) over Grand Canyon to FAA. Under these special 

regulations, air tour operators report quarterly to FAA, for each flight over 

Grand Canyon, the aircraft make, model, and identification number; the 

departure date, time, and airport; and the type of flight—such as a tour, 

pilot training, or the movement of aircraft among landing locations—and 

the route flown. 

However, FAA does not collect these data for the purpose of verifying 

whether air tour operators are reporting to the Park Service all their air 

tours and paying the appropriate fees, and FAA has generally been 

unwilling to share these data with the Park Service. Officials in the FAA 

district office that is responsible for managing air tours over Grand Canyon 

explained that they are unwilling to share these data because they are 

concerned their involvement with fees could cause operators to 

underreport their air tour activity, which could reduce safety. 

Consequently, the Park Service relies on air tour operators to voluntarily 

report all their air tours and pay the required fees. Without the ability to 

verify operators’ air tour activity, the Park Service cannot ensure that 

operators are making all the required payments. In our January 2006 report, 

we recommended that FAA establish procedures for air tour operators to 

record and report their air tours conducted under the Air Tour Management 

Act to both FAA and the Park Service. The Department of Transportation 

agreed with our findings in that report and agreed to consider our 

recommendations as FAA moves forward with the air tour management 

program.
Page 16 GAO-06-468 National Parks Air Tour Fees

The Park Service Cannot 

Effectively Enforce 

Compliance Due to the Lack 

of Air Tour Data

The Park Service—the agency charged with collecting air tour fees—has 

limited ability to enforce compliance because it does not have jurisdiction 

over airspace and lacks sufficient air tour data. Conversely, FAA—the 

agency with authority over airspace and air tour operators—is not required 

to assist with collecting, or enforcing the collection of, air tour fees. 

Neither the Grand Canyon Act nor the Air Tour Management Act requires 

that air tour management plans establish specific mechanisms for air tour 

fee collection and enforcement. Furthermore, neither act requires fee 

compliance as a condition for operators’ authority to conduct air tours over 

park units. As a result, both Park Service and FAA officials told us the 

agencies currently have little or no ability to take enforcement action 

against noncompliant operators. 

Although the Park Service could potentially pursue compliance in court,23

as occurred at Grand Canyon, or through debt collection by the 

Department of the Treasury,24 neither of these options are feasible at the 

other two park units without evidence that an air tour operator flew over a 

park unit and did not pay all the fees owed. The lawsuits over air tour fees 

at Grand Canyon were successful for the Park Service because FAA, in 

those instances, supplied a sufficient amount of data showing that 

operators had conducted air tours over the park unit and should have paid 

a commensurate amount of fees. Alternatively, the Park Service could refer 

outstanding air tour fees owed to the Department of the Treasury for debt 

collection. In this case, the Department of the Treasury would attempt to 

collect whatever amount is owed by noncompliant operators. The Park 

Service would be in a better position to take these more aggressive 

collection actions, which would likely result in increased collections, if the 

agency had the necessary evidence to prove an operator had conducted air 

tours and not paid the required fees. 

23According to an official in Interior’s Office of the Solicitor, the Park Service has general 

enforcement authority to take action against air tour operators that do not pay their 

required air tour fees. The possible fines and prison sentences associated with such an 

enforcement action are found in 18 U.S.C. §§ 3571 and 3581, respectively. For example, a 

class A misdemeanor can result in a maximum sentence of 1 year imprisonment and a fine 

of up to $100,000 for individuals or $200,000 for organizations; a class B misdemeanor can 

result in a maximum sentence of 6 months imprisonment and a fine of up to $5,000 for 

individuals or $10,000 for organizations. 

24If a nontax debt owed to a federal agency has been delinquent for a period of 180 days, the 

agency must generally transfer the debt or claim to the Department of the Treasury, which 

must take appropriate action to collect the debt or claim.
Page 17 GAO-06-468 National Parks Air Tour Fees

Different Geographic 

Applicability of Two Laws 

Complicates Efforts to 

Collect Air Tour Fees

The fees legislation and the Air Tour Management Act and/or their 

respective implementing guidelines and regulations have different 

geographic applicability, which complicates the Park Service’s efforts to 

collect air tour fees. Under the fees legislation, an air tour operator is 

required to pay a fee when a tour enters the airspace over a park unit, 

whereas the Air Tour Management Act defines air tours as flights over a 

national park unit or within a half-mile outside its boundary. Furthermore, 

the applicable flight altitudes used by the Park Service to determine the air 

tours that are subject to the fees legislation differ from the flight altitudes 

established by FAA to determine the air tours that are subject to the Air 

Tour Management Act. For example, at Haleakala, payment of the air tour 

fee is triggered when air tours cross the park unit’s boundary and fly below 

an altitude of 12,000 feet mean sea level. However, air tours are regulated 

under the Air Tour Management Act at this park unit when they fly over or 

within a half-mile of its boundary and below 5,000 feet above ground level. 

Figure 1 shows the difference in the geographic scope of the acts as they 

apply to Haleakala.
Page 18 GAO-06-468 National Parks Air Tour Fees

Figure 1: Geographic Applicability of the Fees Legislation and the Air Tour Management Act at Haleakala National Park 

The different geographic applicability of the two laws has complicated the 

Park Service’s efforts to collect air tour fees by providing some air tour 

operators with a plausible explanation for why they are not paying fees. 

Under the existing system, air tour operators can assert that they only fly 

within a half-mile of a park unit boundary but do not cross it; therefore, 

their air tours are covered by the Air Tour Management Act but not by the 

fees legislation. For example, two air tour operators told Park Service 

officials in November 2004 that they did not cross Hawaii Volcanoes’ 

boundary during their air tours of the park unit and, therefore, did not owe 

any fees, despite the Park Service’s perception that they crossed the 

boundary. To enable the Park Service to verify air tour activity under both 

laws and determine the appropriate level of fees owed under the fees 

legislation, air tour operators would have to track and report two sets of 

data: one for air tours that cross the park unit boundary for fee collection, 

and another for air tours that fly within a half-mile of a park unit boundary 

for the Air Tour Management Act. As an alternative, the fees legislation and 

0

3,000

6,000

9,000

12,000

15,000

1/2 mile Park unit 

outside 

park unit 

boundary

1/2 mile

outside 

park unit 

boundary

Haleakala National Park

Air tour fee payment area

Air tour management area

Both air tour fees and management area

Feet above sea level

Source: GAO analysis of Park Service information.
Page 19 GAO-06-468 National Parks Air Tour Fees

the Air Tour Management Act would have to be reconciled to have 

consistent geographic applicability. 

Expanding Air Tour 

Fees to Additional Park 

Units Should Be 

Balanced against 

Potential Impacts on 

Air Tour Operators

As of March 2006, air tour operators had authority from FAA to conduct air 

tours over 86 park units,25 yet only 3 of those park units charge air tour fees. 

In specifying that additional park units could assess such fees only if their 

level of air tour activity matched that of Grand Canyon or Haleakala, the 

fees legislation set a high threshold. As a result, only one additional park 

unit, Hawaii Volcanoes, has qualified to charge fees in the past 12 years. 

According to FAA data, operators had authority to conduct a combined 

total of 91,250 air tours annually over Grand Canyon; 28,441 over Hawaii 

Volcanoes; and 26,325 over Haleakala. However, several other park units 

have relatively high levels of authorized air tour activity, although not as 

high as any of those three park units (see appendix II).26 For example, 

operators have authority to conduct a combined total of 14,074 air tours 

annually over Glen Canyon National Recreation Area. This park unit 

charges an admission fee, which is the fees legislation’s other requirement 

for a park unit to assess air tour fees. Park Service officials told us they 

would like to charge air tour fees at additional park units that charge 

admission fees (see table 2), but the fees legislation would have to be 

changed to lower the air tour activity threshold.

25In addition, under the Air Tour Management Act, “new entrant” operators that do not 

already have authority to conduct air tours over park units may apply for such authority, and 

existing operators may apply for such authority at additional park units, in the future.

26As of November 2005, operators conducting air tours over Statue of Liberty National 

Monument and Governors Island National Monument also had authority to conduct a 

combined 35,837 and 29,432 air tours annually, respectively—a higher level of activity than 

Haleakala National Park. However, Statue of Liberty and Governors Island National 

Monuments do not charge admission fees, which makes those park units ineligible under 

the fees legislation for charging air tour fees. In addition, air tour operators had authority to 

conduct a combined 68,814 air tours annually over Lake Mead National Recreation Area, but 

FAA believes that the total number of air tours conducted annually over Lake Mead may be 

as low as 12,880. FAA believes most of the authorized “air tours” are actually 

transportation-only flights en route to Grand Canyon National Park. The Park Service 

charges fees for those tours over Grand Canyon.
Page 20 GAO-06-468 National Parks Air Tour Fees

Table 2: Park Units with Authorized Air Tours, Grouped by Types of Admission Fees

Sources: GAO analysis of FAA and Park Service data.

Note: There are no park units with air tours that charge only a per-vehicle, and not a per-person, 

admission fee.

a

We are excluding 55,934 of the 68,814 authorized air tours over Lake Mead National Recreation Area 

because FAA believes most of the authorized “air tours” are actually transportation-only flights en route 

to Grand Canyon, not air tours over Lake Mead. Operators nonetheless applied for the authority to 

conduct tours over Lake Mead because of their uncertainty in how the Air Tour Management Act would 

be implemented. We are therefore including the remaining 12,880 authorized air tours over Lake Mead 

because FAA believes the total number of air tours conducted annually over Lake Mead by 3 operators 

may be as low as 12,880. However, FAA acknowledged it may discover more air tours are being 

conducted over Lake Mead as the agencies develop the air tour management plan for that park unit.

Expanding air tour fees to other park units could generate additional 

funding for the Park Service, but such an expansion would require a 

legislative change and should be balanced against any potential impacts on 

air tour operators. The legislation could explicitly provide for the use of 

additional funding to develop air tour management plans, which officials 

from both agencies told us may otherwise be hindered due to insufficient 

Park Service funding. In January 2006, we reported that the Park Service 

had not funded its share of the development costs for air tour management 

plans required by the Air Tour Management Act. 

With respect to the effects that air tour fees are likely to have on operators, 

FAA drafted a report in January 2001, which is still pending review at the 

Department of Transportation. The FAA draft report said that, due to the 

nature of the industry, air tour fees have been and will continue to be 

shifted to consumers in the form of higher tour prices in most cases. While 

the draft report said FAA had no specific information regarding passenger 

price sensitivity for air tours, it said estimates suggest that if ticket prices 

were raised by 1 percent, a reduction of 2 percent to 4 percent in tickets 

Number 

of park 

units

Total number of 

authorized air 

tours per year

Percentage of 

authorized air 

tours per year

Park units with air tours that charge 

air tour fees 3 146,016 49.0%

Park units with air tours that charge 

both per-person and per-vehicle 

admission fees 34 46,048a 15.4

Park units with air tours that charge 

only a per-person admission fee 21 3,990 1.3

Park units with air tours that do not 

charge any type of admission fee 28 102,119 34.3

Total 86 298,173a 100.0%
Page 21 GAO-06-468 National Parks Air Tour Fees

sold would be expected. The draft FAA report also said that if air tour fees 

were not charged at any park units other than Grand Canyon, there would 

be an estimated 2.0 million or 2.1 million air tours over the next 10 years, 

assuming a 3 percent or 5 percent growth rate, respectively. If fees were to 

be established at all park units, the draft report continued, that estimate 

would drop to 1.8 million or 1.9 million at the same growth rates. To offset 

the impact of such fees on operators, the draft FAA report stated, air tour 

fees could potentially be used as a credit against aviation excise taxes. 

However, the draft report said such a credit would present serious 

concerns because FAA relies on these taxes for its expenditures. 

Consequently, any shortfall would need to be made up by spending 

reductions, increased payments by other aviation system users, or the 

general taxpayer. The draft FAA report also said the Park Service could use 

air tour fees to help finance the development of air tour management plans 

and, subsequently, for monitoring air tour activities—but that these 

applications should not be linked to a reduction in aviation taxes. Once 

FAA submits its report, Congress, the Park Service, and other stakeholders 

will have additional information to evaluate whether air tour fees should be 

expanded to additional park units.

Conclusions The current process for the Park Service’s collection of air tour fees has 

three significant limitations: (1) fee payments are based on operators’ 

voluntary compliance, (2) there is no verification that the correct fees have 

been paid, and (3) there is little or no ability to take enforcement actions 

against operators that do not pay their fees because the Park Service lacks 

the necessary air tour data. While each one of these factors in isolation may 

not cause an insurmountable problem, combined they have led to the 

ineffective collection of air tour fees. Voluntary compliance could be 

effective if it were combined with (1) reliable data to verify that operators 

are complying with the fee requirement and (2) appropriate enforcement 

actions against operators that do not pay. However, the current process for 

collecting air tour fees has emboldened some operators not to pay the 

required fees. As a result, those air tour operators that are paying their fees 

are put at a competitive disadvantage against those operators that are not 

paying the required fees. 

The different geographic applicability of the fees legislation and the Air 

Tour Management Act has complicated collection efforts and created an 

additional disincentive for operators to accurately report their air tours and 

pay the appropriate fees. If the geographic applicability of the acts were 

consistent, operators could record and report one set of data to the Park 
Page 22 GAO-06-468 National Parks Air Tour Fees

Service for verification and collection of fees and for air tour management 

plans. 

In our January 2006 report, we recommended that FAA take steps to 

require that operators record and report their air tours under the Air Tour 

Management Act to FAA and the Park Service. The implementation of this 

recommendation, combined with making the geographic applicability of 

the acts consistent, would provide the Park Service with the necessary data 

to verify that the proper fees are being paid at Haleakala and Hawaii 

Volcanoes—and any future park unit that develops an air tour management 

plan, if air tour fees are expanded to additional park units. However, a gap 

exists in the reporting requirement for Grand Canyon because the special 

federal aviation regulations implementing the Grand Canyon Act required 

the data be reported to FAA but not the Park Service.

Finally, by stipulating that additional park units could charge air tour fees 

only if they charge admission fees and if their level of activity meets that of 

Grand Canyon or Haleakala, the fees legislation sets the bar very high: in 

the past 12 years, only one additional park unit has qualified. Lowering the 

threshold for air tour activity would allow the Park Service to expand air 

tour fees to additional park units and use the proceeds as appropriate 

under the recreation fee program. The Air Tour Management Act required 

FAA to report to Congress by October 2000 on the effects that air tour fees 

are likely to have on air tour operators. Although FAA drafted this report in 

January 2001, FAA officials told us the Department of Transportation has 

not approved it for submission to Congress. Releasing that report would 

enable Congress, the Park Service, and the air tour community to 

understand the impacts of air tour fees on operators’ businesses and help 

stakeholders to determine whether such fees should be expanded to 

additional park units. 

Matter for 

Congressional 

Consideration

To enhance the collection of air tour fees, Congress should consider 

amending the fees legislation or the Air Tour Management Act to reconcile 

the geographic applicability of the two laws.

Recommendations for 

Executive Action

In order to improve compliance with air tour fee payments and to help 

understand the impacts of such fees on air tour operators’ businesses, we 
Page 23 GAO-06-468 National Parks Air Tour Fees

recommend that the Secretary of Transportation direct the Administrator 

of FAA to take the following two actions:

• Establish a procedure for air tour operators at Grand Canyon National 

Park to report their air tour information simultaneously to the Park 

Service and FAA, or ensure that the air tour information is forwarded to 

the Park Service once it is reported to FAA by air tour operators. 

• Report to Congress on the effects that air tour fees are likely to have on 

air tour operators as required by the Air Tour Management Act.

Agency Comments and 

Our Evaluation

We provided the Departments of the Interior and Transportation with a 

draft of this report for review and comment. Interior agreed with our 

findings, conclusions, and recommendations, particularly those that 

address the need for more accurate and reliable air tour data. Interior, 

representing the Park Service, also said it supports lowering the threshold 

for the level of air tour activity in order to expand collection of air tour fees 

to additional park units. Interior provided written comments that are 

included in appendix III, along with our specific response. The Department 

of Transportation, representing FAA, offered substantive and technical 

comments and, after our revisions discussed below, generally agreed with 

our findings, conclusions, and recommendations. 

Our draft report contained a Matter for Congressional Consideration that 

stated Congress should consider amending the Grand Canyon Act and the 

Air Tour Management Act to require compliance with air tour fee payments 

as a condition for operating authority to conduct air tours over national 

park units. In providing oral comments on the draft report, FAA’s Regional 

Administrator for the Western-Pacific Region disagreed with this matter. 

The Regional Administrator stated that fee collection, and enforcement of 

fee collection, is the responsibility of the Park Service. FAA was also 

concerned that since the Park Service currently lacks an administrative 

process to provide air tour operators with legal due process before 

potentially revoking their operating authority, that this administrative 

burden would likely fall on FAA and distract from FAA’s primary focus of 

aviation safety. We believe that the collection and enforcement of air tour 

fees should be largely the responsibility of the Park Service. However, in 

those cases where FAA exclusively receives data that the Park Service 

needs to perform this function, FAA should share the data with the Park 

Service, as we have recommended. We also agreed with FAA that there was 

a risk that much of the administrative burden for making operators’ air tour 
Page 24 GAO-06-468 National Parks Air Tour Fees

operating authority conditioned on fee compliance could unduly fall on 

FAA. As a result, we have removed that matter from the report. We now 

emphasize in the report that the Park Service could take more aggressive 

enforcement actions once it has the necessary air tour flight data. 

We are sending copies of this report to the Secretaries of Transportation 

and the Interior, and other interested parties. We will also make copies 

available to others upon request. In addition, the report will be available at 

no charge on the GAO Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me 

at (202) 512-3841 or nazzaror@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix IV.

Robin M. Nazzaro

Director, Natural Resources

 and Environment 
Page 25 GAO-06-468 National Parks Air Tour Fees

 List of Requesters

The Honorable Daniel Inouye

Co-Chairman

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Jeff Bingaman

Ranking Minority Member

Committee on Energy and Natural Resources

United States Senate

The Honorable Daniel K. Akaka

Ranking Minority Member, Subcommittee on National Parks

Committee on Energy and Natural Resources

United States Senate

The Honorable Lamar Alexander

United States Senate

The Honorable John McCain

United States Senate
Page 26 GAO-06-468 National Parks Air Tour Fees

Appendix I

Scope and Methodology AAppenednxidexiIs

We identified and analyzed applicable laws, regulations, National Park 

Service (Park Service) policies, guidance, procedures, and other relevant 

documents to assess the Park Service’s collection of air tour fees and 

operators’ compliance in paying fees. In addition, we visited the three 

relevant park units—Grand Canyon, Haleakala, and Hawaii Volcanoes 

National Parks—and reviewed the Park Service’s data on the collection of 

air tour fee payments at these three park units. We then adjusted these 

figures to express them in inflation-adjusted 2005 dollars. We also reviewed 

the Federal Aviation Administration’s (FAA) data on the number of air tours 

reported by operators at Grand Canyon National Park. We determined that 

both agencies’ data were sufficiently reliable for the purposes of this 

report. We also interviewed Park Service and Department of the Interior 

(Interior) officials at headquarters, Park Service officials at the three park 

units that have established air tour fees, and FAA officials at headquarters 

and at the two relevant district offices. 

In addition, we interviewed a probability sample of 18 operators of the 33 

that had authority from FAA to conduct air tours at the time of our visits in 

2005 over the three relevant park units. The sample was selected in such a 

way as to serve the purposes of both this report and our January 2006 

report on the National Parks Air Tour Management Act of 2000 (Air Tour 

Management Act).1

 To choose the air tour operators to interview, we 

stratified the operators at each park unit into three groups based on the 

number of annual air tours FAA authorized at each park unit: small (3,000 

or fewer air tours), medium (between 3,001 and 10,000 air tours), and large 

(more than 10,000 air tours). The 18 air tour operators we interviewed 

were: Air Grand Canyon, Inc.; Aris, Inc.; Aviation Ventures, Inc.; Big Island 

Air, Inc.; Call Air, Inc.; Grand Canyon Airlines, Inc.; Helicopter Consultants 

of Maui, Inc.; K&S Helicopters, Inc.; King Airelines, Inc.; Manuiwa Airways, 

Inc.; Maverick Helicopters, Inc.; Mokulele Flight Service, Inc.; Rainbow 

Pacific Helicopters, Ltd.; Safari Aviation, Inc.; Scenic Airlines, Inc.; 

Schuman Aviation, Co. Ltd.; Sunshine Helicopters, Inc.; and Vista 

Helicopter Services, Inc. 

For Grand Canyon National Park (Grand Canyon), 11 of the 17 operators 

that had authority to conduct air tours in July 2005 also had authority to 

conduct air tours over nearby Lake Mead National Recreation Area (Lake

1

GAO, National Parks Air Tour Management Act: More Flexibility and Better 

Enforcement Needed, GAO-06-263 (Washington, D.C.: Jan. 27, 2006).
Appendix I

Scope and Methodology

Page 27 GAO-06-468 National Parks Air Tour Fees

Mead).2 For purposes of this report and our January 2006 report, we 

needed to focus on those operators that had authority to conduct air tours 

at both park units, so we randomly selected operators from those 11 

operators. Specifically, we interviewed 3 of the 6 small, 3 of the 3 medium, 

and 1 of the 2 large operators that had authority to conduct air tours over 

both Grand Canyon and Lake Mead. 

For Haleakala and Hawaii Volcanoes National Parks (Haleakala, Hawaii 

Volcanoes), 8 operators had authority to conduct tours over both park 

units, and 8 other operators had authority to conduct tours over either 

Haleakala or Hawaii Volcanoes, but not both. Ten of these 16 operators 

were small, 5 were medium, and 1 was large. We interviewed the 1 large 

operator, 3 of the 5 medium operators (selected randomly), and 7 of the 10 

small operators (selected as follows). For purposes of our January 2006 

report, we needed the perspective of operators that had authority to 

conduct air tours over all 6 national park units in Hawaii, so we first 

selected all operators (3 small operators) that met that criterion. This 

meant we interviewed those 3 small operators, plus we randomly selected 4 

of the remaining 7 small operators that had authority at either Haleakala or 

Hawaii Volcanoes, but not both. Table 3 details the selection of our sample 

of operators.

2

Three of the 17 operators that had authority to conduct air tours over Grand Canyon (but 

did not have authority for Lake Mead) at the time of our visit in July 2005 have subsequently 

gone out of business and have therefore lost their authority to conduct air tours, according 

to FAA.
Appendix I

Scope and Methodology

Page 28 GAO-06-468 National Parks Air Tour Fees

Table 3: Air Tour Operators We Interviewed, and the Total Number of Operators, at 

the Three Park Units That Charge Air Tour Fees

Source: GAO.

a

As noted above, 17 operators had authority to conduct air tours over Grand Canyon at the time of our 

visit in July 2005, but for the purposes of our January 2006 report, we selected from the 11 operators 

that also had authority to conduct air tours over nearby Lake Mead.

We assessed budget data describing the Park Service’s requests for annual 

appropriations and FAA’s funding dedicated to developing air tour 

management plans. This budget information covered fiscal years 2001 

through 2006 and were obtained from budget appropriation reports, the 

agencies’ budget requests, and budget summaries provided by FAA and a 

contractor. We determined that these data were sufficiently reliable for the 

purposes of this report.

To identify what factors hinder the collection of air tour fees, and to 

provide information on the possible expansion of air tour fees to additional 

park units, we considered the results of our January 2006 report, 

particularly the sections on the lack of data on air tour activity over park 

units and the Park Service’s not funding its share of the cost of developing 

air tour management plans. We also interviewed Park Service, Interior, and 

FAA officials and reviewed FAA’s January 2001 draft report to Congress on 

the likely effects that air tour fees will have on air tour operators. In 

addition, we reviewed Park Service data on the park units that charge 

admission fees. We also assessed data reflecting the number of annual air 

tours authorized by FAA for operators over various national park units 

Size of air tour operators

National park unit Small Medium Large Total

Grand Canyon National Park

Number we interviewed 3 3 1 7

Total number with authority to conduct air tours 6 3 2 11a

Haleakala National Park (only)

Number we interviewed 0 1 0 1

Total number with authority to conduct air tours 1 1 0 2

Hawaii Volcanoes National Park (only)

Number we interviewed 4 1 0 5

Total number with authority to conduct air tours 4 2 0 6

Both Haleakala and Hawaii Volcanoes

Number we interviewed 3 1 1 5

Total number with authority to conduct air tours 5 2 1 8
Appendix I

Scope and Methodology

Page 29 GAO-06-468 National Parks Air Tour Fees

under the Air Tour Management Act and the National Parks Overflights Act 

of 1987. We interviewed agency officials regarding a series of data 

reliability questions addressing areas such as data entry, data access, 

quality control procedures, and data accuracy and completeness. We asked 

follow-up questions whenever necessary. We determined that these data 

were sufficiently reliable for the purposes of this report.

We performed our work from January 2005 through April 2006 in 

accordance with generally accepted government auditing standards. 
Page 30 GAO-06-468 National Parks Air Tour Fees

Appendix II

Number of Authorized Air Tours over National 

Park Units and Admission Fee Information ApendxiI

Name of park unit

Total number of air 

tours authorized 

per yeara

Park unit charges a 

per-person 

admission feeb

Park unit charges a 

per-vehicle 

admission feeb

Grand Canyon National Park 91,250 ✔ ✔

Lake Mead National Recreation Area (includes part of 

Parashant National Monument) 68,814c ✔ ✔

Statue of Liberty National Monument (includes Ellis Island 

National Monument) 35,837

Governors Island National Monument 29,432

Hawaii Volcanoes National Park 28,441 ✔ ✔

Haleakala National Park 26,325 ✔ ✔

Glen Canyon National Recreation Area 14,074 ✔ ✔

Rainbow Bridge National Monument 10,175

Cape Hatteras National Seashore 8,170

Mount Rushmore National Memorial 5,608

Acadia National Park 4,585 ✔ ✔

Badlands National Park 4,117 ✔ ✔

Bryce Canyon National Park 3,488 ✔ ✔

Golden Gate National Recreation Area (includes Alcatraz 

Island, Muir Woods National Monument, Presidio of San 

Francisco, and Fort Point National Historic Site)d 2,900 ✔

Point Reyes National Seashore 2,900

San Francisco Maritime National Historical Park 2,900

Kalaupapa National Historical Park 2,250

Great Smoky Mountains National Park 1,920

Glacier National Park 1,793 ✔ ✔

Big Cypress National Preserve 1,260

Canyonlands National Park 1,039 ✔ ✔

Zion National Park 742 ✔ ✔

Arches National Park 675 ✔ ✔

Everglades National Park 674 ✔ ✔

North Cascades National Park (includes Lake Chelan 

National Recreation Area) 437

Capitol Reef National Park 334 ✔ ✔

Navajo National Monument 277

Timpanogos Cave National Monument 254

Biscayne National Park 200

Natural Bridges National Monument 195 ✔ ✔
Appendix II

Number of Authorized Air Tours over 

National Park Units and Admission Fee 

Information

Page 31 GAO-06-468 National Parks Air Tour Fees

Montezuma Castle National Monument 185 ✔

Canyon de Chelly National Monument 177

Mount Rainier National Park 173 ✔ ✔

Yellowstone National Park 148 ✔ ✔

Chaco Culture National Historical Park 147 ✔ ✔

Colonial National Historical Park 147 ✔

Olympic National Park 139 ✔ ✔

Bandelier National Monument 126 ✔ ✔

Yosemite National Park 115 ✔ ✔

Dry Tortugas National Park 100 ✔

Sunset Crater Volcano National Monument 98 ✔

Hovenweep National Monument 92 ✔ ✔

Lassen Volcanic National Park 89 ✔ ✔

Aztec Ruins National Monument 83 ✔

Cedar Breaks National Monument 79 ✔

Grand Teton National Park 74 ✔ ✔

Death Valley National Park 67 ✔ ✔

Mesa Verde National Park 63 ✔ ✔

Yucca House National Monument 63

Tuzigoot National Monument 62 ✔

Petrified Forest National Park 60 ✔ ✔

Voyageurs National Park 60

Wupatki National Monument 60 ✔

Colorado National Monument 57 ✔ ✔

Walnut Canyon National Monument 49 ✔

Petroglyph National Monument 45

El Malpais National Monument 43

El Morro National Monument 43 ✔

Fort Union National Monument 32 ✔

Pecos National Historical Park 32 ✔

Hubbell Trading Post National Historic Site 27

Gila Cliff Dwellings National Monument 26 ✔

Pipe Spring National Monument 26 ✔

Devils Tower National Monument 22 ✔ ✔

Saguaro National Park 20 ✔ ✔

San Juan Island National Historical Park 20

(Continued From Previous Page)

Name of park unit

Total number of air 

tours authorized 

per yeara

Park unit charges a 

per-person 

admission feeb

Park unit charges a 

per-vehicle 

admission feeb
Appendix II

Number of Authorized Air Tours over 

National Park Units and Admission Fee 

Information

Page 32 GAO-06-468 National Parks Air Tour Fees

Sources: FAA and the Park Service.

a

With the exception of Grand Canyon National Park, this information reflects interim operating authority 

that FAA has granted under the Air Tour Management Act as of November 2005. For Grand Canyon, 

FAA determined the number of authorized air tours under the Grand Canyon Act based on operators’ 

air tour activity from May 1, 1997, to April 30, 1998, and made one adjustment in 2005 with an increase 

of 3,711 air tour allocations due to a change in the regulations. Collectively, air tour operators have 

authority from FAA to conduct air tours over 86 of the nation’s 390 national park units.

b

The Omnibus Budget Reconciliation Act of 1993 uses the term “admission fees” to refer to the fees 

charged at some park units’ entrances, which the Park Service also calls “entrance fees.”

c

At the time of our review, FAA officials believed that the total number of air tours conducted annually 

over Lake Mead National Recreation Area may be as low as 12,880. FAA officials believe most of the 

authorized “air tours” are actually transportation-only flights en route to Grand Canyon National Park. 

Transportation-only flights are exempt from the Air Tour Management Act, but operators nonetheless 

applied for operating authority over Lake Mead because of their uncertainty in how that act would be 

implemented. 

d

Of the Golden Gate National Recreation Area’s subunits listed, Muir Woods National Monument 

charges a per-person admission fee but no per-vehicle admission fee; all the other subunits do not 

charge any admission fees.

Carlsbad Caverns National Park 18 ✔

Guadalupe Mountains National Park 18 ✔

Salinas Pueblo Missions National Monument 17

Great Sand Dunes National Park and Preserve 16 ✔

Mojave National Preserve 15

Capulin Volcano National Monument 13 ✔ ✔

Lake Roosevelt National Recreation Area 12

Golden Spike National Historic Site 11 ✔ ✔

Sequoia & Kings Canyon National Park 10 ✔ ✔

Dinosaur National Monument 9 ✔ ✔

Black Canyon of the Gunnison National Park 7 ✔ ✔

Casa Grande Ruins National Monument 6 ✔

Big Bend National Park 5 ✔ ✔

Coronado National Memorial 5

Fort Bowie National Historic Site 5

Fort Davis National Historic Site 5 ✔

Hohokam Pima National Monument 5

Organ Pipe Cactus National Monument 5 ✔ ✔

Rio Grande Wild & Scenic River 5

Tumacacori National Historical Park 5 ✔

(Continued From Previous Page)

Name of park unit

Total number of air 

tours authorized 

per yeara

Park unit charges a 

per-person 

admission feeb

Park unit charges a 

per-vehicle 

admission feeb
Page 33 GAO-06-468 National Parks Air Tour Fees

Appendix III

Comments from the Department of the 

Interior ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.
Appendix III

Comments from the Department of the 

Interior

Page 34 GAO-06-468 National Parks Air Tour Fees
Appendix III

Comments from the Department of the 

Interior

Page 35 GAO-06-468 National Parks Air Tour Fees
Appendix III

Comments from the Department of the 

Interior

Page 36 GAO-06-468 National Parks Air Tour Fees

The following are GAO’s comments on the Department of the Interior’s 

letter dated April 20, 2006.

GAO Comments 1. Our draft report did not contain any recommendations to the National 

Park Service. 
Page 37 GAO-06-468 National Parks Air Tour Fees

Appendix IV

GAO Contact and Staff Acknowledgments ApendxiIV

GAO Contact Robin M. Nazzaro, (202) 512-3841, nazzaror@gao.gov

Staff 

Acknowledgments

In addition to the individual named above, Jeffery D. Malcolm, Assistant 

Director; Josey Ballenger; Alisha Chugh; Wyatt R. Hundrup; Richard 

Johnson; Alison O’Neill; Judy Pagano; Anne Rhodes-Kline; and Carol 

Herrnstadt Shulman made key contributions to this report. Also 

contributing to the report were Roy Judy, Steve Martin, and Jena Sinkfield.

(360667)
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