Recreation Fees: Agencies Can Better Implement the Federal Lands Recreation Enhancement Act and Account for Fee Revenues
Published: 2006-09-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In recent years, Congress has expressed concerns about the federal land management agencies' ability to provide quality recreational opportunities and reduce visitor confusion over the variety of user fees. In December 2004, Congress passed the Federal Lands Recreation Enhancement Act (REA) to standardize recreation fee collection and use at federal lands and waters. GAO was asked to determine (1) what the agencies have done to coordinate implementation of REA, (2) what agencies have done to implement REA, (3) the extent to which agencies have controls and accounting procedures for collected fees, (4) how projects and activities are selected to receive funding from fees, and (5) the extent of unobligated fund balances. To answer these objectives, GAO reviewed agency guidance, analyzed fee data, interviewed officials, visited 26 fee-collecting units, and administered a nationwide survey to 900 fee-collecting units.
section_title: What GAO Found
paragraphs: The Departments of the Interior (DOI) and Agriculture (USDA) established four working groups to facilitate interagency cooperation and coordination of REA implementation. Each working group has made progress, but some issues remain unresolved. For example, the Interagency Pass working group has yet to determine the price to charge for the new pass, which is to be implemented in January 2007. To implement REA, agencies reviewed their fee programs and made modifications to the fee programs at some of their units. For example, several of USDA's Forest Service units dropped 437 sites from their fee program, such as picnic areas, because they did not meet REA criteria. However, not all units are in compliance with REA. Many agency officials said that while the agencies have issued some interim guidance, REA was difficult to interpret and suggested the need for more specific and detailed guidance on the fee program. In addition, DOI's Bureau of Reclamation has not yet determined whether to implement REA. Reclamation is assessing how REA applies to its operations. Some agencies lack adequate controls and accounting procedures for collected recreation fees and lack effective guidance for establishing such controls. On the basis of visits, some units did not have an effective means of verifying whether all collected fees are accounted for. In addition, many units have not implemented a system of routine audits to help ensure that fees are collected and used as authorized and that collected funds are safeguarded. The various agencies participating under REA have different processes for selecting projects to be funded with recreation fee revenues. At DOI's Bureau of Land Management and Fish and Wildlife Service and USDA's Forest Service, most proposed projects are approved at the local unit level, usually within a few weeks. At DOI's National Park Service, fee projects are reviewed and approved at the unit, regional, and headquarters or department level before projects are funded. According to National Park Service officials, under this process, it can sometimes take a year or more to obtain approval for a requested fee project, which delays project implementation and contributes to unobligated fee revenue balances. Agencies have $300 million in unobligated fee revenue balances. Unit officials cited several reasons for the unobligated balances, such as the need to save for large projects. Many unit officials also said that recreation fee revenues are essential to providing services at their recreation areas that would not otherwise be funded.

section_title: Letter
paragraphs: Over the past several years, Congress has expressed concern about the  operation and maintenance of federal recreation sites and the ability of  federal land management agencies to continue providing visitors high- quality recreational opportunities, while at the same time protecting  natural and other resources. To help address these concerns, Congress  passed legislation in 1996 authorizing an experimental initiative called the  Recreational Fee Demonstration Program (Fee Demo), under which  participating agencies were authorized to establish and collect recreation  fees at a number of sites and to use the revenues to enhance visitor  services, manage and protect resources, and reduce maintenance backlogs,  among other uses. Agencies participating in the Fee Demo program  included the Department of the Interior’s (DOI) Bureau of Land  Management (BLM), Fish and Wildlife Service (FWS), and the National  Park Service (NPS), as well as the U.S. Department of Agriculture’s (USDA)  Forest Service (FS). The Fee Demo program created two types of  recreation fees: entrance fees for basic admission to an area and user fees  for specific activities, such as camping or boat launching. Between 1996  and 2004, Congress reauthorized the program several times. The program  was designed to allow agencies to be creative in developing and  experimenting with new fees and fee collection practices for improving  visitor services, and to alleviate visitor confusion by coordinating multiple  or overlapping recreation fees. The program required that at least 80  percent of fee revenues be used at the sites where they were collected,  while allowing for the remaining 20 percent to be distributed to other sites  that may or may not be participating in the demonstration program.  Despite these program benefits, our reviews of the Fee Demo program identified a number of areas needing improvement. Specifically, we  reported that opportunities remained for the agencies to be more  innovative and cooperative in designing, setting, collecting, and  coordinating fees. We also reported that heavily visited sites might  eventually have more revenue than needed for their projects, while other  sites could have unmet needs as a result of adhering to the requirement that  80 percent of the revenues be used at the sites where they were collected.
To address these and other issues, in December 2004, Congress passed the  Federal Lands Recreation Enhancement Act (REA), which repealed the  Fee Demo program. Under REA, five federal agencies—BLM, FWS, NPS,  and the Bureau of Reclamation (Reclamation) in DOI, and FS in USDA— are authorized to charge and collect recreation fees at federal lands and  waters. When Congress authorized REA, it attempted to improve upon the  demonstration program by providing fee authority for 10 years until  December 2014, standardizing the types of fees, increasing flexibility for  fee revenue expenditures, and authorizing a new national, interagency  “America the Beautiful—the National Parks and Federal Recreational  Lands Pass” designed to minimize visitor confusion over which passes can  be accepted where. REA also provides criteria for establishing several  different kinds of fees (entrance, standard amenity, expanded amenity, and  special recreation permit) and prohibits charging of fees for certain  activities and services such as outings conducted by schools for  noncommercial educational purposes.
Under REA, only NPS and FWS are authorized to collect entrance fees. An  entrance fee simply refers to a fee charged to enter lands managed by these  agencies. BLM, FS, and Reclamation are authorized to collect standard  amenity fees, which is a fee for access to a National Conservation Area; a  National Volcanic Monument; a destination visitor or interpretive center  that provides a broad range of interpretive services, programs, and media;  or use of an area that provides significant opportunities for outdoor  recreation and contains all of the following six amenities: (1) designated  developed parking; (2) a permanent toilet facility; (3) a permanent trash  receptacle; (4) an interpretive sign, exhibit or kiosk; (5) picnic tables; and  (6) security services. In addition, each of the five agencies can collect  “expanded amenity fees,” as well as fees for special recreation permits.  Expanded amenity fees may be charged for the use of a specialized facility,  equipment, or service, such as a campground, boat launch, reservation  service, or interpretive tour. REA outlines the criteria that must be met in  order to charge this fee. For example, in order for a BLM, FS, or  Reclamation unit to charge an expanded amenity fee for use of a developed  campground, the campground must include at least a majority of nine  specified amenities such as tent or trailer spaces, drinking water, and  simple devices for containing a campfire. Each of the five agencies can also  collect a special recreation permit fee in connection with the issuance of a  permit for specialized recreation uses of federal recreational lands and  waters, such as group activities, recreation events, and motorized  recreational vehicle use.
In general, REA directs the Secretaries of the Interior and Agriculture to  involve the public in developing recreation fees and requires BLM and FS to  establish committees, called Recreation Resource Advisory Committees  (RRACs) or use an existing Resource Advisory Committee, to allow public  input on recommendations for fee amounts and their usage, and the  establishment of new fee sites. REA provides that recreation fee revenues  are available for expenditure without further appropriation, until expended  and, in general, requires that the collecting unit retain a minimum of 80  percent of revenues from recreation fees. However, REA does give the  agencies some flexibility to make an annual decision to reduce the  percentage allocation to a collecting unit to as little as 60 percent if they  determine the revenues collected at a given unit exceed its reasonable  needs. The remainder of these revenues goes into a central agency account  for expenditure on an agencywide or regional basis. While we describe  agency procedures for distribution of these funds, the use of these central  funds was beyond the scope of this review. Furthermore, the law extends  the agencies’ authority to collect recreation fees to December 2014. The  primary differences between the Fee Demo program and REA authority are  illustrated in table 1.
You asked us to provide an early assessment of REA implementation and to  help ensure that the guidelines being developed to implement the new law  are based on sound management practices. As requested, we determined  (1) what agencies have done to coordinate the implementation of REA,  including preparing for the new interagency federal lands pass; (2) what  agencies have done to implement REA fee and amenity requirements and  sufficiency of guidance for REA implementation; (3) the extent to which  the agencies have control and accounting procedures for collected  recreation fee revenues; (4) how participating agencies prioritize and  approve activities and projects funded with fee revenues; and (5) the extent  to which units have unobligated fund balances and if recreational fees are  being used to fund projects formerly funded with other appropriations. We  are also providing in appendix II information on how recreation fees vary  by type, amount, and the level of amenities offered at units with similar  recreational opportunities across and within agencies participating in REA.
To address these objectives, we obtained and reviewed applicable laws,  regulations, agencywide policies and procedures, regional policies and  procedures, and the fees collected at selected units under the Fee Demo  program and REA in order to determine what changes have resulted since  REA implementation. We developed and administered a nationwide survey  to about 900 units collecting fees under REA, and 89 percent of the units  responded. We supplemented the survey information with records reviews,  analyses of documents, and testimonial evidence gathered during 26 unit  visits and in meetings with state, regional, and headquarters officials.  Appendix I shows the 26 units we visited, as well as a more detailed  description of our objectives, scope, and methodology. We conducted our  work between June 2005 and August 2006 in accordance with generally  accepted government auditing standards.
subsections: section_title: Background
paragraphs: DOI’s BLM, FWS, NPS, and Reclamation, and USDA’s FS manage more than  638 million acres of land in the United States, including lands in national  forests, grasslands, parks, refuges, and reservoirs. These agencies manage  the federal lands for multiple uses, including recreational activities such as  camping and boating. To enhance visitor services while protecting natural  and other resources, as well as to address concerns about the prior  recreation fee program, Congress passed REA, which authorized the  collection and use of recreation fees at federal lands and waters.
BLM’s mission is to sustain the health, diversity, and productivity of the  public lands for the use and enjoyment of present and future  generations. BLM manages more than 260 million acres located  primarily in 12 western states. The agency manages and issues permits  for activities such as recreation, livestock grazing, timber harvesting,  and mining. Recreation fees are collected under REA at about 100 BLM  field offices.
The mission of the FWS is to work with others to conserve, protect, and  enhance fish, wildlife, and plants and their habitats for the continuing  benefit of the American people. FWS manages more than 545 national  wildlife refuges and 37 large, multiple-unit wetland management  districts on more than 96 million acres of land throughout the nation, 69  national fish hatcheries, and 46 administrative sites. As of August 2006,  recreation fees are collected under REA at 166 FWS sites. An additional  32 national wildlife refuges only sell passes.
The mission of NPS is to conserve the scenery, the natural and historic  objects, and the wildlife of the national park system so that they will  remain unimpaired for the enjoyment of this and future generations.  NPS manages 390 national park units covering more than 84 million  acres in 49 states, the District of Columbia, American Samoa, Guam,  Puerto Rico, Saipan, and the Virgin Islands. NPS manages many of the  nation’s most precious natural and cultural resources. About 190 park  units collect recreation fees such as entrance, use, and pass sales. An  additional 31 units only generate revenue from the National Parks Pass  and other pass sales.
The mission of Reclamation is to manage, develop, and protect water  and related resources in an environmentally and economically sound  manner in the interest of the American public. Reclamation manages  about 8.5 million acres of land associated with water projects in 17  western states. The agency delivers water and hydroelectric power  through the maintenance and administration of dams and reservoirs.  Currently, Reclamation has identified seven locations that meet REA  requirements for collecting standard amenity fees.
The mission of the USDA FS is to sustain the health, diversity, and  productivity of the nation’s forests and grasslands to meet the needs of  present and future generations. FS manages more than 190 million acres  throughout the country.  The agency manages and issues permits for  activities such as skiing, livestock grazing, recreation, timber harvesting,  mining, and rights-of-way for road construction. Recreation fees are  collected at about 410 ranger districts in 155 national forests.
BLM, FWS, NPS, and FS have had broad authority to collect recreation fees  for over 40 years, first under the Land and Water Conservation Fund  (LWCF) Act of 1965 and later under Fee Demo. Initially, Fee Demo  authorized only a limited number of sites to charge and retain recreation  fees—up to 100 sites per agency—but Congress later expanded the  authority to allow any number of sites to charge and collect recreation fees.  Under Fee Demo, the agencies were encouraged to be innovative in  designing and collecting fees and to coordinate their fees with other  federal, state, and local recreational sites. The program yielded substantial  benefits for recreation sites by funding significant on-the-ground  improvements. Total fee collections were about $192 million in fiscal year  2004, with about 67 percent or $129 million collected by NPS; the four  agencies collected a total of over $1 billion in recreation fee revenues  during the 8 years of the Fee Demo program. Nevertheless, under the  demonstration program, the majority of the agencies’ funds were still  provided to them through annual appropriations.
Between 1998 and 2004, GAO conducted several reviews of the Fee Demo  program, resulting in numerous reports and testimonies. During these  reviews, we found that Fee Demo was successful in raising revenues and  providing benefits to the agencies, but that improvements could be made to  better the program. GAO informed Congress of several areas that needed to  be addressed to ensure the program’s success. These included: (1)  providing a more permanent source of revenue to supplement existing  appropriations by providing the agencies with a more permanent fee  authority; (2) encouraging effective coordination and cooperation among  agencies and individual fee sites to better serve visitors by making the  payment of fees more convenient and equitable, while at the same time  reducing visitor confusion about similar or multiple fees charged at  adjacent federal recreation sites; (3) providing the agencies with greater  flexibility regarding fee revenue expenditures by modifying the  requirement that at least 80 percent of fee revenues remain at the collection  site; and (4) encouraging fee innovation through pricing structures based  on extent of use or peak pricing. In 2004, Congress passed REA, in part, as  a response to the suggestions and concerns documented in these previous  reports. REA repealed several prior authorities such as those contained in  LWCF Act, Fee Demo, and the National Parks Omnibus Management Act of  1998, which authorized national passes including the National Parks Pass.
However, many of the fees currently charged under REA were first  instituted under the LWCF Act or during the Fee Demo program.
For fee revenues, REA provides that recreation fees collected under the act  be deposited in a special fund account and remain available for  expenditure without further appropriation action. REA allows the revenues  to be used in a variety of ways such as for repair, maintenance, and facility  enhancement; interpretation and visitor information; law enforcement; and  direct operating or capital costs associated with the fee program. However,  not more than an average of 15 percent of total recreation fee revenues may  be used for administration, overhead, and indirect costs related to the  recreation fee program. Further, REA prohibits the use of recreation fee  revenues for employee bonuses or for biological monitoring under the  Endangered Species Act.
Both visitors to federal lands and agency officials generally support  recreation fees and tout the benefits that fee revenues provide through  improved facilities and services. Some assert that the recreation fee  program will improve recreational opportunities and that it is a needed  supplement to general fund appropriations. However, concerns about the  recreation fee program continue to exist for a variety of reasons. For  example, some people are concerned that the fee program under REA does  not go far enough in simplifying fees, that federal lands will be  overdeveloped to attract fee-paying tourists, and that the law fails to ensure  that most collections will be used for the agencies’ highest priorities. Other  critics continue to oppose recreation fees in concept, in large part, on the  grounds that the cost of operating and maintaining federal lands should be  covered by general fund appropriations and that these fees constitute a  barrier to public access to federally managed lands. However, in times of  budget constraints, recreation fees may provide an important source of  additional funding needed to sustain agency operations.
section_title: Working Groups Formed to Foster Interagency Cooperation and Coordination on REA Implementation Issues Have Made Progress, but Some Issues Remain Unresolved
paragraphs: The four technical working groups formed by DOI and USDA to facilitate  interagency cooperation and coordination on specific REA implementation  issues have made progress. However, progress has been slow in some  areas, such as resolving issues surrounding the RRACs and the new  interagency pass, possibly delaying agency implementation of these  aspects of the law. For example, the working group responsible for forming  advisory committees, such as RRACs, has missed target dates, which has  ultimately delayed the establishment of some new recreation fees. GAO has  reported in the past that agencies face barriers any time they attempt to  work collaboratively, but that there are key practices that can be applied to  help enhance and sustain agency collaboration. For example, it is  important to establish compatible policies, procedures, and other means to  operate across agency boundaries. While one working group has finalized  its interagency handbook, one is not planning to issue any guidelines, and  two have not issued all of their interagency guidelines and agreements. For  example, the working group responsible for preparing for the new  interagency federal lands pass has not issued interagency guidelines  outlining such details as pass eligibility requirements and distribution of  costs and revenues among the agencies, which could potentially delay  implementing the new pass.
subsections: section_title: The RRACs/Public Participation Working Group is Facilitating the Establishment of State and Regional RRACs, but Progress Has Been Slow
paragraphs: The RRACs/Public Participation working group has focused on establishing  RRACs or utilizing existing advisory councils as part of the REA public  participation requirements. These committees may make  recommendations to the Secretaries of Interior and Agriculture related to  public concerns about implementation of standard and expanded amenity  fees or the establishment of a specific recreation fee site managed by BLM  or FS, among other issues. However, the development of the RRACs has  been slow, which has delayed the implementation of new fees or fee  changes at some units. According to a June 2005 interagency presentation,  it was expected that the RRACs would be established with members  appointed by the end of 2005. Despite progress toward establishing RRACs,  some tasks have taken longer than originally estimated and, as of August  2006, no state or regional RRACs are fully operational. Before the working  group can move forward with many aspects of establishing RRACs— including issuing a charter and soliciting nominations for membership—or  existing advisory councils can begin reviewing fee issues, an interagency  agreement on implementing the RRAC requirements had to be signed. This  interagency agreement, which covers issues such as the specific duties of  the new RRACs and existing advisory councils, was finalized on September  1, 2006, but there is no time line for implementation, according to an  agency official. In addition, other preparatory work to implement the new  RRAC requirement has begun.  For example, BLM and FS have begun  educating existing advisory councils and the public about recreation fees  and the REA public participation requirements.
Because BLM and FS generally cannot create new fees or modify existing  fees (per each agency’s interim policy) without the participation of RRACs,  or existing advisory councils, the delay in establishing these advisory  committees has prevented many units from making fee decisions. Agency  officials at 26 percent of BLM and almost 38 percent of FS fee-collecting  units responding to our survey, or 171 units out of 481 total units, said that  the establishment of or changes to recreation fees at their units had been  prevented or delayed to a moderate, great, or very great extent since the  passage of REA in December 2004. For example, the Dillon Ranger District  in the White River National Forest in Colorado is currently considering  modifying its fee structure but has been delayed because the RRACs are  not operational. Because adding new fees or increasing existing fees  generally results in an overall increase in fee revenue, some units may be  losing fee revenue that could be used to further enhance visitor services  without functioning RRACs in place. Some units, however, were allowed to  add or modify fees prior to implementation of the new RRAC requirement if  the fee changes were already in progress, and public notification and  participation requirements had been met. For example, about 25 new  expanded amenity fees have been implemented at FS units since early  2006, most of which are for cabin rentals, according to the FS Fee Program  Coordinator. In addition, in some states there are no units that currently  want to add or modify fees, so the implementation of the RRAC  requirements is not delaying fee changes at any units in those states.
The organizational structure for the RRACs and use of existing advisory  councils was approved by DOI and USDA in March 2006 via an interagency  organizational agreement that established, among other things, how the  REA RRAC requirement will be met in each state/region. In the majority of  western states, BLM and FS will use joint RRACs or committees, many of  which will be composed of existing BLM advisory councils—REA allows  existing advisory committees or fee advisory boards to perform the RRAC  duties. In addition, five new RRACs are being established nationwide.  Appendix III outlines the organizational structure and membership  requirements for the RRACs.
Finally, in addition to the specific requirement for BLM and FS to establish  RRACs or use existing advisory councils to review fee issues, REA has  several other provisions for public participation that apply to all agencies,  and these new public participation requirements have also delayed the  implementation of new fees or fee changes at some units. DOI and USDA  issued interagency guidelines on public participation that apply to all  participating agencies in September 2005. The guidelines direct the  Secretaries of Agriculture and Interior to publish a Federal Register notice  for establishing each new recreation fee area 6 months prior to its  establishment, as required by REA.  The guidelines also direct the agencies  to identify outreach efforts, such as public meetings, to encourage public  involvement in establishing recreation fee areas and to annually post  notices at each recreation fee area describing the use or anticipated use of  recreation fees collected at that site during the previous year. Some of the  agencies, including NPS, BLM, and FS, have issued agency-specific  guidance for meeting REA public participation requirements. According to  agency officials, the public participation requirements have delayed fee  changes or the establishment of new fees at some units. Agency officials at  almost 17 percent of fee-collecting units within all four agencies  responding to our survey said that the public participation process in  general had delayed or prevented the establishment of or changes to  recreation fees at their unit to a moderate, great, or very great extent since  the passage of REA in December 2004.
section_title: Interagency Pass Working Group Has Made Progress Preparing for the New Interagency Federal Lands Pass, but Some Issues Remain Unresolved
paragraphs: The Interagency Pass working group has mainly focused on preparations  for the new interagency “America the Beautiful—the National Parks and  Federal Recreational Lands Pass.” While the agencies have made progress  in preparing to implement the new pass, some issues remain unresolved.  For example, while the working group has generally determined how  revenues from passes sold centrally will be distributed for the first 3 to 5  years, it is unclear how these revenues will be distributed among all  participating agencies beyond this time frame. In addition, the working  group has not determined the price to charge for the new pass. According  to DOI, the most complex and time-consuming aspect of implementing  REA relates to establishing this new pass. The Interagency Pass working  group has been addressing the various issues involved with the pass,  including the price of the pass, the distribution of revenues from the sale of  the pass, and operational issues like accepting the pass and tracking its use  at recreation sites. The target date for implementing the new pass is  January 1, 2007, with passes available for distribution by November 1, 2006.  According to the working group, this is a very tight time line that will  require the contracting processes to stay on schedule and for subsequent  design, production, and shipping deadlines to be met.
The standard version of the new pass will be available to the general public;  in addition, there will be versions of the pass available to senior citizens,  persons with disabilities, and volunteers. Table 2 provides a description of  each of the versions of the new pass. The price of the standard pass has not  yet been determined. The Golden Eagle, Age, and Access Passports, and  the National Parks Pass will continue to be sold until the new interagency  passes are available and all existing passes will be valid for the lifetime of  the pass (e.g., 1 year from purchase for National Parks Pass and Golden  Eagle Passport; lifetime of the pass holder for Golden Age and Access  Passports).
While the price of the new standard pass has yet to be determined as of  August 2006, the pricing decision is critically important because of the  potential impact of the pass on entrance and standard amenity fee  revenues. In particular, agency officials at NPS have emphasized the  importance of pricing and marketing decisions and their potential impacts  on entrance fee revenue. To provide information to help determine the  price of the new pass, the agencies entered into a cooperative agreement  with the University of Wyoming to conduct a pricing analysis. For the study,  researchers conducted six focus groups throughout the nation, collected  benchmarking information from a number of U.S. state parks and Canadian  national parks, and developed and implemented a random telephone  survey of recreation users. According to a NPS headquarters official, the  working group is not considering potential revenue losses due to the new  interagency pass, only what the public is willing to pay for the new pass.  However, in commenting on a draft of this report, NPS headquarters  officials informed us that revenue impacts will be considered in the pricing  decision. According to a DOI official, the price of the new pass was to be  determined in the summer of 2006. As of August 2006, the price of the new  standard (annual) pass had not yet been established.
The details of the plan for distributing revenues from the sale of new  interagency passes sold centrally, such as through the Internet or outside  vendors, beyond the first 3 to 5 years of the pass program is still uncertain.  All pass revenue from passes sold at units will remain within the agency  where the pass was sold, and it will be up to each agency to determine how  to redistribute pass revenues within the agency. For the first 3 to 5 years of  the pass program, revenues from passes sold centrally will initially be used  to cover administrative costs of the new pass and to reimburse NPS for the  almost $2.4 million it loaned to fund development of the new pass. After  administrative costs for the new pass are covered and NPS is reimbursed,  any remaining central pass revenues will be distributed equally among all  participating agencies for at least the first 3 to 5 years of the program, with  the goal of assisting all agencies in establishing a pass program. However,  this plan may be revisited if central pass sales significantly increase or  decrease or if central pass revenue after 3 years is not adequate to cover  administrative costs of the program or to reimburse NPS for its loan. The  long-term plan for revenue distribution beyond the initial 3 to 5 years is  more uncertain because these plan details have not been agreed upon.  According to an official from the working group, the current long-term plan  is to distribute central pass revenues to the agencies based on a formula  that takes into account pass use, where passes were purchased, and  possible additional factors. However, the details of the formula have not  been determined, and there are some potential problems with the  collection of pass-use data to be used in the formula.
While units are generally able to track the number of passes sold, it would  be difficult for many units to collect accurate data about use of the pass. At  most NPS and FWS sites, fees covered by the new interagency pass will  generally be collected at staffed entry points, whereas at BLM and FS sites,  fees covered by these new passes will generally be collected at unstaffed  and often remote locations where fee compliance and enforcement will be  irregular and infrequent. One way to track pass usage would be to swipe a  magnetic strip on the passes at recreation site entry gates. However, even  within NPS, whose sites frequently have staffed entry points, only one-third  of the sites with entrance fees are currently capable of reading magnetic  strips at their entry gates. It would likely be difficult and expensive to  install technology to read magnetic strips at many remote and unstaffed  units, and compliance with such systems would be difficult to enforce at  sites without staffed entry booths by January 2007. According to a member  of the working group, the working group is aware of these issues and, while  it has not yet addressed them, the group plans to develop a consistent data  collection strategy that the agencies can use at unstaffed locations to  determine pass usage. Agencies will be responsible for implementing the  strategy and units will be expected to collect data on the use of the pass  after the new interagency pass is released.
As of August 2006, the agencies are engaged in a contracting process to  acquire the goods and services necessary to implement the new  interagency pass and are planning to issue the pass by the January 2007  target date. A Request for Proposal (RFP) for the contract was published  on June 5, 2006, and, according to agency officials, it is unknown when the  contract will be awarded. The U.S. Government Printing Office (GPO) will  print the new pass and any accompanying products. Agency officials from  the Interagency Pass working group have acknowledged that they are  working within a very tight time line, but have said that they are committed  to issuing the new pass by January 2007. However, certain critical aspects  in the pass development time line have taken much longer than originally  anticipated. For example, an earlier estimated date for issuing the RFP for  contracting services was fall 2005 before it was pushed back several times  and finally published in June 2006. In addition, interagency guidelines for  the new pass that were estimated in June 2005 to be completed in fall 2005  had not been completed as of August 2006. However, the working group  still has several months to meet their target pass implementation date of  January 2007.
One goal of the new single interagency pass is to reduce visitor confusion  over which passes can be accepted where, since the various passes  currently offered by the agencies create considerable confusion among the  visiting public. The majority of units responding to our survey, almost 63  percent, were aware that the visiting public was confused about the use of  current national passes, regional passes, or annual passes. The factor most  frequently cited for causing visitor confusion was where the different types  of passes are accepted, with 82 percent of units responding that this factor  causes confusion to a moderate, great, or very great extent. Other factors  cited by more than two-thirds of survey respondents as causing confusion  were the differences in the benefits between passes, the recreation uses  covered by each pass, the differences in the Golden Eagle Passport versus  the National Parks Pass, the difference between federal and nonfederal  units, and understanding the differences between various passes (e.g.,  eligibility, cost, benefits, etc.). Given that there will be overlap between the  current National Parks Pass, the Golden Eagle, Age, and Access Passports,  and the new interagency pass, it will be important for the new pass  guidelines and agency-specific guidance and training on it to address these  issues and provide unit staff with materials and information to better  educate the public.
section_title: Fee Collection/Expenditure Working Group Has Issued Final Interagency Guidance in an Attempt to More Clearly Define REA Terminology
paragraphs: The Fee Collection/Expenditure working group was established to address  organizational concerns, implementation issues, and coordination among  the agencies as they relate to fee collections and expenditures. While the  agencies individually took steps after the enactment of REA to assess their  recreation fee programs and begin implementing the new act, the working  group’s main task was to develop common definitions and policy guidance  to establish a basis for consistent implementation of REA and common  reporting by each of the agencies. This working group finalized an  interagency handbook with common definitions and guidance—the  Interagency Implementation Handbook for Federal Lands Recreation  Enhancement Act—in March 2006.
The interagency handbook provided definitions for some of the terms used  in the law, such as “designated developed parking,” “permanent trash  receptacle,” “reasonable visitor protection,” and “special recreation permit  fees” in order to clarify terms that may be interpreted differently by the  various agencies. In addition to the definitions, the handbook provided  general policy guidance regarding certain aspects of the law—such as  overall guidance on some aspects of the new interagency pass and annual  reporting of budgetary information—while delegating the authority to  develop and implement policies on other issues to the individual agencies.  For example, the handbook directed the agencies to develop and  implement a policy for revenue distribution decisions, including retention  of recreation fee revenues and agencywide distribution of funds. For the  sections of REA that were delegated to the individual agencies, the  handbook directed the agencies to develop written policy guidance that  incorporates the standard definitions and policy guidelines. According to a  working group official, the Fee Collection/Expenditure working group is no  longer formally meeting since developing the interagency handbook was  the group’s main task, and the handbook has now been finalized.
section_title: Communications Working Group Has Been Used to Facilitate Interagency Communication with Congress and the Public
paragraphs: The Communications working group was formed to facilitate interagency  communications about REA implementation issues with Congress, the  public, and other interested third parties, such as states and localities. The  working group organized listening sessions to gain public input on the  RRACs and the new interagency pass. The agencies have periodically  briefed congressional staffers on a variety of issues, including the Federal  Lands Recreation Enhancement Act First Triennial Report to Congress;  Fiscal Year 2006, which was released in May 2006.  According to agency  officials, the working group now meets infrequently and has not issued any  joint press releases to the public since all press releases regarding REA  have thus far been issued by individual agencies.
section_title: Most Agencies Have Reviewed and Begun to Modify Recreation Fee Programs to Implement REA, but Some Units are Still Transitioning, Reclamation Is Not Yet Participating, and Agencies Have Been Slow to Issue Final Guidance
paragraphs: After the passage of REA, agencies directed their units to assess and  modify their fee programs to comply with REA criteria. Although most  units have made some modifications to their programs, such as converting  fees, eliminating sites and fees, or adding amenities, some units are still in  transition and may still need to add required amenities. Some responding  units, however, reported collecting standard amenity fees, without having  all six amenities required under REA. In commenting on a draft of this  report, agency officials said many of these survey responses were in error.  Although Reclamation was included as a participating agency under REA, it  has yet to make a final decision about whether to implement REA. Also,  most BLM, FWS, NPS, and FS units reported that some kind of guidance is  available; however, the agencies have not yet issued final guidance, and  many unit officials indicated that some aspects of the law are unclear and  that they need more specific guidance on how to add new fee sites or  modify existing fees to fully implement the law.
subsections: section_title: Agencies Assessed Existing Fee Programs and Made Changes to Comply with REA, but Some Units Are Still in Transition, and Reclamation Is Deciding Whether to Implement REA
paragraphs: To implement REA, participating agencies reviewed their recreation fees  under the former Fee Demo program and other legal authorities and  instructed units to make necessary modifications to ensure compliance  with key REA provisions. While most units converted fees, eliminated fees,  or added amenities to comply with REA, some are still transitioning toward  taking such actions and, in some cases, are charging fees without having all  of their required amenities. One agency, Reclamation, has assessed its  recreation fees but has not decided whether it will implement REA.
subsections: section_title: Agencies Assessed Recreation Fee Programs and Made Changes
paragraphs: In 2005, all agencies assessed existing fee programs to determine whether  existing fee collecting sites met REA requirements, and some units made  modifications to comply with REA. Overall, the transition from Fee Demo  to REA was easiest for NPS and FWS, both of which charged entrance fees  under Fee Demo, were authorized to charge such fees under REA, and  continued to charge entrance fees. Therefore, the transition for these  agencies to REA did not have much impact. NPS eliminated a day-use fee at  the Exit Glacier site in Kenai Fjords National Park in Alaska because of  concerns that it would be perceived as an entrance fee, which is prohibited  under both the Alaska National Interest Lands Conservation Act and REA.  FWS eliminated an entrance fee at Gavin’s Point National Fish Hatchery in  South Dakota because fish hatcheries are not allowed to charge entrance  fees under REA.
The transition from Fee Demo to REA had more of an impact on FS and  BLM since REA provided additional criteria for fee sites and prohibitions  on certain fees at these agencies. Unlike Fee Demo, REA limits the  authority of BLM and FS, authorizing these agencies to collect fees only at  locations with a certain level of infrastructure and/or services and prohibits  charging fees for parking, general access to dispersed areas with little or no  investment, and scenic overlooks, among others. BLM and FS assessed  existing fee programs and either eliminated fees, converted fees, or added  amenities in order to convert entrance or day-use fees to standard amenity  fees. BLM and FS also assessed existing campgrounds and other developed  facilities to ensure that they had at least the minimum number of required  amenities to charge an expanded amenity fee.
BLM eliminated several fees after passage of REA, including fees for  overlooks at Imperial Sand Dunes in California, fees at undeveloped sites at  Orilla Verde Recreation Area in New Mexico, and youth fees at several  sites, including Cape Blanco Lighthouse in Oregon. For BLM, a key change  was converting existing entrance fees to standard amenity fees where sites  met the new criteria. According to a BLM headquarters official, BLM  converted entrance fees at 10 sites to standard amenity fees. According to  state coordinators, only one of these sites, located in Arizona, did not meet  standard amenity criteria and had to add an informational kiosk. Other  BLM sites converted various fees charged for activities such as camping to  expanded amenity fees. For example, campgrounds at Fisherman’s Bend  Recreation Area in western Oregon had at least the minimum amenities  required by REA to convert a camping fee to an expanded amenity fee.
FS reviewed its existing recreation fees and stated that it dropped 437 sites,  such as trailheads and picnic areas, from its fee program because they did  not meet the new criteria described under REA. Under Fee Demo, FS  charged fees for entrance into large areas, sometimes entire forests.  However, REA prohibited FS from charging entrance fees and only allowed  FS to charge standard amenity fees if the sites provide the required level of  amenities. In addition to dropping fee sites, numerous FS units added  amenities to bring sites into compliance with REA. According to one FS  regional coordinator, if a developed site was missing one or two amenities,  then the unit added those amenities, otherwise, the site was dropped from  the fee program.
Concerns about FS compliance with REA criteria have been raised by users  who are critical of the use of High Impact Recreational Area (HIRA)  designations and standard amenity fee areas. While HIRAs are not  specifically mentioned in REA, FS relies on a section of REA that  authorizes standard amenity charges for the use of “an area” as authority to  designate HIRAs. The Interagency Implementation Handbook for Federal  Lands Recreation Enhancement Act defines a HIRA as an area of  concentrated recreation use that includes a variety of developed sites  providing a similar recreation opportunity that incur significant  expenditures for restoration, public safety, sanitation facilities, education,  maintenance, and other activities necessary to protect the health and safety  of visitors, cultural resources, and the natural environment. The handbook  also defines limitations on which areas can be designated as a HIRA. For  example, whole administrative units, such as a national forest or a  Reclamation project, cannot be declared a HIRA. During the past few years,  FS identified HIRA sites and has proceeded to charge standard amenity  fees for the use of these areas under REA. According to the agency’s  officials, the HIRA designation is a logical way of categorizing amenities  supporting high levels of recreation use, and collected fees go to maintain  and clean these provided amenities, such as restroom facilities.
Another concern about the HIRAs is that some access points into parts of  wilderness areas that are not considered part of a HIRA are only accessible  via the HIRA, so visitors must still pay the standard amenity fee to access  these parts of the national forests. In addition, some assert that because  REA prohibits charging a fee “solely for parking” or “driving through,  walking through, boating through, horseback riding through, or hiking  through…without using the facilities and services,” the standard amenity  fees for HIRAs are prohibited in some cases. For example, a visitor to an  Arizona national forest challenged FS citations issued to her for failing to  display the required day pass permit to travel into a HIRA. The visitor was  cited on two occasions because she parked within a HIRA to hike the area  without having paid for the day pass permit. On September 5, 2006, a  district court held that the REA bars the FS from collecting fees for parking  along roads or trailsides and that the FS acted “far beyond its legislative  authority” in its attempt to collect the fee. Accordingly, the court dismissed  the citations against the visitor.
According to FS officials, the agency significantly decreased the size of  many of its HIRAs to only cover areas where required standard amenities  are within reasonable access. For example, the entire Flaming Gorge  National Recreation Area in Utah and Wyoming had an entrance fee under  Fee Demo; now only 4 percent of the recreation area is subject to fees.  Another example is the Los Padres National Forest in southern California,  which reportedly decreased the size of its HIRA from almost 1.5 million  acres to 71,000 acres while also removing 37 fee sites. However, in  testimony before the Senate Committee on Energy and Natural Resources,  Subcommittee on Public Lands and Forests, on October 26, 2005,  representatives from the Arizona and Western Slope No-Fee Coalitions  charged that the BLM and FS are using the HIRA and standard amenity  concepts to circumvent the intent of Congress and charge fees for areas  that do not have the amenities required by REA. However, REA does not  provide a definition for “area” and thus the criteria used to define an “area”  are open to the agencies’ discretion. For example, the Arapaho National  Recreation Area in Colorado charges a standard amenity fee for an area it  defines as an HIRA that contains 25 developed sites including picnic areas,  boat launches, campgrounds, and trailheads. Not all six of the amenities  that are required under REA are collocated at each of the developed sites.  However, since all six of the required amenities are somewhere within the  hundreds of acres of their designated HIRA, the FS is charging a standard  amenity fee for the entire area under REA. In the October 26, 2005, Senate  subcommittee hearing, a USDA official acknowledged that FS  implementation of REA is a “work in progress” and that different local  conditions and characteristics make it difficult to develop HIRA criteria  that fit all circumstances. According to this official, FS has continued to  work on providing consistent signage and to identify areas that may not  meet the criteria for charging fees and plans to have the RRACs comment  on how the agency is applying HIRA criteria.
section_title: Some BLM and FS Units Do Not Have All Required Amenities to Charge Standard Amenity Fees
paragraphs: We also found that some BLM and FS units still do not meet REA  requirements for charging standard amenity fees. Based on the results of  our survey, of the 195 BLM and FS units that reported that they charge a  standard amenity fee, 38 reported they did not provide all six amenities that  are required for them to charge the fee. Two BLM units and 36 FS units  reported that they did not provide all six required amenities. The amenities  that the units were most frequently lacking were a permanent trash  receptacle and interpretive signs, exhibits, or kiosks. Although these units  reported in survey responses that their unit did not have all six required  amenities, BLM state-level officials and FS headquarters officials stated  they believed all of their fee-collecting units were in compliance with REA  criteria. In commenting on a draft of this report, both BLM and FS indicated  their unit officials had likely been confused by the fee terminology in the  survey question and/or may have misunderstood the definitions of the  required amenities, rather than because these units lack amenities such as  picnic tables.
However, during interviews with agency officials, we learned that some  units charging a standard amenity fee did not have all six required  amenities, but had plans to add these amenities. For example, the Meadow  Creek site at the Arapaho-Roosevelt National Forest in Colorado lacked  two of the six amenities—picnic tables and interpretative signage— required under REA when we visited it in December 2005. The unit has  continued to charge a standard amenity fee since REA passed because unit  officials thought it would be confusing to visitors to temporarily  discontinue the fee while they worked on upgrading the area to meet REA  criteria. The unit received a $20,000 grant in 2005 from the central fee  revenue fund to add picnic tables and signage, as well as fire rings to the  area. According to a unit official, the required amenities were added during  the summer of 2006, and the Meadow Creek site now has all of the required  amenities in place.
Some FS unit staff also found the standard amenity criteria at odds with  wildlife management practices. For example, several national forests near  the Canadian border are in grizzly bear areas, so FS has instructed the  public to “pack out,” or dispose of their trash outside of camping and day- use areas, rather than install costly bear-proof garbage cans. Now, if these  forests are going to continue charging recreation fees at these sites, REA  requires FS to put trash receptacles in the areas. In another example, picnic  tables were previously removed from Mt. Evans, in the Arapaho-Roosevelt  National Forest, because of wildlife interaction issues. However, in order to  comply with REA, FS must provide all six required amenities, including  picnic tables.
In commenting on a draft of this report, BLM headquarters officials stated  that they checked with the two units that reported having less than six  required amenities in their response to our survey. The officials determined  that the two units’ reports were in error and that the units did offer all six  amenities. Similarly, the FS headquarters staff made further inquiries of the  36 units that reported less than the six required amenities and determined  that some of the information that the units reported on their survey  response was in error. Based on information from FS officials and our  analysis, the status of those units is as follows:  12 units did not have a standard amenity fee but instead had an  expanded amenity fee, which does not have the same amenity  requirements under REA.  11 units did have the required six amenities and did not accurately  report this in their survey response to us.  4 units had a standard amenity fee for a visitor or interpretive center,  which under REA may be charged without having the six required  amenities.  2 units had no standard amenity fee and should have reported this in  their survey response to us.  7 units have not yet responded to the follow up inquiries.
It should be noted, however, that the results of BLM and FS headquarters  officials’ inquiries have not been verified.
section_title: Reclamation Undecided on Implementing REA
paragraphs: Reclamation has not made a decision to move forward with REA  implementation. The agency officials are assessing Office of the Solicitor  advice concerning how the act applies to their operational situation and to  the alternate authority for Reclamation to charge fees under the Federal  Water Project Recreation Act (FWPRA). Reclamation had requested advice  from the solicitor’s office because of their unusual operational situation  that includes the management of about 250 of Reclamation’s approximately  300 sites by partner organizations, such as other government entities. In  2005, Reclamation conducted an assessment to determine which of its  recreation sites met REA requirements. Reclamation identified 7 of the 50  sites it directly manages that would qualify to charge standard amenity fees  under REA, one of which was New Melones Reservoir in California. New  Melones collected about $170,000 in 2004 under LWCFA, which was  repealed by REA. Reclamation is now using FWPRA as its authority to  collect recreation fees at New Melones. Any fees collected under FWPRA  are to be deposited into a Department of the Treasury (Treasury) account,  unless project specific legislation provides otherwise. Reclamation has not  indicated how many of the 50 sites they directly manage meet REA criteria  for charging an expanded amenity fee.
section_title: Although Most Units Have Received Some Guidance, Final Policy Guidance on REA Is Still Pending for all Agencies, and Many Unit Officials Said Some Aspects of the Law Are Unclear and More Specific Guidance Is Needed
paragraphs: After REA passed, the Interagency Implementation Handbook directed  agencies to develop written policy guidance that incorporates the standard  definitions and overarching policy guidelines established in the handbook.  Although agencies reported that they made the transition from Fee Demo  to REA without major problems, many units said that some aspects of REA  are unclear, and more specific guidance is needed. For example, some unit  officials expressed confusion about how to add new fees or modify existing  fees, while others expressed confusion about amenity criteria.
BLM and FS issued interim guidance documents, and the NPS has issued  memos and provided training on REA implementation, while FWS has  issued no formal guidance to the field. BLM and FS issued interim  recreation fee guidelines within months after the passage of REA, and both  have since issued additional guidance on different aspects of the law. NPS  issued transitional guidelines and memos on various aspects of REA and  has provided training on REA implementation. FWS formed a working  group with representatives from headquarters and the field to work on  various implementation tasks, including drafting guidance and policy on  REA. According to an FWS official, interim guidance will be out by the end  of fiscal year 2006. Since Reclamation has not yet determined whether the  agency will implement REA, the agency has not issued any guidance on the  new law.
While most respondents to our survey indicated that some type of guidance  on the fee program is available, many unit and regional officials indicated  during interviews that additional guidance is needed. Based on the results  of our survey, most units responding indicated that some kind of guidance  is available from national headquarters and a regional or state office, with  the majority of units indicating that the existing guidance is at least  moderately useful on authorized types of fees and passes. For example, 85  percent of BLM, FS, FWS and NPS units reported that written guidance is  available from national headquarters. Most units also indicated that  unwritten, unit-specific guidance, staff knowledge, and experience are  additional sources of guidance that are generally available to them.  However, although the vast majority of survey respondents reported that  some kind of written guidance was available, unit officials at the state and  regional level, as well as at some of the sites we visited, emphasized that  more specific guidance is needed, including detailed policy and procedures  for implementing and managing fee programs. For example, as BLM and FS  unit staffs have implemented REA, some unit agency officials have found  REA amenity criteria and terminology ambiguous, and some units  expressed confusion about how to interpret and apply such criteria as  “reasonable security” and “permanent trash receptacle.” Other unit officials  at the various agencies said they needed more guidance on how to add new  fee sites or modify existing fees. For example, according to an FWS official,  the main obstacle to implementing fees at a refuge complex in Nevada has  been a lack of policies and procedures, as well as basic guidance, on how  to implement a fee program. According to FWS officials, such guidance  should include examples of implementation plans, information on how to  set up accounts, effective ways to share lessons learned among the seven  FWS regions, and contact information for other agency officials with fee  program experience.
section_title: Some Agencies Do Not Have Adequate Controls and Accounting Procedures for Collected Fees and Lack Effective Guidance for Establishing a System of Internal Controls, Including Routine Audits
paragraphs: We found that some agencies’ units did not have adequate controls for  safeguarding and accounting for collected fee revenues. While current  federal guidance requires managers to establish and maintain accounting  systems that incorporate effective internal controls, we determined that  some BLM, FWS, and FS units did not have sufficient guidance—including  examples of best practices—to follow for implementing internal controls  over collected fee revenues. NPS has also been slow to issue updated  guidance on accounting for and controlling collected fee revenues.  However, despite this lack of guidance, NPS units we visited appear to have  generally implemented effective internal controls. Furthermore, routine  audits are an integral part of any system of effective internal controls over  agencies’ financial assets. However, less than 37 percent of respondents to  our survey indicated their units have been examined by auditors since  October 2000. Without effective internal controls, the units cannot provide  reasonable assurance that the fee revenues collected are properly  controlled and accounted for.
subsections: section_title: Some Agencies Lack Adequate Controls on Collected Fees
paragraphs: Federal internal control standards require management to identify risks  that could impair the safeguarding of agency resources, such as fee  revenues at the unit level, and suggest that management should formulate  an approach for risk management that identifies the internal controls  necessary to mitigate those risks. A good set of internal controls should  incorporate physical control over vulnerable assets—such as cash—with  other controls such as segregation of duties, controls over information  processing, accurate and timely recording of transactions and events, and  access restrictions to and accountability for resources and records.  However, cash collection is an area where agencies are particularly  vulnerable to the risk of theft. Some locations, such as BLM’s Gunnison  Field Office, have such limited staff running their recreation fee program  that their program coordinator indicated the appropriate separation of  duties, not to mention using procedures such as two staff jointly counting  fee receipts, is simply not possible. Unfortunately, this circumstance may  not be unusual, especially at smaller units where resource management  staffs—generally with little or no accounting or business operations  experience—are tasked with implementing the fee program, including cash  handling procedures. The staffs at these units face many challenges ranging  from the development of safe and secure procedures for gathering and  transporting fee envelopes from remote campground sites to assuring that  staff with appropriate knowledge and skills are assigned to process and  account for collected fees. In addition, survey respondents indicated a  myriad of other problems such as  security concerns over the delivery of collected cash fees from their unit   local banks not accepting agency procedures for depositing funds to a   local banks and/or post offices charging fees for issuing the money  order or cashier’s check necessary to make deposits in Treasury  accounts,   employees having to pay bank fees for money orders or cashiers checks  with their own funds and then seek reimbursement from the agency, and  the closest local bank sometimes being an inconvenient 30 to 60 miles  away from fee collecting locations.
According to federal internal control standards, management should strive  to remove the temptation for unethical behavior by avoiding the receiving  and handling of cash by individual staff without a reasonable means of  determining the amount of revenues the employee has received. For  example, at the Tonto National Forest Mesa Ranger District, near Phoenix,  staff members sometimes collect cash fees directly from visitors when the  automated fee machines are broken. Most of the district’s fees are collected  by automated machines that are owned and serviced by a contractor.  However, one or more of the unit’s automated fee machines are often  broken. To avoid a loss of revenues when the machines are not working,  the managers designate staff members as collection officers to work at  busy entry points to collect fees and direct traffic flow. According to  district management, the staff later feed the collected fees into a working  automated machine someplace else in the district. However, the managers  have not developed physical or other compensating controls over these  cash collections (easily amounting to several hundred dollars on a busy  day) that would enable managers to verify that all of the fees collected by  any given staff member are actually fed into a working machine. In  commenting on a draft of this report, FS headquarters officials indicated  that they believe that automated fee machines should rarely be broken and  they also noted that local officials are responsible for reasonable internal  controls over cash collection.
In addition, the safety of staff involved in collecting the cash could be  jeopardized due to the risk of being targeted for robbery. In another  example, at BLM’s Gunnison Field Office, in western Colorado, one or two  staff members collect the fee envelopes containing campground fees from  a remote self-service fee station and place the envelopes into a bag for  transport back to the office. At the office, the envelopes are placed in a safe  until another employee has an opportunity to open the envelopes, count  the cash, and record the fees collected. However, the manager has not  developed physical controls over the cash collections and accounting to  provide assurance that all of the fee envelopes collected by the first staff  member(s) are turned in at the office or that all of the funds counted by the  second employee are deposited and accurately documented. Consequently,  in both of these examples, the managers were left without reasonable  assurance that the revenue each employee collected was received and  accounted for by the agency.
section_title: Some Agencies’ Units Lack Adequate Guidance to Establish Accounting Procedures and an Effective System of Internal Controls for Collected Fee Revenues
paragraphs: Most available agency guidance provides overall objectives for establishing  and maintaining an effective accounting system. For example, the FS  Manual on Accounting states that one of the overall objectives is to  “establish and maintain an accounting system that provides: A system for  internal control and accountability of funds, property, and other assets  from acquisition to disposition.” However, this guidance does not provide  the detailed, “cook book” type of instructions most unit-level fee program  managers need to successfully implement an effective system of internal  controls. In contrast, Yosemite National Park’s written opening procedures  provide detailed step by step instructions as follows:   Check the accountable stock ; verify that the numbers are in  sequence.
Make note of any missing passes.
Enter the first and last number of each type of pass on the shift report.
Date and initial the shift report.
According to several unit-level officials we interviewed, agency-level  support and training on accounting and control issues is needed to help  units develop this type of detailed procedures for their fee programs. Some  field staffs have also requested training opportunities to help them learn  how they should manage their fee programs. The lack of both written  procedures that are current and comprehensive and fee program training  are obstacles to developing successful internal controls.
Due to the numerous comments shared by agency staff about the need for  updated guidance, we included questions about this issue in our  nationwide survey of BLM, FWS, NPS, and FS units. Of those units that  reported receiving some sort of guidance related to controlling and  accounting for collected fees, over one-third (277/752) indicated the  guidance they received was less than moderately useful. When asked about  whether staff had been provided training on controlling and accounting for  collected funds, over 40 percent indicated they had not received training on  this issue. Of the survey respondents who did receive training, over 60  percent indicated the training was less than moderately useful. In  commenting on a draft of this report, FS acknowledged the need for  revising the Forest Service Manual and indicated it will expedite  publication of the handbook and updated procedures as soon as  practicable.
Although NPS units we visited appear to have implemented reasonable  accounting procedures and effective internal controls, the agency has been  slow to issue updated guidance on accounting and controlling collected fee  revenues. NPS parks are still following NPS-22, the 1989 NPS policy for fee  collection. However, technologies have changed so much since 1989 that  the old policy does not even address issues such as electronic processing of  credit card payments. The parks have been waiting for years for a new fee  collection policy to be issued, and several unit and regional officials stated  that the revised policy guidance is needed immediately. NPS management  indicated they had developed a draft of the new policy when REA passed in  late 2004, making portions of the previous draft obsolete. NPS fee program  coordinators in the headquarters office said they recognize that units need  and want updated guidance and, although they are trying hard to get the  guidance on recreation fees out as soon as possible, could not provide an  estimated time frame for issuance.
Some units’ fee coordinators, such as the coordinators at Rocky Mountain  National Park in Colorado and the Shasta Trinity National Forest Shasta  Lake Ranger District in California appear to have a good handle on how to  develop and implement sound financial and accounting internal controls.  However, many other units lacked both the technical and professional  expertise to develop sound procedures without detailed guidance. Since  many unit-level staffs have not received detailed agency guidance that  would be useful in establishing such procedures on their own, they  continue to struggle with these issues and the risks associated with poor  internal controls.
section_title: Some Agencies Do Not Have a System of Routine Audits to Account for Collected Fee Revenues
paragraphs: Many units have not implemented a system of routine audits to help ensure  that fees are collected and used as authorized and that collected funds are  safeguarded. Only 37 percent of the 752 units responding to this question in  our survey reported having their fee collection program examined by an  auditor since October 2000. The percentage of units having their fee  collection programs examined varies significantly by agency. For example,  NPS reported the highest percentage of audits of unit-level fee programs  with about 63 percent of units (110/175) having their control and  accounting procedures examined since October 2000. According to a NPS  regional fee program coordinator, some NPS regions are aggressive about  audits, such as the Intermountain Region where one staff person is  dedicated to conducting audits. Other regions may not have dedicated  resources to conduct audits. For example, the Northeast Region has only  one fee coordinator available to conduct fee program audits, and she does  not feel she is justified in going to parks unless unit managers ask her to  review how the unit is doing operationally. In the past, the NPS  headquarters fee project coordinator reportedly proposed using a portion  of the centrally held recreation fees to fund a national audit program, but  the proposal was only partially implemented in one region. In commenting  on a draft of this report, NPS stated its intention to reconvene a workgroup  to develop a National Audit Program.
Other agencies reported having many fewer routine audits of their  programs: only 14 percent of FWS units, 27 percent of BLM units, and 33  percent of FS units reported having examinations. According to some unit  officials with whom we spoke, they either did not believe they have access  to internal or external audit resources or they rationalized that they did not  need to implement an audit program since they had trustworthy staff. A  lack of staff resources is also a factor in the limited number of units that  have had their recreation fee programs audited during the past 5 years.
Routine audits are an important internal control that could allow agency  officials to promptly detect unauthorized transactions involving recreation  fee revenues and assess the design, implementation, and effectiveness of  controls over these assets agencywide.
One example that highlights the need for routine audits was at the Tonto  National Forest Mesa Ranger District, where officials acknowledged that  no audit had been conducted on the contractor who maintains the  automated machines and processes the fees collected through the  machines. In fact, the district officials said they had seen no reason to  request that the contractor, who owns and services the automated fee  machines, be audited. The contractor collects the fees (cash and credit  card payments) directly from the machines and then prepares quarterly  reports for the FS unit, stating the amount collected and the amount to be  remitted to FS under the contract. Over the life of the contract, FS staff  members have verified the amount of the contractor’s remittance against  the reported total collected fees to ensure the contractor submitted the  correct percentage of the fees under their contract. Unfortunately, by  simply relying on this approach, FS officials have no way of independently  verifying actual receipts because they have no access to raw data from the  automated machines. FS was simply verifying the contractor’s  mathematical calculation against what the contractor had self-reported as  total fee receipts.
In commenting on a draft of this report, FS officials noted that it is FS  policy to audit collection officers at least annually, but acknowledged they  have not been meeting this goal. In order to begin addressing FS’s  recognized shortfall in meeting their prescribed audit program, they have  assigned a full-time FS Albuquerque Service Center (ASC) resource to  monitor the program, nationwide. Also, according to a FWS headquarters  official, in fiscal year 2004, FWS implemented a procedure to help target  units for visitor service reviews.
section_title: Agencies Have Different Processes for Selecting Projects to Be Funded with Fee Revenues
paragraphs: While REA establishes the basic priority of using recreation fee revenues  for enhancing visitors’ experience, each agency has a different process for  selecting projects to be funded with fee revenues based on the agency’s  needs and revised policies under REA. These different processes affect the  types of projects the agencies fund and their time lines for project  implementation. Agencies fund a wide variety of priority projects with fee  revenues, typically maintenance, operations, and some capital  improvements. Examples of projects and activities funded with fee revenue  include campground renovations within American Fork Canyon at the  Uinta National Forest in Utah, interpretive panels at Colonial National  Historic Park in Virginia as pictured in figure 1, interpretive staff at BLM’s  Red Rock Canyon National Conservation Area in Nevada, and trail work at  FWS’s Rocky Mountain Arsenal National Wildlife Refuge in Colorado as  pictured in figure 2. Some units also use recreation fee revenues to leverage  funds received from other sources, such as grants or donations.
subsections: section_title: Project Prioritization Processes Are Based on REA Criteria and Agency Guidance
paragraphs: REA established limits on the use of recreation fees to focus the  expenditures more directly on benefiting the people who visit the unit at  which they were collected. For example, REA supports the use of  recreation fees to repair, maintain, and enhance facilities related directly to  visitor enjoyment, visitor access, and visitor health and safety but restricts  the use of recreation fees for biological monitoring under the Endangered  Species Act or for employee bonuses. It also limits the use of fee revenues  to not more than an average of 15 percent of total revenues for  administration, overhead, and indirect costs related to the recreation fee  program. Other sanctioned uses of recreation fee revenues include a myriad of things ranging from interpretive signage to law enforcement to  certain limited types of habitat restoration. Specifically, REA mandates that  fee revenues only be used for the following:  repair, maintenance, and facility enhancement related directly to visitor  enjoyment, visitor access, and health and safety;  interpretation, visitor information, visitor service, visitor needs  assessments, and signs;  habitat restoration directly related to wildlife-dependent recreation that  is limited to hunting, fishing, wildlife observation, or photography;  law enforcement related to public use and recreation;  direct operating or capital costs associated with the recreation fee   a fee management agreement or a visitor reservation service.
In addition to REA guidance, BLM, NPS, and FS have all issued at least  interim guidance on expenditure priorities for projects funded with fee  revenues. BLM guidance emphasizes that fee revenues be used to support  projects or activities related to recreation and stipulates a specific  percentage of funding be spent in this area. NPS has established deferred  maintenance projects as its first priority for recreation fee revenues and  stipulates the percentage of funding that should be spent in support of this.  FS guidance essentially repeats the priorities established in REA.  FWS has  not issued any interim guidance on expenditure priorities, but draft  guidance that has not been finalized also repeats the priorities established  in REA, similar to FS guidance. Each of the agencies’ guidance also  stipulates the amount of fee revenues that can be spent for either (1)  administration, overhead, and indirect costs or (2) collections cost. Table 3  shows the guidance developed by the agencies for how recreational fee  revenues should be spent.
section_title: Project Selection Processes Are Guided by Agency Needs and Revised Policies under REA
paragraphs: While REA establishes the basic priority of using recreation fee revenues  for enhancing visitors’ experience, each agency has a different process for  selecting projects to be funded with fee revenues based on the agency’s  needs and policies revised under REA. These different processes can affect  the types of projects agencies fund and their time lines for project  implementation. At BLM, FWS, and FS, most proposed projects are  approved at the local unit level. Unit staff indicated that most projects  funded with fee revenues are usually approved within a couple of days to a  few weeks or, in some cases, implemented immediately without unit  manager approval. At NPS, however, projects must be reviewed and  approved at the unit and regional levels, as well as at the headquarters or  department level before projects are funded. In commenting on a draft of  this report, NPS noted that its project approval process was put in place by  DOI and the Office of Management and Budget and has been articulated in  congressional appropriations report language.
BLM, FWS, and FS project approvals generally occur at the local unit level.  The initial project suggestions are typically generated by local unit staff  members who have identified a need that could be filled with fee revenues.  In BLM and FWS units, it is generally a field office or refuge manager that  approves proposed projects. For example, at BLM’s Upper Colorado River  unit, ideas for fee projects are suggested, discussed, and agreed upon by  unit staff members and the field office Manager has final approval on all  recreation fee projects.  This was also the case at FWS’s Back Bay National  Wildlife Refuge, where unit staff members suggest and jointly prioritize fee  projects, while the refuge Manager has final approval. Similarly, the FS  Manager of a ranger district may decide on projects or, in some cases, the  projects are reviewed at a higher level—by the Forest Supervisor or  regional office. At some FS units, a fee board reviews and approves  proposed projects. For example, at the Shasta-Trinity National Recreation  Area within the Shasta-Trinity National Forest in California, any employee  may propose a fee project, which must be presented to the Recreation  Area’s fee board for approval.
Suggestions for projects within NPS are also typically generated by local  unit staff, except this is only the first of several steps in an often time- consuming NPS project approval process. NPS project requests are entered  into the Project Management Information System (PMIS) by unit staff in  advance of regional and NPS headquarters—the Washington Office  (WASO)—project call due dates for prioritization by the park management  team, with approval at the park level. After the units submit their project  proposals, the regional official(s) review the project proposals/requests  and generally either approve the proposals or mark them for edits.  According to one regional official, a regional reviewer may occasionally  reject a proposal if the project does not comply with established criteria or  if the requesting unit did not meet their deferred maintenance goal;  however, most projects are forwarded to WASO for approval. In  commenting on a draft of this report, NPS headquarters informed us that  on average, a Fee Demo project remains at the region or park level for 3  years as the data and information are edited and updated. Those projects  that do not have accurate and complete data in PMIS are delayed in the  approval process at all levels.
The project approval process at WASO was put in place by DOI and NPS to  improve accountability. This process is managed by the NPS Headquarters  Park Facilities Management Division to provide review for consistency to  established policies. According to a Facility Management Specialist within  this division, project approval depends on the dollar amount of the project  because NPS’ Development Advisory Board, DOI, Congress, and the Office  of Management and Budget (OMB) all approve projects over certain dollar  amounts. For example, the agency’s Development Advisory Board reviews  and approves all projects over $500,000, and Congress approves projects  over $500,000 and all projects over $100,000 if the money comes from the  central fund. Meanwhile, DOI reviews all projects over $100,000, and  regional and national projects are approved at the national level. The  complexity of the approval process has required parks and regions to be  proactive in getting projects into the process early. However, according to  NPS officials, it can sometimes take 1 year or more to obtain approval to  fund a project under this process. Many agency officials at the unit and  regional levels expressed frustration about the length of time it takes to  obtain approval for funding NPS projects, and some noted that the  approval process has delayed project implementation and/or has  contributed to units having unobligated fee revenue balances. For example,  one park unit official noted in the survey that the lengthy approval process  jeopardizes projects, especially partnership projects that may be time  sensitive. However, others noted that the approval process can be  expedited in emergency situations to enable project approval within a  couple of months.
According to some unit officials, part of the reason WASO approvals take  so long is that parks’ priorities for fee revenue projects do not always  match WASO priorities and, as a result, WASO may question a project’s  appropriateness and delay or deny its approval, even if it is consistent with  projects allowed by law or under NPS policy. In addition, while WASO  officials sometimes contact regional officials to question or offer  suggestions on a project that has not yet been approved, WASO will, in  other cases, allow projects to remain in the system indefinitely without  approval or disapproval, according to another agency official. NPS  headquarters officials explained that the lack of accurate and complete  data in PMIS is the primary reason for projects remaining in the system  indefinitely and pointed to mistakes by the units and regions as the cause of  this problem.
According to a Facility Management Specialist, the agency is implementing  a comprehensive plan approach under REA, which should help units and  regions to better manage their projects through an advance 5-year planning  process. According to this official, the Regional Directors can also approve  projects estimated to cost under $500,000, but she still retains the authority  to review these approved projects and related project data to ensure that  projects funded are consistent with REA and to assure accountability. NPS  headquarters officials stated that the 5-year plan of projects, which was  first instituted in fiscal year 2003, requires parks to be strategic and  proactive in submitting projects for approval, and to identify their  sequential needs for compliance, design and planning prior to project  execution.
section_title: Agencies Fund a Variety of Maintenance, Operations, and Capital Improvement Projects with Fee Revenues
paragraphs: Recreational fee revenues are used by the agencies to fund a variety of  maintenance, operations, visitor services, and some capital improvement  projects. The specific types of activities or projects funded with these fees  vary by agency. For example, in fiscal year 2005, NPS spent the majority of  fees they collected under REA on various types of maintenance work,  mostly focusing on deferred maintenance. Meanwhile, FS units spent about  40 percent of the fees collected under REA on maintenance, which  included deferred maintenance, annual maintenance, and capital  improvements. For example, recreation fee revenues at the Sequoia  National Forest in California funded capital improvements including a new  restroom (see fig. 3), paving of a parking lot, and the installation of trash  receptacles, picnic tables, and grills at the Big Meadows Winter Trailhead,  which is heavily used by snowmobile riders and skiers in the winter.  While  BLM and FWS also funded some maintenance work, they spent a large  portion of their revenues on visitor services. BLM spent about 33 percent of  their fee revenues on visitor services, such as increased seasonal staff to  complete trail work and other projects and to help monitor and teach river  safety along the Merced River. FWS also focused a lot of their resources on  providing/enhancing visitor services, almost 44 percent of the total fees  they collected under REA. For example, at Chincoteague National Wildlife  Refuge in Virginia and Maryland, REA fee revenues have funded visitor  services such as the design, development, and installation of interpretive  exhibits along four separate trails.
Some units are quite creative with their use of recreation fee revenues to  fund fee projects. For example, agency officials at the Shasta-Trinity  National Forest in northern California use recreation fee revenues to  purchase materials to make “pack-out bags” that are given to mountain  climbers to facilitate the removal of human waste from Mount Shasta. The  bags help with resource protection since climbers are able to remove their  waste using the bags rather than leaving it on the mountain, as was done  prior to the inception of the program. Also at the Shasta-Trinity National  Forest, recreation fees funded the lake directional signage on Shasta and  Trinity Lakes pictured in figure 4. The lakes are quite large—Shasta Lake  has about 420 miles of shoreline—so the signs improve visitor services by  helping direct boaters to various locations on the lakes. At Rocky Mountain  National Park in Colorado, recreation fee revenues have been used to fund  campsite improvements, including new tent pads, fire rings, and picnic  tables, as can be seen in figure 5. These improvements enhanced visitor  services by improving the level of amenities while also protecting natural  resources by containing visitor impacts.
Recreation fee revenues at NPS’s Whiskeytown National Recreation Area in  northern California were used to construct the universally accessible  fishing piers pictured in figure 6, which have improved visitor services and  are heavily used, according to the park Superintendent. Many units within  various agencies have used recreation fee revenues to purchase and install  improved restroom facilities, such as the one pictured earlier in figure 3 at  Sequoia National Forest. Such restrooms improve visitor services while  also enhancing resource protection, according to Sequoia’s Assistant  Recreation Fee Coordinator.
Many units, especially within BLM and FS, use fee revenue for daily site  maintenance and operations and, while these activities may not be as  visible as capital improvement projects such as new restrooms, officials  noted they still provide valuable services to visitors. For example, at  Desolation Canyon in Utah, which is managed by BLM’s Price Field Office,  the main source of recreation fee revenue is rafting permits. The revenues  are then primarily used to fund ranger staff who fulfill multiple roles  including inspecting rafters’ equipment and permits, patrolling the waters,  providing interpretive information to rafters, and maintaining the launch  and take-out sites along the Green River. Another example of a unit that  funds operations and maintenance activities with fee revenues is  Blackwater National Wildlife Refuge in Virginia, where recreation fees fund  restroom maintenance, including toilet pumping and supplies. At most  units, a portion of fee revenues are also used to cover other operations,  such as the cost of collecting fees.
Finally, some units use recreation fee revenues to leverage funds received  from other sources, such as grants or donations. For example, the Klamath  Falls National Wildlife Refuge Complex on the California-Oregon border  worked with a birding group to construct the universally accessible photo  blind pictured in figure 7. The birding group provided funds to construct  the handicapped accessible pathway leading to the blind, while FWS  leveled the ground for the pathway and purchased materials to construct  the photo blind with fee revenues. Another example is NPS’s Antietam  National Battlefield, where recreation fee revenues were leveraged with  other funds to restore a 106-year old monument located at the unit, see  figure 8. The total cost of the project was $300,000—the unit’s largest fee  project to date—with $255,000 of the project cost funded by recreation fee  revenues and the remaining $45,000 leveraged from other sources,  including a $31,000 donation from the state of Maryland, funds from the  “Adopt-a-Monument Program,” and donations from a local newspaper.  Recreation fees have been used to leverage grant funding at BLM’s  Gunnison Field Office in Colorado, which received about $100,000 in grants  in 2006. The interpretive panels pictured in figure 9 at American Basin,  managed by the Gunnison Field Office, were partially funded with  recreation fees.
section_title: The Collection and Distribution of Central and/or Regional Funds Varies by Agency and by Region
paragraphs: The collection and distribution of central and/or regional funds varies by  agency and sometimes by region. Three of the participating agencies— NPS, FWS, and FS—have central or regional funds where a portion of fee  revenues are deposited, as shown in table 4. The projects and activities  funded with central or regional funds vary by agency and, in some cases, by  region, but generally the central and regional funds are distributed among  the units based on project proposals or are used to cover the administrative  costs of the recreation fee program. For example, FWS Region 2, which has  a 20 percent regional fund, uses a portion of its regional funds to cover  administrative charges and distributes the remaining funds to refuges  within the region based on submitted project proposals. Similarly, FS  Region 5 uses a large portion of its 5 percent regional fund to cover fee  program management costs, and special project expenditures, such as the  RRAC start-up costs, and distributes a portion of the regional funds back to  the units in the form of resource and internship grants. Within FWS and FS,  the distribution of regional funds is generally determined at the regional  level. At NPS, project proposals must be reviewed and approved at both the  regional and WASO levels before central funds are distributed to the units.
section_title: Agencies Have Millions of Dollars in Unobligated Recreation Fee Balances to Fund Future Projects; Some Projects Funded May Be Similar to Those Formerly Funded with Other Appropriations
paragraphs: The four agencies collecting recreation fees under REA have accumulated  unobligated balances of nearly $300 million dollars at the end of fiscal year  2005. These balances have accrued for several reasons that included their  units’ plans to undertake large projects requiring them to have all required  funds available before initiating the project, the need to carry over funds  for the next season’s operations, and the lack of adequate staffing to  administer and implement projects in a more timely fashion. Many agency  sources believe that the recreation fees are to supplement and not replace  funds from other appropriations, such as construction and operations.  Despite this, the majority of officials at the units we surveyed indicated  they believed to a moderate, great, or very great extent that recreation fee  revenues are being used to fund projects formerly funded with other  appropriations at their unit. In addition, the majority of agency officials told  us they believe that they may need to replace appropriations with  recreation fee revenues in the future. However, in commenting on a draft of  this report, FS and DOI noted that historically, fee revenues have not  replaced appropriations and there is no reason to expect this change in the  future.
subsections: section_title: Overall, Agencies Report Unobligated Balances Consisting of Millions of Dollars at the End of Fiscal Year 2005
paragraphs: According to the agencies’ recent report to Congress, BLM, FWS, FS, and  NPS reported a total unobligated balance of $295.8 million at the end of  fiscal year 2005, or 61 percent of the $483.8 million available for obligation  (total fee revenues collected plus unobligated balance and recoveries). In  response to our survey, 75 percent of fee-collecting units in NPS, BLM, and  FWS reported unobligated balances at the end of fiscal year 2005.  Furthermore, 93 percent or 107 of 115 of the FS’s national forests reported  unobligated balances. FS headquarters reported unobligated balances at  the forest level, and the balances were not available for individual units  (ranger districts) because of changes in their accounting system. The fiscal  year 2005 revenue, unobligated balance and recoveries, funds obligated,  and unobligated balances reported by the four agencies are provided in  table 5 below. A 5-year history of the agencies’ recent revenue and  obligations are provided in appendix IV.
Typically, units collecting recreation fees had an unobligated balance of  these funds in their accounts at the end of fiscal year 2005 because not all  funds collected during a fiscal year are spent during that fiscal year.  According to the NPS Facilities Management Specialist, the majority of  revenues, especially at large western park units, are typically collected  during the last 3 months of the fiscal year and, therefore, are unlikely to be  obligated that same year.
We also found that at the end of fiscal year 2005, unobligated balances for  many of the units or forests exceeded the revenues collected that year. For  example, on the basis of our survey responses, 114, or 42 percent of 270  BLM, NPS, and FWS units and 63 of 107 FS forests with unobligated  balances had balances that were greater than 100 percent of the total fee  revenue they reported for fiscal year 2005. Table 6 shows for each of the  four agencies the number of units/forests with unobligated balances and  those with unobligated balances that exceeded the annual revenues  collected by 100 percent or more.
Also, on the basis of information provided by units responding to our  survey and information provided on national forests, the top 10 units with  the largest unobligated balances at the end of fiscal year 2005 were all in  NPS. Table 7 lists the 10 units with the highest unobligated balances  compared with their fiscal year 2005 fee revenues. Appendix V provides a  listing of the top 10 units with the largest unobligated balances in all four of  the agencies.
REA provides a mechanism for units to reduce their unobligated balances.  As part of the new REA authority for the recreation fee program, Congress  included a provision that allows the Secretary of the Interior or the  Secretary of Agriculture to reduce the percentage allocation of the  recreation fees and site-specific pass revenues to a unit from 80 percent to  60 percent for a fiscal year. This authority can be exercised if the Secretary  determines that the revenues collected at the unit or area exceed the  reasonable needs that may be addressed during a fiscal year. As part of the  interagency guidance developed for the implementation of REA, the  Secretaries have agreed to delegate to the individual agencies the authority  to develop and implement policy for this provision, including identifying  the metrics and benchmarks required to determine when a unit’s revenue  retention may be reduced and devising a method for distributing the  remaining funds. To date, none of the agencies have completed the process  of establishing final criteria for implementing this provision, although it is  reportedly under discussion in NPS.
section_title: Fee-Collecting Units Cite Several Reasons for Unobligated Balances
paragraphs: Those recreation fee collecting units reporting an unobligated balance  cited a variety of reasons for why all available funds were not obligated. To  a moderate, great, or very great extent, units cited the following as the most  common reasons for their unobligated balances: (1) saving funds to ensure  they had sufficient funds to pay for large projects, (2) saving funds needed  for the following season’s operations, (3) lack of personnel to administer  and implement projects on a more timely basis, and (4) completing  environmental compliance or analysis. Table 8 provides a complete list of  reasons cited for the unobligated balances overall, and by each agency, and  the percentage of the units citing the reason to moderate, great, or very  great extent.
The following examples highlight some of the reasons for unobligated  balances at specific units.
Officials at Yosemite National Park, the unit with the highest  unobligated balance of about $36.7 million or 245 percent of its annual  revenue, cited the following as the primary reasons for its unobligated  balance: legal actions need to be resolved that have delayed spending on  certain projects and the lack of personnel to manage, oversee, and  implement the projects planned for these funds. Park officials said that  unobligated funds accumulated in the early years of the Fee Demo  program when obligations were lower relative to collections.  Obligations have now increased as major projects have passed the  planning and design phase. Another factor in the amount of obligations  for projects funded with recreation fees was that the same Yosemite  staff concurrently managed the 1997 flood recovery work funded by an  appropriation. The flood recovery work occupied the same Project  Managers that manage recreation fee funded projects thereby reducing  the amount of work and obligations under that program. A major part of  the fee revenues are planned for utility projects that are under way,  including replacing sewers and reconstructing other utilities, the staff  said.
Officials at Grand Canyon National Park, with an unobligated balance  also of about $36.7 million, or 184 percent of its annual revenue, stated  that the primary reasons for its unobligated balance that has  accumulated over at least 3 years were the need to save funds for large  projects and the lead time needed to complete design and engineering  work that had delayed the actual expenditure of most funds allocated  for a particular project.  Park staff reported plans to use the unobligated  balance primarily for an alternative transportation system for park  visitors, involving parking area and road construction, and upgrading  the current shuttle bus system. These improvements are expected to  cost approximately $47 million and take 9 years to complete in phases  using unobligated funds already accumulated, as well as a portion from  future fee revenues.
Officials at BLM’s Coos Bay District Office in North Bend, Oregon, cited  saving funds for large projects, needing funds for the next season’s  operations, and using other appropriated dollars before fee revenues as  the primary reasons for its unobligated balance. Coos Bay’s unobligated  balance was about $320,000 at the end of fiscal year 2005 or about 202  percent of the fee revenues.
Officials at Crab Orchard National Wildlife Refuge in Marion, Illinois,  reported an unobligated balance of about $645,000 at the end of fiscal  year 2005, which was 184 percent of its fee revenue. Refuge officials  cited needing to save funds for a large project, completing design and  engineering work, and needing funds for the next season’s operations as  the primary reasons for the unobligated balance.
Shasta-Trinity National Forest in northern California had an unobligated  balance of about $2.8 million in fiscal year 2005, which was 246 percent  of its fee revenue and the largest reported for a national forest. Forest  staff cited the need to save these funds to cover programs and services  during the next year that were previously funded with the fee revenue  from the marina area. Under REA, the unit is no longer authorized to  keep approximately $900,000 in annual marina revenues that the unit   collected under the Fee Demo program from marina operations. Staff  indicated the unobligated balance will be used to continue a number of  marina area programs including a fish rearing program, boat patrols,  floating toilets, illegal dump cleanups, boating safety program, and  interpretive programs that began under Fee Demo.
section_title: Agencies Use Fee Revenues to Fund All or Part of Needs Formerly Funded with General Appropriations and View Fee Revenues as an Important Supplement to General Appropriations
paragraphs: During our site visits and in response to our survey, recreation fee- collecting units also provided many examples in which recreation fee  revenues were used in conjunction with other general appropriated funds,  donations, or other revenues to complete projects within their units.  According to responses from units in the four agencies responding to our  survey, 58 percent of the units indicated that they believed to a moderate,  great, or very great extent that recreation fee revenues are being used to  fund projects formerly funded with other general appropriations at their  unit, such as the construction account. The percentage of units within each  agency that expressed this opinion varied from a high of 65 percent in FS to  a low of 46 percent in FWS. In addition, about 64 percent of the units  believed to a moderate, great, or very great extent that, over the next 5  years, fee revenues will be used to fund projects that would have been  funded with other general appropriated dollars. The portion of respondents  in each agency believing this was 74 percent in BLM, 67 percent in FS, 57  percent in FWS, and 58 percent in NPS. In contrast to the opinions of unit  level officials, FS and DOI comments on a draft of this report noted that fee  revenues have not historically replaced appropriations and denied there is  any reason to expect this to change in the future.
We identified a number of NPS projects similar to those funded by other  general appropriations, such as items typically funded by the construction  appropriations account, which are being or have been funded wholly or in  part by recreation fee revenues. For example, the fiscal year 2006  construction appropriation for NPS includes $11.8 million for a conversion  to narrowband radios to ensure rapid response to emergency and life- threatening situations. NPS stated in its fiscal year 2007 budget justification  that it was proposing to reduce funding for the narrowband radio system  program in order to fulfill higher priority needs in other areas. NPS added  that to minimize the delay in achieving full conversion to narrowband radio  equipment, those systems that are to be converted after fiscal year 2005  will be funded through construction appropriations and augmented, as  necessary, by other NPS fund sources, such as recreation fee revenues.
In response to our survey or during our site visits, many NPS units reported  completed, planned, or ongoing expenditures from recreation fee funds for  the narrowband radio upgrade, including:  Yosemite National Park, $3.4  million; Grand Canyon National Park, $3.0 million; Lake Mead National  Recreation Area, $1.0 million; Gateway National Recreation Area, $1.7  million;  Sequoia-Kings Canyon National Park, $0.9 million; Acadia National  Park, $0.7 million; Olympic National Park, $0.7 million; Channel Islands  National Park, $0.7 million; Great Smokey Mountains National Park, $0.6  million; and Glacier National Park, $0.6 million. NPS officials said the  decision to fund the radio upgrade with fee revenues was made because of  concern that construction appropriations would not be enough to fund the  new system.
Many NPS units listed other projects that have been funded wholly or in  part by recreation fee revenues similar to those previously funded by  general appropriations, such as construction appropriations account. See  table 9 for a list of examples.
In addition, many of the unit staff we visited or who commented on our  survey stated that recreation fee revenues are essential to providing  services at their recreation areas that would not otherwise be funded.  The  following is a sampling of such comments from units in each agency:  “The recreation fee program has been a great asset to the overall  recreation program. Without these dollars coming back into the system  to help augment other appropriation dollars, BLM could not continue  with current standards for existing facilities, developing new facilities,  providing proper monitoring of special recreation permits, or to provide  the public with service they need and deserve.”  “Unfortunately, our recreation fee funds collected have become the  primary source of revenue for our (unit). This was not the original intent  of the fee demo program but with shrinking budgets it has become our  main funding source.”  “In this time of declining budgets and increasing use of national forests  as the Baby Boomer generation retires, a loss of REA funds would be  devastating to our ability to provide recreation opportunities.”   “Our unit has become very much dependent on REA funds to provide  basic care and maintenance activities of our developed facilities. These  include the high costs of solid waste disposal; toilet pumping and  disposal; and maintaining a seasonal workforce to meet standards and  guidelines for recreation management.”   “Funding for projects via the recreation fee program has enabled the  park to make modest improvements in visitor facilities and services.  Without the recreation fee program, very little of work that has been  done would have been done.”  “Recreational fee revenues allow us to accomplish projects which  wouldn’t have been accomplished with other (general) appropriated  funds. While some of the more urgent projects might have been  accomplished with other (general) appropriations, fee dollars enable us  to accomplish much more.”  “Most public use activities and projects would not be conducted if we  did not have funds from a recreation fee program.”   “The recreation fee program has provided additional revenue to support  visitor needs and enhance the visitor experience. Without these funds,  we could not provide visitors with a high quality of visitor service.”
section_title: Conclusions
paragraphs: REA was essentially designed to mitigate past problems with the recreation  fee demonstration program, such as having multiple passes that caused  visitor confusion, provide a more sustainable long-term authority to  support effective planning and management of fee programs, encourage  increased public participation, protect recreational resources, and provide  the public with quality visitor services. In addition, REA authorized a new  multiagency recreation pass to help relieve visitor confusion associated  with having to use multiple passes to access and enjoy federal recreation  sites. REA was enacted almost 2 years ago, and our early assessment of the  participating agencies’ implementation of the act indicates that they are  making progress. Still, there are areas in need of management attention.  Two key working groups established to facilitate REA implementation have  yet to take important steps to carry out REA, such as completing necessary  tasks to allow RRAC requirements to be fully implemented, which will  enhance public participation requirements. Also, our analysis indicates that  some of the DOI agency and FS units are struggling with how to interpret  certain aspects of the agencies’ interim guidance for implementing the act,  which has caused confusion regarding the types and amount of fees to  collect. Furthermore, unit officials are in need of guidance on facilitating  public participation and how to ensure projects funded with REA fees are  connected to the visitor experience. Unless actions are taken to issue final  regulations and implementation guidance for the fee program, including  detailed policy and procedure guidance, many unit officials will continue to  struggle with how to effectively and consistently implement the recreation  fee program.
Measures the agencies have in place to control and account for collected  fee revenues is another area that needs attention. While the results of our  analysis cannot be projected to all fee-collecting sites, we noted  weaknesses in the controls over fee collections at some BLM, FWS, and FS  sites that warrant attention because they not only affect the accounting for  the collected revenues, but they may also affect the safety of the  individuals involved in the collection efforts.  Although millions of dollars  are collected annually through REA, some agencies have not provided  adequate guidance or conducted routine audits needed by the units to  ensure that they develop and maintain proper controls over their fee  revenues and provide reasonable physical protection for their staff.
Despite the fact that Congress intended all five federal land management  agencies to implement REA, Reclamation has not determined whether it  will implement the act. Unlike the other participating agencies,  Reclamation operates most of its recreation sites through partnerships that  collect fees to support the costs of administering the recreation programs  they provide. Reclamation has determined that its recreation areas that are  managed by nonfederal partners will not be participating in REA, and thus  will not accept the new multiagency pass. Further, the federal managing  partners will be allowed to decide on their own how REA impacts the  recreation areas located on Reclamation lands that they manage.  Reclamation has not yet decided what actions to take with regard to those  units managed by Reclamation that it identified as meeting REA criterion  for charging recreation fees.
section_title: Recommendations for Executive Action
paragraphs: To allow for public input on new fees or modifications to existing fees, we  recommend that the Secretaries of the Interior and Agriculture expedite  completing the steps needed for the RRACs and existing advisory councils  to begin implementing REA.
In order to improve agencies’ implementation of the Federal Lands  Recreation Enhancement Act and improve the accountability and controls  for recreation fee collection, we recommend that the Secretary of the  Interior direct the  Director, National Park Service; Director, Bureau of Land Management;  and Director, Fish and Wildlife Service to promptly issue final  regulations and implementation guidance on the fee program, including  detailed policy and procedure guidance; and  Director, Bureau of Land Management and Director, Fish and Wildlife  Services to ascertain the extent to which their units do not have  effective processes and procedures for accounting for and controlling  collected fees and develop guidance for implementing appropriate and  effective internal controls over cash management. This guidance for  implementing such controls should identify and encourage the use of  best practices, such as routine audits.
We recommend that the Secretary of the Interior direct the Commissioner  of the Bureau of Reclamation to expedite its decision on implementation of  REA.
In order to improve the Forest Service’s implementation of the Federal  Lands Recreation Enhancement Act and improve the accountability and  controls for collected recreation fees, we recommend that the Secretary of  Agriculture direct the Chief of the Forest Service to take the following two  actions:  promptly issue final regulations and implementing guidance on the fee  program, including detailed policy and procedure guidance; and   ascertain the extent to which its units do not have effective processes  and procedures for accounting for and controlling collected fees and  develop guidance for implementing appropriate and effective internal  controls over cash management. This guidance for implementing such  controls should identify and encourage the use of best practices, such as  routine audits.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the Departments of the Interior and Agriculture with a draft of  this report for review and comment. Their written comments are provided  in appendixes VI and VII, respectively. DOI generally agreed with our  findings and recommendations. It said that our recommendations further  REA implementation efforts and it was dedicated to addressing them  promptly. Specifically, with regard to issuing final regulations and  implementation guidance for the new interagency pass, the department  said that, while guidelines had not been formally completed, most of the  policy decisions composing the guidelines have been taken and discussed  in congressional testimony. Although this may be the case, the results of  our survey and site visits indicated that those who are to implement REA in  each of DOI’s agencies are in need of clarifying guidance, particularly with  regard to adding new fee sites or modify existing fees to fully implement  the act, which will also help to ensure consistency in applying the  requirements of REA.
We also recommended that DOI direct that BLM and FWS ascertain the  extent to which their units have effective processes and procedures for  accounting for and controlling collected fees and develop effective  guidance and internal controls over cash management, such as routine  audits. Although this recommendation was not directed at the Park Service,  the department’s comments state that the Park Service has the intention to  recommitting to a National Audit Program. It said that such a program has  been delayed due to other program priorities and lack of staff resources.  However, it said that the Park Service has a working group that is being  reconvened to restart the process of developing a National Audit Program  and that, once additional resources are in place, it will be possible to  implement a more standardized program. On the basis of our visits to eight  sites, we observed practices for controlling and accounting for fee  revenues that appeared to be working well at these locations in the Park  Service. However, we are encouraged by the additional actions that the  Park Service plans to take to improve their processes in this area and any  lessons learned from this effort may also benefit BLM and FWS.
With regard to our recommendation that the department direct  Reclamation to expedite its decision on implementing REA, the department  provided comments from the bureau that said that the bureau had only  identified seven sites that currently meet the statutory criteria for charging  standard amenity fees under REA. Given this fact and the likely costs of  implementing REA for the agency, it said that there is a strong possibility  that Reclamation would require all recreation sites meeting the criteria to  participate in REA. However, as recognized in our report, Reclamation  should decide this issue soon so that its units can begin taking the needed  steps to implement REA.
The Department of Agriculture did not specifically state its agreement or  disagreement with our recommendations. However, it outlined actions it  has planned or under way to address them. Specifically, it acknowledged  the Forest Service’s need to revise several policies that relate to REA and  collections in general. It said that the Forest Service had already initiated  policy revisions for its manuals and handbooks, which it plans to produce  by September 2007. It also said that the Forest Service is in the process of  revising its policies on billings and cash collections, which it will expedite  for publication as soon as practicable.
Both DOI and the Department of Agriculture provided other comments for  updating information in the report or for providing technical clarifications  that we have incorporated, as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 2 days from the  report date. At that time, we will send copies of this report to the Secretary  of the Interior, the Secretary of Agriculture, 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 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. Key contributors to this report are listed in appendix VIII.
section_title: Objectives, Scope, and Methodology
paragraphs: Based on the congressional request letter of May 2005 and subsequent  discussions with your staffs, we agreed to determine (1) what agencies  have done to coordinate the implementation of the Federal Lands  Recreation Enhancement Act (REA), including preparing for the new  interagency federal lands pass; (2) what agencies have done to implement  the REA fee and amenity requirements and sufficiency of guidance for REA  implementation; (3) the extent to which the agencies have control and  accounting procedures for collected recreation fee revenues; (4) how  participating agencies prioritize and approve activities and projects funded  with fee revenues; and (5) the extent to which units have unobligated fund  balances and if recreational fees are being used to fund projects formerly  funded with other appropriations. In addition, we are providing  information on how recreation fees vary by type, amount, and level of  amenities offered at units with similar recreational opportunities across  and within agencies participating in REA.
To address the objectives, we obtained and reviewed applicable laws;  regulations; agencywide policies and procedures; regional policies and  procedures; and the fees collected at selected units under the Fee  Demonstration Program and REA in order to determine what changes have  resulted since the implementation of REA. We developed and administered  a nationwide survey to agency officials responsible for fee programs under  REA. We supplemented the survey information with records reviews,  analyses of documents, and testimonial evidence gathered during unit  visits and in meetings with state, regional, and headquarters officials.
To obtain information on all of our objectives related to the implementation  of REA, the collection and expenditure of recreation fee revenues, we  designed and administered a national survey of units collecting these fees.   We worked to develop the survey instrument with social science survey  specialists to administer to staff at National Park Service (NPS) units,  Forest Service (FS) ranger districts, Bureau of Land Management (BLM)  field offices, and Fish and Wildlife Service (FWS) refuges. Because this was  not a sample survey, there are no sampling errors. However, the practical  difficulties of conducting any survey may introduce errors, commonly  referred to as nonsampling errors. For example, differences in how a  particular question is interpreted, in the sources of information that are  available to respondents, or how the data are entered into a database can  introduce unwanted variability into the survey results. We took steps in the  development of the surveys, the data collection, and data analysis to  minimize these nonsampling errors. For example, prior to administering  the survey, we pretested the content and format of the surveys with several  site officials at each agency to determine whether (1) the survey questions  were clear, (2) the terms used were precise, (3) respondents were able to  provide the information we were seeking, and (4) the questions were  unbiased. In addition, we provided a draft of the survey to the national fee  program coordinators at the four agencies and met with them to obtain  comments and corrections to the wording and structure of the questions in  the survey. We made changes to the content and format of the final  questions based on pretest results. We verified some financial information  from a random sample of 25 non-FS units by asking these respondents to  check their answers originally provided to four questions and verify the  reported dollar amounts or provide corrections.  Our analysis showed that  a significant number of units reported they had made errors in providing  the original survey data; however, total dollars reported after correction did  not differ significantly from the dollars reported originally. The revised sum  of the total fees collected differed from the original by less than plus or  minus 2 percent and for unobligated balances, less than plus or minus 4  percent. We also checked a sample of cases to ensure the accuracy of data  entry and made corrections as needed. We performed computer analyses to  identify inconsistencies in responses and other indications of error. We  contacted survey respondents, as needed, to correct errors and verify  responses. In addition, a second independent analyst verified that the  computer programs used to analyze the data were written correctly. It is  our opinion that the data we present is valid and reliable for the purposes  of this report.
To identify the current fee-collecting units to complete the survey, we  asked the national fee program coordinators at NPS, FS, BLM, and FWS to  provide a full list of these units including phone numbers and e-mail  addresses. The survey was designed to be distributed as a locked MS Word  document attached to a transmittal e-mail, allowing the document to be  saved on unit computers, altered with answers, and returned via  attachment to e-mail messages. Respondents were instructed to complete  one survey per unit to reflect all recreation fee activities managed as a  single unit. Based on phone calls from respondents and returned surveys,  we determined some surveys included responses for more than one unit on  the list provided by the agency. In other cases, surveys were returned for  units that were not on the list. In either case, we contacted the unit to  determine the status of the unit. If we found that the management of a fee  program extended across the boundaries of more than one unit, and its fee  collection and spending were combined, with funds commingled and  project priorities jointly determined, then we accepted a single survey for  more than one unit. Because some units were combined, and because  others indicated that they were not collecting fees, contrary to the lists  provided by agency headquarters, the number of units in the universe for  this survey declined. Table 10 provides the estimated response rates by  agency and overall.
The number of units identified, 904, reflects the total number of units  remaining in the universe after adjustments, when units reported that they  had been administratively merged with another unit or, in a few cases,  when they were not included on the list provided by the agencies.  The  units identified by the agencies included units that indicated that they did  not collect fees under REA. These respondents were not intended to have  been included in the universe and, therefore, were dropped from the  analysis of responses. Once the surveys were received, logged in, and  printed, they were checked for completeness and logic, and the responses  were then coded into a database for summarization and analysis.
To assess the accounting and control procedures in place at various fee- collecting units, we conducted unit visits to a sample of unit locations  where we collected documents, observed accounting and control practices,  and interviewed staff. Information that we gathered during our site visits  and during our interviews represents only the conditions present in the  units at the time of our review. We cannot comment on any changes that  may have occurred after our fieldwork was completed. Furthermore, our  fieldwork focused on in-depth analysis of only a few selected units. Based  on our interviews, we cannot generalize our findings beyond the units and  officials we contacted.
As of 2005, four of the five agencies were actually collecting recreation fees  under REA—the same four that had previously been authorized to collect  fees under the Fee Demo program. The amounts of recreation fee  collections varied substantially among the four agencies. For example,  NPS’s top fee-collecting unit, Grand Canyon National Park, collected  $15,773,239 in Fee Demo revenue in fiscal year 2003, while FWS’s top fee- collecting unit, Chincoteague National Wildlife Refuge, collected $658,497  in the same fiscal year, and there were only seven units within the entire  FWS agency that collected over $100,000 in recreation fee revenue.  Therefore, in order to ensure that we visited fee units of varying sizes  within each of the four agencies, we created different small, medium, and  large fee categories for each agency. These categories were identified by  sorting the fee-collecting units within each agency from highest to lowest in  fee revenue for fiscal year 2003. After sorting the data by fee revenue, we  analyzed the data to see where natural breaks for small, medium, and large  units fell, in order to determine the categories for each agency. The  resulting categories are shown in table 11.
Our original plan was to visit at least three large units, two medium units,  and one small unit within each agency. In addition, to address  congressional concerns about large unobligated carryover balances, we  planned to visit at least two more units with very large carryover balances.  We also recognized the importance of visiting units in several different  geographic areas to document possible differences in the implementation  of the fee programs within different states or regions. We completed this  original methodological plan with one exception; we only visited two large  FWS units. However, given the relatively small size of even the largest of  FWS’ fee-collecting units, we believe that our review had already  sufficiently covered their program. Table 12 identifies the recreation fee  units we visited.
Finally, we spoke with headquarters officials at all five agencies to obtain  their views on the implementation of REA, their plans for future monitoring  and assessment activities, the status of the new interagency federal lands  pass, and their opinions on the future impact of REA fees on their agency’s  appropriations.
We conducted our work between June 2005 and August 2006 in accordance  with generally accepted government auditing standards.
section_title: Fees for Recreational Uses Vary by Agency and for Amenities Across and within Agencies Participating in REA
paragraphs: This appendix provides information on how the fees charged and the  amenities provided for use of recreational units across the country vary by  the activity offered, the provisions of the Federal Lands Recreation  Enhancement Act (REA) and the agency offering them. For example, under  REA, units of the National Park Service (NPS) and the Fish and Wildlife  Service (FWS) are authorized to charge entrance fees for accessing the  lands they manage. REA does not specify minimum amenity requirements  for entrance fees. The Bureau of Land Management (BLM) and Forest  Service (FS) units, on the other hand, are authorized to charge standard  amenity fees, not entrance fees. Unlike entrance fees, REA specifies the  minimum amenities required at recreation sites to charge this fee.
subsections: section_title: NPS and FWS Entrance Fees
paragraphs: Of the 271 NPS and FWS units responding to our survey, 168, or 62 percent  had entrance fees. Of the 168 units with entrance fees, 137, or 82 percent  were NPS, and 31, or 18 percent, were FWS units. In NPS, the entrance fees  ranged from a low of $1 per person to a high of $300 per bus or group, while  FWS units reported an average fee ranging from a low of $1 per person to a  high of $50 per bus. The entrance fees are typically charged per visit, on per  vehicle, per person, per group, or commercial vehicle bases, as well as on  an annual basis. Table 13 shows the number of units that reported charging  an entrance fee and the minimum and maximum fees charged for the  various entrance categories.
section_title: BLM and FS Standard Amenity Fees
paragraphs: Standard amenity fees were authorized by REA to be charged for federal  recreational lands and waters under the jurisdiction of BLM, Reclamation,  or FS.  As mentioned earlier in this report, Reclamation has not  implemented REA and, therefore, is not included in these results. The law  sets criteria for the establishment of standard amenity fees: the area where  charged must have significant outdoor recreation, a substantial federal  investment, allow efficient collection of fees, and must have the following  amenities:  designated developed parking, a permanent toilet facility, a  permanent trash receptacle, interpretive sign, exhibit or kiosk,  picnic  tables, and security services. Of the 472 survey responses from BLM and FS  units, 38 of 85 (45 percent) BLM units and 157 of 387 (41 percent) of FS  units reported having standard amenity fees. BLM’s units responding to the  survey had standard amenity fees ranging from a low of $1 to a high of $10  for each person and from $2 to $10 per vehicle. FS’s units reported standard  amenity fees ranging from a low of $0.50 per person to a high of $7.50 per  person and per vehicle standard amenity fees that ranged from $1 to $50.  Table 14 outlines the number and types of standard amenity fees charged  and the range of fees of each category reported.
section_title: Many Units Offer More Amenities Than What Is Required Under REA
paragraphs: Our survey identified 195 BLM and FS units that reported charging a  standard amenity fee for recreation use in their units. In addition to the six  amenities required under REA to charge a standard amenity fee, many of  the units reported providing various other amenities for the visiting public.  Table 15 shows the various amenities provided at the 195 BLM and FS  units, for either the minimum or maximum (if any) standard amenity fee,  including the amenities required under REA for the unit to charge a  standard amenity fee.
Our survey also identified that 52 of the 195 units that charge standard  amenity fees had more than one standard amenity fee. For example, one  recreation site at a unit could offer such amenities as attendant fee  collection in addition to the amenities required by REA and charge a fee of  $3 per person. Another recreation site at the same unit could offer these  same amenities but charge a higher fee amounting to $5 per person because  it also offers additional amenities such as picnic shelters and drinking  water.  Of the 52 units with more than one standard amenity fee, the five  most common additional amenities offered for the higher fee were picnic  shelters, drinking water, shower or bath house, fire ring or grill, and a  permanent trash receptacle. It should not be implied that the higher fees  are solely due to these added amenities. However, according to our survey  results, the units responding indicated that the level of amenities offered  was one of the most influential factors in determining the type and amounts  of fees charged. Other factors that had a significant influence on these fees  were professional judgment, fees at comparable sites, and agency policy.
section_title: Fees Charged for Similar Activities Vary
paragraphs: We also collected information on the various types of activities, amenities,  or services for which units charge a fee, other than entrance fees. These  could be standard or expanded amenity fees and special recreation permit  fees authorized by REA.  The most common activities, amenities, or  services for which a fee is charged are camping, outfitter or guides, day  use, Christmas tree cutting, and cabin rentals. Table 16 shows the number  of units charging a fee under REA for the various types of activities,  amenities, or services provided.
To determine the extent to which similar fees are charged for similar  activities or services, we asked units for further details on the specific fees  charged for a few of the common activities or services at recreation units:  camping, motor boating, and access to a body of water for rafting,  canoeing, or kayaking. Specifically, we asked the units to identify a  minimum and maximum fee for the activity or service, as well as the  amenities provided for the fee charged. To illustrate, a campsite at a unit  may charge $5 per night per individual for camping and for that fee provide  only a site to put up a tent, whereas another campsite at this unit may  charge $10 per night per individual and provide a site, shower facilities,  drinking water, and electrical service. Our analysis of responses from NPS,  BLM, FS, and FWS units indicated that there was a wide range of fees  charged for these common activities or services, and a variety of amenities  were available at the locations where these fees were charged.
subsections: section_title: Campsite Fees and Amenities
paragraphs: Units may have more than one campsite available for recreation and charge  fees for their use. Our survey asked each unit to identify the fees and  amenities for their lowest priced campsite and for their highest priced  campsite. The fees charged for a campsite in BLM, FS, FWS, and NPS units  ranged from a low of $2 in BLM and FS to a high of $225 in FS. This range  includes both individual and group campsites. Table 17 shows the number  of units offering camping for a fee, their median fees, and range of fees  charged for the lowest and highest priced campsites.
Camping for a fee is offered in 55 percent of the units responding to our  survey. FS had the greatest percentage of units offering camping for a fee,  71 percent of units responding. FWS had the lowest, with only 2 percent of  the units responding offering camping for a fee.
We asked units to identify which amenities were provided at the campsites  with the minimum and maximum fees within that unit.  Overall, an average  of 10.7 amenities was offered at the minimum fee campsites, and an  average of 12.1 amenities was offered at the maximum fee campsites. The  amenities most often available for the maximum fee sites, and not the  minimum fee sites, are drinking water, availability of reservation system,  electrical hookups, water hookups, and sanitary dump stations.  Within the  individual agencies, the difference in number of amenities between  minimum fee camping sites versus maximum fee camping sites was on  average within two amenities or fewer.
section_title: Motor Boating Fees and Amenities
paragraphs: Our analysis of responses from NPS, BLM, FS, and FWS units on the  minimum and maximum fees for motor boating charged in the unit also  focused on amenities available for these fees. Boating for a fee is offered in  10 percent of the units overall with FS having the largest number of units  with motor boating for a fee available, 52 units, or 13 percent of FS units  responding.  FWS has the lowest number of units with boating fees, with  only 4, or 4 percent of units reporting a motor boating fee.  The results of  our survey on the extent of motor boating fees are given in table 18.
Motor boating fees at units in the four agencies surveyed are charged on a  number of bases:  per person, per boat, or other bases, such as a per trip  charge.  A total of 5 FS and FWS units reported charging motor boating fees  on a per person basis, with the minimum and maximum fees per person  starting at $1 and ranging up to $4. A total of 41 units in all four agencies  reported charging on a per boat basis, with the minimum fees starting at $1  per boat and ranging up to a maximum of $40. Fees charged on various  other bases, such as per trip, were reported in 30 units, with the fees starting at $0.50 and ranging up to a maximum of $300. Survey  responses showed that only 9 of the 72 units with a fee for motor boating  and related activities had a maximum fee in addition to the minimum fee  listed for these activities.
We asked the units with a motor boating fee to identify which common  amenities were provided for boating with the minimum and maximum fees  within that unit. Overall, an average of 11.5 amenities was offered at the  minimum fee areas, and an average of 11.9 amenities was offered at the  maximum fee areas, virtually the same when considering all the units.
section_title: Special Recreation Permit Fees for Rafting, Canoeing or Kayaking, and Amenities
paragraphs: The third type of fee we asked survey respondents about was special  recreation permit fees for access to a body of water for rafting, canoeing, or  kayaking. A total of 45 units reported this type of fee, with the greatest  number in FS and BLM, and few reported by NPS or FWS.  Table 19  provides a breakdown of the agency units reporting on our survey a special  recreation permit fee for these activities.
These special recreation permit fees for rafting, canoeing, or kayaking at  units in the four agencies surveyed are charged on a number of bases:  per  person per day, per group per day, per boat per day, per trip, or other bases.   A total of 12 BLM, FS, and FWS units reported charging per person per day  fees for this activity, with the fees per person starting at $1 and ranging up  to a maximum of $6. A total of 9 units in BLM and FS reported charging on  a per person per trip basis, with the fee starting at $3 and ranging up to a  maximum of $404. Fees were charged on various other bases, such as per  group per day, or per boat per day, with the fees starting at $1 and ranging  up to a maximum of $90. Our survey showed that only 10 of the 45 units  with special recreation permit fees for rafting, canoeing, or kayaking had a  maximum fee in addition to the minimum fee listed for these activities.
We asked the units with a special recreation permit fee for rafting,  canoeing, or kayaking to identify which common amenities were provided  for boating with the minimum and maximum fees within that unit. Overall,  an average of 9 amenities was offered at the minimum fee areas, and an  average of 9.3 amenities was offered at the maximum fee areas, virtually  the same when considering all the units.
section_title: Information on Organizational Structure, Costs, and Membership Requirements of Recreation Resource Advisory Committees
paragraphs: This appendix provides information on the organizational structure, costs,  and membership requirements of Recreation Resource Advisory  Committees (RRAC). In March 2006, the Department of the Interior (DOI)  and the Department of Agriculture (USDA) approved the organizational  structure for the RRACs and existing advisory councils via an interagency  organizational agreement. Table 20 outlines the nature and type of RRACs  and advisory councils that Bureau of Land Management (BLM) and Forest  Service (FS) have agreed to use in each state and/or region. In the majority  of western states, BLM and FS will use joint RRACs or committees, many of  which will be composed of existing BLM advisory councils since the  Federal Lands Recreation Enhancement Act (REA) allows existing  advisory committees or fee advisory boards to perform the RRAC duties. In  addition, five new RRACs are being established nationwide. Two of the new  RRACs are being formed in the eastern United States and will primarily  address FS fees since BLM has minimal land and only one fee-collecting  unit in the East. Of the two new eastern RRACs, one will cover all of FS  Southern Region (Region 8), and one will cover all of FS Eastern Region  (Region 9). The remaining three new RRACs are being formed in the  western states: one joint RRAC covering all of California, one joint RRAC  covering Washington and Oregon, and one joint RRAC covering Colorado.
The March 2006 interagency organizational agreement states that BLM is  responsible for the direct costs of its advisory councils, while FS will be  responsible for the direct costs of the new RRACs. FS estimates that it will  cost about $90,000 to $120,000 per year to fund each new RRAC—based on  travel costs for the RRACs to meet twice per year, FS staff time, and the  assumption that each RRAC will have one to five subcommittees—and all  funding for the RRACs will come from the FS’s 5 percent regional funds,  according to a FS headquarters official. However, implementing the RRACs  may cost more the first year since the members of the RRACs may need to  meet more frequently than twice per year during the initial establishment of  the RRACs. BLM is allocating $3,000 per state per year in base funds  starting in fiscal year 2007 to implement the RRAC requirements where  existing advisory councils are used, according to a BLM headquarters  official.
The new RRACs will be composed of 11 members. In appointing members  to the RRACs, the Secretary is to provide for a broad and balanced  representation of the recreation community; table 21 outlines the  requirements for the composition of the RRACs. Nominations for the new  RRACs will be solicited during a 30-day nomination period established in a  Federal Register notice that will be published once the interagency  agreement is finalized. The Secretary of Agriculture will make formal  appointments to the RRACs once the nominations are received and  evaluated by FS. According to agency officials, it is unknown how long the  appointment process will take but it is hoped that nominees will be  appointed within 90 days of issuance of the interagency agreement, which  occurred on September 1, 2006.
The RRACs and existing advisory councils may form subcommittees to  allow for local representation and to provide additional advice and  recommendations to the RRAC or existing advisory council. DOI and USDA  will be providing advice on subcommittee membership; however, final  determination on whether subcommittees are utilized and their  membership will be the determination of the existing advisory councils and  not the agencies involved.
section_title: Information on Total Fee Revenues, Obligated Funds, and Unobligated Balances
paragraphs: This appendix provides information on the fee revenue and obligations  collected under the Recreational Fee Demonstration Program (Fee Demo)  and the Federal Lands Recreation Enhancement Act (REA) as reported by  the agencies to Congress. Table 22 shows the fee revenue, the funds  obligated, and unobligated balances for fiscal years 2001 through 2005 for  the Department of the Interior’s Bureau of Land Management, Fish and  Wildlife Service, the National Park Service, and Department of  Agriculture’s Forest Service.
section_title: Information on Participating Agencies’ 10 Units with Largest Unobligated Fund Balances
paragraphs: This appendix provides information on the unobligated balances for  recreation fee funds collected under the Recreational Fee Demonstration  Program (Fee Demo) and the Federal Lands Recreation Enhancement Act  (REA). Table 23 shows the 10 units with the largest unobligated fund  balances of recreation fees for Bureau of Land Management (BLM),  National Park Service (NPS), Fish and Wildlife Service (FWS), and Forest  Service (FS).
section_title: Comments from the Department of the Interior
paragraphs: The following are GAO’s comments on the Department of Interior’s letter  dated September 12, 2006.
subsections: section_title: GAO Comments
paragraphs: 1. We disagree with NPS’s comment concerning distribution of the new  pass revenues. The NPS noted in its comments that “the revenue share  formula appears to be identified.”  However, the details of the formula  have not yet been determined. The working group has only determined  that the revenue will be distributed based on a formula that takes into  account pass use and other factors. Therefore, the long-term revenue  distribution strategy is unclear. 2. We stand by our description of NPS’ efforts to update its guidance on  accounting and controlling collected fee revenues as “slow.”  NPS’  current guidance on this subject was last published in 1989, which it  recognizes as needing to be revised. In addition, the NPS’ statement  that our report language indicates “NPS does have effective internal  controls in place,” is incorrect. We specifically state that NPS units we  visited, which are only 8 of 390, appear to have implemented  reasonable accounting procedures and effective internal controls.  Thus, we cannot attribute this condition to the entire universe of NPS  units. 3. BLM provided additional detail on the results of their inquiries to units  that responded to our survey that they did not offer all six amenities  required to charge standard amenity fees under REA. We have  summarized this information on pages 27 and 28 of the report. In  essence, BLM officials imply from the results of their inquiries that their  units did offer all six amenities required under REA. This new  information would have to be verified to attest to its accuracy. 4. We agree that “slow” is a relative term but believe that it is used  appropriately in the context of the information presented in the  paragraph pertaining to the development of the RRACs. The  information in the paragraph notes that, according to a June 2005  interagency presentation, the RRACs were expected to be established  with members appointed by the end of 2005. Since none of the  members for any of the RRACs have been appointed, we feel  comfortable in referring to this RRAC development as “slow.” 5. One of REA’s goals was to reduce visitor confusion. We believe that  Reclamation’s approach to allowing each managing partner to make its  own determination of  how REA impacts each unit, to include the  decision of  whether or not to accept the new pass, will create an  inconsistent and more confusing system of fees for the visitors. 6. We disagree with DOI’s contention that evaluating the validity and  interpreting the responses of units to our survey is problematic, since  we have simply reported the survey results. The results we reported are  based on two opinion survey questions that we asked both FS and DOI  field-level officials to respond to. The first question asked if the unit  officials believed recreation fee revenues are being used to fund the  types of projects formerly funded with appropriations at their unit. The  second question sought the officials’ opinions about the extent to  which they believe that recreation fee revenue will be used to fund the  types of projects over the next 5 years at their units that would have  been funded with appropriated dollars. We recognize that individual  units do not have agencywide perspectives on these issues. Also,  including these survey results in our report is not intended to forecast  the future, but rather to share the perspective of the survey  respondents responsible for the on-the-ground implementation of this  program. No GAO conclusions or recommendations were based on  these stated perceptions. 7. The concerns noted in the background are general concerns that are  frequently cited by critics of the fee program. Implementing both Fee  Demo and the recreation fee program under REA has been  controversial and many people and groups, such as the Western Slope  No-Fee Coalition and the Arizona No-Fee Coalition, have spoken out  against recreation fees. 8. Same as comment 4. 9. Since the working group has not determined a formula and how pass  use or other factors will be considered in such a formula, it is still not  clear how revenues will be distributed beyond the first 3 to 5 years of  the pass program. Therefore, the long-term revenue distribution  strategy is unclear. The potential problems with collecting pass use  data are outlined in this report. Accurate pass-use data will be difficult  to collect at remote locations and many units within the agencies do  not have the infrastructure in place to collect pass-use data. This may  lead units to have inaccurate pass-use data or data largely based on  estimates. Since pass use revenue distribution will be tied to the pass-  use data, units and/or agencies may benefit from submitting inflated  pass-use estimates. All of these issues are potential problems with the  collection of pass-use data.
section_title: Comments from the Forest Service
paragraphs: The following are GAO’s comments on the Department of Agriculture’s  Forest Service letter dated September 7, 2006.
subsections: section_title: GAO Comments
paragraphs: 1. FS provided additional detail on the results of their inquiries to units  that responded to our survey that they did not offer all six amenities  required to charge standard amenity fees under REA. We have  summarized this information on pages 27 and 28 of the report. In  essence, FS officials imply from the results of their inquiries that many  of these unit officials were not aware of the type of fees they were  charging or the amenities offered for the fees charged under the REA  authority when they replied to our survey. This new information would  have to be verified to attest to its accuracy. 2. The GAO survey was sent to 467 FS Ranger District officials directly  responsible for implementation of the fee program, under REA. The  results we reported are based on two opinion survey questions that we  asked both FS and DOI field-level officials to respond to. The first  question asked if the unit officials believed recreation fee revenues are  being used to fund the types of projects formerly funded with  appropriations at their unit. The second question sought the officials’  opinions about the extent to which they believe that recreation fee  revenue will be used to fund the types of projects over the next 5 years  at their units that would have been funded with appropriated dollars.  We recognize that individual units do not have agencywide perspectives  on these issues. Also, the inclusion of these survey results in our report  is not intended as a forecast of the future but rather as a way to share  the perspective of the survey respondents responsible for the on-the- ground implementation of this program. No GAO conclusions or  recommendations were based on these stated perceptions. In addition,  we have added the FS statement that, historically, fee revenues have  not replaced appropriations, and there is no reason to expect this to  change in the future in order to also share the agency’s official  perspective on this issue. 3. We agree that “slow” is a relative term but believe that it is used  appropriately in the context of the information presented in the  paragraph pertaining to the development of the RRACs. The  information in the paragraph notes that according to a June 2005  interagency presentation, the RRACs were expected to be established  with members appointed by the end of 2005. Since none of the  members for any of the RRACs have been appointed, we feel  comfortable in referring to this RRAC development as “slow.” 4. We recognize that the FS interim implementation guidelines for REA  have definitions of the standard amenities; however, these guidelines  have not prevented confusion about amenity criteria. In their  comments on a draft of this report (bottom of page 104), the FS  contends 31 of their unit officials erroneously reported they were out of  compliance with REA’s standard amenity requirements because they  were either confused over the difference between standard and  expanded amenities, or, because “there was misunderstanding over the  definitions of the amenities.”  Such results further highlight the need for  more specific FS guidance on implementing and managing the fee  program.  5. We believe that for department-level management to have assurance  that collected fees are controlled effectively and accounted for  properly, detailed department- or bureau-level guidance on procedures  are an important tool for local managers and imperative for those who  have little or no formal accounting training or background.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Roy Judy, Assistant Director;  Carolyn Boyce; Elizabeth Curda; John Delicath; Denise Fantone; Doreen  Feldman; Timothy Guinane; Anne Hobson; Susan Irving; Stanley Kostyla;  Diane Lund; Robert Martin; Matt Michaels; Angie Nichols-Friedman; Lesley  Rinner; John Scott; Jack Warner; and Amy Webbink made key  contributions to this report.