Recreation Fees: Agencies Can Better Implement the Federal Lands Recreation Enhancement Act and Account for Fee Revenues
Released: 2006-09-25T00:00:00

Letter

Background

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.

Working Groups Formed to Foster Interagency Cooperation and Coordination on REA Implementation Issues Have Made Progress, but Some Issues Remain Unresolved

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.

The RRACs/Public Participation Working Group is Facilitating the Establishment of State and Regional RRACs, but Progress Has Been Slow

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.

Interagency Pass Working Group Has Made Progress Preparing for the New Interagency Federal Lands Pass, but Some Issues Remain Unresolved

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.

Fee Collection/Expenditure Working Group Has Issued Final Interagency Guidance in an Attempt to More Clearly Define REA Terminology

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.

Communications Working Group Has Been Used to Facilitate Interagency Communication with Congress and the Public

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.

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

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.

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

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.

Agencies Assessed Recreation Fee Programs and Made Changes

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.

Some BLM and FS Units Do Not Have All Required Amenities to Charge Standard Amenity Fees

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.

Reclamation Undecided on Implementing REA

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.

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

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.

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

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.

Some Agencies Lack Adequate Controls on Collected Fees

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.

Some Agencies’ Units Lack Adequate Guidance to Establish Accounting Procedures and an Effective System of Internal Controls for Collected Fee Revenues

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.

Some Agencies Do Not Have a System of Routine Audits to Account for Collected Fee Revenues

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.

Agencies Have Different Processes for Selecting Projects to Be Funded with Fee Revenues

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.

Project Prioritization Processes Are Based on REA Criteria and Agency Guidance

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.

Project Selection Processes Are Guided by Agency Needs and Revised Policies under REA

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.

Agencies Fund a Variety of Maintenance, Operations, and Capital Improvement Projects with Fee Revenues

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.

The Collection and Distribution of Central and/or Regional Funds Varies by Agency and by Region

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.

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

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.

Overall, Agencies Report Unobligated Balances Consisting of Millions of Dollars at the End of Fiscal Year 2005

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.

Fee-Collecting Units Cite Several Reasons for Unobligated Balances

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.

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

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.”

Conclusions

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.

Recommendations for Executive Action

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.

Agency Comments and Our Evaluation

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.

Objectives, Scope, and Methodology

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.

Fees for Recreational Uses Vary by Agency and for Amenities Across and within Agencies Participating in REA

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.

NPS and FWS Entrance Fees

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.

BLM and FS Standard Amenity Fees

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.

Many Units Offer More Amenities Than What Is Required Under REA

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.

Fees Charged for Similar Activities Vary

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.

Campsite Fees and Amenities

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.

Motor Boating Fees and Amenities

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.

Special Recreation Permit Fees for Rafting, Canoeing or Kayaking, and Amenities

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.

Information on Organizational Structure, Costs, and Membership Requirements of Recreation Resource Advisory Committees

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.

Information on Total Fee Revenues, Obligated Funds, and Unobligated Balances

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.

Information on Participating Agencies’ 10 Units with Largest Unobligated Fund Balances

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).

Comments from the Department of the Interior

The following are GAO’s comments on the Department of Interior’s letter dated September 12, 2006.

GAO Comments

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.

Comments from the Forest Service

The following are GAO’s comments on the Department of Agriculture’s Forest Service letter dated September 7, 2006.

GAO Comments

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.

GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

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.