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At the March UPS meeting I becane aware of
arastic hikes in OAV nermit fees for Assettague
Islanu National seashore (AINS). It was not too
long ago that there was no fee, Then s.6 fee was
institute, which although reasonable: in hindsigt
appears to have been just a planned start and
perhaps should have been opposed. In 1982 the
fee was raised to €16 and now in 1964 it is $30.

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Ir a period of three years the fee was inoren sea six fola. I can think of no other federal entry/u3" fee tnat has seen this sort of escalation. It has no connection whatsoever to the inflationary rate or comra rable services and facilities provided commensurate with the increase.

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Apparently there has not even been an increase

in law enforcement presence or the beach to assure visitor safety and resource protection so that the 144 veniole limi: coula be raised and therefore end the frustration of those who have come to fish and are turned away because the limit has been reached. (The reasonableness of this 144 vehicle limi: Is Amothes matter that nueas to be discussed at another time. )

In sum, the incrua 883 are without rational Justification and gre exhorbitant. I can only hope that they are not deliberately intended to "sock it to" the mobilesport fisherman, but from where I sit one might make a case for this sort of discrimination.

In adaltion, wiile the short term visitor was recoznized in th.. 1902 hike by establishing a lesser fte (of 6:01 in 1968, it is unfortunately umodne triis uluss that a greater monitorină of misconduct is necessary. Their fue WeS not ifested by the 1984 nikes: thus in the three year Deriod their increase huis heen a two folo one so that they are not bearing a comng rable:shire of enforcement personnel costs, whici. In any eri nt has not been commitled In examining the statutory fee setting oriteria which was authorized by the Land and Water Conservation Fund Act (LWCFA), we find that it (lo JSC 4601-6a(d)) specifies that fees shall be fair and equitaole, taking into consideration the direct and indirect costs to the government, benefits to the recipient, the public policy or interest served, the comparable recreation fees charged by non-i'ederal public agencies.The LWCFA (16 USC 4601alol) authorizes special recreation permit fees for "motorized recreation vehicle" uses.

In accordance with each of these criteria we offer the following comment:

a. Pair and equitable

We believe the fue is neither. The cost of a Golden Eagle Passport for free samission to all entrance fee units is 10 and provides access to real property capital inrestments provided by the government as well as to services provided by VPS rersonnel. The vehicle permit fce exceeds the cost of this passrort and only allows access to one unit.AI:S.

The Golden Age Passport is provided free of charge to those who attain age 62 (ana the similar free lifetime admission rerrit for federally recognized disable persons) and provides free admission , these units. The la ter two permits/rassports rrovide a 50% discou?". on recreation use fees for use of major federal investments such as campgrounds which can charge a use pee of as little as $3 rer for group use; often in direct competition with similar facilitie: /services offered by the private sector, which charge fees well in excess of federal use fees. There is no similar discount for senior citizens or digauled trying to live on a flea income in regard to the vehicle fee, which was ļ the cost of the Golden fly passrora 1 counle of years 90 Ind which is now three times its cost.

b. virect, and i:luirect government costs

Trulle have duen no capital investments, direct or inuirect, by the government for the area of mobile sportfishing use. The only cost expense incurred is that necessary for law enforcement for win. a personnel expense would be required even in the absence of any mobile sport fishing activity. There has been no discerngule increase in enforcement activity since inception of rermit fees or any other service or beneficial return to permitees that are funneled back to enhance this particular outdoor recreational program. In addition, members of Assat vague Mobile Snortfishermen gre available to assist the NPS with conservation and volunteer projects in the use area it needed to help minimize an; exrenses.

father, it seems, the fee is nothing more than a raising measure that has now ocen raised to the level that the traffic will bear, even if it will result in denial of access to the shore for those una ule to afford tre cost of access for their sport.

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c. Benefits to the recipient

The permit allows mooile sportfishirg and hunting access to seashore resources. Without it such access would be confined to an extremely limited area thereby severely curtailing "2093 to the majority of resources and eliminating the opportunity to search

iwr and find tl.o fish or the ability to keep up with moving sonools sou would sinilürly deny bunting opportunities. The nermit also Louviuos su oprortunity for some to engage in off roud vehicle criving activity for thut rejrestional purpose only.

ind Dav fte sorves to discourage mobile sport fishermen from avisiling themselves of the ocnefits of seashore fishery resources for tnost last wole to afford it as well as those from afar Who are able to only occasionally travel to the seashore during fear fishing Sessons.

w. Puolio police or interest served

juation of the INS enabling tot specifically requires that loloboting id fishing shall be allowed the permit fulfills that rujuiredcnt in purt by authorizing mobilo sportfishing access to the southern portion of the seashore. In addition, in conjunction with implementing regulstions for the usu it satisfies the requireilic:its of excultivo o racis with regard to URV use. It helps to fulfill ono manautos oi tne Coastal Zone Janageme at det to provide for 'und improve recitational access to the coast; in particular those ruortational activities that are dependent on such access for iillillncnt. 'ilic (ce works to reverso utisotuation of ti.ese ľudicios/intcrusts.

c. Jom puruolu rourtation fees chårdca by non-t'waeral rublic etncies

It nough trac LWTEA authorizes establishment oi usur ices, it dous :. it require iti oven in un colaparaolo non-ftoural or private use all's Art nearuy, nor require tout fuaerul fuos Dc equul.

In revicw of Public Luw 43-303 legislative history. un 0:3 luiter aisuusseu complaints from the non-teatral and private soutors that idoral use ftes were too low and implied that unfair feucral COMDctition caused revenue loss to these parties. In that Sutlaric troci teneral competition was hurting thest derties. Vihure Incro sre no other nearby use areas or a question of loss of revenues from funeral competition there should be no effort to louit use of suoliu resources or create an artificial fee barrier cu such ust.

with regard to other comparaolt neurby non-ftdurgí agency or Trivate mobile sportfisning areas, there are no others in the entire buto of Carylinu. Aris is the only gaine in town for laryland Itinents. The only other Greys on the entire Delmarva Peninsula dre those operutca by the State of Delaware of which tnere are to.due stato Turks i Cape Henlopen, Indian River and benwick Islind wiute Piras). Thu total miles of beach available for mobile sorttisnitie provided by tree State of Delaware excoteas that of sitä oy at least 50ži ana a 30 JAV pernit provides access to all urtus as well us to pyrking sreus ut state parks. The stato rrovides 'sir compressors 96 thu ourks for re-inflation of tires and for the Taiw affiliutu in the state l Delaware Kobile Sportfishermen, they also furnisn picnic tablos 4:14 porta-john sanitary facilities tu accomodati tris affiliatu': unusi (picnic) evolt on the besch.

Non-residento 10.8.from orylend) are churged a Poes double ti.it of ucinis re ruudu sits wils. Ouvivusly disudursges out of state visitors is... wsille tlowwi l'uviliciuy. 'Ciwisa (311:10 5.?.is 3011.0 22-21 miles w..5:lt trou is, wisqe Houlopu!l wit. in 13-1i inilus 'way with Liivi on liver.. SO:10 1:100 riuuliato distiello Uutwuori tric two.

4

None of the three parks have any limit on the number of vehiclos sllowed entry, tinus as is thu case with AINS, no one experiences the frustration of being denied acces to the beach after having traveled many milus auc thu vehicle limit veing reached.

in sum, there are no comparable use Areas in the commut ing region unu even those outsiue the region hare superior provisions, thus there is no comparability.

f. Special recreation permit fees for recreation venicle use

The LV CEA 716 450 4601-6a7o) sp cifies that fees for this use may be set; 11 aous not require it. It is our bellof those the uefinition of recreation vehicle use would identify such use is those forns of recreation that are derived directly and exclusively frim the oneration of the vehicle. There are those whoso 138 of AS980 eague beaches are for the purrose of off-road driving. There is the mobile sport fisherman who derives his recreation from the sport of fishing. The vehicle serves the purpose of proriding 4c0e33 to the beach and the fishery resources in the absence of other practicel access to the beach and the fishery resources, and whico permits transport of food, clotning, tackle, enuinment, bait. 040ch and provides shelter in inclement weather. It aids in and enhances the sport fishing experience and the right of access privilege for hunting ana fishing granted by Section 60 ATIS enabling law. It is therefore our belief that establishment of nermin fees for mobile sportfishermen is not in accordance with she LWCZA unich established the user fee system and which explicitly specifie; (16 3C 4601-68 (a)(4)) that no fees of any kind sh9]l be collected f'rom any rersons who have a right of yccess for huntin; or fishing rrivileges unaer a specific provision of law, in vita ? the lack of other 9lternate means of access to the shore for fishing it to us the fue violates this provision of lan with regrut to mobile sportfishermen's sucess.

In conclusion, the latest fue hike nas become orore:3:{ve and con no lonzor je ignorea. We believe there is no fairness, colity. relationship to government. costs incurred, benefit returned to the recipient, comparability or justificution under rrorisions of low. We therefore request that you order a review is specified under Section (c)(1) of Executive Order 11200 (Establishment of recreation User i'tos).

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I recently learned that your Sub-Committee on Public Lands was studying the issue of recreational user fees. I would appreciate an opportunity to comment on this subject.

Having worked for the U.S. Forest Service back in 1965 when the "first" recreational user fees were first implemented I can speak from some experience. Also being involved with organized recreation for well over 10 years now I can relate to experiences, impressions, and desires of the recreationists who will have to "pay".

Basically the concept of recreational user fees is largely supported by recreationists. Most people realize that nothing is "free". The questions in people's minds relate to equity and uses of the fees collected. The fee charged the recreationist must be equitable. The fellow camping in a tent alongside the road shouldn't pay as much as the fellow with the 40ft. rolling hacienda. Most importantly the fees collected must be ear-marked to be used in the areas and for the purposes that they were collected. The fees paid by outdoor recreationists must be used to further enhance the campgrounds, etc. that they were collected in. No one wants to see their dollars going to a "general fund" that buys pool cues for some nieghborhood rec-hall in downtown DC.

The federal agencies providing for public outdoor recreation need an equitable user fee system. The agencies just don't have adequate funding to provide for this vital need of our society. We need a recreational user fee that "dedicates" the fees collected for enhancement of the facilities and providing for more recreational opportunities. Perhaps one way to provide the facilities needed would be to "lease" certain public recreational sites to commercial developers. Equitable fees could be established and certainly money collected would be turned back into the enterprise to further profits. This would of course require adequate legislation to extend leasing periods beyond the present limitations so that the entrepeneur can find the necessary financing.

I do believe that equitable and manageable recreational user fees can be formulated. With a little understanding of the needs of recreationists, some creative thinking, and a system of dedicated fees there should be little problem in implementing this program.

Sincerely;

StuBeugsen

Stu Bengson
Director, Land-Use
UFWDA

CC: Derrick Crandall, ARC

RESPECT...PROTECT...AND ENJOY: LAND, WATER, MOUNTAINS, AND SUN RESOURCES

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