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HOME arrow BLOG arrow Disappearing Senior and Disable Discounts
Disappearing Senior and Disable Discounts
Written by Scott Silver   
Saturday, 23 January 2010

The following is a coverletter recently sent to the US Forest Service. It is Wild Wilderness' response to proposed rule changes that relate to public land concessionaires, the National Parks and Federal Lands Pass, senior discounts, discounts for the disabled and the  prevarication of management control of publicly owned recreation sites and facilities. Additional information is available from Western Slope NoFee Coalition.

The full comments of Wild Wilderness are available here.

To:     Carolyn Holbrook (Recreation and Heritage Resources Staff)
cc:     T. Tidwell, J. Holtrop, H. Kashdan, J. Bedwell

Dear Ms. Holbrook:

Wild Wilderness is a 501(c)(3) non-profit organization founded in 1991. We are located in Bend Oregon and have supporters in each of the 50 states. Our focus is outdoor recreation and public lands.

We are troubled by the direction the FS seeks to take with the proposed rule changes published in the Federal Register on December 1, 2009: "Proposed Directives for Forest Service Concession Campground Special Use Permits" (RIN 0596-AC91).

Our extensive comments are appended in PDF format. We ask that they be entered in the public record and request that your receipt of these comments be acknowledged via e-mail.

We appreciate that you, Ms. Holbrook,  will carefully review the complete comment document. For the benefit of the Chief and others copied on this message I summarize here our key contentions.

It is the contention of Wild Wilderness that the proposed rule change is part and parcel of the commercialization and privatization of outdoor recreation that began with Chief F. Dale Robertson.

It is the contention of Wild Wilderness that at least portions of the proposed rule change are clearly illegal.

It is the contention of Wild Wilderness that the proposed rule change results from closed door meetings between the US Forest Service and various special interest organizations.

It is the contention of Wild Wilderness that the proposed rule change is a direct response to concessionaires whom the US Forest Service looks upon as "partners" and whose profitability the USFS seeks to increase.

It is the contention of Wild Wilderness that the Forest Service has greater allegiance to its partners than to the citizens of the United States of America and that when asked to choose between those competing interests as it has done with the proposed rule change, the Forest Services has chosen in favor of its commercial partners.

And finally, it is the contention of Wild Wilderness that the most important aspect of the proposed rule change is not the most obvious portion of the rule change. While we anticipate that the proposed changes to senior and disabled discounts will be the focus of most public comment, we believe that the proposed change regarding Standard Amenity Recreation Fees is vastly and profoundly more important. It is, in our estimation, so much more important that we might even speculate that this change was bundled with the senior and disabled discount issue so that it would effectively go unnoticed. We suggest that the most flagrantly illegal portions of the proposed rule change are associated with those provisions which deal with the charging of SARFs by concessionaires and with those provisions which permit concessionaires to NOT accept recreation passes legally authorized by the Federal Lands Recreation Enhancement Act (REA), as signed into law on December 8, 2004.

Thank you for giving our full comments careful consideration. I look forward to receiving confirmation that they have been entered into the record. We sincerely hope the FS will take no action prohibited by law or which is not in the public's best interest.


Scott Silver
Executive Director


Comments (1) >>

cj blaney said:

  It's time to write, call, picket,and march or just sit home and wonder what the hell happened. i do not want the corporations taking over control of our lands. i am alarmed and will continue to work through the various organizations to which i belong to stop this insidius trend. cj blaney.
January 25, 2010
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