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HOME  BLOG Disappearing Senior and Disable Discounts
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Disappearing Senior and Disable Discounts |
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Written by Scott Silver
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Saturday, 23 January 2010 |
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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.
Sincerely,
Scott Silver
Executive Director
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