January
22, 2007
Jerry R. Seaver
Chairman Imperial Sand Dunes
Recreation Area
Technical Review Team
2950 W State Ave
Phoenix, AZ 85051
Dear Mr. Seaver:
The
Imperial Sand Dunes Recreation Area (ISDRA) Technical Review Team (TRT) was
originally established to ensure public involvement in the management of the
"Fee Demo" program. The TRT currently provides citizen input in the
collection process administered by the Bureau of Land Management (BLM) under the
terms of the Federal Lands Recreation Enhancement Act (FLREA).
BLM has elected to outsource fee
collection from the very beginning: initially under an agreement with Central
Parking and more recently with the Imperial County Sheriff's Office (ICSO). The
current agreement with the ICSO includes provision for the enforcement of fee
compliance. The TRT was consulted by the BLM during the development and
administration of the fee collection and compliance agreements.
While fee compliance has improved during the 2006-07
season, compliance continues to be below levels required to properly fund ISDRA
operations. The TRT has encouraged BLM to take reasonable measures to improve
compliance, however, the results fall far short of what is needed. Continued
recommendations are mostly ignored. The BLM El Centro field office rationalizes
the poor performance by deferring fault to the outsource contractors.
From the very beginning, the BLM
has not fulfilled its fee collection management responsibilities. This
mismanagement is particularly appalling because BLM has chosen to reduce
emergency medical and law enforcement services due to the lack of funding rather
than to hold Central Parking and the ICSO accountable.
It is incumbent upon the TRT to
identify the deficiencies and communicate the concerns of the ISDRA visitors to
the BLM. A review of the BLM responsibility set forth in the fee collection
legislation enabling the Cooperative Agreement between BLM and ICSO clearly
places the ultimate responsibility for fee collection and compliance with BLM.
During this era of limited federal appropriation, it is critically important
that the provisions of FLREA be
fully and effectively administered.
The fee collection program
provides the largest single source of funding for the ISDRA. The current
contractual arrangement with the ICSO provides Imperial County an opportunity to
share in this revenue stream. Based on current ISDRA visitation estimates, the
fee collection could provide as much as $6,000,000 annually. Under the present
agreement with ICSO, the Imperial County could receive $1,800,000. Based on our
forecast of fee compliance, the 2006-07 collection will total about $4,000,000.
One must question why the agencies are willing to settle for two thirds of what
could be produced from an efficiently administered permit program.
At
the request of ASA Board of Directors, Board
member Brian Crain conducted a comprehensive analysis of the cooperative
agreement between the BLM and the ICSO. His report, accepted by the Board,
conveys the concerns of the ASA. It is enclosed with this letter.
Based on the foregoing concerns
the ASA Board of Directors respectfully requests that the TRT conduct an intense
review of the fee collection process. The ASA Board suggests that this review
consider and address the following inquiries and concerns:
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Please
provide a summary of fee collections broken down by months: particularly
during the past two riding seasons (2005-06 and 2006-07).
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What
is the associated level of compliance represented in terms of percent of
ISDRA visitors required to purchase permits?
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What
is the number of fee non-compliance citations issued per riding season?
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Please
summarize permit sales by authorized vendors broken out by seasons.
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Paragraph
I. B. on page 1 of the BLM ICSO Cooperative Agreement calls for the
development and implementation of a Marketing Plan. Has the BLM provided the
TRT visibility of this Plan? If so, please make the plan available.
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Has
the TRT been provided the report required in paragraph III A. 3. on page 4
of the Cooperative Agreement? If so, please make the
report available.
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When
will the fee collection machines be in service?
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Request
the BLM to initiate the suggested review under the terms of paragraph III.
C. 15. b. on page 8 of the Cooperative Agreement.
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The ASA desires to
be a part of the solution rather than to participate in a finger-pointing
exercise designed to lay blame for past failures. The ASA makes this request to
improve fee compliance and to increase the funding available to assure a quality
recreation experience at the ISDRA.
ASA representatives will attend
the January 30, 2007 TRT meeting to discuss and reinforce the concerns in this
letter.
Respectfully yours,
Bob Mason
Chairman
ASA Board of Directors
Direct dial: 602 818
1748
E-Mail: RwmSkm@cox.net
Encl: ASA Review of the
Cooperative Agreement between BLM and ICSO
cc: Via E-Mail
Steven Borchard, BLM Manager, California Desert District
Vicki Wood, BLM Manager, El Centro
Field Office
Sheriff Loera, Imperial County
Sheriff
Sharon Housouer, Imperial County
Under sheriff
Steve Gutierrez, Imperial County
Chief Deputy
Victor Carrillo, Chairman Imperial
County Board of Supervisors
Wally Leimguber, Imperial County
Board of Supervisors District 5
