As we head into 2014 some of the major regulatory issues we expect to
address are listed below.
Some of the big issues are:
- The Coast Guard has funded "safety partners" who appoint
"subject matter experts" to develop a series of boating and paddlesports safety
standards. Paddlesports education and skills standards for entry level
paddlesports are the first step. The outfitting industry needs to be involved
as these standards move forward to ensure that the quest for "safety" does not
prohibit the public from participating in adventure sports. Here is an excerpt
from the briefing which will given at the AOA conference by the consultant
coordinating the new paddling skill standards:
comprehensive System of Standards that can be recognized by the USCG as key
components of boater education programs nationwide would involve national
consensus-?driven development of the People, Process and Press
(environment) standards to complement the Product (skills) standards being
generated by the current work. Hopefully, long-? term work will also
continue on the development (refinement) and integration of
performance-?based standards for beginner, intermediate and advanced
skills across the domains of POWER,SAIL and HUMAN recreational boat
- Amendments to Forest Service and BLM Cost Recovery
regulations. Agencies with tight budgets are expected to ramp up their
efforts to cover the cost of NEPA analyses and other documentation related to
issuance of permits. We need to modify the cost recovery regulation to ensure
that permit issuance is streamlined and not a threat to the business and
organizations who depend upon them.
- The Federal Lands Recreation Enhancement Act. The authority for
issuing outfitter and guide permits in National Forests and on BLM lands
expires in 2015. It has to be reauthorized before then to give the agencies
authority to issue longer term permits and to make sure the fees collected are
used to support permit administration.
- Continue our efforts to make NPS Insurance requirements
reasonable. We are making progress on this issue, but there is more work
to begun. A big step will occur at the AOA conference in December.
- Work with a coalition to implement a Save Americas Trails
Campaign. The Forest Service trails budget is $81 million. 30% stays in
Washington and the regions take another cut. So too little of it gets to the
ground. We need a comprehensive campaign to include redirecting this funding
and a portion of agency amenity fees to provide credits to outfitters and
others for the work they do to keep trails open.
- Amend FMCSA regulatory authority. As one outfitter just
learned from the $11,900 civil fine levied against him for 48 record keeping
violations and a few other unmet regulations, which he was unaware of,
compliance with the FMCSA regs if you cross state lines in a commercial motor
vehicle is mandatory. We fully understand the need for regulation and
inspection of commercial motor carriers. However, if you pass a state
inspection, federal inspectors will still spend days in your business looking
for violations and may shut you down without proper operating authority, as too
many outfitters have discovered. We would like to see some amendments to this
regulatory authority to give operators the opportunity to correct oversights
for minor infractions like papework violations before draconian fines are
levied and for Congress to consider allowing state's which adopt federal
standards to be the inspection authority instead of having to submit to
duplicative state and federal inspections.
Our work on these issues is not the only benefit of AOA membership. We
are working on more benefits to lower your operating costs, improve the quality
of your staff, reduce your exposure to loss, and grow your revenues.
If you have comments on these or other issues, we'd appreciate your
feedback. Email David Brown at firstname.lastname@example.org.