Comments on "Recreational Renaissance Plan B"

First, the proposed codified Rule changes are not in OCR machine readable format, they are an image file, and therefore cannot be cut-and-pasted to comment and work with. The files can just as easily be posted online as OCR files by DLNR in the future.

My comments in bold follow the italicized quotes in order from the following document:

http://hawaii.gov/dlnr/recreate/planb/RR-PLAN-B-FACT-SHEET

RECREATIONAL RENAISSANCE “PLAN B”
*** BACK TO BASICS ***

...We have to take action now, and not just wait. Otherwise, we will lose some of these important places forever.

We don't have to take action now. These places will not be lost forever. Koke'e and Kalalau will still be there. They will be there longer than us. We can take a few more months to wait for the Koke'e Advisory Council recommendations instead of the raised camping and admission fees.

...to support debt service on capital improvements in State parks, harbors, hiking trails, boat ramps, and piers.

...We trust the legislature will support our progress and grant the bond authority next year...

You all may or may not be aware, but last month Hawaii tried to sell over $655 million and possibly as much as $800 million in General Obligation Bonds and there were no takers on that issue. The State was not able to sell those bonds because the yield and terms were not high enough for the perceived performance risk of the State. I don't think you all understand that bonds for park operating expenses in this environment are just not realistic. This is partly why the Recreational Renaissance bonding authority the first time around was not granted by the Legislature, because that would have been competing with the State's General Obligation bonds in the market, which the State is having a hard enough time selling. Beyond that, bonds are suppose to be for capital improvements, not operating expenses.

...If you subtract the four lifeguard contracts and utilities, that leaves about $93,000 per park per year for all operational costs in fiscal year 2009. With today‟s budget and restrictions, we're down to about $70,000 per park per year for operations.

...If we are successful in raising $4 million total through fees and other means, then parks will have approximately $127,000 per park per year, with the entire sum of the increase going to repair and maintenance and improved operations at parks statewide.

This is a worthless statistic. There is no point in calculating an average "per park per year" dollar figure for fees collected. The size of the State Parks varies greatly. Only a few of them are large State Parks and they cannot be accurately compared to much smaller roadside parks. Furthermore, there is no usefulness in comparing a "per park per year" figure for the State Parks to a "per park per year" figure for the few much larger National Parks in Hawaii. That whole comparison is wasted calculations and serves no useful purpose but to possibly mislead.

...Parks will begin with parking fees for tourists only at $5 per car, walk-ins remaining free. The parking fee can be collected through an automated system that differentiates tourists from resident and is low-cost to operate. Footnote - 1 Entry fees are the same as proposed in Recreational Renaissance - $1 walk-in; $5 car...

First you say no charge for walk-ins and then the footnote says $1 for walk-ins. It should be NO charge for walk-ins. Further, you say "will begin" with $5 per car for tourists. At a minimum, it should stay that way, $5 per car for tourists and NO charge per car for kama'aina, ever. If you imply one thing, then you should remain consistent on it.

...In addition, Parks will charge modest fee increases at campgrounds and cabins, mainly by starting a split fee system with slightly higher fees for non-residents.

I noticed that in all of the documentation for today and in the proposed new rule changes, you do not mention the fee increases that the BLNR already approved on August 14, 2009. That includes overnight camping permit fees from $10 to $12 for residents and from $10 to $18 for visitors. I think a lot of the residents in the audience today are not aware of this. These are hefty camping fees. If these raised camping fees are to stay, then the BLNR should also offer an annual Kama'aina Camping Permit for something like $50. Also, if DLNR is going to collect these kinds of camping fees, then they should at least see to it that trash is kept picked up and facilities are properly maintained at the camping grounds. In the case of Kalalau, that has not been done, and the visitors are rightly complaining that they feel the current $10 per night that they pay is not being used to properly maintain the Park that they are using. If the BLNR is going to almost double the visitor camping fee, then they need to make sure trash is picked up and the campgrounds are maintained regularly. Kalalau went all last winter without trash being picked up.

...All revenue generated in Parks will stay in fixing up Parks. All revenues generated by the Na Ala Hele Trail system will stay in fixing up trails.

This is misleading. Everybody on Kaua'i knows the BLNR intends to take fees collected from Kaua'i's two large State Parks and trails and use them for Parks and trails on other islands.

...Pilot asset management system at 1 Park, 1 Harbor, 1 Trail.

The DLNR Chairperson says part of the problem is that they don't have an accounting system that indicates which park that fees were collected for and don't have expenses broken down to each park. If that is the case, then I propose for this "Pilot asset management system" that the first Park it's used on be Koke'e and that the funds collected from that stay on Kaua'i, and that the first Trail it's used on be Kalalau and that the funds collected from that stay on Kaua'i.

...The goals of Plan “B” dedicate 100% of new revenues to improved repair, maintenance, and operations in the interim. We‟ll also start the longer-term process of raising new revenues from vacant lands so we can do more capital improvements faster...

All I can say is that developing these vacant lands looks like one big open-ended money making effort that may not really benefit DLNR or the State as opposed to preferred private interests.

One last point, if BLNR/DLNR has the patience to wait for the Legislature to act upon Koke'e Advisory Council recommendations, the idea of a modest fee on rental cars to go to a Special Fund for State Parks is a good one that can reasonably raise the necessary funds. By my own calculations a 50 cent fee per day per rental car statewide could raise $11 million dollars per year. The Koke'e Advisory Council conservatively calculates that a 50 cent fee per day per rental car statewide would raise $8 million per year, or that a $1 fee per day per rental car would raise $16 million dollars per year. That solves the State Parks revenue problem and justifiably allows the funds to be spent proportionately on each Park however the BLNR sees fit. So what's the rush?