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Online CUA System for Road-based Commercial Tours
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Proposed Changes to Road-based Commercial Tour Requirements and Fees
The National Park Service (NPS) is seeking comments on its proposal to standardize commercial use authorization (CUA) requirements and CUA fees for road-based commercial tour operators, including moving the CUA application and reporting process to an online system.
BACKGROUND
In Fall 2017, the NPS proposed to standardize its CUA requirements for road-based commercial tours (RBCTs) in response to feedback from the commercial tour industry. A number of RBCT providers frequently operate in more than one park unit and expressed frustration over inconsistencies at the park level within the NPS CUA program. At that time and to this day, RBCT operators must comply with park specific CUA application requirements, processes, and fees, which has led to operator confusion. Additionally, many parks that needed to manage RBCT operations did not have RBCT operators under any permitting authorization.
The 2017 proposal consisted of a $300 RBCT CUA application fee per park and a $5 per person RBCT CUA management fee to cover ongoing management costs. The NPS provided an opportunity for public comment on the proposal through the NPS Planning, Environment and Public Comment (PEPC) website. The NPS considered comments received and revised its proposal to incorporate the development of an online system to simplify and standardize the RBCT CUA application and reporting process.
Due in part to the COVID-19 pandemic, the NPS paused the development of the RBCT CUA application and reporting system and the implementation of standard RBCT CUA requirements and fees on May 28, 2020. This pause prohibited parks from issuing RBCT CUAs unless the park had historically issued RBCT CUAs. Parks that did historically issue RBCT CUAs were prohibited from changing historic RBCT CUA fees.
PLAN
The NPS is restarting its effort to improve consistency and processes by standardizing RBCT CUA requirements, implementing an agency wide RBCT CUA fee structure, and launching an online CUA system for RBCT CUAs. The proposed plan will go into effect for RBCT operators that apply for a CUA to operate in 2025 in parks that have historically issued RBCT CUAs and were not affected by the 2020 pause. For RBCT operators that apply for a CUA to operate in 2026 and beyond, the NPS will standardize the CUA requirements, process, and fees across all NPS units that need to manage RBCT operations.
WHAT TO KNOW FOR 2025
Application Process
The NPS will modify the existing CUA application and reporting system to accept RBCT CUA applications. RBCT operators that plan to operate in 2025 in parks that have historically issued RBCT CUAs will apply for a RBCT CUA via this online CUA system.
While RBCT operators will apply separately for each park in which they need a CUA, the online system will streamline the application process by creating a user profile for applicants. Applicants will not need to reenter business information or upload required documentation each time they apply for a RBCT CUA because the user profile will securely store that information and incorporate it into each application. Once an applicant has received one or more RBCT CUAs, they are able to login to the system using their secure user profile to submit the annual CUA report required for each CUA.
The system will feature user guides for RBCT CUA applicants and holders, demonstration videos, and FAQs so applicants are fully prepared to use the system successfully.
RBCT CUA Fees
Existing RBCT CUA fees will not change for the 2025. Operators should note RBCT CUA fees may be different across individual parks.
WHAT TO KNOW FOR 2026 AND BEYOND
Application Process
RBCT operators that plan to operate in 2026 and beyond will apply for RBCT CUAs using the online system in all NPS units. The online system will list which parks require a RBCT CUA and RBCT operators are responsible for checking the system and securing CUAs for those parks.
Responsible Entity
The NPS understands the business model for RBCT operators can make it difficult to determine which entity is responsible for securing the CUA. Ultimately, the business entity who assumes the responsibility and liability of the clients travelling in the park is responsible.
This entity is most commonly the tour company who accompanies paying clients to the NPS unit(s). It may also be the tour packager who develops and packages the RBCT and sells the RBCT to a third-party (e.g., international tour operator), but does not accompany the clients to the NPS unit(s). In this case, the RBCT CUA conditions require the CUA holder (the tour packager) to assume responsibility for the third-party while that third-party is operating in the NPS unit(s) under the RBCT CUA.
Motorcoach operators who are providing chartered transportation services only are not required to apply for and secure a RBCT CUA, as it is the responsibility of the tour provider to obtain the RBCT CUA. RBCT CUAs provide for the use of owned, rented, leased, or chartered motorcoaches. In some cases, however, parks may require motorcoach operators providing transportation services only and not working under a tour provider's RBCT CUA, to secure a Transportation CUA. in order to avoid unacceptable impacts resulting from the motorcoach operations. Parks will not require a RBCT CUA and a Transportation CUA for a single trip. However, if a single operator is providing transportation and RBCT services on different trips, they may be required to have both a Transportation CUA and a RBCT CUA.
Insurance Requirements
RBCT CUA holders must have a commercial general liability insurance policy in the amount of $500,000 per occurrence, at a minimum, and must provide proof of insurance upon application submission through the online CUA system. The general commercial liability insurance policy must list the United States of America or National Park Service as additional insured. Applicable commercial automobile insurance, as required by the Department of Transportation, is also required for all RBCT operations. RBCT applicants must provide proof of commercial automobile insurance coverage upon application submission for owned tour vehicles.
The NPS understands that requiring proof of commercial auto insurance for tour vehicles at the time of application submission is difficult when those vehicles are leased or rented or chartered. Accordingly, the NPS has built into the online CUA system the functionality necessary to accommodate such arrangement.
When a RBCT CUA applicant indicates they will use leased or rented vehicles, the online CUA application and reporting system only requires the applicant provide vehicle size because the NPS understands that an applicant may not know additional vehicle information at the time of application. The application conditions, however, include the following language to which an applicant must agree:
If the CUA applicant or holder will use rented or leased vehicles in performance of the authorized service, the applicant or holder must secure appropriate insurance for that rented or leased vehicle in the amount required by the CUA application. If proof of insurance secured directly from the rental or lease company is not available upon application submission, applicants must provide proof of insurance coverage after application submission upon NPS request.
If the CUA applicant or holder will use the services of a chartered transportation company, the CUA conditions require the applicant to ensure the chartered transportation company meets the Federal and State commercial vehicle insurance requirements but does not require proof of this insurance at any time.
RBCT CUA Fees
The NPS will standardize the RBCT CUA application fee for applications received to operate in 2026 and beyond. A $350 CUA application fee will be due to each park in which a RBCT operator desires to conduct business. A reduced application fee of $250 will be charged for subsequent applications received in the same park for the same CUA season for other types of services. The NPS recognizes that some RBCT companies provide other types of services in parks that are not incidental to the road-based travel and the discounted application fee will be applied to those other services. The NPS will periodically review the application fee to ensure cost recovery collection and reserves the right to adjust these fees in the future.
PUBLIC COMMENT PERIOD
The NPS is interested in receiving public comments on the functionality of the online CUA system for RBCT CUA operators. Suggestions on system needs from the CUA applicant and CUA holder perspective will be considered and may be used to further improve the online system before or after implementation. The NPS is also interested in public comments related to standard CUA requirements and CUA fees for RBCT operators.
To review plan details and provide comments, use the "Open for Comment" link in the left side navigation menu. Review the linked videos demonstrating system functionality, the frequently asked questions and plan overview, and use the "Comment Now" button. The public comment period will run from June 27, 2024, through August 10, 2024. To submit written comments, mail comments to: National Park Service, NPS Commercial Services, 1849 C Street, NW, Mail Stop: 2225 Washington, DC 20240.
The National Park Service (NPS) is seeking comments on its proposal to standardize commercial use authorization (CUA) requirements and CUA fees for road-based commercial tour operators, including moving the CUA application and reporting process to an online system.
BACKGROUND
In Fall 2017, the NPS proposed to standardize its CUA requirements for road-based commercial tours (RBCTs) in response to feedback from the commercial tour industry. A number of RBCT providers frequently operate in more than one park unit and expressed frustration over inconsistencies at the park level within the NPS CUA program. At that time and to this day, RBCT operators must comply with park specific CUA application requirements, processes, and fees, which has led to operator confusion. Additionally, many parks that needed to manage RBCT operations did not have RBCT operators under any permitting authorization.
The 2017 proposal consisted of a $300 RBCT CUA application fee per park and a $5 per person RBCT CUA management fee to cover ongoing management costs. The NPS provided an opportunity for public comment on the proposal through the NPS Planning, Environment and Public Comment (PEPC) website. The NPS considered comments received and revised its proposal to incorporate the development of an online system to simplify and standardize the RBCT CUA application and reporting process.
Due in part to the COVID-19 pandemic, the NPS paused the development of the RBCT CUA application and reporting system and the implementation of standard RBCT CUA requirements and fees on May 28, 2020. This pause prohibited parks from issuing RBCT CUAs unless the park had historically issued RBCT CUAs. Parks that did historically issue RBCT CUAs were prohibited from changing historic RBCT CUA fees.
PLAN
The NPS is restarting its effort to improve consistency and processes by standardizing RBCT CUA requirements, implementing an agency wide RBCT CUA fee structure, and launching an online CUA system for RBCT CUAs. The proposed plan will go into effect for RBCT operators that apply for a CUA to operate in 2025 in parks that have historically issued RBCT CUAs and were not affected by the 2020 pause. For RBCT operators that apply for a CUA to operate in 2026 and beyond, the NPS will standardize the CUA requirements, process, and fees across all NPS units that need to manage RBCT operations.
WHAT TO KNOW FOR 2025
Application Process
The NPS will modify the existing CUA application and reporting system to accept RBCT CUA applications. RBCT operators that plan to operate in 2025 in parks that have historically issued RBCT CUAs will apply for a RBCT CUA via this online CUA system.
While RBCT operators will apply separately for each park in which they need a CUA, the online system will streamline the application process by creating a user profile for applicants. Applicants will not need to reenter business information or upload required documentation each time they apply for a RBCT CUA because the user profile will securely store that information and incorporate it into each application. Once an applicant has received one or more RBCT CUAs, they are able to login to the system using their secure user profile to submit the annual CUA report required for each CUA.
The system will feature user guides for RBCT CUA applicants and holders, demonstration videos, and FAQs so applicants are fully prepared to use the system successfully.
RBCT CUA Fees
Existing RBCT CUA fees will not change for the 2025. Operators should note RBCT CUA fees may be different across individual parks.
WHAT TO KNOW FOR 2026 AND BEYOND
Application Process
RBCT operators that plan to operate in 2026 and beyond will apply for RBCT CUAs using the online system in all NPS units. The online system will list which parks require a RBCT CUA and RBCT operators are responsible for checking the system and securing CUAs for those parks.
Responsible Entity
The NPS understands the business model for RBCT operators can make it difficult to determine which entity is responsible for securing the CUA. Ultimately, the business entity who assumes the responsibility and liability of the clients travelling in the park is responsible.
This entity is most commonly the tour company who accompanies paying clients to the NPS unit(s). It may also be the tour packager who develops and packages the RBCT and sells the RBCT to a third-party (e.g., international tour operator), but does not accompany the clients to the NPS unit(s). In this case, the RBCT CUA conditions require the CUA holder (the tour packager) to assume responsibility for the third-party while that third-party is operating in the NPS unit(s) under the RBCT CUA.
Motorcoach operators who are providing chartered transportation services only are not required to apply for and secure a RBCT CUA, as it is the responsibility of the tour provider to obtain the RBCT CUA. RBCT CUAs provide for the use of owned, rented, leased, or chartered motorcoaches. In some cases, however, parks may require motorcoach operators providing transportation services only and not working under a tour provider's RBCT CUA, to secure a Transportation CUA. in order to avoid unacceptable impacts resulting from the motorcoach operations. Parks will not require a RBCT CUA and a Transportation CUA for a single trip. However, if a single operator is providing transportation and RBCT services on different trips, they may be required to have both a Transportation CUA and a RBCT CUA.
Insurance Requirements
RBCT CUA holders must have a commercial general liability insurance policy in the amount of $500,000 per occurrence, at a minimum, and must provide proof of insurance upon application submission through the online CUA system. The general commercial liability insurance policy must list the United States of America or National Park Service as additional insured. Applicable commercial automobile insurance, as required by the Department of Transportation, is also required for all RBCT operations. RBCT applicants must provide proof of commercial automobile insurance coverage upon application submission for owned tour vehicles.
The NPS understands that requiring proof of commercial auto insurance for tour vehicles at the time of application submission is difficult when those vehicles are leased or rented or chartered. Accordingly, the NPS has built into the online CUA system the functionality necessary to accommodate such arrangement.
When a RBCT CUA applicant indicates they will use leased or rented vehicles, the online CUA application and reporting system only requires the applicant provide vehicle size because the NPS understands that an applicant may not know additional vehicle information at the time of application. The application conditions, however, include the following language to which an applicant must agree:
If the CUA applicant or holder will use rented or leased vehicles in performance of the authorized service, the applicant or holder must secure appropriate insurance for that rented or leased vehicle in the amount required by the CUA application. If proof of insurance secured directly from the rental or lease company is not available upon application submission, applicants must provide proof of insurance coverage after application submission upon NPS request.
If the CUA applicant or holder will use the services of a chartered transportation company, the CUA conditions require the applicant to ensure the chartered transportation company meets the Federal and State commercial vehicle insurance requirements but does not require proof of this insurance at any time.
RBCT CUA Fees
The NPS will standardize the RBCT CUA application fee for applications received to operate in 2026 and beyond. A $350 CUA application fee will be due to each park in which a RBCT operator desires to conduct business. A reduced application fee of $250 will be charged for subsequent applications received in the same park for the same CUA season for other types of services. The NPS recognizes that some RBCT companies provide other types of services in parks that are not incidental to the road-based travel and the discounted application fee will be applied to those other services. The NPS will periodically review the application fee to ensure cost recovery collection and reserves the right to adjust these fees in the future.
PUBLIC COMMENT PERIOD
The NPS is interested in receiving public comments on the functionality of the online CUA system for RBCT CUA operators. Suggestions on system needs from the CUA applicant and CUA holder perspective will be considered and may be used to further improve the online system before or after implementation. The NPS is also interested in public comments related to standard CUA requirements and CUA fees for RBCT operators.
To review plan details and provide comments, use the "Open for Comment" link in the left side navigation menu. Review the linked videos demonstrating system functionality, the frequently asked questions and plan overview, and use the "Comment Now" button. The public comment period will run from June 27, 2024, through August 10, 2024. To submit written comments, mail comments to: National Park Service, NPS Commercial Services, 1849 C Street, NW, Mail Stop: 2225 Washington, DC 20240.