The International Inbound Travel Association (IITA) represents tour operators who provide services to America's key international visitor markets, handling the key international trade aspect of our national parks.
As the National Park Service (NPS) is seeking public comments on its proposal to standardize commercial use authorization (CUA) requirements for road-based commercial tours (RBCT), including moving the CUA application and reporting process to an online system for 2025 and a systemwide CUA requirement in 2026, IITA respectfully submits the following comments for consideration.
First, on behalf of IITA’s Board of Directors and members, we want to thank the National Park Service for working closely with IITA and allied associations on the plan for RBCT CUAs, since the previously proposed plan was put on hold in 2020. Your effort to better understand how the travel and tourism industry works, particularly group tours and tour operators, has proven to be time well spent.
We also applaud the development of the new centralized, online CUA application and reporting system, which will streamline tour operators’ administrative time in applying for CUAs at multiple parks, year after year.
Proposed 2026 Fee Structure
On behalf of its 50 international inbound tour operator members and Board of Directors, IITA opposes the proposed standardized fee of $350 per park in 2026 for RBCT CUA applications and requests that the National Park Service provide a tiered rate structure that not only lessens the impact of the significant cost increase to tour operators, but actually incentivizes them to add more parks to spread out visitation and reduce pressure on the most popular parks.
As a flat rate for each park, the fee is exorbitant and will create a number of unintended consequences for tour operators, particularly smaller companies, as well as the national parks.
One such consequence is that the steep fee for each park will discourage inclusion of new park destinations in tour packages as tour operators avoid additional costs. A typical group tour of the west, for example, visits at least five national parks, which would cost $1,750 in CUA fees alone, resulting in a significant per-person cost increase. It particularly impacts smaller tour operators that don’t have a volume of tours to the parks, making it impossible for them to compete with larger companies that can amortize the fees across many more tours.
Effectively dispersing visitors from overcrowded areas is not only a goal of the industry but also of the National Park Service and the National Travel and Tourism Office’s National Travel and Tourism Strategy. The result of less usage of those smaller, lesser-known parks (which need visitor revenue) and increased usage of the most popular and crowded parks flies in the face of the national strategies.
Tour operators can help manage the visitation with the right rate structure.
International visitors choose their tours based on the inclusion of the iconic parks they are most familiar with, however, inbound tour operators can control their groups’ movements to spend less time in those parks and more time in those that are less crowded, supporting the national goals and improving the visitor experience.
In discussions with NPS for the past year, leaders of the tour and motorcoach industry have proposed a pricing strategy that would provide rate reductions based on the number of RBCT CUAs tour operators need. If incentivized by a tiered rate structure, tour operators would be more likely to add additional parks to their itineraries.
In Conclusion
As facilitators of both independent and group travel, IITA tour operators have control over a large percentage of visitation to the parks. Inbound tour operators have the power to adjust programming in ways that will distribute visitors to less-crowded times/seasons and to lesser-known parks in the system to alleviate some of the pressure on America’s most visited attractions.
IITA and its members stand ready to assist the NPS in developing a practical fee structure to address the overcrowding and traffic congestion issues. Together we can enhance the experiences for travelers while preserving our nation’s greatest treasures.
Looking to the Future
Related issues that must be considered in alignment with the RBCT CUA permit are timing of CUA applications, reporting requirements, timed-entry reservations, and the entrance fee structure. IITA understands these to be issues for future discussions and offers the following thoughts.
- Timing for CUA applications has historically been within a certain timeframe, e.g., opening three months in advance and closing by the start of the season, which is ineffective for tour operators. CUA applications should be submittable year-round to allow operators to secure them farther in advance for early bookings and within the season for late bookings.
- Management reporting and fee for commercial tour operators must be reviewed to 1) avoid undue administrative burdens on tour operators by requiring end-of-year reporting, which may be duplicative or inaccurate, and 2) avoid additional costs at a time when commercial tour operators will be adjusting to the system-wide requirements for CUA fees.
- Entrance fee increases should be carefully considered, again, to avoid adding costs to tours that make them significantly more expensive to the tour traveler. Appropriate spacing of fee increases will allow the market to adjust more smoothly to price adjustments.
- Timed entry reservation systems for commercial tour operators are impractical and could be extremely burdensome for the motorcoach, tour, and travel industries as well as park entrance staff.
IITA Comments on RBCT CUA Plan for 2025 and 2026
The International Inbound Travel Association (IITA) represents tour operators who provide services to America's key international visitor markets, handling the key international trade aspect of our national parks.
As the National Park Service (NPS) is seeking public comments on its proposal to standardize commercial use authorization (CUA) requirements for road-based commercial tours (RBCT), including moving the CUA application and reporting process to an online system for 2025 and a systemwide CUA requirement in 2026, IITA respectfully submits the following comments for consideration.
First, on behalf of IITA’s Board of Directors and members, we want to thank the National Park Service for working closely with IITA and allied associations on the plan for RBCT CUAs, since the previously proposed plan was put on hold in 2020. Your effort to better understand how the travel and tourism industry works, particularly group tours and tour operators, has proven to be time well spent.
We also applaud the development of the new centralized, online CUA application and reporting system, which will streamline tour operators’ administrative time in applying for CUAs at multiple parks, year after year.
Proposed 2026 Fee Structure
On behalf of its 50 international inbound tour operator members and Board of Directors, IITA opposes the proposed standardized fee of $350 per park in 2026 for RBCT CUA applications and requests that the National Park Service provide a tiered rate structure that not only lessens the impact of the significant cost increase to tour operators, but actually incentivizes them to add more parks to spread out visitation and reduce pressure on the most popular parks.
As a flat rate for each park, the fee is exorbitant and will create a number of unintended consequences for tour operators, particularly smaller companies, as well as the national parks.
One such consequence is that the steep fee for each park will discourage inclusion of new park destinations in tour packages as tour operators avoid additional costs. A typical group tour of the west, for example, visits at least five national parks, which would cost $1,750 in CUA fees alone, resulting in a significant per-person cost increase. It particularly impacts smaller tour operators that don’t have a volume of tours to the parks, making it impossible for them to compete with larger companies that can amortize the fees across many more tours.
Effectively dispersing visitors from overcrowded areas is not only a goal of the industry but also of the National Park Service and the National Travel and Tourism Office’s National Travel and Tourism Strategy. The result of less usage of those smaller, lesser-known parks (which need visitor revenue) and increased usage of the most popular and crowded parks flies in the face of the national strategies.
Tour operators can help manage the visitation with the right rate structure.
International visitors choose their tours based on the inclusion of the iconic parks they are most familiar with, however, inbound tour operators can control their groups’ movements to spend less time in those parks and more time in those that are less crowded, supporting the national goals and improving the visitor experience.
In discussions with NPS for the past year, leaders of the tour and motorcoach industry have proposed a pricing strategy that would provide rate reductions based on the number of RBCT CUAs tour operators need. If incentivized by a tiered rate structure, tour operators would be more likely to add additional parks to their itineraries.
In Conclusion
As facilitators of both independent and group travel, IITA tour operators have control over a large percentage of visitation to the parks. Inbound tour operators have the power to adjust programming in ways that will distribute visitors to less-crowded times/seasons and to lesser-known parks in the system to alleviate some of the pressure on America’s most visited attractions.
IITA and its members stand ready to assist the NPS in developing a practical fee structure to address the overcrowding and traffic congestion issues. Together we can enhance the experiences for travelers while preserving our nation’s greatest treasures.
Looking to the Future
Related issues that must be considered in alignment with the RBCT CUA permit are timing of CUA applications, reporting requirements, timed-entry reservations, and the entrance fee structure. IITA understands these to be issues for future discussions and offers the following thoughts.
Categories
Most Recent Posts