TITLE: B-307319, National Park Service--Special Park Use Fees, August 23, 2007
BNUMBER: B-307319
DATE: August 23, 2007
***********************************************************************
B-307319, National Park Service--Special Park Use Fees, August 23, 2007

   Decision

   Matter of: National Park Service--Special Park Use Fees

   File: B-307319

   Date:  August 23, 2007

   DIGEST

   The National Park Service (NPS) may set special park use fees based on
   market value when it is acting under business-type conditions, but it may
   not double charge for costs by setting a two-part fee in which one part is
   based on market value and the other based on costs. Both the Independent
   Offices Appropriations Act (IOAA) of 1952, codified at 31 U.S.C. sect.
   9701, and section 3a of title 16 of the United States Code authorize NPS
   to charge a user fee. When providing commercial goods, services, or
   resources, NPS may charge a fee based on market value under the IOAA and,
   under section 3a, calculate its actual costs, deduct that amount from the
   fee collected, and credit that amount to the current NPS appropriation.
   Any fees collected in excess of costs must be deposited into the
   miscellaneous receipts of the Treasury. Alternatively, NPS may choose to
   set special park use fees to recover only its actual costs and retain
   those under section 3a.

   DECISION

   In February 2006, GAO reported that National Park Service (NPS) park units
   were not consistently implementing NPS special use permit guidance for
   fee-setting and cost-recovery.[1] In the course of this work, we raised
   concerns about the underlying legal authority for NPS fee-setting
   guidance. We were concerned that park units, following NPS guidance, might
   charge fees higher than authorized. This decision addresses whether NPS
   has authority to charge fees for special park uses that may exceed agency
   costs for managing or supporting such uses.[2] We conclude that NPS may
   base fees on market value, but may not charge a two-part fee based on both
   costs and market value. Current NPS guidance improperly permits park units
   to combine actual costs incurred by NPS and market value in setting the
   user fee.

   BACKGROUND

   NPS provides user fee guidance to park units in three key documents:
   first, NPS's Management Policies 2001, which provides agencywide guidance
   on a variety of topics, including special park uses and fees;[3] second,
   Director's Order #53: Special Park Uses, which clarifies and supplements
   Management Policies 2001 by setting forth policies and procedures for
   administering special park uses on lands;[4] and third, Reference Manual
   53: Special Park Uses, which provides detailed guidance for carrying out
   the agency's special park use program.[5]

   Management Policies 2001 envisions a two-part fee: a cost recovery and a
   use charge. Management Policies 2001, sect. 8.6.1.2. It requires that
   "[a]ll costs incurred by the Service in writing the permit, monitoring,
   providing protection services, restoring park areas, or otherwise
   supporting a special park use will be reimbursed by the permittee. When
   appropriate, the Service will also include a fair charge for the use of
   the land or facility."[6] Id. Director's Order #53 implements this
   two-part fee by specifying that charges should reflect the "fair market
   value" for the requested use, noting that the fair market value of a
   special park use "is the value of the lands or facilities used, plus NPS
   costs incurred in managing or supporting the use." Director's Order #53,
   sect. 3.6. It further addresses the separate disposition of the two parts
   of the fee by noting that "NPS will retain funds recovered for the cost of
   managing a special park use" while "[c]harges arising from the use of NPS
   lands and facilities must be deposited in the U.S. Treasury, unless
   otherwise specifically authorized by law." Id. Reference Manual 53
   provides detailed guidance for calculating the two parts of the fee in
   separate sections addressing recoverable costs and land or facility use
   fees. Reference Manual 53 at C10-3 to C10-6.

   NPS guidance cites two statutory authorities under which it charges
   special park use fees. Id. at C10-1. NPS is authorized by 16 U.S.C. sect.
   3a to recover, and credit to current appropriations, costs of providing
   necessary services associated with special use permits. In addition, the
   Independent Offices Appropriations Act of 1952 (IOAA), codified at 31
   U.S.C. sect. 9701, authorizes federal agencies to prescribe regulations
   establishing a user fee for a service or thing of value provided to a
   person by the agency. Unless a statute provides otherwise, agencies must
   deposit user fees charged under IOAA into the general fund of the Treasury
   as miscellaneous receipts. 31 U.S.C. sect. 3302(b); see, e.g., 49 Comp.
   Gen. 17 (1969).

   Reference Manual 53 cites 16 U.S.C. sect. 3a as authority for the recovery
   and retention of costs, and 31 U.S.C. sect. 9701 as authority for the
   imposition of additional charges for the value of the land or facilities
   used, or the services provided. Reference Manual 53 at C10-1. It also
   discusses the separate disposition of the amounts recovered under each
   authority, noting that funds recovered for costs may be retained while
   those collected for land or facility use must be deposited as
   miscellaneous receipts. Id. at C10-7 to C10-8.

   DISCUSSION

   NPS guidance for imposition of special park use fees presents the
   following issue: whether IOAA authorizes NPS to charge fees set at market
   value for special park uses, and if so whether this may be done in
   addition to NPS's section 3a authority to recover agency costs for
   managing or supporting such uses.

   Section 3a, by its own terms, does not permit NPS to recover amounts
   exceeding its costs. It provides, "Notwithstanding any other provision of
   law, the National Park Service may . . . recover all costs of providing
   necessary services associated with special use permits, such
   reimbursements to be credited to the appropriation current at that time."
   16 U.S.C. sect. 3a (emphasis added). This authorizes NPS to recover and
   credit to its appropriations a fee equal to its total costs. There is
   nothing in the language of the statute that authorizes NPS to charge a fee
   exceeding its costs.

   The Office of the Solicitor has asserted that NPS's authority to impose
   additional fees above and beyond the costs authorized in 16 U.S.C. sect.
   3a is provided by IOAA, commonly referred to as the "User Charge"
   statute.[7] The Solicitor's Office argues that interpreting these two
   statutes in pari materia would permit imposition of a fee equaling costs
   (under section 3a) plus an additional fee equal to the value of the
   facility, land, or service provided (a market value calculation under
   IOAA).[8]

   Market value fees under IOAA

   Before addressing the propriety of the two-part fee envisioned by the
   Solicitor's Office and NPS guidance, we will consider whether IOAA permits
   NPS to charge a fee based on the market value of the facility, land, or
   service provided.

   IOAA establishes a government policy that "each service or thing of value
   provided by an agency . . . to a person . . . is to be self-sustaining to
   the extent possible." 31 U.S.C. sect. 9701(a). IOAA authorizes heads of
   agencies to prescribe regulations establishing charges for a service or
   thing of value provided by an agency, and requires that fees be "fair" and
   based on four factors: "(A) the costs to the Government; (B) the value of
   the service or thing to the recipient; (C) public policy or interest
   served; and (D) other relevant facts." 31 U.S.C. sect. 9701(b). Judicial
   interpretation to date has applied IOAA to the government's exercise of
   its regulatory functions, and in that context courts have narrowed the
   application of these factors so that fees charged under IOAA are "limited
   to the cost to the agency of a specific benefit rendered to a particular
   entity." Florida Power & Light Co. v. United States, 846 F.2d 765, 767
   (D.C. Cir. 1988), cert. denied, 490 U.S. 1045 (1989).

   This understanding of IOAA is based on federal case law from the
   mid-1970s, beginning with two Supreme Court decisions issued on the same
   day in 1974. In National Cable Television Ass'n (NCTA) v. United States,
   415 U.S. 336 (1974), the Supreme Court considered fees set under IOAA by
   the Federal Communications Commission (FCC) for regulation of community
   antenna television (CATV) systems. FCC had calculated fees based on FCC's
   total costs of regulating the CATV industry. NCTA, 415 U.S. at 340. The
   Court rejected this methodology and drew a clear distinction between
   permissible fees assessed for benefits received by a specific recipient
   and impermissible fees (or taxes) for benefits inuring to the public as a
   whole. Id.  at 341--43. The Court rejected recourse to the "public policy
   or interest served" and "other relevant facts" factors of IOAA because,
   the Court said, these factors "if read literally, [carry] an agency far
   from its customary orbit and [put] it in search of revenue in the manner
   of an Appropriations Committee of the House." Id.  (emphasis in original).
   Because FCC had levied charges to recoup its total costs of regulating the
   CATV industry rather than fees based on the "value to the recipient" of
   FCC services, the Court viewed the charges as taxes. Id.  at 343--44.

   In a companion case to NCTA issued the same day, the Supreme Court
   considered yearly assessments set under IOAA by the Federal Power
   Commission (FPC) to recoup a portion of its costs of regulating gas and
   power utilities. Federal Power Commission v. New England Power, 415 U.S.
   345, 346--47 (1974). FPC charged these fees even to utilities that had had
   no proceedings before FPC during a particular year. Id.  at 351. The Court
   rejected this scheme. The Court agreed with the Office of Management and
   Budget's interpretation of IOAA as permitting charges only when there is
   an "identifiable recipient for a measurable unit or amount of Government
   service or property from which he derives a special benefit" and that "no
   charge should be made . . . `when the identification of the ultimate
   beneficiary is obscure and the service can be primarily considered as
   benefiting broadly the general public.'" Id.  at 349--51, quoting OMB
   Budget Cir. No. A-25 (Sept. 23, 1959).

   In a follow-up to NCTA, the D.C. Circuit Court of Appeals addressed a
   revised annual fee scheme established by FCC under IOAA. National Cable
   Television Ass'n v. FCC, 554 F.2d 1094 (D.C. Cir. 1976). FCC, once again,
   set fees based on the total costs to FCC of regulating the industry,
   although the agency now sought to recover only certain aspects of those
   costs. Id. at 1098. Finding that FCC had not been sufficiently explicit in
   detailing the specific expenses which made up the cost basis for its
   individual fees, the court rejected the new FCC effort. Id.  at 1104--05.

   In doing so, the D.C. Circuit held that FCC was "required to show the
   particular costs which they are assessing against the recipients so as to
   assure them that they are paying only for the specific expenses which are
   incurred in connection with the service of granting them their operating
   authority." Id. The court interpreted NCTA and FPC to mandate that an
   agency "look not at the value which the regulated party may immediately or
   eventually derive from the regulatory scheme, but at the value of the
   direct and indirect services which the agency confers." Id. at 1107
   (emphasis in original). Thus, IOAA "must be interpreted to limit the [FCC]
   to assessing fees at a rate which reasonably reflects the cost of services
   performed or the expense of other value transferred to the payor." Id. In
   a footnote in a companion decision issued the same day, the court
   explained its rationale: "When the cost of the benefit conferred is
   exceeded by any material amount, one immediately gets into the taxing
   area, and the result is revenue and not a fee." National Ass'n of
   Broadcasters v. FCC, 554 F.2d 1118, 1129 n. 28 (D.C. Cir. 1976). It is at
   that point, the court said, that charges "cease being fees and become
   taxes levied, not by Congress, but by an agency." Id.

   In that case, Judge Tamm included a concurring opinion arguing against
   what he viewed as the D.C. Circuit's undue narrowing of agency discretion
   by defining "value to the recipient" as including only "costs and not also
   the value of the benefits bestowed on a regulatee." Id.  at 1134 (Tamm,
   J., concurring). Judge Tamm asserted that NCTA "does not dictate that the
   proportion-of-cost basis is the only acceptable method of determining a
   proper fee." Id. In response, the majority opinion noted that fees based
   on value created or derived by recipients were clearly prohibited, but
   that "[a]s to whether it is possible under NCTA to promulgate `value to
   the recipient' fee schedules not initially related to costs, we express no
   opinion." Id. at 1129, n. 28 (emphasis added).

   The D.C. Circuit, in another decision issued the same day, summarized the
   requirements of the cost-based standard:

     "First, the [FCC] must justify the assessment of a fee by a clear
     statement of the particular service or benefit which it is expected to
     reimburse. Second, it must calculate the cost basis for each fee
     assessed. This involves (a) an allocation of the specific direct and
     indirect expenses which form the cost basis for the fee to the smallest
     practical unit; (b) exclusion of any expenses incurred to serve an
     independent public interest; and (c) a public explanation of the
     specific expenses included in the cost basis for a particular fee, and
     an explanation of the criteria used to include or exclude particular
     terms. Finally, the [FCC] must set a fee calculated to return this cost
     basis at a rate which reasonably reflects the cost of the services
     performed and value conferred upon the payor."

   Electronic Industries Ass'n v. FCC, 554 F.2d 1109, 1117 (D.C. Cir. 1976)
   (emphasis in original).

   The D.C. Circuit has since applied the cost-based standard in reviewing
   fees assessed by the Interstate Commerce Commission in regulating motor
   carriers,[9] the Nuclear Regulatory Commission (NRC) in regulating nuclear
   power licensees,[10] and the Environmental Protection Agency in regulating
   engine manufacturers under the Clean Air Act.[11] The Fifth Circuit Court
   of Appeals followed suit in a case considering NRC licensing fees.[12]

   These court cases involved agencies exercising their regulatory functions.
   No court has directly addressed the question facing us here; that is, may
   an agency, when acting not in a regulatory context but in a commercial or
   proprietary context, set fees based on market value rather than recovery
   of agency costs? Or should we read federal case law to require that even
   in a commercial or proprietary context, fees may only reflect the costs
   incurred by the agency in providing a service or thing of value to a
   recipient?

   Special park uses, in many ways, are factually distinct from the
   regulatory activities contemplated to date in federal case law. Generally,
   there is a voluntary element present when a rancher, for example,
   approaches NPS to use park land for grazing that is not present when a
   television broadcast company approaches FCC for a license to use the
   public airwaves. If the rancher does not want to pay what NPS will charge,
   the rancher can decide whether to seek grazing rights elsewhere. The
   television broadcast company, however, cannot walk away from its
   transaction (unless, of course, it decides to walk away, also, from its
   broadcast business); the federal government is the only source for a
   broadcast license. Unlike grazing rights, a license to broadcast is not a
   commodity traded in an open market. The license has a very real economic
   value nonetheless--indeed, it could amount to the value of the company's
   broadcast business. This could obviously be quite high, and using it as
   the limit for user charges would give agencies extraordinarily broad
   authority. It is in this sense that we understand the D.C. Circuit's
   holding that basing a fee for a license on value derived would be in the
   nature of a tax. A fee based on the cost to the government of providing
   this economic value to the licensee reflects a balance between the IOAA
   policy that federal activities be self-sustaining to the extent possible
   and the Supreme Court's admonition that Congress, in IOAA, did not
   delegate taxing authority to agencies.

   Grazing rights, on the other hand, do have a value that can be determined
   by the open market. In such a commercial transaction, as in the regulatory
   context, it is possible that the government may incur very little cost,
   and the economic value of the government's action may exceed the
   government's costs.[13] In that case, a fee that is designed merely to
   recover the government's costs could very well interfere, however
   inadvertently, with a competitive marketplace by having the government
   "selling" below the market rate. A fee based on the market price of the
   transaction would reflect a balance between the IOAA "self-sustaining"
   policy and a healthy respect for the marketplace.[14]

   We see nothing in IOAA to prohibit an agency from setting a fee in a
   commercial or proprietary transaction that reflects the market price. In
   IOAA, Congress directed agencies to base fees on four factors, including
   "the value of the service . . . to the recipient" and "public policy or
   interest served." 31 U.S.C. sect. 9701(b)(2)(B), (C). While, as the
   Supreme Court explained, this does not permit an agency to tax, we believe
   that at least in a commercial transaction, an agency may fairly decide
   that it should set its fees in reference to prices that arise out of
   competition in open markets.[15] Therefore, we believe that IOAA permits
   agencies to appropriately weigh the statutory factors in accordance with
   executive branch policies, and with respect to commercial transactions, to
   set fees based on market price.

   This distinction was broached by the Court of Claims while referring to
   IOAA in Yosemite Park & Curry Co. v. United States, 686 F.2d 925, 932--34
   (Ct. Cl. 1982). Yosemite involved a contract dispute between NPS and a
   concessioner in Yosemite National Park, the Yosemite Park and Curry
   Company. As part of the concession, the concessioner purchased electricity
   from NPS. NPS is authorized by 16 U.S.C. sect. 1b(4) to provide
   electricity to concessioners on a reimbursable basis. The concessioner
   asserted that NPS was overcharging for the electricity it supplied because
   NPS charged rates based on local utility rates, which could exceed NPS
   costs. The Court of Claims referred to a variety of authorities, including
   IOAA, in concluding that the NPS rate-setting methodology was "reasonable"
   within the meaning of the contract, although it, in fact, might result in
   NPS charging a rate in excess of cost. Id. at 930.

   In referring to IOAA, the Court of Claims acknowledged the line of federal
   cases interpreting IOAA to "mandate a cost based fee schedule" and
   establish that "cost must be the ultimate basis of fees," but found that
   those cases were "not apposite" to NPS's authority under 16 U.S.C. sect.
   1b(4). Id.  at 930--32. Instead, the court relied on the fact that the
   government was not acting, in that instance, as a sovereign: "In the
   present case . . . the Government has not created the need for
   electricity, nor is the service provided a regulatory one." Id. at 932. In
   selling electricity to the concessioner, the government was entering into
   a voluntary contract for the sale of electricity to a willing partner. Id.
   at 934. This is fundamentally different from the circumstances in NCTA,
   for instance, where "the Government's power to allocate the airwaves and
   to issue licenses came not from its ownership of the airwaves but from its
   sovereign power to regulate certain activities. . . ." Id. Thus, the Court
   of Claims found the comparative-rate system methodology used by NPS to set
   rates for electricity acceptable, despite the fact that those rates could
   exceed NPS costs.[16]

   We conclude that in a commercial transaction, an agency may set its fees
   under IOAA based on market price. However, consistent with IOAA, we
   recommend that NPS establish its special park use fee structure through
   the rulemaking process and in accordance with executive policy as
   reflected in OMB Circular A-25.

   Two-part fee

   NPS guidance, as described above, contemplates a two-part fee, including
   both a market value charge and a cost-based charge. As explained below, we
   find that even under business-type conditions, the NPS two-part fee for
   special park uses is inconsistent with OMB Circular A-25. In addition, we
   do not think that the two applicable statutes may reasonably be read as
   authorizing the two-part fee, which double counts costs.

   First, OMB Circular A-25 does not support charging a two-part fee as
   delineated in the NPS guidance. Rather, it sets out alternative
   methodologies for calculating the appropriate user fee: (1) "full cost"
   recovery, which should be used when the government is acting in its
   capacity as sovereign, and (2) "market price," which should be used under
   business-type conditions, such as when leasing or selling goods or
   resources. OMB Cir. No. A-25, sect. 6.a.2. The Circular defines market
   price as "the price for a good, resource, or service that is based on
   competition in open markets, and creates neither a shortage nor a surplus
   of the good, resource, or service" and provides that "when substantial
   competitive demand exists for a good, resource, or service, its market
   price will be determined using commercial practices, for example . . . by
   reference to prevailing prices in competitive markets . . . ." [17] OMB
   Cir. No. A-25, sect. 6.d.2.

   The Circular states that under these conditions, user charges "need not be
   limited to the recovery of full cost and may yield net revenues." OMB Cir.
   No. A-25, sect. 6.a.2(b). Thus, under the Circular, where use of a market
   price is appropriate, costs are treated as an inherent component of that
   price and are not to be separately added to the market price in setting
   the user fee. Market price is used as an alternative methodology to the
   full cost methodology, not in addition to it. We conclude that the use of
   both the full cost and the market price methodologies to set a two-part
   fee, as provided for in the NPS guidance, is contrary to the Circular. We
   recognize that section 3a gives the NPS specific authority to retain its
   costs associated with special park use permits. Hence, we are not
   concluding that NPS cannot charge market price and also calculate its
   costs for purposes of knowing how much money it can credit to its
   appropriation under section 3a.

   Second, NPS asserts authority to charge a two-part fee (market price plus
   full cost) by citing both IOAA and 16 U.S.C. sect. 3a. We do not think
   this is a reasonable reading of these two fee-setting statutes because it
   fails to read them harmoniously as part of an overall statutory scheme.
   IOAA is the predominant federal user fee statute, and it is the only
   governmentwide authority. In 1993, more than 40 years after enactment of
   IOAA, Congress enacted 16 U.S.C. sect. 3a, which, as stated, authorizes
   NPS to recover its costs of providing necessary services associated with
   special use permits and to credit those costs to its current
   appropriation. See Department of the Interior and Related Agencies
   Appropriations Act, 1994, Pub. L. No. 103-138, title I, 107 Stat. 1379,
   1387 (Nov. 11, 1993). This authority was provided "[n]otwithstanding any
   other provision of law." Id. While there is little legislative history
   available to help understand section 3a, it differs from IOAA authority by
   permitting NPS to credit funds recovered to its current appropriation
   rather than depositing them into the general fund of the Treasury as
   miscellaneous receipts.[18] Thus, we read the "notwithstanding any other
   provision of law" clause contained in section 3a as creating an exception
   to the miscellaneous receipts statute for actual costs associated with
   special use permits. While section 3a addresses cost recovery, already
   authorized under IOAA, there is no indication in the statute or the
   legislative history that it was intended to supersede NPS's general user
   fee authority under IOAA. Rather, the two laws can be read harmoniously by
   observing that section 3a modifies the disposition (credit to the agency's
   appropriation) of certain fees recovered under IOAA (costs of providing
   necessary services).

   While the NPS guidance acknowledges the two statutes, the two-part fee
   system described in its guidance essentially construes them as allowing
   for recovery of the same costs under each. Specifically, the guidance
   defines market value as the value of the land being used as determined by
   the market price (Reference Manual 53 at C10-5) plus NPS costs incurred.
   [19] Director's Order # 53, sect. 3.6. Calculating market value in this
   manner essentially double counts the costs to the government that may be
   recovered as part of the fee, a result clearly not supported by any
   reasonable reading of the underlying statutes.[20]

   CONCLUSION

   Under IOAA, NPS may charge fees for special park uses based on market
   value when it is acting under business-type conditions but may not
   separately charge an additional fee for its costs. Consistent with IOAA,
   we recommend that NPS establish its fee structure through the rulemaking
   process and in accordance with executive policy as reflected in OMB
   Circular A-25.[21] NPS may charge a fee based on market value under IOAA
   and, under section 3a, calculate actual costs to the government, deduct
   that amount from the fee collected, and credit that amount to the current
   NPS appropriation. NPS should deposit into the miscellaneous receipts of
   the Treasury any amounts collected that exceed the actual costs to the
   government. We suggest that NPS inform the relevant congressional
   committees of its actions and keep them informed throughout the rulemaking
   process.

   Gary L. Kepplinger
   General Counsel

   ------------------------

   [1] GAO, National Park Service: Opportunities Exist to Clarify and
   Strengthen Special Uses Permit Guidance on Setting Grazing Fees and
   Cost-Recovery, GAO-06-355R (Washington, D.C.: Feb. 9, 2006), at 3. See
   also GAO, Livestock Grazing: Federal Expenditures and Receipts Vary,
   Depending on the Agency and the Purpose of the Fee Charged, GAO-05-869
   (Washington, D.C.: Sept. 30, 2005).

   [2] Our practice when rendering decisions is to obtain the views of the
   relevant federal agency to establish a factual record and to elicit the
   agency's legal position on the subject matter of the request. GAO,
   Procedures and Practices for Legal Decisions and Opinions, GAO-06-1064SP
   (Washington, D.C.: Sept. 2006), available at www.gao.gov/legal.htm. In
   this instance, we received the views of the Office of the Solicitor,
   Department of the Interior, in March 2006. Letter from Arthur E. Gary and
   Barry N. Roth, Office of the Solicitor, U.S. Department of the Interior,
   to Thomas H. Armstrong, Assistant General Counsel for Appropriations Law,
   GAO (Mar. 7, 2006) (Solicitor's Letter). The Solicitor provides legal
   support for NPS.

   [3] At the time of our February 2006 report, NPS was operating under
   Management Policies 2001. On August 31, 2006, NPS issued a new edition,
   Management Policies 2006, www.nps.gov/policy/MP2006.pdf (last visited July
   11, 2007). With regard to fees for special use permits, there are no
   material differences between the 2001 and 2006 edition. Management
   Policies 2001 defines "special park use" as--

     "a short-term activity that takes place in a park area, and that:
     [p]rovides a benefit to an individual, group, or organization rather
     than the public at large; [r]equires written authorization and some
     degree of management control from the Service in order to protect park
     resources and the public interest; is not prohibited by law or
     regulation; [i]s not initiated, sponsored, or conducted by the Service;
     and [i]s not managed under a concession contract, a recreation activity
     for which the NPS charges a fee, or a lease . . . ."

   Management Policies 2001, NPS D 1416 (Dec. 2000),  at sect. 8.6.1
   (internal citations omitted), available at www.nps.gov/refdesk/mp (last
   visited July 9, 2007).

   [4] A few of the types of special park uses contemplated under Director's
   Order #53 are agricultural or livestock uses; special events such as
   regattas, pageants, or large group camps; and filming and photography
   activities. Director's Order #53, sections 11-14 (Apr. 4, 2000), available
   at www.nps.gov/policy/DOrders/DOrder53.html (last visited July 9, 2007).

   [5] Reference Manual 53: Special Park Uses, RM-53 (Apr. 2000), available
   at www.nps.gov/refdesk/DOrders (last visited July 9, 2007). The Office of
   the Solicitor has informed us that our understanding of NPS guidance in
   this area is "essentially correct." Solicitor's Letter at 2.

   [6] See also Management Policies 2006, sect. 8.6.1.2 ("When appropriate,
   the Service will also collect a fee for the use of the land or facility
   based on a market evaluation.").

   [7] The Solicitor's Office states, "The NPS is entitled to utilize both 16
   U.S.C. sect. 3a and the IOAA in determining and charging fees for special
   use permits." Solicitor's Letter at 2.

   [8] Statutes in pari materia are those "on the same subject; relating to
   the same matter." Black's Law Dictionary 807 (8^th ed. 2004).

   [9] Central & Southern Motor Freight Tariff Ass'n v. Interstate Commerce
   Commission, 777 F.2d 722 (D.C. Cir. 1985). The court found in this
   instance that some of the ICC's cost based calculations were not
   adequately precise, or adequately explained. Id. at 737-39.

   [10] Florida Power & Light Co. v. United States, 846 F.2d 765, 767 (D.C.
   Cir. 1988), cert. denied, 490 U.S. 1045 (1989). The issue in this case was
   the application of a fee statute other than IOAA, but the court, in dicta,
   did reinforce its prevailing interpretation of IOAA. Id. at 767, 774.

   [11] Engine Manufacturers Ass'n v. Environmental Protection Agency, 20
   F.3d 1177 (D.C. Cir. 1994). In this case, the court stated a slightly
   broader proposition that "[a]n agency may not charge more than the
   reasonable cost it incurs to provide a service, or the value of the
   service to the recipient, whichever is less." Id.  at 1180 (emphasis
   added), citing National Cable Television Ass'n, 554 F.2d at 1104-07.

   [12] Mississippi Power & Light Co. v. U.S. Nuclear Regulatory Commission,
   601 F.2d 223 (5^th   Cir. 1979), cert. denied, 444 U.S. 1102 (1980). The
   Fifth Circuit cited D.C. Circuit precedent for the proposition that "the
   fee assessed cannot exceed the cost to the agency of rendering the
   service." Id. at 230, citing Electronic Industries Ass'n, 554 F.2d at
   1114.

   [13] One commentator referred to the economic value in circumstances such
   as this as the "benefits of exclusive use." Clayton P. Gillette and Thomas
   D. Hopkins, Federal User Fees: A Legal and Economic Analysis, 67
   B.U.L.Rev. 795, 862-63 (1987).

   [14] See generally B-124195, Apr. 15, 1973 (the Alaska Railroad, owned and
   operated at that time by the federal government, should ascertain the fair
   market value of the property it leased to private concerns and establish a
   rental rate in accordance with sound business management principles and
   comparable commercial practices).

   [15] We recognize that this is an inexact science and at times there may
   be no comparable private sector supplier.

   [16] The Office of Management and Budget (OMB) adopted the court's
   distinction between the government acting as a sovereign and the
   government acting commercially in a 1993 revision to its Circular A-25.
   OMB Cir. No. A-25, User Charges, 58 Fed. Reg. 38142 (July 15, 1993).
   Circular A-25 has set out executive policy for establishing user charges
   under IOAA.

   [17] The Circular lists "grazing lands in the general vicinity of private
   ones" as an example. OMB Cir. No. A-25, sect. 6.d.2(a)(ii).

   [18] Under the miscellaneous receipts statute, 31 U.S.C. sect. 3302(b),
   agencies must deposit user fees charged under IOAA into the general fund
   of the Treasury as miscellaneous receipts. See, e.g., 49 Comp. Gen. 17
   (1969).

   [19] Valuing the land by reference to its market price incorporates a cost
   component into the formula since comparable prices in an open market will
   presumably be determined, at least in part, based on cost. We note,
   however, that it is conceivable that market value in some circumstances
   may have little relation to actual costs or be less than actual costs.

   [20] It is possible that NPS inartfully drafted its guidance and does not
   intend to double charge for costs in its two part fee. Nevertheless, this
   is the effect of separately allowing for the recovery of both market price
   and actual costs. In establishing a fee structure consistent with this
   decision and OMB Circular A-25, NPS should ensure that when NPS is leasing
   or selling goods or resources under business conditions, and the fee
   charged is based on market value, an additional recovery of costs is not
   permitted.

   [21] See, e.g., Grazing Fees on National Forest System Lands in the
   Eastern States, 55 Fed. Reg. 2646 (Jan. 26, 1990), codified at 36 C.F.R.
   part 222.