Coyote Blog

I thought folks might be interested in a letter I just wrote to the US Forest Service.  I have left some of it out, but these are the guts of it.  As many of your know, we manage parks and campgrounds under concession contract for public entities.  As such, we typically must get changes to customer fees approved in advance by the agency.  This is a version of a letter we just wrote to a number of US Forest Service offices in California explaining the substantial increases to camping rates that must occur over the coming years to accommodate the new California minimum wage laws.

2017 Fee Proposal & Impact of California Minimum Wage Increases on Camping Rates

The purpose of this letter is to make you aware of the substantial effect that the recent increase in California minimum wages will have on use fees. I will get into details below, but in short the newly-legislated 50% increase in the state minimum wage is likely to increase our costs by about 22%, even ahead of inflation in other categories of expenses. Just to stay at parity and to avoid cuts in service, we (and other California concessionaires) are going to need substantial increases in fees over the next five years. Frankly, this does not make me very happy – our company will have to struggle with public resentment of the new fees without making an extra dollar in profit – but it is the reality we must face together. The only other alternative would be large cuts in service (e.g. bathroom cleaning frequency) which frankly I am not going to accept.

Background on the Minimum Wage Increase

California minimum wages have already risen over the last three years by 25% from $8 to $10 an hour. The new California law, which will apply to most concessionaires, demands the following timetable for minimum hourly wages (smaller companies with fewer employees than we have will have one extra year to comply):

2016: $10.00

2017: $10.50

2018: $11.00

2019: $12.00

2020: $13.00

2021: $14.00

2022: $15.00

Note that given the terms of other portions of labor law, these same sorts of percentage increases must trickle up to all managers and salaried employees in California as well.

Background on Concessionaire Cost Structures

Not surprisingly, as a labor-intensive service business, a substantial portion of concessionaire costs are directly tied to wage rates. The minimum wage increase will increase at least three categories of our costs:

• Wages
• Payroll taxes (which are calculated as a percentage of wages, so will go up by the same percentages as wages go up)
• Workers compensation insurance premiums (which like payroll taxes are calculated as a percentage of wages and go up by the same percentage wages go up)

Looking at our financials for our California permits (we have three large permits in the Inyo NF and one in the Cleveland NF) these three categories make up 44% of our total costs.

Preliminary Estimated Fee Impacts

Let’s look, then, and how much our costs may rise between now and 2022.

For the labor and labor-related charges discussed above, we know that costs will rise 50% between now and 2022. A 50% price increase on 44% of our costs raises our total cost structure by 22% (0.5 * 0.44).

But all of our other costs will also continue to rise during this period by at least the national rate of inflation. It is very possible that these costs will increase faster in the future due to this minimum wage increase – for example, our waste disposal costs will almost certainly go up as the labor costs of waste disposal companies rise. For a starting point, we will assume 3% general inflation in 2016 and 2017 and 4% in the years after that. This would yield a 24% increase in the other 56% of our costs for an impact on our total costs of 13.4% (0.24*0.56). Combining these two effects, we can expect a total cost increase to operate campgrounds in California by 2022 of 35.4%.

Note that though we bid based on trying to earn a profit margin around 9%, our actual profit margin in the USFS campgrounds we operate in California has been between 3% and 7% of revenues (5% in 2013, 7% in 2014, 3% in 2015). There is simply no room in that margin to absorb a 35.4% cost increase. We are going to have to therefore seek fee increases over the next 6 years in the 35% range, or between $6 and $8 on the $18-$23 camping rates that currently obtain. This is about a dollar or year, or two dollars every other year.

Competitor Analysis

We understand that the USFS wants to justify fee increases based on market conditions. One problem we will have is that even though we don’t open until April or May at seasonal locations, we need to get fee approval the previous September or October. We fully expect private operators will have to pursue fee increases of a similar magnitude; however, they may not announce their new higher rates in time for our very early fee-setting process. This makes local competitive analysis misleading.

Fortunately, in California we have another large public campground provider, California State Parks (CSP), that has many of the same public service and land management goals as has the US Forest Service. They therefore make a very good comparison. While rates vary by park, CSP is typically charging $35 a night for a no-hook-up campsite in parks that are very comparable in their natural settings to USFS campgrounds.

We currently charge no more than $23 for a no-hook-up site in the USFS in California (both in the Inyo and Cleveland NF). Even with a $6 fee increase, we would still be offering no-hookup campsites at 17% lower cost than does the State of California today (and presumably even lower in 6 years given that CSP is likely to continue to increase its camping fees).

[Rest of the letter on exact fee recommendations and other contract issues omitted]

I do a lot of work with California State Parks, being a concessionaire in some of their parks, so I have been following the various scandals in that agency closely.  One part of the scandal was that CSP apparently hid something like $54 million in reserve funds from the legislature.  I wondered how it was possible for the state to not know there was $54 million lying around un-reported.

It seems like we have a partial solution to my quandary.  It is possible to misplace $54 million when you also misplace another $2 billion.

More than $2 billion in California taxpayer money has apparently been stashed in hundreds of special funds unaccounted for by the state Department of Finance, a newspaper reported on Friday.

An examination of more than 500 special fund accounts, like the $54 million discrepancy in state parks money, showed a $2.3 billion "discrepancy" between state controller and Department of Finance numbers, according to the San Jose Mercury News ( http://bit.ly/MPdkls).

No one checks the controller's figures, so the difference wasn't caught.

The analysis showed at least 17 accounts appear to have significantly more reserve cash than what was reported to the Finance Department.

The violent crime victim restitution fund, for instance, was off by $29 million, and a low-cost child health insurance fund was off by $30 million. The fund that rewards people who recycle bottles and cans was $113 million off.

State finance officials operate under a  longtime honor system. The controller's figures were never checked and oversight groups didn't catch the discrepancies even though the numbers are publicly available on two state websites.

LOL, politicians' "honor".  We can see what that is worth.

Letter I sent to Governor Schwartzenegger in response to his plan to close a number of California State Parks due to budget problems:

I know many people are
probably contacting you to oppose proposed closures of state parks to help meet
budget targets. My message is a bit
different: Closing these parks is
totally unnecessary. 

I own and manage one of the
larger concessionaires in the California State Park (CSP) system. We are the concessionaire at Clear Lake and Burney Falls. At Burney Falls, for example, we have invested over a million dollars
of our money in a public-private partnership with the state to revamp to the
park. We also operate parks for the
National Park Service, the US Forest Service, Arizona State Parks, Texas State Parks, and other public authorities.

Traditionally, CSP has
engaged concessionaires to run stores and marinas within parks, but not to run
entire parks. However, in many other
states, our company runs entire parks and campgrounds for other government
authorities, and does so to the highest quality standards. 

So, I can say with confidence
that many of the California State Parks proposed for closure would be entirely
viable as private concessions. For
example, we operate the store and marina at Clear Lake State Park but
could easily run the entire park and make money doing so, while also paying
rent to the state for the privilege.

I know that there are some
employees of the CSP system that oppose such arrangements with private
companies out of fears for their job security. But it would be a shame to close parks entirely when an opportunity
exists to keep them open to the public, and improve the state budget picture in
doing so. 

Even if California decides to keep these parks open, I would encourage
you to have your staff investigate the possibility of expanding private
operation of state parks. CSP already
has one of the best and most capable concession management programs in the
country, a success you should seek to build on. The infrastructure is already there in CSP to solicit bids for these
projects and ensure that management of them meets the state's quality and
customer service standards.

Even though everything I said here is true, it probably is a non-starter because most state organizations are dead set against such private management.  They would rather close services to the public than establish the precedent of private management. 

Besides, the whole parks closure may well be a bluff.  Unlike private company budget discussions, where it is expected that managers offer up their marginal projects for cuts, the public sector works just opposite:  Politicians propose their most popular areas of spending (parks, emergency services) for cuts in a game of chicken to try to avoid budget cuts altogether.  As I wrote here:

Imagine that you are in a budget meeting at your company.  You and a
number of other department heads have been called together to make
spending cuts due to a cyclical downturn in revenue.  In your
department, you have maybe 20 projects being worked on by 10 people,
all (both people and projects) of varying quality.   So the boss says
"We have to cut 5%, what can you do?"  What do you think her reaction
would be if you said "well, the first thing I would have to cut is my
best project and I would lay off the best employee in my department". 

If this response seems nuts to you, why do we let politicians get
away with this ALL THE TIME?  Every time that politicians are fighting
against budget cuts or for a tax increase, they always threaten that
the most critical possible services will be cut.  Its always emergency
workers that are going to be cut or the Washington Monument that is
going to be closed.  Its never the egg license program that has to be cut.

Update: Here is the form letter the governor's office sent out in response to my letter:

A weakened national economy and auto-pilot state spending has created a projected budget shortfall of $14.5 billion for fiscal year 2008-09. Although state government revenues this coming year are actually forecast to hold steady, the problem is that every year automatic spending formulas increase expenditures.  Left unchecked, next year's budget would need to grow by 7.3-percent, which is $7.6 billion; even booming economies can't meet that kind of increase.  To immediately combat this crisis, the Governor has proposed a 10-percent reduction in nearly every General Fund program from their projected 2008-09 funding levels.  While these reductions are unquestionably painful and challenging, this across-the-board approach is designed to protect essential services by spreading reductions as evenly as possible.

To achieve this difficult reduction, State Parks will be reducing both its permanent and seasonal workforce.  As a result, 48 park units will be closed or partially closed to the public and placed in caretaker status.  By closing parks and eliminating positions, remaining resources can be consolidated and shifted to other parks to provide for services necessary to keep those parks open and operating.  While 48 parks are affected by closures, 230 parks-or 83% of the system-will remain open.

We must reform our state budget process.  Government cannot continue to put people through the binge and purge of our budget process that has now led to park closures.  That's why the Governor has proposed a Budget Stabilization Act.  Under the Governor's plan, when revenues grow, Sacramento would not be able to spend all the money.  Instead, we would set a portion aside in a Revenue Stabilization Fund to stabilize the budget in down years.  If a deficit develops during the year, instead of waiting to accumulate billions of dollars of debt, the Governor's plan would automatically trigger lower funding levels already agreed upon by the Legislature.  Had this system been in place the past decade, we would not be facing a $14.5 billion deficit. 

As Governor Schwarzenegger works with his partners in the Legislature, he will keep your concerns in mind.  With your help, we will turn today's temporary problem into a permanent victory for the people of California.