Special Recreation Permit Audits
January 12, 2021
In Reply Refer To:
2930 (CA-932) P
EMS TRANSMISSION 01/15/2021
Instruction Memorandum No. CA-2021-005
Expires: 09/30/2021
To: DM’s, FM's, and Outdoor Recreation Planners
From: State Director, California
Subject: Special Recreation Permit Audits
Program Area: Recreation and Visitor Services – Special Recreation Permits
Purpose: The purpose of this Instruction Memorandum (IM) is to provide information and instructions regarding an upcoming audit of commercial Special Recreation Permits (SRPs) in California. The Federal Land Policy and Management Act established a national policy requiring the BLM to charge fees and assure a fair return to the public for the commercial use of public land. The Federal Lands Recreation Enhancement Act (FLREA) also gives BLM authority to charge fees for SRPs. The planned audit is necessary to: 1) assure a fair, equitable, and consistent business environment for permit holders, 2) assure that the American public receives fair market value from the commercial use of its public land, and 3) help the BLM determine if we are applying the H-2930-1 – Recreation Permit Administration Handbook regulations appropriaPolicy/Action: BLM California will conduct an SRP audit across the state. The period being audited is 2018 through 2020. Each individual permit audited will cost approximately $1200. Each office will conduct at least one SRP audit with a maximum of 3 audits depending on how many SRPs they have issued over the past three years. Funding should come from State Office 1232 and 1220 accounts. Each Field Office will work closely with Andrew Burrows, Lead California Outdoor Recreation Planner, and the contracted Auditor, as required, through the audit process.
The California State Office is responsible for:
1. Taking the lead on all procurement steps including the purchase request.
2. Developing and implementing a communication plan."
3. Writing and mailing all official correspondence to each permit holder and
other concerned parties.
4. Coordinating the audit process with the Field Offices, the Auditor, the Contracting
Officer from the National Operations Center, and the permit holders.
5. Acting as the primary contact for the selected permit holders and other concerned
parties.
6. Developing the post audit action plan.
The Field Offices are responsible for:
1. Identifying a Field Office point of contact.
2. Providing permit holder cocntact information.
3. Providing financial information for audit payment.
4. Selecting the permit holders to be audited (unless a random selection is request).
5. Providing copies of permit files on selected permit holders.
6. Responding to the Auditor for additional information upon request.
7. Initiating appropriate permit actions upon completion of the audit.
8. Implementing the post audit action plan.
Attachment 1 is the Special Recreation Permit Audit Toolkit. The toolkit explains the necessary steps for the pre-audit, the audit, and the post audit.
Attachment 2 is the Audit Timeline with due dates for each step of the auditing process.
Attachment 3 is the letter that will be sent to all permittees from the State Office.
Attachment 4 is the fill-in table for the FOs to enter the list of all permit holders that operated during the timeframe between 2018 and 2020 and contact information for those permit holders.
Attachment 5 is the fill-in table for the FOs to enter selected permit holders for the audit.
Timeframe: Refer to attachment 2, Timeline, for milestones. The Audit process is to be completed by September 2021. A final audit report is expected by April 2022.
Budget Impact: Each individual permit audited will cost $1,200. Total estimated costs to California are approximately $40,000.
Background: Audits are authorized by 43 CFR 2932.55 which reads: “…When must I allow BLM to examine my permit records? (a) You must make your permit records available upon BLM request. BLM will not ask to inspect any of this material later than 3 years after your permit expires. (b) BLM may examine any books, documents, papers, or records pertaining to your Special Recreation Permit or transactions relating to it, whether in your possession, or that of your employees, business affiliates, or agents.”
Permit holders are notified of these requirements both when applying for an SRP (Form 2930-1), and when receiving their permit (Form 2930-2) by the General Terms, item (k), listed on both forms, which reads as: “…The authorized officer, or other duly authorized representative of the BLM, may examine any of the records or other documents related to the permit, the permittee or the permittee’s operator, employee, or agent for up to three years after expiration of the permit.”
Manual/Handbook Sections Affected: H-2930-1 - Recreation Permit Administration.
Coordination: This IM has been coordinated with WO250, Recreation and Visitor Services.
Contact: If you have questions or concerns regarding this IM, contact Andrew Burrows California Lead Outdoor Recreation Planner at (916) 200-9543.
Signed by: Authenticated by:
Karen Mouritsen Larry Weitzel
State Director GIS/Applications Mgmt. Branch, CA-946
Attachment(s)
1 – Special Recreation Permit Audit Toolkit
2 – Audit Timeline
3 – Letter to all Permittees
4 – FOs list of all permittee’s holders between 2018-2020
5 – Selected Permit Holders