09 CC-GRSM002-25 Exhibit B Operating Plan new CMD.pdf

CC-GRSM002-25 Exhibit B: Operating Plan Table of Contents

V8.2013

EXHIBIT B

OPERATING PLAN

1) INTRODUCTION

2) DEFINITIONS

3) MANAGEMENT RESPONSIBILITIES

A) Concessioner B) Service

4) GENERAL OPERATING STANDARDS AND REQUIREMENTS

A) Schedule of Operation B) Rate Determination and Approval Process C) Purchasing D) Reservation Policy and Procedures E) Evaluations and Inspections F) General Policies G) Human Resource Management H) Staffing and Employment I) Interpretive Services J) Resupply Operations K) Mt. LeConte Weather Observations L) Winter Caretaker M) Interactions with Wildlife

5) ENVIRONMENTAL MANAGEMENT

A) Environmental Management Program B) Environmental Evaluations

6) RISK MANAGEMENT PROGRAM

A) Risk Management Plan B) Emergency Response

7) PROTECTION AND EMERGENCY SERVICES

A) Incident Reporting and Requests for Assistance B) Law Enforcement C) Structural Fire Protection D) Emergency Medical Care and Search and Rescue

8) PUBLIC RELATIONS

A) Required Notices B) Public Statements C) Advertisements and Promotional Material

9) TRADEMARK MAINTENANCE, RENEWAL, AND USE APPROVALS

CC-GRSM002-25 Exhibit B: Operating Plan Table of Contents

A) Maintenance and Renewal B) Approval for Use

10) SERVICE SPECIFIC OPERATING STANDARDS AND REQUIREMENTS

A) General B) Lodging Accommodations C) Food and Beverage Service D) Retail E) Souvenir Photographs

11) UTILITIES

A) Service Responsibility B) Concessioner Responsibility

12) REPORTING REQUIREMENTS

A) Concessioner Operational Reports B) Monthly Contract Monitoring Reports C) Franchise Fee Payment Documentation D) Summary of Initial and Recurring Due Dates

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1) INTRODUCTION

This Operating Plan between the Concessioner (Concessioner) and the National Park Service (the Service) describes the Concessioner’s and the Service’s operating responsibilities regarding those lands and facilities in Great Smoky Mountains National Park (the Area) that are assigned to Concessioner for the purposes the Contract authorized.

When there is any conflict between the Contract terms and this Operating Plan, the Contract terms, including its designations and amendments, will prevail.

After consulting with the Concessioner, the Superintendent will review this plan annually and revise it as the Superintendent of the Area decides is necessary. Any revisions shall not be inconsistent with the main body of this Contract. Any revisions must be reasonable and further the Contract’s purposes.

2) DEFINITIONS

Besides all defined terms in the Contract, its Exhibits, and 36 C.F.R. § Part 51, the following definitions apply to this Operating Plan.

A) Environmentally Preferable. Products or services that have a lesser or reduced negative effect on human health and the environment when compared with competing products or services that serve the same purpose. This comparison may consider raw materials acquisition, productions, manufacturing, packaging, distributions, reuse, operations, maintenance, or disposal of a product or service. Product considerations include, but are not limited to, the environmental impacts of the product’s manufacture, product toxicity, and product-recycled content including post-consumer material, amount of product packaging, energy, or water conserving features of the product, product recyclability, and biodegradability. These include those products for which standards have been established for federal agency facilities and operations.

B) Environmental Purchasing. Purchasing of environmentally preferable products.

C) Post-consumer Material. Material or finished product that has served its intended use and has been diverted or received from waste destined for disposal.

D) Recycling. The act of producing new products or materials from previously used and collected materials.

E) Service Policy. The directives, policies, instructions, and guidance regarding the National Park System and the Service that are in writing and the Secretary of the Interior or a Department of the Interior or National Park Service official to whom appropriate authority has been delegated approved, may be amended, supplemented, or superseded throughout the Contract term.

Service Policy includes, for example, NPS-48. Service Policy is available on request from the Service.

3) MANAGEMENT RESPONSIBILITIES

A) Concessioner

To achieve an effective and efficient working relationship between the Concessioner and the Service, the Concessioner must:

(1) Designate a General Manager who:

(a) has the authority and managerial experience to operate the Concession Facilities and services the Contract requires, and

(b) must employ staff with the expertise and training to operate all services the Contract authorized with a minimum of the following:

• Onsite Manager(s) manages the concession operations and the Concession Facilities in the General Manager’s absence

• Food Service Manager

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• Reservations Manager

(c) implements the Service’s policies and directives

(d) Management Listing. The Concessioner must provide the Service with a list identifying key management and supervisory personnel by department with their job titles, and office and emergency phone numbers by March 1 of each year and provide a revised list showing changes within 14 calendar days of each change.

B) Service

(1) The Superintendent manages Great Smoky Mountains National Park and is responsible for all operations, including concession operations. The Superintendent carries out Service Policy, including Concession Contract management. Directly, or through designated representatives, the Superintendent reviews, directs, and coordinates Concessioner activities regarding to the Area.

(2) The Superintendent’s duties regarding concessions include, but are not limited to:

(a) evaluating Concessioner services and facilities, and

(b) reviewing and approving rates charged for all commercial services

(3) Contact information. The Service provides a current list to Concessioner with all appropriate points of contact.

4) GENERAL OPERATING STANDARDS AND REQUIREMENTS

A) Schedule of Operation

(1) Minimum operation season and hours are as follows:

Service Operating Season

Hours of Operation

All Services (Lodging, Food and Beverage, Shuttle, Retail)

March 25 thru November 15

9 am to 9 pm 7 days/week

(2) Normal Operations

(a) The Concessioner must submit proposed opening and closing dates, and operational hours for all locations to the Service no later than September 1 for the next season, which must include, at least, the operating season and hours of operation as listed above.

(b) The Concessioner must prominently post the operation’s hours. The Concessioner must follow the minimum hours of operation unless the Concessioner requests changes and the Service approves the changes in writing. The Service may require occasional closures, delayed opening, or early closings due to weather, natural disasters, project to repair infrastructure, and similar occurrences. Other than in emergency circumstances, the Service will give reasonable notice to the Concessioner of these dates.

(c) The Concessioner will not provide lodging, food and beverage, or retail services to Park visitors or allow guests to use the Lodge while the Lodge is closed for the winter, except in emergencies the Service approved.

(d) Closure for Inclement Weather, Emergencies, or Unusual Circumstances

(e) Notwithstanding the minimum operating season and hours Section 4A specifies, there may be times when the Concessioner will close or not offer all required and authorized services because of inclement weather, emergencies, or other unusual circumstances. Generally, the Concessioner must provide services per the approved operating season and hours unless inclement weather, emergencies, or other

CC-GRSM002-25 Exhibit B: Operating Plan Page B-3 unusual circumstances result in unsafe conditions or would preclude providing satisfactory services to the public.

(f) Whenever there is a question as to whether conditions justify closing or canceling services, the Concessioner should consult with the Concessions Management Specialist before initiating this action.

(g) In the event of inclement weather, emergency, or unusual circumstances that require a sudden unscheduled closure, the Concessioner must notify the Park Communications Center (865-436-1294). The Concessioner also must notify the Concessions Management Division of unscheduled closures as soon as possible.

(h) If the concession operation will be closed, the Concessioner must make every reasonable effort to notify its patrons of the closure, duration, and reason for the closure. Additionally, the Concessioner must post a notice at the concession entrances or office advising the public of the closure’s duration and reason for the closure.

B) Rate Determination and Approval Process

(1) Rate Determination. All rates and charges to the public by the Concessioner must comply with the provisions of Section 3(e) of the Contract. The NPS ensures that the Concessioner’s rates and charges to the public are commensurate with the level of services and facilities provided in Section 3(e) of the Contract, and are reasonable, justified, and comparable with similar facilities and services provided by the private sector. The reasonableness of rates is determined based upon current concession rate approval policies and guidelines documented in the NPS Concession Rate Administration Guide as it may be amended, supplemented, or superseded throughout the term of this Operating Plan.

(a) Backcountry Lodging Accommodations. Backcountry Lodging Accommodation Rates initially will be determined by the Direct Comparability Method. After the initial rates are set, the Indexing Method, using the Consumer Price Index for all Urban Consumers (CPI-U) for “all items,” U.S. city average will be used.

(b) Food and Beverage. Rates are based on the Core method, using the Comparability methodology. Rates for non-core items are set using the National Park Service Competitive Market Declaration (CMD) methodology.

(c) Shuttle. The Concessioner will determine prices for shuttle service per CMD guidelines.

(d) Retail. Rates are set using the CMD guidelines.

(e) Convenience Items. Rates are set using Manufacturer Suggested Retail Price (MSRP,) if printed on packaging, or National Association of Convenience Stores (NACS) Markup Percentages.

(f) Souvenir Photographs. Rates are set using the CMD guidelines.

(2) Changes to Methods. Changes initiated by the Service. Changes in market conditions or other factors may result in the Service modifying the rate approval method utilized for any service types offered under the Contract. The Concessioner will be notified by the Service of such a change at least 60 days prior to any rate request due date the Service will prescribe.

(a) Changes requested by the Concessioner. The Concessioner may request a change to rate approval method, but must submit a request to change rate approval method at least 60 days prior to the date the next rate request is or would be due. A Concessioner request to change rate approval methods must include an analysis of market forces criteria, including:

• A list of competitors who provide reasonable substitutes of the Concessioner’s service.

• A review of the similarity of competitor services

• Identification of travel time/distance to competitors/the competitive market

• Availability of booking information to visitors

• An assessment of how critical the service or product is to visitors https://www.nps.gov/subjects/concessions/rate-administration.htm https://www.nps.gov/subjects/concessions/rate-administration.htm

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(b) A summary of the Concessioners pricing strategy regarding its position relative to its competitive market

(c) [For requests to use CMD] The Concessioner’s proposed monitoring plan, including occupancy/utilization data and visitor satisfaction information.

(d) [For requests to use CMD] The Concessioner’s proposed financial offsets.

(2) Rate Requests. Rate requests are applicable to service types approved under the Comparability and Core rate methods, but not to service types approved under the Competitive Market Declaration, MSRP, or markup rate methods.

(a) Annual Rate Request. The Concessioner must submit all requests for rate changes to the Service annually in writing by July 1, and at least 90 calendar days before their intended effective date.

(b) Contents of Rate Requests: The concessioner must submit its proposed rates in writing and in accordance with the rate request timeline. The concessioner’s rate request must include:

• Proposed rates, charges, and fees.

• A listing of comparable service providers, including those identified through existing comparability studies conducted by the NPS and any new comparables the concessioner would like to introduce for consideration.

• Descriptions or inventories of the ‘extra quality features’ of the concessioner’s service and its comparables which illustrate any differences in the concessioner’s rate position relative to its ‘comparables.’

• A listing of comparable service provider rates, charges, and fees.

• A basic analysis of the concessioner’s rates and comparable rates, including minimum, maximum, averages, or other relevant statistics. If proposed rates vary by season or include ‘peak’ rates, these should be analyzed separately.

(3) Interim Implementation. Once the Service deems the request complete, the Concessioner may notify visitors making reservations 90 or more days in advance of the anticipated rates subject to review. If the Concessioner’s anticipated rates are not approved, the Concessioner must refund the difference to the visitors except as described below.

(4) Rate Approval Timeframes.

(a) Within 20 days of receipt of the rate request, the Service will provide the Concessioner with a written determination that the request is complete or, if not, a description of the information required for the request to be complete.

(b) For requests that do not require a full comparability study. the Service will inform the Concessioner of the approval of the rates or the reason for any disapproval or adjustment within 10 days of determining that the request was complete.

(c) If the request requires a full comparability study, the Service will inform the Concessioner of the approval of the rates or the reason for any disapproval or adjustment within 30 days of the Service determining that the request was complete.

(d) If the Service requires a longer response period due to extraordinary circumstances, the Service will inform the Concessioner and provide an expected response date.

(5) Rate Implementation when Service Approval is Delayed. If the Service does not meet the timeframes described above and has not notified the Concessioner in writing of extraordinary circumstances that justify delay, the Concessioner may implement the requested rates without a final, written decision from the Service. If the Service denies the requested change to rates after the Concessioner implements the requested rates, the Concessioner is not required to retroactively adjust rates for services booked prior to the denial.

(6) Management of Rates under the CMD Method. The Concessioner is permitted to set and change prices based upon what the Concessioner determines the market will bear for service types approved under the CMD method.

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(a) Rate Adjustment. The Concessioner may adjust rates of CMD and non-core goods and services without prior notification to or written approval from the Superintendent.

(b) Service Rate Monitoring. The Service will monitor to verify that rates remain reasonably like those of competitors, that utilization (occupancy) remains similar to prior periods and does not decline due to rates and charges, and that visitor satisfaction data demonstrate visitors are satisfied with the Concessioner’s services. Rate monitoring will be conducted by Service category using Concessioner data provided in accordance with Operational Reporting Requirements outlined in Section 7.A of this Operating Plan and available data on the Concessioner’s competitors.

(c) Concessioner Rate Monitoring Plan. Within 60 days of the contract effective date, the Concessioner must submit a rate monitoring plan that includes its rate setting strategy regarding how it will price against competitors and initiate its own adjustments to rates in response to changes in competitor rates, occupancy, and visitor satisfaction levels, and what thresholds, standards, or benchmarks it will use as actionable trigger points. The plan must also describe the type, source, and scope of available data, occupancy/utilization information, and visitor satisfaction information it will supply to the NPS. The concessioner’s rate monitoring plan is subject to Service approval. The Concessioner’s plan must describe a variety of monitoring components, including:

• Monitoring by service type

• Competitors by service type

• How it will track competitor pricing

• What its strategy is for pricing against competitors

• How it will monitor utilization

• How it will monitor visitor satisfaction

(d) Rate Monitoring Information. The concessioner must supply the Service rate monitoring information as described above and as proposed in its rate monitoring plan on a monthly basis, aligned to its operational performance report.

(7) Published Rates and Compliance

(a) Approved Rate Posting. The Concessioner must prominently post all rates for goods and services available to visitors. In the case of Comparability, Core, MSRP, and Markup, the Concessioner must ensure no published or posted rates exceed any respective maximum rates approved by the Service.

(b) Rate Compliance Monitoring. The Service checks rate compliance during periodic operation evaluations and throughout the year. In the case of rates set through Comparability and Core methods, approved rates must remain in effect until superseded by changes approved in writing by the Service.

(c) Published Rate Monitoring. The Concessioner must ensure no published rates exceed the maximum rate approved by the Service, which includes, but is not limited to, Concessioner website, Concessioner telephone reservations system, and third-party booking agents. Third-party companies (travel agencies, online booking engines, etc.) that are selling rooms or services for the Concessioner must sell those rooms or services at or below the Service-approved maximum rate. The Concessioner must include any service fee or commission that the third-party charges in the approved maximum rate.

(9) Reduced Rate for Government Employees. Goods and services will not be provided to government employees or their families without charge or at reduced rates unless equally available to the general public and/or agreed upon in the annual rate request.

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C) Purchasing

(1) Competitive Purchasing. The Concessioner may buy from a facility the Concessioner or parent company operates or owns, if the product is comparable in quality and price to similar products from unrelated suppliers or manufacturers.

(2) Discounts. To the extent applicable to the rate approval method in place, the Concessioner must take advantage of all available trade, cash, and quality discounts and rebates and pass them through to the consumer.

(3) Environmental. The Concessioner must purchase and use Environmentally Preferable products whenever available and feasible.

D) Reservation Policy and Procedures

(1) Lodging Reservations, Deposits, Refunds and Shuttle

(a) The Concessioner will staff the Reservations Office adequately to meet the needs during peak and non-peak hours. A reservation agent must be available within 30 minutes of call initiation during peak periods and 10 minutes of call initiation during non-peak periods. The Concessioner will accept telephonic reservation requests and at least three of the following additional modes: internet, mail, fax, email.

(b) The Concessioner will maintain a bed space waiting list to efficiently and equitably utilize spaces that become available because of cancellations during the reservation season.

(c) The Concessioner may accept reservations up to 18 months and one day in advance. Visitors may be required to submit a deposit amount up to the full amount for occupancy, meal charges, and tax to hold a reservation. The deposit requirement and refund policy is a part of the rate approval process. Customers may pay any deposit by cash, check, money order, major credit card or any combination of these.

(d) If a customer cancels 30 or more calendar days before a reservation, the Concessioner will refund the full deposit. If the cancellation is made less than 30 calendar days in advance, the deposit is forfeited unless the rooms are filled. Rates confirmed by the Concessioner will be honored at the time of stay. Refunds will be processed within one month of cancellation.

(e) The Concessioner will email guests a reservation confirmation. The confirmation email must advise guests that demand for parking often exceeds capacity at trailheads, that guests must avoid parking in marked “no parking zones” and include a link to the Park’s parking norms webpage (https://www.nps.gov/grsm/learn/management/park-safely.htm). The Concessioner’s shuttle operation procedures will be provided to guests at the time of reservation. The Service will add the contact information of the Concessioner’s shuttle service to the park’s Directions & Transportation shuttle website (https://www.nps.gov/grsm/planyourvisit/shuttles.htm). This link will be included in the reservation confirmation email. The Concessioner’s website must also advise prospective visitors of the above by providing the advisory and the links on their reservation pages.

(f) The Concessioner must submit its Reservation and Refund Policy (including the text of the confirmation email) to the Service within 120 calendar days of the award of this Contract and 30 calendar days before the implementation of any new reservation and refund policy changes.

(g) Minimum staffing hours for the telephone reservation line will be 8:30 a.m. to 5:00 p.m., Monday – Friday.

https://www.nps.gov/grsm/learn/management/park-safely.htm https://www.nps.gov/grsm/planyourvisit/shuttles.htm

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(2) Room Assignments

(a) Unless the reserving guest requests specifically, the Concessioner will not assign guests other than immediate family members to share a guest room.

(b) Each bedroom in the two- and three-bedroom lodges is considered a separate guest room and may be booked accordingly.

(c) When a reservation results in room or bed sharing, the Concessioner will advise guests about type and number of beds that are available in the guest room or rooms assigned (e.g., bunk, double, twin, etc.).

(3) Priority Reservation Termination

(a) National Park Service policy prohibits granting special privileges to certain individuals or groups in the award of reservations. The priority reservation system used under prior concessions contracts is terminated. Reservation holders do not have an option to renew preexisting reservations.

(4) Standing Reservations for Park Educational Programs

(a) Notwithstanding the reservation policy, when the Service makes a request before the regular reservation period starts, the Concessioner will reserve space for educational programs that the Service sponsors. The Service may reserve space for up to 20 participants per night and for up to three dates per season. The Service may request standing reservations for certain dates that are renewable for subsequent seasons.

(b) The Service will request reservations or confirm standing reservations for the following season by September 15 each year and the Service will be required to pay the required deposit by November 1 each year to retain these reservations for the following season. Before releasing these standing reservations for booking by other parties, the Concessioner will contact the Service and obtain written confirmation that these organizations do not plan to use their standing reservation for the following season. If the required deposit is not received by December 1, the Concessioner may release the standing reservation for booking by other parties.

(c) The education partners who hold written agreements with the park and support the Area’s resource education objectives by conducting field trips and programs are permitted to hold up to three standing reservations for LeConte Lodge for the same dates each year. These educational organizations may reserve space for up to 20 program participants per night.

(d) The standing reservation dates for the education partners during the first season under this Contract will be the dates the education partners reserved during the final season under the previous Contract or other available dates the Service approved before the first reservation period under this Contract . The education partners must submit requests to change the standing reservation dates by September 15 each year.

(e) By September 15 each year, education partners with standing reservations must confirm their reservations for the following season and must pay the required deposit by November 1 each year to retain these reservations for the following season. Before releasing the standing reservations, the Concessioner will contact the education partners and get their written confirmation that they will not use their standing reservation for the following season. If the Concessioner receives the required deposit by December 1, the Concessioner may release the other parties standing booking reservation.

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(f) The Service may modify the list of educational partners eligible for this consideration as required. Current partners include:

• Great Smoky Mountains Institute at Tremont

• Smoky Mountain Field School

• Great Smoky Mountains Association

• Friends of the Smokies

(g) The educational partners may not charge participants a lodging and meals fee that is more than the Concessioner’s approved rate for these services. However, these educational organizations are not precluded from charging a separate fee for the educational programs they provide.

E) Evaluations and Inspections

(1) Service Concession Review Program. The Service will evaluate the concession facilities and services to assess and rate concessioner performance per the NPS Concession Review Program as the Service Policy’s describes. The Service will use the evaluation results to prepare an Annual Overall Rating. Service personnel may implement the NPS Concession Review program and prepare the Annual Overall Rating. The Service may request third-party subject matter experts’ help. The Service may incorporate the experts’ findings in the Service’s evaluations. The Concessioner must give full access to managers, facilities, documents, and other resources the Service needs to conduct these evaluations. The Concessioner must work with Service officials to prioritize, schedule, correct deficiencies, and implement improvement programs resulting from these activities. The Service may consider how the Concessioner addresses deficiencies on schedule and timely in deciding the Concessioner’s rating. The Concession Review Program evaluations components are:

(a) Periodic Operational Evaluations. The Service will evaluate the concession facilities and services periodically to assess if the Concessioner is following applicable service standards and other operational requirements. The Service may contact the Concessioner during facility evaluations so that a Concessioner representative may accompany the evaluator.

(b) Operational Performance Report. The Operational Performance Report and Rating collates the individual periodic evaluations scores and weights them if necessary.

(c) Administrative Compliance Evaluation. The Service will assess how the Concessioner follows administrative and contractual requirements annually, including the Annual Financial Report’s timely submission, submitting franchise fees timely and accurately as well as following proof of insurance requirements.

(d) Asset Management Evaluation. The Service will conduct an annual asset management evaluation and rating. The evaluation will consider performance against requirements in maintaining facilities as the Concession Contract defines, including but not limited to, the Maintenance Plan.

(e) Environmental Management Program Evaluation. The Service will evaluate the Concessioner’s Environmental Management Program (EMP) annually. The evaluation will consider how the Concessioner protects natural resources, meets environmental compliance requirements, and operates per the Concessioner’s documented EMP. Performance in addressing the Concessioner’s environmental audit findings will also be an evaluation component.

(f) Public Health Program Evaluation. A United States Public Health Service (USPHS) representative will evaluate Concessioner’s food and beverage operations periodically. The representative will use the U.S. Food Code and other applicable public health standards to evaluate these operations per Service Public Health Service procedures. The Concessioner must post a public notice in its food and

CC-GRSM002-25 Exhibit B: Operating Plan Page B-9 beverage operation that the results of food and beverage facility public health inspections are available from the Superintendent’s Office.

(g) Risk Management Program Evaluation. The Service will evaluate the Concessioner’s Risk Management Program (RMP) annually. This evaluation will consider performance in implementing life safety and fire safety programs and operating per the Concessioner’s documented RMP. The Service will conduct any life or fire safety inspections; this will be an evaluation component of Periodic Operational Evaluations.

(h) Visitor Satisfaction Review. The Service will review the Concessioner’s visitor satisfaction program results, complaints, and comments on Concessioner’s services.

(i) Annual Overall Rating. By April 1 for the preceding calendar year, the Service will decide and give the Concessioner an Annual Overall Rating. The Service will base the rating on the Concession Review Program evaluations results. The results of other Service audits and inspections and operating performance information may also be considered in this rating.

(2) General. Both the Service and the Concessioner will inspect and monitor concession operations, including the concession facilities, regarding Service policy, applicable standards, authorized rates, safety, public health, impacts on cultural and natural resources, and visitor concerns and reactions.

(3) Health and Safety

(a) The Concessioner’s Safety Manager is responsible for health and safety inspections in employee housing areas. The Safety Manager will ensure employees follow Service’s health, fire, and safety code regulations, policies, and guidelines. The Safety Manager will perform periodic interior and exterior safety inspections of all the concession facilities and operations, per its documented Risk Management Plan.

(b) The Area's Safety Manager will conduct at least one annual comprehensive safety and occupational health inspection evaluation.

(c) The Regional Public Health Consultant (RPHC) will conduct periodic food service, water, and wastewater system evaluations; RPHC may inspect without prior notice.

The Concessioner will maintain and follow a formal, written food service sanitation self-inspection program. The Service will help develop and update the program as necessary.

(d) The Concessioner will have a qualified professional perform interior and exterior fire inspections of all concession facilities within 30 calendar days of initial occupancy and annually thereafter. By no later than May 1 during each Contract year, the Service’s professional will give the Concessioner a complete and signed written inspection report.

F) General Policies

(1) Facilities Use. The Concessioner may use concession facilities only for activities or services that directly and exclusively support contractual services the Contract require and authorize.

(2) Smoking Policy. All buildings in the concession facilities are designated as non-smoking per Directors Order 50D.

(a) Smoking is not permitted in public buildings at LeConte Lodge or in shared employee housing or interior work areas.

(b) The Concessioner will post notices in all public buildings and interior workspace as necessary.

(c) The Concessioner will designate specific outdoor areas for smoking by Lodge guests and employees.

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(d) Payment Methods. The Concessioner must accept the following pay methods for all services.

(e) U.S. Currency

(f) Cashier’s checks and traveler’s checks with proper identification

(g) Credit Cards. At least, the Concessioner must honor at least three types of major credit cards. The Concessioner must accept debit cards.

(h) Receipts. The Concessioner will give guests digital receipts and will keep a digital inventory of transactions.

(i) Lost and Found. The Concessioner must establish and provide an effective program for handling lost and found or unattended property in concession facilities. This program must include property that the concession employees may have abandoned. This program must integrate with the Area’s existing Lost and Found Property Procedures, Management Directive No. 10. The Service will give the most recent version including Form No. 10-166, “Lost-Found Report”, for use.

(j) The Concessioner must report lost and found items at or turned in at the concession facilities on the Lost-Found Report (Form 10-166) with enough information as possible to return the item. The Concessioner will turn over to the Park items not claimed in seven calendar days, including the item’s proper identification, name, address, and signature of receipt.

(k) The Concessioner must give the Park a copy of its lost and found policy within 60 calendar days after the Contract’s effective date and within 30 calendar days of any policy changes.

(l) The Concessioner must maintain a centralized location to store all lost and found items that includes secure storage for items like money, jewelry, or other valuable articles.

(m) Visitor Comments

(n) Comment Cards.

• The Concessioner must make Service-approved comment cards available to visitors to measure service and quality standards, product mix, pricing and overall Area experience.

• The Concessioner must keep an adequate comment cards inventory available at appropriate concessions facilities.

• At least, the Concessioner must maintain one labeled visitor comment box with comment cards in a highly visible concessions facility.

(o) Comments or complaints the Concessioner received.

• Within 14 business days after the Concessioner receives a visitor complaint about its services, the Concessioner must investigate and respond. The Concessioner must give the Service a copy of the initial comment, the Concessioner’s response, and any other supporting documents.

• The Concessioner must give the Service all visitor comments that allege misconduct by Concessioner or Service employees, or concerns of visitor or employee safety, or concerns of the safety of Area resources within 24 hours of receipt of the comment by the Concessioner.

(p) Comments or complaints the Service receives

• The Service will forward to the Concessioner any comments or complaints received about the concession facilities or services. The Concessioner must investigate and respond to any complaints within 14 business days after receiving the complaint. The Concessioner must give a copy of any responses to the Service. The Service will forward to the Concessioner copies of its responses, if any.

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(q) Visitor comment reporting

• The Concessioner must include a summary of visitor comments received during the prior month in the Monthly Contract Monitoring Report that is due by the 15th of each month during the operating season. If applicable, the Concessioner must provide any visitor comments analysis and any action plan developed to correct any service-related issues the data identified. Instead of the summary, the Concessioner may submit copies of each comment card received during the prior month.

• If applicable, the Concessioner must also submit within 14 business days of receipt, a copy of any customer satisfaction data third parties collected on the Concessioner’s behalf including any statistical analysis of this data.

• On request, the Concessioner must give the Service copies of individual comment cards or other supplemental information that supports the summary provided.

G) Human Resource Management

(1) Employee Identification and Appearance. The Concessioner must ensure that all employees who interact with the public wear uniforms or standardized clothing with a personal nametag.

Employees must be neat and clean in appearance and must project a hospitable, positive, friendly, and helpful attitude. Attire must be freshly laundered and in good condition (not torn, stained, or excessively faded). The Concessioner must submit initial uniform standards for Service approval and any changes at least 60 calendar days before buying uniform items.

(2) Firearms: Concession employees may not possess firearms while on duty. The Concessioner must advise employees about this prohibition. Federal law prohibits firearms in federal facilities, like Service visitor centers; these facilities are posted with appropriate notices at public entrances.

Additionally, firearms are not allowed in concession-managed facilities that are posted with firearms prohibited signs.

(3) Employee Hiring Procedures

(a) Staffing Requirements. The Concessioner must hire enough employees to ensure satisfactory visitor services during the operating season. The Concessioner must offer employees a full work week whenever possible. Before employment, the Concessioner must inform employees about salary, schedules, holiday pay, overtime requirements, and the possibility that less-than-full-time employment may occur during slow periods.

(b) Drug-free Awareness and Testing Program. The Concessioner must give its drug and alcohol abuse policies and have educational program(s) for its employees to deter drug and alcohol abuse. The Concessioner must make results of drug testing available to the Service on request.

(c) Background Checks. The Concessioner must request and review a state certified copy of the applicant's criminal history and driving transcript. The Concessioner must not hire an employee with any active warrants (current fugitive from justice). In reviewing any past criminal convictions, the Concessioner should consider the appropriateness of hiring the applicant into a position, given the purpose of maintaining a healthful, law abiding, and safe working environment for the public, and park and concessioner employees. In doing so, the Concessioner should consider the nature of any past offenses, the amount of time that has transpired, and the applicant's academic or employment track record since the time of any offenses. The Concessioner must make available, upon request, the type and status of background investigations conducted on employees to the Chief Ranger’s Office. Prospective employees must be made aware before the hire that this information may be made available to the Service.

CC-GRSM002-25 Exhibit B: Operating Plan Page B-12

(d) Driver Requirements. The Concessioner-owned vehicle drivers operating under the Contract must have a valid state operator's license for the size and class of vehicle driven.

(e) Service Employees. The Concessioner must not employ in any status a Service employee, his or her spouse, or a minor child without the Superintendent’s written approval. The Concessioner must not employ in any status the Superintendent’s, Deputy Superintendent’s, Administrative Officer’s, Concessions Management Specialist’s, or Safety Officer’s spouse or children.

(4) Training

The Concessioner must provide appropriate training as follows:

(a) Manuals. The Concessioner must develop written training materials for its employees as an Employee Training Manual. The Concessioner must give the Service an initial copy of these materials within 60 calendar days after the Contract’s effective date and within 30 calendar days of any changes.

(b) Safety. The Concessioner must train its employees annually per the Risk Management Plan training requirements.

(c) Orientation. The Concessioner must give at least 8-10 hours of mandatory orientation and training for its employees.

• The Concessioner must emphasize to its employees that they may not feed wildlife.

• The Concessioner may request Service staff present on park purpose and mission.

(d) Job Training. The Concessioner must give appropriate job training to each employee before duty assignments and working with the public. Training must include the following besides job-specific skills:

• Service Concessions Management. The Concessioner must orient its managers to Service evaluation and rate policies, as outlined in Concessions Management Guidelines.

• Customer Service. The Concessioner must give customer service and hospitality training for employees who have direct visitor contact.

• Resource and Informational Training. The Concessioner must provide training about Area resources, visitor attractions, and visitor services for all employees who interact with the public. Training must incorporate information the Service gives for this purpose specifically, if any.

• Interpretive Training. The Concessioner must give interpretive skills training to all employees who provide interpretive services. The Concession employees who will provide these programs are encouraged to attend the seasonal orientation program the Service provides for its resource education employees.

• First Aid and CPR. At least, employees must be trained in basic first aid and CPR and possess a current certification.

• Environmental Training. The Concessioner must give environmental training to all employees per its Environmental Management Program.

• Llama or helicopter operations training as per the requirements under the Operating Plan.

(5) Employee Responsibilities. The Concessioner must require their employees to always follow all federal and state laws.

CC-GRSM002-25 Exhibit B: Operating Plan Page B-13

H) Staffing and Employment

(1) Employee Housing

(a) The Concessioner must provide all services in a consistent, environmentally sensitive, and high-quality manner and must operate per the operating standards of the Service’s Concessioner Operational Performance Standards. The applicable Service standard, Employee Housing (10-EHO), can be found at https://www.nps.gov/subjects/concessions/standards-and-evaluations.htm ) and specifies the minimum operating standards that the Concessioner must meet in providing the required service under the Contract. This Contract (including Exhibits) presents Area-specific requirements, additions, and exceptions to these standards.

Where there are conflicts between the applicable Service standards and the requirements in the Contract (including Exhibits), the Contract (including Exhibits) requirements prevail.

(b) The Concessioner will provide housing and food service for its employees who work on site at LeConte Lodge routinely. The Concessioner should provide food service and room board at or below cost to the extent possible. The Concessioner should ensure that employee room and board charges do not exceed employee earnings.

(c) The Concessioner will inspect all quarters for fire and safety compliance within 30 calendar days of initial occupancy of a residence.

(d) The Concessioner will ensure that employee rooms are adequately furnished to serve the number of occupants. Minimum employee room amenities will include:

• bed with mattress and foundation,

• pillow,

• clean bed linens for each employee at least weekly or anytime another employee will occupy the room,

• bath and hand towel,

• dresser or chest for clothing and personal items,

• chair,

• propane space heater,

• oil lamp, and

• curtains or other window coverings.

(e) Both the Service's Safety Manager and the Concessioner's Risk Management Manager are responsible for health and safety inspections in employee housing areas. The Area's Concession Management Specialist inspects concession employee housing periodically.

(f) The Concessioner will provide adequate cooking and food storage facilities for the winter caretaker. The Concessioner will assure its employees follow the Service’s health, fire, and safety code, regulations, policies, and guidelines. Food storage facilities will be bear and vermin proof.

(2) Employee and Staffing Practices

(a) The Concessioner will establish and enforce written uniform and personnel appearance standards for its employees to assure that employees who deal with the public present a neat, clean, and otherwise attractive personal appearance.

(b) The Concessioner will ensure that employees project a hospitable, friendly, helpful, positive attitude, and can and will provide visitor assistance. The Concessioner will take appropriate steps to enforce these rules.

(3) Service Employees and Families

CC-GRSM002-25 Exhibit B: Operating Plan Page B-14

(a) The Concessioner will not employ in any status a Service employee, his or her spouse, or Service employee’s minor children without the Superintendent’s approval.

Employees must submit a written request to the Superintendent. The Concessioner will not employee in any status the Superintendent’s, the Assistant Superintendent’s, Concessions management Specialist’s, Regional Public Health Consultant’s or Safety Manager’s spouse or children.

I) Interpretive Services

(1) Concessioner Resource Education Plan

(a) The Concessioner will develop and implement a Concessioner Resource Education Plan that focuses on employee training, personal interpretive services, non-personal interpretive services, and retail items.

(b) Before implementing the plan, the Concessioner will send it to the Service for approval.

(2) Personal Interpretive Services

(a) Employee Knowledge. Employees must show their knowledge of the National Park Service, its mission and values and the cultural and natural resources in Great Smoky Mountains National park generally and specifically Mount LeConte. Staff must use appropriate interpretive techniques in their interactions with visitors when doing functions like giving directions and answering basic Area questions.

(b) Comprehensive Resource Education Plan. The Concessioner’s management employees and supervisors must know the Area’s Comprehensive Resource Education Plan, that the Service will give to the Concessioner. The Concessioner will use this plan as a guide to give visitor services in a way that supports the interpretive themes, goals, and objectives that this document describes.

(c) Formal Education Programs. With the Service’s approval, the Concessioner may offer formal educational programs to guests, the public or both. If the Concessioner chooses to offer these programs, they must offer them to Lodge guests and the public at no cost.

• The Concessioner will submit to the Resource Education Division for approval, the programs’ themes and outlines including any handouts, props to be offered, or both before offering these programs. The Concessioner will develop Individual Service Plans (ISP) for all programs offered (i.e., hikes, walks, talks, and contact station areas) and submit these for Service review.

• The Concessioner will post notices for Concessioner provided programs to inform guests of the program schedule and will advise guests of the program schedule at check-in.

• If the Concessioner offers educational programs, the Concessioner will hire enough employees to conduct these programs with an educational background that qualifies them to conduct the programs. The Concessioner will give additional training to these employees as needed to enable them to meet NPS Standards for quality programs for the public. The employees will be encouraged to participate in the NPS Interpretive Development Program and submit products for certification. The Concession employees that will give these programs will be required to attend the seasonal orientation program the Service provides for its resource education employees. This training is usually offered the first two weeks after Memorial Day and includes up-to-date resource information and interpretive skills training. The Service may be able to provide limited training for employees on site at LeConte Lodge at a time that is determined to be mutually convenient. The Concessioner may be required to reimburse the Service for the cost of providing on-site training.

CC-GRSM002-25 Exhibit B: Operating Plan Page B-15

• The Service will audit these programs at least two times each season to evaluate these programs’ quality and suitability, and to give constructive suggestions to the employees presenting these programs.

• The Concessioner will keep these programs’ attendance records and report to the Service these figures as part of the Monthly Recreation Visits report. The Service will evaluate these programs’ effectiveness annually based on attendance, audits, and discussions with the Concessioner and may modify this requirement based on this evaluation.

(3) Non-Personal Interpretive Services

(a) Locations. The Concessioner must integrate Area interpretive themes into the interior decor of merchandise and service facilities and must install and maintain educational displays in common areas at the Lodge (office and dining room) providing pertinent information about Mt. LeConte, LeConte Lodge, LeConte trails, safety messages, and the Area’s resource education themes.

(b) Area Information. The Concessioner must make Park informational handouts available at the Concession Facilities.