08 Exhibit G Operating and Maintenance Standards_508.pdf

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Table of Contents

EXHIBIT G

OPERATING AND MAINTENANCE STANDARDS

TABLE OF CONTENTS

I. INTRODUCTION

II. OPERATING STANDARDS

A. Services Required B. Lodging C. Food and Beverage D. Retail G. Food Trucks H. Equipment Rental I. Public Laundry and Showers J. Guest Trailhead Shuttle K. Step-on Guide Service L. Employee Housing and Services M. Service Standards N. Periodic evaluations and inspections O. Guest Satisfaction Survey System P. Smoking Policy Q. Possession of Firearms R. Interactions with Wildlife S. Human Resources Management T. Public Relations U. Informational and Interpretive Materials V. Procedure for use of NPS “Authorized Operator” Mark W. Structural Fire Prevention, Protection, and Suppression X. Risk Management Program Y. Environmental Management Program

III. MAINTENANCE STANDARDS

A. GENERAL STANDARDS .................................................................... Error! Bookmark not defined.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-1

I. INTRODUCTION

These Operating and Maintenance Standards, as defined in the Agreement, will be reviewed annually by the Owner in consultation with the Management Company and Asset Manager and revised as determined necessary by the Superintendent of the Area.

Any revisions will be consistent with the main body of the Agreement and must be reasonable and in furtherance of the purposes of the Agreement.

II. OPERATING STANDARDS

A. Services Required

In the Area, the Management Company will operate lodging rooms, suites, and cabins; upscale-casual, fast-casual, and quick-service food and beverage operations; retail; public showers; public laundry; recreational equipment rental; and employee housing and other services agreed to between the Owner and Management Company. The Owner has specific definitions for each of these service types which can be found on the BRCA VEIA Prospectus/Business Opportunities website.

The Owner intends to contract with an experienced Asset Manager to advise the Owner with respect to the Hotel and the decisions to be made about the Hotel by the Owner under this Agreement, as described in Section 4.10.B. of the Agreement.

The Management Company will operate and maintain the Hotel and provide the required services per the minimum operating schedules specified for each service as described below. If the Owner decides to require that certain facilities be open earlier than scheduled, or the Management Company agrees to extend the season, or operate year-round, the Owner will give the Management Company at least eight (8) weeks’ notice of the schedule change. The Management Company, through the Asset Manager, may also request an extension of the operating season for all or some facilities.

The visitor services that the Owner requires the Management Company to provide at the Hotel are described further in the chart below.

Number Service Description 1 Lodging 114 units, with midscale hotel units including cabins 2 Food and beverage Upscale casual restaurant at Bryce Canyon Hotel, fast-casual restaurant adjacent to Bryce Canyon Hotel, and a grab-and-go at the General Store

3 Retail Gift shops at the Bryce Canyon Hotel and General Store and vending machines

4 Equipment Rental Recreational equipment rental and limited retail and snacks related to equipment rentals out of the historic service station https://www.nps.gov/subjects/concessions/brca-veia.htm

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-2

Number Service Description 5 Guest services Laundromat (at General Store), Public Showers (coin-operated at General Store)

The Management Company will maintain the Hotel in good operating order, repair, and condition, including making necessary replacements and improvements and formulating and implementing preventative maintenance and other programs designed to maintain the condition of the facilities, including all "back of the house" areas, the HVAC systems serving the Hotel, fire and life safety, plumbing, and other Systems as described in Section 3.15 of the Agreement.

B. Lodging

The main lodging facility, the Bryce Canyon Lodge (“Lodge”), frequently considered among the “Great Lodges of the National Parks,” was constructed by the Union Pacific Railroad in 1925. On the National Register of Historic Places, the Lodge houses the reception desk for lodging, four guest suites, administrative offices, retail space, patio seating, a full-sized restaurant and kitchen, the employee dining room, public restrooms, and lounging spaces with large stone fireplaces in the main lobby and a separate auditorium.

The Management Company will provide space, at no charge, to accommodate selling tickets for the concessioner providing guided horseback rides (currently “Canyon Trail Rides”) in the lobby area.

The Owner recently completed the installation of buried fiber-optic lines that can service many of the Hotel facilities. The lines connect directly to the Lodge, and the Ponderosa and Whisperings Pines dorms. The Owner may require the Management Company to expand the fiber-optic lines to other facilities.

The Management Company will operate 114 lodging accommodations as summarized in the following chart.

Lodging Facilities Number of rooms Classification Minimum Operating Season

Sunset Motel 35 Midscale Late March through December

Sunrise Motel 35 Midscale Late March through early November

Lodge Suites 3 Midscale Late March through early November

Lodge Studio Suite 1 Midscale Late March through early November Western Cabins (quadraplexes) 20 Midscale May through

September Western Cabins (duplexes) 20 Midscale May through

September

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-3

C. Food and Beverage

The Management Company will operate three types of food and beverage service. From late March through early November, the Management Company will operate a full-service (currently 172 seats) restaurant inside the Lodge that serves breakfast, lunch, and dinner in the “upscale casual” classification. The maximum capacity, assuming four table turns during an evening dinner service, is approximately 650 covers per night. During the remainder of the year, the Management Company may propose, subject to Owner approval, to keep the Lodge open and operate with reduced seating, amenities, and menu selection.

The Management Company will operate a fast-casual food and beverage outlet at the historic recreation hall, located across the parking lot from the Lodge, from late March through early September. The historic recreation hall has indoor and outdoor seating for 36 people. Finally, the Management Company will carry a variety of prepackaged food and beverages that focus on high quality, fresh offerings of grab-and-go, and hot and cold food, at the General Store and Historic Service Station from March through December. During the peak season the food and beverage facilities serve a large volume of people and have significant surges in demand.

The Owner may require the Management Company to add additional beverage and light food service in the Lodge through a coffee cart or bar cart in the auditorium and create a relaxing, community gathering space. NPS rangers would continue to use the auditorium to give scheduled public presentations two to three times per week during the summer months as well as astronomy programs two to three times per week in the spring and fall when outdoor venues are too chilly. The Management Company and the Area superintendent will cooperate and negotiate the auditorium scheduling and the responsibilities for moving lounge furniture and auditorium seating to expand program seating as needed for popular events.

D. Retail

The Management Company will operate two primary retail outlets. The Management Company will operate the General Store at least from March through December selling merchandise including camping supplies, grab-and-go food, groceries, beer and wine, convenience items, souvenirs, apparel, ice, and bundled firewood. From late March through early November, the Management Company will sell merchandise including gifts, souvenirs, and limited convenience items from the store inside the Lodge. Additionally, the Management Company will operate vending machines in areas convenient to the public and subject to Owner approval and offer a limited supply of retail related to equipment rentals, including limited snacks, at the Historic Service Station.

The Owner has the right to review and approve all merchandise sold within the Area. The Owner may determine certain items are inappropriate and unacceptable for sale.

The Management Company will develop and implement an Owner-approved Merchandise Plan no later than 90 days from the Commencement Date of the Agreement. The Merchandise Plan must

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-4 incorporate environmental considerations (in accordance with the EMP and laws and policy), and educational and interpretive themes, in accordance with the Bryce Canyon National Park Gift Shop Mission Statement (found after Section III). The Merchandise Plan will address the following:

• Sales mix and types of merchandise, including gifts, souvenirs, Indian products as defined at 25 C.F.R. § 309.2, convenience items, groceries, camper/hiker supplies, apparel, and vending machines.

• How merchandise is consistent with the Operating Standards in this Exhibit.

• Display standards, including interpretive and educational messaging, and stocking requirements.

• Finding, purchasing, displaying, and selling “Made in the USA” products, local Indian products, and local artists’ handcrafts.

Items Available for Sale:

• Gifts and Souvenirs. Gifts and souvenirs will include items that have a direct relationship to Bryce Canyon National Park, its environs, history, or related natural or cultural topics. This will provide visitors with opportunities to buy memorabilia of their visit while at the same time obtaining information or educational messages related to the Area’s resources.

• Convenience Items, Sporting Goods, and Recreational Equipment. At the Gift Shop and the General Store, the Management Company will carry a selection of convenience items, sporting goods, recreational equipment, and clothing to meet the needs of visitors who may have forgotten items, need additional items for personal safety, or need emergency replacements. The intent of this visitor service is to provide an appropriate selection of items representing a range of price and quality levels. The Management Company must request and receive permission from the Owner for any sale of insecticides and pesticides.

• Groceries and Related Convenience Items. The Management Company will provide a wide range and selection of and pricing for grocery and convenience items appropriate for the Area at the General Store.

E. Sale of Specimens

The Management Company will not sell reproduction artifacts or specimens (projectile points, fossil casts, etc.) that are not clearly labeled as such. Merchandise sales outlets will display the following message at a prominent location within the store, such as at the register: “The natural materials – rocks, plants, animal products – featured in some of our merchandise come from legally authorized sources obtained outside National Park Service areas.”

F. Vending Machines

All vending machines must feature a design and color that complement the aesthetics of the building and surroundings. The Management Company must obtain the Owner’s approval of all machine locations and exterior aesthetics before placing the machines in the Hotel. The

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-5

Management Company will keep all machines clean, properly stocked, and in good working condition. The Management Company will ensure that machines are adequately illuminated but do not contribute to night light pollution. The Management Company will place computer-generated signs on any vending machine that is temporarily out-of-service. The Management Company may not offer cigarette vending machines but is permitted to sell tobacco products at the General Store and the Gift Shop.

G. Food Trucks

The Management Company may be required to provide food truck service in developed areas of the Area (specifically along the scenic roadway to various viewpoints).

H. Equipment Rental

The Management Company must provide recreational equipment rentals (including, at a minimum, bicycle rentals) and limited retail and snacks related to equipment rentals from May 1 (or earlier if weather permits) through October 31 from the Historic Service Station. The Management Company must coordinate with the Owner for approval on the number and type of equipment rentals and operating hours. When equipment rentals are available, the Management Company must provide custodial service to the attached restrooms from May 1 (or earlier as weather permits) through October 31.

I. Public Laundry and Showers

The Management Company will operate the public laundry and showers at the General Store during the campground season, currently April through September.

J. Guest Trailhead Shuttle

The Owner may require the Management Company provide a guest shuttle to Rainbow Point or transportation to other trailheads and viewpoints. The Management Company will inspect each of its vehicles used for this service daily and retain records of each inspection. The Management Company will correct all safety defects found before the vehicle resumes service. All vehicles are subject to random and unannounced inspections by the State of Utah and the Owner. All vehicles transporting visitors will maintain two-way radio contact with Management Company dispatchers.

The Management Company will ensure that supervisory staff is available to communicate with drivers as necessary.

K. Step-on Guide Service

The Owner may consider offering step-on interpretive guide service to buses touring the Area.

Either the Management Company or another authorized entity would provide the service. The Owner would provide training sessions in the Area’s fundamental resources, values, and interpretive themes to Management Company’s staff if it provides the tours. The Management Company would develop and submit to the Owner for approval its interpretive program.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-6

L. Employee Housing and Services

The Management Company will employ all employees required to operate the Hotel and will oversee in-park housing, food service, and a recreation program for its seasonal and permanent workforce. The employee dining room is located in a wing of the Lodge adjacent to the restaurant kitchen. The table below lists the employee housing facilities managed by the Management Company by location. The Management Company will work with the Owner to determine the number of employees assigned to each facility. Up to 139 employees have resided at these locations.

To reduce the number of employees housed in the Area, the Management Company must locate back-of-house administrative positions outside the Area in a corporate or other remote location to the greatest extent possible. Housing in the vicinity of the Area is relatively scarce, and employee housing for both Management Company and Owner staff is at a premium. The Owner would prefer the Management Company allocate some of the employee housing outlined below to Owner staff.

Description Number of Bedrooms/Unit B-67 Dormitory A (Whispering Pines Dormitory) 20 B-68 Dormitory B (Ponderosa Dormitory) 21 B-66 Married Dormitory (Manzanita Lodge) 10 HS-106 Male Dormitory (Knotty Pine Dormitory) 17 B-47 Bunkhouse 1 Bunkhouse Trailer Sites (with full hook ups) 2 sites

M. Service Standards

The Management Company must operate the Hotel in accordance with the Owner’s service standards which are consistent with industry classifications. The Owner’s service standards are available on the BRCA VEIA Prospectus/Business Opportunities website.

N. Periodic evaluations and inspections

The Management Company will provide appropriate access to facilities, staff, and records so the Owner, or a third party authorized by the Owner, may conduct both announced and unannounced periodic operational evaluations of services to ensure conformance to applicable operational and maintenance standards, including of the following:

i. Safety and Fire Prevention. In addition to the risk management component of periodic evaluations, the Owner may conduct safety and fire prevention inspections of the Hotel.

ii. Animal Pest Exclusion. The Owner will evaluate whether the Management Company complies with Owner’s pest exclusion standards.

iii. Accessibility. The Management Company is responsible for understanding and complying with accessibility laws.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-7

iv. Healthy and Sustainable Food. The Owner will evaluate the food and beverage operations’ compliance with the Owner’s Healthy Food Choice Standards (required) and Sustainable Food Choice Guidelines (recommended).

1. Public Health Inspections. An officer of the U.S. Public Health Service will conduct periodic evaluations of the food and beverage operations. These evaluations will be conducted in accordance with the U.S. Food Code.

2. Environmental Audits. The Owner may conduct environmental audits to evaluate the operations with respect to environmental compliance and environmental best management practices in accordance with the Owner’s VEIA Environmental Management Program Standards. The Owner considers the Management Company’s performance in closing audit findings in specified timeframes in the annual evaluation of the Management Company’s Environmental Management Program.

3. Integrated Pest Management Inspections. The Owner may conduct integrated pest management inspections of all facilities and operations, which may consider issues such as vector control and exclusion practices, pesticide application practices, and others.

4. Informational and Interpretive Materials Review. The Owner may evaluate the Management Company’s informational and interpretive materials to ensure appropriateness, accuracy, quality, and the relationship to Area Fundamental Resources and Values in addition to service-specific reviews that occur during periodic evaluations.

5. Other Inspections. The Owner reserves the right to enter the facilities at any reasonable time for any evaluation or when otherwise deemed necessary.

O. Guest Satisfaction Survey System

The Management Company will be responsible for developing and maintaining a Guest Satisfaction Survey System with the input of the Asset Manager for the approval of the Owner prior to the Commencement Date of the Management Agreement. “Guest Satisfaction Survey System” means an internet-based or electronic system that provides guest satisfaction surveys designed to measure visitor satisfaction with the quality, services, product mix, pricing, facilities maintenance, and guest experience at the Hotel. The Management Company will develop an appropriate weighting and scoring system to tabulate the surveys and to determine acceptable guest satisfaction scores.

The Guest Satisfaction Survey System must be capable of creating reports and summaries of electronically submitted surveys. A monthly summary of all comments and complaints must be submitted to the Owner within fifteen (15) days of the last day of each month.

If the Owner completes development of a centralized, web-based guest satisfaction program to solicit feedback from customers, prior to the Commencement Date, the Management Company will have the option to adopt the Owner’s program.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-8

P. Smoking Policy

The Owner prohibits smoking, including the use of e-cigarettes, inside all its facilities, including in outdoor areas within twenty-five (25) feet of air intake ducts, windows, doorways, and bay doors.

The Management Company must post notices of this prohibition in all public areas as necessary. The Management Company must designate employee-smoking areas and provide appropriate receptacles and training to ensure cigarette butts are disposed of properly.

Q. Possession of Firearms

The Management Company is responsible for determining how it will interpret and implement State and Federal firearm possession laws in regard to its visitors. The Management Company must provide the Owner its written policy articulating how it will implement these State and Federal firearm possession laws concerning its operation for review and approval within 60 days of the Agreement Commencement Date. Management Company employees may not possess firearms while on duty. The Owner, in their sole discretion, may grant exceptions to this prohibition upon consideration of a written request from the Management Company general manager with a thorough explanation of the basis of the request. The Owner will provide a written response to the Management Company. Management Company-employed security personnel have only the authority of private citizens in their interaction with Area visitors and employees. They have no authority to take law enforcement action.

R. Interactions with Wildlife

The Owner prohibits feeding and harassing of wildlife within all units of the National Park System.

The Management Company must control and contain food and liquid supplies, laundry, waste containers, and storage areas throughout the Hotel to avoid attracting wildlife and pests. The Management Company must develop and display signs that discourage littering and feeding of wildlife and warn visitors of the risks associated with such activity. Signs must use symbols and pictures to convey the message. The Management Company must not prop open doors or windows without screens, including in housing, to avoid allowing in wildlife and insects and must inspect and maintain structural ventilation on at least an annual basis to permit air circulation as designed and to prevent the entering of wildlife.

S. Human Resources Management

1. Employee Identification and Appearance. All Management Company employees must be issued an employee photo identification card that includes their name and an expiration date based on the employee’s anticipated departure date. Each employee must carry their identification card while in the Area and show it to enter the Area at the entrance station or onboard the shuttle.

The Management Company must collect identification cards upon termination of employment or at the end of the season for seasonal employees.

2. Area Entrance Pass. The Management Company must contact the Fee Supervisor’s Office to obtain Area entrance passes (windshield stickers) for permanent and seasonal employees’

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-9 personal vehicles. The Management Company must collect and surrender all employee windshield stickers upon termination of employment.

3. Employee Training and Orientation. Employee orientation and training for each employee must include information regarding National Park Service regulations, Agreement requirements, and National Park Service policies that affect their employment and activities while working and/or living within the Area, including potential safety hazards and their mitigation. The Management Company must orient its employees to the Hotel and basic facts regarding the principal natural and cultural resources of the Area. The Management Company must train employees on the necessity of wildlife-proofing food and water sources, including ensuring waste containers are secured, spills are cleaned up, and fences, gates, windows, and doors are closed, and how and to whom they should report possible concerns. Wildlife concerns may include bear activity; bee or wasp swarms in and near developed areas; household pests (mice, ants, etc.) inside buildings;

wildlife begging behavior (such as ground squirrels or deer approaching people for food); and evidence of wildlife nesting or denning on, in, or under buildings (including bats).

4. Employee Area Knowledge. Employees must demonstrate their knowledge of Area resources to communicate with visitors. At a minimum, Area knowledge must include the basic layout of the Area, typical driving time between Area locations, most popular hiking trails, and general warnings and restrictions intended to ensure visitor safety, such as warnings related to dehydration, hypothermia, lightning, and restrictions related to wildlife interactions.

5. Employee Handbook. The Management Company must provide all employees with a copy of its employee handbook, which will specifically identify the policies and regulations of the Management Company and the National Park Service. The Management Company will submit a copy of the employee handbook to the Owner for a 30-day period of review prior to distribution to its employees to ensure consistency with all Area rules and regulations. When updated, the Owner must review changes.

6. Employee Housing, Food Service, and Recreation. The Management Company must provide furnished housing, food service, and recreation programs for its employees residing within the Area. The Management Company’s written policy regarding employee housing, food service, and recreation programs will be submitted to the Owner and must include information on National Park Service regulations and policies as well as official advisories and notices provided by the Owner.

7. Management Company employees are not allowed to have pets in employee housing, except in Mixing Circle housing (the Bunkhouse and Bunkhouse Trailer Sites) or as allowed as a reasonable accommodation for service animals. Where permitted, employee pet owners are subject to the same pet restrictions as Area visitors, which are set forth under the provisions of 36 C.F.R. § 2.15.

8. Management Company employee housing and food service will be subject to the Owner’s Employee Housing standards and Employee Dining Room standards.

9. Volunteers in the Park (VIP) Program. The Management Company may encourage and permit its employees to participate in the Area’s Volunteers in Parks (VIP) program.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-10

T. Public Relations

The Management Company must accurately inform and educate the public on many topics throughout its operations, including answering questions about the services and facilities provided under this Agreement, providing signage and labels on menus and sales merchandise, and through marketing. The Management Company must post required notices as provided by the Owner including the following at all cash registers and payment areas:

This service is operated by (Management Company’s name), a Management Company under a contract with the U.S. Government that is administered by the National Park Service. The Management Company is responsible for conducting these operations in a satisfactory manner.

Please email comments to the BRCA Superintendent or mail comments to:

Superintendent Bryce Canyon National Park PO Box 640201 Bryce, UT 84764-0201

Media Inquiries. The Management Company must notify and may refer media inquiries related to the Management Company’s operations to the Area Public Information Officer. Additionally, all media inquiries related to the Area but not related to the Management Company’s operations in the Area must be referred to the Area Public Information Officer.

U. Informational and Interpretive Materials

The Management Company must provide a wide array of methods for conveying informational and interpretive messages to visitors on Area topics such as resource protection, appreciation of the Area’s cultural and natural significance, and other topics of emphases for the Area. The Management Company must include informational messages in the lodging, retail, and food service facilities on a variety of items, including in-room information packets, receipts, menus, table cards, and comment cards. All information and interpretive materials, new and updated, must be submitted to the Owner for review and approval at least 30 days prior to publication.

V. Procedure for use of NPS “Authorized Operator” Mark

The NPS must approve all uses of the “Authorized Operator” Mark. Prior to using the “Authorized Operator” Mark, the Management Company must submit a written request to the Area Superintendent’s office that includes proposed applications and sample layouts. The Management Company must wait for approval before using the “Authorized Operator” Mark. Once the NPS approves the request, the Management Company will receive the necessary graphic files from the Owner and can proceed to use the “Authorized Operator” Mark for advertising and promotional activities.

mailto:BRCA_superintendent@nps.gov

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-11

W. Structural Fire Prevention, Protection, and Suppression

The Management Company is required to submit the Structural Fire Management Plan to the Asset Manager for Owner approval, 90 days from the Commencement Date of the Agreement. The Management Company is responsible for developing and implementing this plan, as well as any other necessary plans and procedures to meet or exceed the requirements set forth in International Building Code (IBC), published by the International Code Council (ICC), and Reference Manual-58 NPS Structural Fire Management Program. This includes conducting annual structural fire inspections, certified annual fire extinguisher inspections, and monthly fire extinguisher checks, in addition to designating a structural fire manager.

The Asset Manager, on behalf of the Owner, will review and accept the submitted plans and documentation to ensure compliance with these requirements. Additionally, the Asset Manager will communicate the Structural Fire Management Plan to the Owner’s Authority Having Jurisdiction (AHJ) to ensure that it is integrated with the Owner’s Structural Fire plans promoting a cohesive approach. The review process, including specific procedures and timelines, and the Asset Manager will handle any necessary escalation or higher-level review if issues arise.

X. Risk Management Program

The Management Company must develop, maintain, and implement its own documented Risk Management Program (RMP) in accordance with the Owner’s Risk Management Program Standards and with the National Park Service Reference Manual 50B: Occupational Safety and Health Program, as appropriate. The Owner’s Risk Management Program Standards are available on the BRCA VEIA Prospectus/Business Opportunities website.

The Management Company’s RMP must include a section specific to its recreational rental equipment operation. The Management Company may require equipment renters to sign a waiver of liability prior to renting its equipment. All such forms must comply with Owner requirements and may be subject to the Owner's review for consistency with such requirements. The RMP will be updated as needed to comply with all Applicable Laws and Owner policies.

The required elements of the RMP are as follows:

Element 1 - RMP Scope Element 2 - Responsibility and Accountability Element 3 - Training Element 4 - Documentation and Operational Controls Element 5 - Communication Element 6 - Reporting Element 7 - Inspections and Corrective Action Element 8 - Hazard Incident Investigations and Abatement Element 9 - Management Review Element 10 - Other Agreement Requirements

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-12

The complexity of a Management Company’s RMP must be commensurate with the size and type of operations and services being provided and address the particular organizational structure, safety procedures, and business practices of the Management Company. The Management Company may incorporate additional elements and requirements for its RMP above and beyond those outlined in this section to address its operations. The Owner may also define additional requirements as appropriate as terms of the Agreement.

The Management Company’s initial RMP must be submitted to the Owner within 120 days of the Agreement Commencement Date and annually thereafter by March 1.

Y. Environmental Management Program

The Management Company must develop, implement, and interpret an Environmental Management Program (EMP) in accordance with the Owner’s VEIA Environmental Management Program Standards. The Owner’s VEIA Environmental Management Program Standards are available on the BRCA VEIA Prospectus/Business Opportunities website.

The required elements of the EMP are as follows:

Element 1 - EMP Scope Element 2 - Responsibility and Accountability Element 3 - Training Element 4 - Documentation and Operational Controls Element 5 - Communication Element 5 - Reporting Element 7 - Monitoring, Measurement, and Corrective Action Element 8 - Other Agreement Requirements

The Management Company must submit to the Owner for approval an initial EMP within 60 days of the Management Agreement effective date and an updated EMP annually thereafter by January 1.

Additionally, the Management Company must annually submit to the Owner a summary of its EMP performance for the previous calendar year by March 1.

III. MAINTENANCE STANDARDS

A. GENERAL STANDARDS

1. Facilities Standards

Pursuant to the Agreement, the Management Company is responsible for the maintenance of the Hotel in a manner satisfactory to the Owner. The Owner (NPS) is ultimately responsible for the costs associated with the maintenance, but the Management Company must ensure that its maintenance obligations are fulfilled consistently with these Maintenance Standards. The Management Company must conduct all maintenance activities in compliance with Applicable Laws as defined in the Agreement. Applicable Laws include but are not limited to: Architectural Barriers Act Accessibility Standards (ABAAS) as

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-13 per 41 CFR §§ 102-76.60 and 102-76.65, the International Building Code (IBC), the Uniform Plumbing Code (UPC), the National Electric Code (NEC), and the International Building Code (IBC) published by the International Code Council (ICC)), unless the Owner provides an express written exception. Additionally, Applicable Laws encompass National Park Service (NPS) standards, Department of the Interior (DOI) regulations, and NPS Asset Management Plans and Management Policies, unless an express written exception is provided by the Owner.

2. General Management Company Responsibilities

a. All personnel conducting maintenance must have the appropriate skills, experience, licenses, and certifications to conduct such work.

b. The Management Company, where applicable, must submit project plans to the Owner that are stamped by a Professional Engineer or Registered Architect licensed in the appropriate state.

c. The Management Company, where applicable, must obtain the appropriate permits required by federal, state, or local law and must provide copies of the permits to the Owner.

d. The Management Company must follow, at minimum, those LEED (Leadership in Energy and Environmental Design) standards set for achieving a silver rating for applicable maintenance. However, the Management Company is not required to apply for and receive third-party verification or certification of LEED compliance.

e. Winter Closures. All winter keeping operations are the responsibility of the Management Company. The Management Company must ensure buildings are adequately winterized and secured while unoccupied. The Management Company must perform the following tasks where appropriate: install shutters and bracing to protect unoccupied buildings; keep roofs free of heavy snow loads; drain water lines prior to closing; and shut off utilities. The Management Company will coordinate closing and winter keeping activity schedules with the Owner.

f. Spring Reopening. The Management Company is responsible for all activities required to reopen facilities after the winter season. The Management Company will coordinate opening schedules with the Owner.

3. Environmental, Historic, and Cultural Compliance

1. Certain maintenance actions are subject to compliance procedures under the National Environmental Policy Act (NEPA), National Historic Preservation Act (NHPA), and other Applicable Laws.

2. Any proposed maintenance actions that are subject to these compliance procedures must be submitted to the Owner by the Management Company in the format required.

3. The Management Company may be required to prepare environmental assessments, environmental impact statements, or related documents for certain maintenance actions. The Owner will provide guidance to the Management Company concerning proper process and procedure.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-14

4. Integrated Pest Management

The Management Company must develop and implement an integrated pest management (IPM) plan in accordance with the Owner’s policy set forth under NPS Natural Resource Management Reference Manual #77, Chapter 2, Integrated Pest Management. The Management Company’s IPM plan must include, but is not limited to, the following:

1. Submission of a Pesticide Use Proposal (PUP) for all pesticides (including insecticides, herbicides, fungicides, rodenticides, and personal use pesticides [e.g., insect repellent]) proposed to be purchased and used by the Management Company each calendar year.

2. Annual reporting of all pesticide use, including pesticide name and quantity used to the Area IPM Coordinator.

3. Storage of all pesticides in accordance with Owner policy and the pesticide label.

5. Maintenance Tracking

The Management Company must schedule and track completion of all maintenance actions and associated expenditures in an electronic format. Such electronic format must be acceptable to the Owner and must effectively provide the Owner the maintenance information that the Management Company is required to provide under this Exhibit G.

6. Management Company Inspections

The Management Company must arrange inspections of the Hotel (no less than annually) to track its compliance with the Operating Standards and to compile information that will aide in the development of future maintenance requirements.

7. Owner Inspections

The Management Company will provide appropriate access to facilities, staff, and records so the Owner, or authorized third party, may periodically (as determined necessary by the Owner but no less than annually) inspect the condition of the Hotel and the progress and quality of maintenance activities. The Management Company must provide qualified personnel to accompany the Owner’s staff, or authorized third party, when they perform an inspection of the Hotel.

8. Evaluation of Management Company Maintenance

The Owner will provide the Management Company with an annual evaluation of the Hotel.

The evaluation will be provided to the Management Company as a record of the Hotel’s condition and will document the Management Company’s compliance with its obligation to perform all necessary maintenance.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-15

Bryce Canyon National Park Gift Shop Mission Statement

Area Purpose

Bryce Canyon National Park is set aside to conserve, preserve, and protect its natural and cultural resources, outstanding scenic features and areas of unusual scenic beauty and scientific interest, and importance as a public park for the year-round enjoyment and use for present and future generations.

Mission Statement

The mission of the National Park Service at Bryce Canyon National Park is to preserve, conserve, protect, and provide for the enjoyment of nationally significant resources including spectacular geologic formations, clean air, panoramic vistas, native vegetation and wildlife, and the history of human interaction with them.

Area Significance Statements

Statements of significance clearly define the most important things about the Area’s resources and values. They serve as a foundation for developing primary themes and desirable visitor experiences.

• Bryce Canyon National Park is best known for its hoodoos—erosional features carved from the edge of the Paunsaugunt Plateau in southern Utah. Here, routine events such as freeze-thaw cycles, water run-off, and mineral oxidation combine in unique ways to continuously create and destroy oddly shaped and multi-hued fins, spires, grottoes, and windows from the limestones of the Claron Formation.

• The Area’s location at the top of the Grand Staircase and the clarity of the air provides visitors the opportunity to regularly experience panoramic vistas extending over 100 miles. The absence of human development and artificial lights creates conditions for unimpeded distant views by day and unparalleled viewing of the brilliant night skies.

• The Area and other nearby public lands provide opportunities for visitors from around the world to experience wilderness values such as clean air, peaceful settings, natural soundscapes, solitude, and self-reflection.

• Bryce Canyon National Park provides important protected habitat for natural life and its processes.

• The cultural history of Bryce Canyon and the surrounding area documents the changing human relationships with the land.

• As one of the darkest publicly accessible places in North America, Bryce Canyon National Park has the distinction of the Milky Way Galaxy being visible from horizon to horizon. The clear, clean air and a lack of artificial light in the Area and the region are essential to the unparalleled nighttime experience.

Area Interpretive Themes

Interpretive theme statements convey Area significance. Primary Area-wide interpretive themes are the key ideas through which the Area’s nationally significant resource values are conveyed to the public. They connect Area resources to the larger ideas, meanings, and values of which they are a

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-16 part. They are the core component on which the interpretive program is based. Each primary theme will connect to a number of specific stories or subthemes. These elements are helpful in designing individual services, ensuring that the main aspects of the primary themes are addressed.

• The brilliant red limestone formations at Bryce Canyon form the top step of the Grand Staircase.

This unique geologic feature descends from Bryce Canyon to the Grand Canyon and spans more than 200 million years of geologic history, giving us the ability to view and contemplate what geologic processes can do over eons.

• Water and the power of erosion create the wondrous geologic formations preserved in the Area, a testament to the power of nature to mold and alter our physical environment.

• Bryce Canyon is small in acreage but offers one of the world’s most expansive vistas of untrammeled wilderness. Sparsely populated, this “vast vacantness” provides an outstanding opportunity for visitors from around the world to experience wilderness values such as solitude, clean air, unobscured night sky viewing, natural sounds and smells, and self-reflection.

• Bryce Canyon provides important protected lands, ranging through several life zones, where scientific methods and research are being used to restore natural processes after decades of human influence.

• The Area’s rich cultural history documents changing connections with the land, illustrating an ongoing struggle to balance resource uses and their ecological and societal consequences.

• The first generation of National Park Service leaders and pioneer conservationists worked tirelessly to connect Americans with their national parks, both physically, through transportation and accommodations, and mentally, through emotional and intellectual connections to the resources. Bryce Canyon’s historic districts and cultural resources open a physical window into this foundational era.

Sale of Gifts, Souvenirs, and Other Merchandise

The sale of gifts, souvenirs, and other merchandise within Bryce Canyon National Park is considered necessary and appropriate since these items enhance visitor understanding and appreciation of the Area mission and values and complement visitor experiences. Information tags on merchandise foster awareness about Area resources and values. Souvenirs provide tangible keepsakes to remind visitors of Area experiences.

Objectives for the Sale of Merchandise

The objectives for the sale of merchandise, including gifts, souvenirs, apparel, outdoor recreational supplies, groceries, and visitor convenience items in Bryce Canyon National Park are:

• The primary selection of gifts and souvenirs relate to the Area and its resources.

• Merchandise is attractive, tasteful, and meets the Owner’s service standards.

• Regionally or locally handcrafted or manufactured merchandise is preferred, consistent with

Area themes.

• Interpretive information in displays and on tags address Area themes.

• Information is provided to help visitors have a safe visit and minimize impact on Area resources from their activities.

VA-BRCA003-25 Exhibit G: Operating and Maintenance Standards Page G-17

• Quality items are available at a range of prices.

• Only plants and animals found within the Area are depicted in merchandise.

• Development of unique theme-related items sold only in Bryce Canyon National Park is encouraged.

• Visitors are able to meet their essential and spontaneous needs for food and convenience items.

• Sales staff is knowledgeable about the merchandise as well as Area resources and Area activities and assists visitors by answering questions and providing information about the Area and surrounding area.

Specific Objectives by Sales Outlet

Bryce Canyon Lodge Gift Shop

• Emphasis is on quality gifts, souvenirs, and apparel appropriate for the clientele and relating to a full range of Area themes.

• Convenience items are limited.

• Some sales items, including logo items, are specific to Bryce Canyon Lodge.

General Store

• Emphasis is on groceries, convenience items, and merchandise that meet visitor needs for hiking, backpacking, and camping, and on beverages and snacks, including ready-to-eat items.

• Fresh produce, packaged meats, pre-packaged baked goods, other grocery items, ice and camping supplies meet visitor need for day trips as well as backpacking and camping multi-day stays.

• Information and assistance is available to help visitors select appropriate camping and hiking and other equipment.

• Groceries are sold in suitable sizes to meet the needs of campground users as well as day use visitors.

Historic Service Station

• Limited retail and snacks related to equipment rentals.