National Park Service: Third Party Master Plan Acknowledges Challenges at the Independence Visitor Center

Monday, January 10, 2011

Third Party Master Plan Acknowledges Challenges at the Independence Visitor Center

"IVC & NPS Relationship: The IVC and National Park Service share the Visitors [sic] Center, but they often seem to be in competition with each other. There is a clear divide in the building and the information desk and visitors can feel the apparent tension between the two entities. This can be confusing and awkward for a first time user." -- ex;it (consulting and design firm)

Overview
The Philadelphia Inquirer recently reported that the "DRPA [Delaware River Port Authority] funneled more than $13 million to groups, some with ties to board." As previously discussed on this blog, these funds were outrageously going to the Independence Visitor Center Corporation ("IVCC"), a taxpayer supported public charity, which is chaired by John Estey (who also chairs the DRPA), even though the IVCC has nothing to do with the bridges that the DRPA operates.

Part of the $1.0 Million dollars allocated from the DRPA to the Independence Visitor Center ("IVC") is intended for a "New Wayfinding System." In the IVCC's proposal for the grant funding, the Independence Visitor Center Corporation stated:

"Due to the Visitor Center's long and narrow configuration, the use of the south end of the building for NPS exhibits, and the location of the concierge desk about half way back, the current system of directional signage and pedestrian circulation is ineffective. IVCC has retained exit, a local firm specializing in wayfinding and improving the pedestrian experience in challenging environments. The results of their research will lead to a program of improvements in and around the building which will enhance the visitor experience, improve pedestrian flow and circulation, and make the building more user-friendly and easier to navigate. We will look to implement these improvements in late 2010" (emphasis added).

The "local firm specializing in wayfinding" is "ex;it", and the firm created a "draft preliminary" plan dated September 3, 2010, and titled, "Independence Visitor Center: Visitor Experience Assessment & Touchpointing Master Plan." Ex;it identified five main priorities for the IVC: increase revenue, increase number of visitors, improve visitor experience, increase utilization of services, and increase staff efficiencies. Through its analysis, ex;it also identified some of the challenges facing tour operators at the IVC. Elements of ex;it's analysis are presented below and in the Exhibits. Details about the specific problems facing The Constitutional Walking Tour in terms of visibility and accessibility are presented in this post and in this video.

Problems for Walking Tour Operators
The observations and conclusions in the Master Plan highlight some of the major obstacles challenging walking tour operators at the IVC:

The assessment includes an image of the North End of the IVC labeled "EMPTY" with the caption, "The North Entrance is usually empty and disorienting. Occasionally a tour meets here and clogs the entrance, but there is often only empty tables to welcome visitors."

"Observations show the location of the café is a visual block in the space."

"The Playmotion screen currently resides in the North end and lacks clear identification. It takes away possible seating and generally visitors did not find the screen enjoyable. It is not centered around Philadelphia history nor does it have a clear focus."

"These [concierge] interactions are not typically tailored to the individual, nor do they promote the smaller, lesser known attractions."

"Vendors: There are multiple vendors that serve visitors out of the Visitor Center. Visitors may choose to bypass the Concierge Desk and approach the tour vendor directly. These experiences are often more focused and 'retail oriented.'" These vendors include Ride the Ducks, Philadelphia Trolley Works, Franklin's Footsteps, City of Philadelphia Mural Arts Tours, Max and Me Catering, etc.

"Currently the IVC directs many visitors to use the tourist-centered transportation such as the Phlash bus, taxis or the Big Bus tour. Public transit, like Septa, is difficult to give instructions for, so most visitors are directed to use other transportation." (emphasis added)

Walking tours such as The Constitutional Walking Tour are relegated to a remote, "empty" area of the IVC where they are overshadowed by a large media system (playmotion) that is unfocused and not enjoyable. The cafe further obstructs the visual space that may encourage visitors to head towards the walking tour staging location. According to ex;it's findings, the IVCC's concierge staff does not ameliorate this problem as they appear to promote large companies such as Big Bus tours instead of smaller businesses with less accessibility and visibility to visitors. Furthermore, the lack of a designated space or sales kiosk (which The Constitutional has tried to attain from the NPS and IVCC through a license for comparable space on fair, reasonable and non-discriminatory terms) precludes The Constitutional Walking Tour, for example, from delivering the more direct and focused retail experiences that other vendors can.

Problems for Third Party Vendors, Especially Those Without a Sales Kiosk
Ex;it's assessment also includes observations and analysis that expose challenges encountering many visitors at the IVC:

The survey quotes ex;it's "Visitor #6" as saying, "I walked in looking for information and was very disoriented […]"

"Nearly 1/3 of visitors said it is not clear where Park Rangers are stationed."

"87% of visitors said that the information desk is easy to locate, although some noted they did not know the purpose of the desk."

"Destinations such as the concierge and National Park Service desk, are often missed because they are not clearly identified. Many people confuse these two information desks or do not realize they offer different services."

"IVC & NPS Relationship: The IVC and National Park Service share the Visitors Center, but they often seem to be in competition with each other. There is a clear divide in the building and the information desk and visitors can feel the apparent tension between the two entities. This can be confusing and awkward for a first time user. While both organizations have separate missions and agendas, they should work together for one goal, helping each other and referring visitors to use each others [sic] services when appropriate" (emphasis added).

"This lessens the opportunity for ticket sales and leaves the visitors with more thinking and planning to do on their own. During interviews, a few visitors noted that tickets were difficult to find or the they [sic] process of purchasing tickets could have been easier."

The Master Plan describes an environment that is disorienting and confusing, characteristics that may be amplified when most of those visiting the IVC have little to no prior experience with the building, its services and layout. Unfortunately, according to the above observations, visitors struggle to determine whom to ask for help in navigating the IVC.

Furthermore, ex;it describes an evident conflict between the National Park Services's park rangers and the IVCC's concierge staff. The rangers represent the National Park Service which operates the Independence Visitor Center and then sub-contracts out operations to the IVCC; the concierge staff represents the Independence Visitor Center Corporation. Instead of working together to create a welcoming environment that gives guests a positive impression of Philadelphia, the National Park Service and the Independence Visitor Center Corporation appear to have created an environment in which visitors to the city are left feeling confused and awkward. This situation is not good for tourists, for tour operators, or for Philadelphia.

The IVCC Acknowledges shortcomings at the Independence Visitor Center
The IVCC itself has recognized in a proposal the IVCC submitted for DRPA grant funding that an environment has emerged at the IVC that needs to be rectified:

"The concierge staff desk is the focal point of the building, the place where the visitor truly 'meets' the visitor center. It is occupied by both IVCC and INHP staff. The desk is in critical need of an upgrade, both in appearance and technology. Access for the handicapped and disabled also needs to be improved."

"A series of design concepts has been developed to improve the overall external appearance of the Visitor Center. Current deficiencies include the main Market Street entrance area; the north end entrance; the lack of visibility for the Independence Gift Shop; external signage; and an excessive amount of 'blank wall' space."

These comments reveal that the IVCC is aware of significant issues at the Independence Visitor Center. Unfortunately, instead of pursuing genuine and substantial change that would enhance the customer and vendor experience, the IVCC singles out a supposed lack of visibility for the gift shop (albeit there are two large gift shops, including a very visible shop that is immediately adjacent to the IVCC's main Market Street entrance).

Conclusion
Real issues about lack of accessibility and visibility exist at the Independence Visitor Center. No public money should be used to support any capital projects on this building, which is only a decade old, until meaningful improvements can be made in terms of management processes and operations and the NPS and IVCC start complying with Federal concessions laws with regard to the Independence Park and the Independence Visitor Center.

Public money will not undo the unfair advantage given to large tour operators (i.e., Ride the Ducks, Philadelphia Trolley Works, etc.) over smaller ones, such as The Constitutional. DRPA funds will not dissolve the awkwardness that guests experience when encountering the apparent conflict between the National Park Service and the Independence Visitor Center Corporations, two organizations that should welcome visitors instead of dissuading them from returning. Large grants will not give visibility to walking tour operators that are relegated to a desolate corner over 400 feet away from the main entrance to the Independence Visitor Center.

A more detailed exploration of the specific ways in which walking tours are adversely affected by the challenges posed by the IVC can be found in a letter written by Jon Bari, President of The Constitutional Walking Tour, to Alan Jacobson, President of ex;it.

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Exhibits
*Proposal from the Independence Visitor Center Corporation to the Philadelphia Industrial Development Corporation for Delaware River Port Authority Grant Funding, June 4, 2010

*Draft preliminary by ex;it, "Independence Visitor Center: Visitor Experience Assessment & Touchpointing Master Plan," September 3, 2010

*Letter from Jon Bari, President of The Constitutional Walking Tour, to Alan Jacobson, President of ex;it, January 5, 2011

Background on The Constitutional’s disputes with the NPS and Independence Visitor Center

The Constitutional Walking Tour of Philadelphia (“The Constitutional”) offers guided walking tours of the Independence National Historical Park area by providing a primary overview of Independence Park and visiting more than 20 of Independence Park’s most historic sites including the Liberty Bell, Independence Hall, Carpenters’ Hall, Declaration House, etc.

From 2005 to 2010, the Independence Visitor Center Corporation sold tickets for The Constitutional’s various tours only at the IVC’s main information and sales desk. The IVCC has received a 20.0% (twenty percent) sales commission on each ticket that it has sold for The Constitutional (ranging on average in gross price from $12.50 to $17.50). Since 2005, The Constitutional has requested to also license a dedicated ticket sales booth from the National Park Service and IVCC on fair, reasonable and non-discriminatory terms commensurate with Ride the Ducks and Philadelphia Trolley Works, for example. Additionally, since 2005, The Constitutional has requested to also license marketing opportunities and commercial use authorizations from the National Park Service and IVCC on fair, reasonable and non-discriminatory terms.

The Independence Visitor Center (“IVC”) is owned and operated by the United States of America - National Park Service (“NPS”), which then sub-contracts with the Independence Visitor Center Corporation (“IVCC”), a taxpayer supported public charity, to manage the IVC.

The IVCC and NPS have preferenced third parties including Ride the Ducks and Philadelphia Trolley Works, and the IVCC and NPS have discriminated against The Constitutional Walking Tour. The National Park Service has enabled the creation of this unfair business environment. The National Park Service and the IVCC have ignored and circumvented Federal management and concessions laws for the sale of goods and services at Independence National Historical Park that require open, transparent, competitive and appealable processes awarding concessions contracts for the sale of goods and services including tours.

To facilitate the administration of the National Park Service System, the Secretary of the Department of the Interior, acting through the NPS, is authorized under the National Park Service Organic Act (“Organic Act”) to carry out twelve categories of activities, none of which include transferring administrative responsibility to a private party [i.e., IVCC] or engaging in cooperative administration with a private party [i.e., IVCC]. 16 U.S.C. § 1a-2(a)–(l). Rather than grant the NPS discretion in its dealings with park concessioners, Congress established “carefully controlled safeguards against unregulated and indiscriminate use” of the parks in the National Parks Omnibus Management Act of 1998 (“Management Act”), which governs all national park public accommodations, facilities, and services. 16 U.S.C. § 5951 et seq.; see also 36 C.F.R. Part 51.2 (“policy underlying concessions contracts”). The safeguards are not limited to nationwide policy: Congress also manages the parks with significant visitor traffic on a park-by-park basis. See, e.g., 16 U.S.C. §§ 21–40c (Yellowstone), §§ 91–110d (Mount Rainier), §§ 212–218a (Abraham Lincoln’s Birthplace), and §§ 410z–410z-5 (Boston National). One of the dozens of national parks managed by specific statutes is Independence National Historical Park (“INHP”). 16 U.S.C. §407m–407s. As such, compliance here going forward would require the NPS, first, to reassume from the private IVCC the NPS’s duties “to administer, operate, manage, lease, and maintain” properties at INHP pursuant to 16 U.S.C. § 407s; second, to award “all proposed concessions contracts … through a competitive selection process” pursuant to 16 U.S.C. § 5952; and, third, to issue commercial use authorizations in a rational manner pursuant to a reasonable interpretation of 16 U.S.C. § 5966(c).

The IVCC and NPS have arbitrarily and randomly selected business partners in a non-competitive and clandestine manner; as such, the actions of the NPS and IVCC have from an economics perspective stifled competition, innovation and consumer choice. Ultimately the IVCC’s actions have enabled prices to increase for its preferred vendors to strengthen the for-profits’ financial performance. Visitors to Philadelphia will be better served when the IVCC’s management, manners and methods are fundamentally changed. This would include having the National Park Service abide by Federal concessions management laws. Specifically, this will entail only having the NPS award concessions sales contracts and not having the IVCC involved in any of the selecting, awarding, contracting and managing of Independence Park’s third party concessions, including inside the Independence Visitor Center. This is the model that is practiced in virtually every other of the 390 (three hundred ninety) National Park Service units across the United States (in 49 states) including at Yosemite, Yellowstone, Statue of Liberty, etc. Additionally, visitors and all stakeholders will be better served once the operation of the taxpayer funded IVCC is totally transparent and accountable. While part of the issue centers on a publicly funded charity competing against the private sector (i.e., by offering guided tours and services), it more so has to do with the manner in which the IVCC and NPS operate and discriminate against third party concessionaires, tour operators and vendors in a random and arbitrary fashion (i.e., with the licensing and leasing ticket sales kiosks by the IVCC to third party companies, for example).