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March 29, 2007

Councilwoman Blondell Reynolds Brown
Council At-Large
City of Philadelphia
City Hall
Room 581
Philadelphia, PA 19107

Re: Licensing Tour Guides

Dear Councilwoman Reynolds Brown:

The Constitutional Walking Tour of Philadelphia agrees with you as to the importance of tour guides providing accurate, informative and engaging tours of Philadelphia.

I understand your comments in an interview airing on KYW Newsradio that tour guides in general are "not up to speed on what the actual facts are". Additionally, in spite of Monica Yant Kinney's March 25, 2007 article in The Philadelphia Inquirer entitled, "Phila.'s fictional history tours," in which she profiled two motorized tour operators that made many errors in the accuracy of content on their tours, there are other tour providers such as The Constitutional Walking Tour that operate under stricter self-regulated standards, adhering to a detailed script that has been fact-checked by qualified personnel numerous times. Additionally, The Constitutional Walking Tour utilizes a competitive and highly selective recruiting and screening process to employ the best tour guides in terms of their knowledge, storytelling skill set, communication abilities, performance experience and personality - we rigorously train these tour guides to maintain the accuracy and integrity of our history and our tours.

The Constitutional's tour guides are passionate historians and Philadelphians who hail from top academic institutions. In order to provide the optimal visitor experience, The Constitutional's knowledgeable and friendly tour guides have been specially trained by The Constitutional's "Independence Immersion" program, an intensive and fun curriculum focusing on Philadelphia history, American history and local tourist attractions, as well as best practices in public speaking, storytelling, customer service, hospitality and visitor experience. The Constitutional's guides bring Philadelphia's history alive!

Additionally, The Constitutional utilizes best practice quality assurance testing processes including "mystery shopper tourists" who, unknown to the tour guides during the tour, go on various tours with The Constitutional's guides and then provide a performance review to The Constitutional's management evaluating certain criteria including factual accuracy. We also offer online surveys and feedback reporting that all customers can utilize to communicate with us.

From this feedback loop, we receive positive comments from many customers, including ones from school teachers who have said,
"...an excellent tour guide who really knew his information."
"[The Tour Guide] was so much fun and so knowledgeable."
"[The Tour Guide] was fantastic- especially for people who don't just want to hear American history told through typical American history books."

In a free and unfettered market where all tour operators compete on a level playing field, the quality of tours is one of the factors that should be continually improved upon. In fact, The Constitutional Walking Tour strives to competitively differentiate itself in terms of the accuracy and integrity of our history tours. We are a history tour and not just a tour that happens to travel through the historic district.

Have we ever made mistakes on our tours? Sure we have, since our tour guides are human. Mistakes will undoubtedly occur again with all tour operators, regardless of whether tour guides are officially licensed or not. Practically speaking, the only way to really avoid this would be for every tour to be scripted, vetted and recorded verbatim for accuracy and then played back to visitors. While The Constitutional offers an award winning audio tour is a informative and entertaining, we believe that live guides also serve a purpose and really can bring history alive to those visitors who want to experience Historic Philadelphia with a personable and knowledgeable tour guide.

Any regulation would have to ensure that the licensing agency is truly independent without any ties (i.e., partnership, promotional, funding, other licensing) to any existing constituent in the tourism ecosystem. For example, licensing of tour guides in Colonial Williamsburg is done through the Police Department and licensing of tour guides in New York is administered through the New York City Department of Consumer Affairs. Arguably speaking, I think that the Philadelphia Police have enough on their plates without worrying about tour guide licensing so a new department or group might have to be created, and funds are constrained.

That said, while we agree that it may be meritorious to have a discussion over the need for tour guide licensing, it has to be an interactive dialogue between various constituents (including government and tour operators) that addresses the costs and benefits, direct and indirect, of formally regulating the tour guides as opposed to a unilateral feel-good decision. Additionally, this interactive discussion needs to realistically consider the alternatives including self-regulation such as the industry certification that is being done in many big city tourist destinations including Boston and Chicago, for example, according to the National Federation of Tourist Guide Associations - USA.

Knee-jerk regulation and licensing will just serve as another tax, if you will, in terms of time and money for tour operators and tour guides. Ultimately, this fee will likely get passed onto visitors with higher prices for all tours in the City, and that arguably speaking is also a disservice to visitors who come to experience Philadelphia's rich history. Thank you.

Sincerely,

Jonathan H. Bari
President
jon@TheConstitutional.com