a parking pass still require one. To avoid a fine, a wise hiker will telephone a Forest Service office or check the maps of High Impact Recreational Areas online of the individual forests to determine in advance his or her permit needs, since adequate signage pertaining to the need for an Adventure Pass is not yet common. Although supposedly many areas do not require the pass, most of these locations are less convenient to populated areas and can be accessed only from areas that do require a pass. Controversy The continued collection of fees for use of the National Forest Lands remains controversial since the 9th circuit court of appeals ruled in February 2012 in the case Adams v. U.S. Forest Service, that "The Federal Lands Recreation Enhancement Act ("REA")", the authority under which the fee structure was enacted, "prohibits the United States Forest Service from charging fees "[s]olely for parking". In spite of this clear prohibition, what many consider to be "parking only" fees are still required at numerous locations in the San Bernardino and Angeles National Forests as well as other National Forest Locations. The ruling stated that while fees are allowed in certain instances, the "fee" sites must conform to the following requirements as listed below: (A) that provides significant opportunities for outdoor recreation; (B) that has substantial Federal investments; (C) where fees can be efficiently collected; and (D) that contains all of the following amenities: (i) Designated developed parking. (ii) A permanent toilet facility. (iii) A permanent trash receptacle. (iv) Interpretive sign, exhibit, or kiosk. (v) Picnic tables. (vi) Security services. The Forest Service "maintains that the latter part of § 6802(d)(1)(A), which prohibits fees "solely for . . . picnicking along roads or trailsides," clearly permits fees for road or trailside picnics that take place within a larger area (delineated by the Forest Service) if that larger area offers amenities". The Court rejected such an interpretation of the REA statute stating: "Because this reading is so illogical, we will consider another interpretation of the agency's position. Perhaps the Forest Service is really saying that a fee is "[s]olely for parking" when imposed in a location where a visitor has no option to do something else, whether or not that "something else" is an amenity required by the statute." The Court further went on to illustrate: "Consider what would happen if a restaurant-goer inspected his bill