Summary of Alternative H
Chart of Alternative A & H
Non-commercial permitting system
Wilderness
Is Alternative H salvagable?
What is AzRA/GC Discovery most concerned about?
How can you give your comments the most weight?
History
Links

*Please note that for management purposes, the NPS is seeking to divide the Colorado River into two sections, and has presented separate draft planning alternatives for each. Alternative H only concerns the upper section, Lees Ferry to Diamond Creek.

Preferred Alternative H provides for a mix of motor and non-motor use with a loss of 45 motor commercial trips and an increase of 37 non-motor commercial trips per year. Under Alternative H, the commercial motor season would be from March through August as opposed to the current December 16 through September 15.

Helicopter use at Whitmore would be allowed from May through August and would be limited to 5000 PAX out and up to 5000 in.

Commercial use would continue to be capped at the current 115,500 days and would take place between March and October. Commercial motor use would be capped at the previous six year historic average of 74,260 days.

There would no longer be a regulatory numerical cap on non-commercial use; instead, such use would be limited as a practical matter by the function of allowable launches multiplied by group size and trip length maximums. The maximum potential non-commercial user-days under the plan (all trips at 100% load running their maximum length) is 131, 488; NPS calculates "probable" non-commercial at 78% capacity, for a "probable" non-commercial user-day use of 102, 725 per year.

The current non-commercial group size maximum of 16 would be retained and relabeled as a non-commercial "standard" trip, and a new trip type would be created, the non-commercial "small" trip, which would be limited to a maximum group size of 8 participants.

Alternative H Season Definitions
Summer: May, June, July, August
Shoulders: March, April, September, October
Winter: November, December, January, February

Summer Season Size Details
32 commercial group size max counting guides (down from 43 people for motorized and 39 people for non-motorized)
16 group size maximum non-commercial standard trips (same)
8 group size max non-commercial small trips (a new designation)

Summer Season Length Details
16-day non-motor trip maximum for both commercial and non-commercial trips (down from 18 days)
10-day motor trip maximum for commercial trips (down from 18 days)

Summer Launch Pattern
6 maximum per day (5 ½ daily average) (down from 9)
4 commercial (three motor and one non-motor required each day) (down from 150 people)
1 ½ non-commercial (one standard and one small every other day) (up from 8 per week)

Shoulder Seasons Management Details
24 commercial group size max counting guides (down from 43 people for motorized and 39 people for non-motorized)
16 group size maximum non-commercial standard trips (same)
8 group size max small non-commercial trips (new designation)
18-day non-motor trip maximum for both commercial and non-commercial trips (down from 21)
10-day trip commercial motor trip maximum (down from 21)
Lees to Phantom Ranch trip minimum of 3 nights/4 days (up from 2 nights/4 days)

March Launch Pattern
2 maximum per day (same)
1 commercial motor (same)
1 non-commercial standard (same)

April Launch Pattern
3 maximum per day (up from 2 per day)
2 commercial (1 motor, 1 non-motor) (up from 1 per day)
1 non-commercial standard

September Launch Pattern
3 maximum per day (down from 9 per day)
1 ½ commercial non-motor (down from 150 people per day)
1 ½ non-commercial standard (up from 8 per week)
Non-motor only (down from non-motor beginning Sept. 15)

October Launch Pattern
2 maximum per day (same)
1 ½ non-commercial non-motor (up ½)
½ commercial non-motor (down ½)
Non-motor only (same)

Winter Season Management Details
1 non-commercial launch per day (same)
16 group size maximum non-commercial standard (same)
25-day trip maximum (down from 30)
Non-motor only (down from motors beginning Dec. 15)

ADDITIONAL PREFERRED ALTERNATIVE H ELEMENTS
All users limited to one trip per year
Guides to accompany all hikes, including exchanges
No paid guides allowed on non-commercial trips
Guides will not count against commercial user-days

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(1) All information taken from "Lees Ferry Alternatives," page 36 of the Draft Environmental Impact Statement of the Colorado Management Plan published by the National Parks Service
(2) The 113,083 number is based on 6 year average of use, about 98% of maximum for commercial trips. The 115,500 number is the current and preferred alternative cap on commercial use.
(3) The 58,048 number is based on 6 year average of use, about 106% of maximum for non-commercial trips. The 102,725 number is based on 78% of maximum for non-commercial trips; the National Park Service deems 78% to be the probable use.

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The NPS preferred option for non-commercial permit distribution is to phase out the waiting list in favor of a weighted lottery. A "weighted" lottery means that those players who did not win a permit would be given an extra chance each year they played the lottery until they won.

Wilderness Recommendation

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1. The Adjustable split-allocation approach and the All-user registration system.

Under the all-user registration system (proposed for every action alternative), every guest must first register their interest with Grand Canyon National Park before they can book a trip with us or place their name in the private permit lottery. The information will be used to measure demand and adjust the allocation between commercial use and private use over time (ref.: pages 25, 652, and 653 of the DEIS).

The Split Allocation Approach is also a system designed as a one way door— toward the privates—during the months from April through the end of August. There is a caveat in the document that says that neither user group can drop below 40% in any given month. However, the private sector is already below 40% during the summer months. Therefore the outfitted public could never pick up any launches from the private sector during this time and what they picked up from the outfitted public (until privates reach 40%), we could never gain back. Therefore, since the privates have already been granted about 50% of the user days (47% if they’re only 78% efficient; 53% if they’re 100% efficient), the general public/commercial passengers will only lose allocation, to less than 50% of the overall user-days. What gives? Well, in theory, the general public/commercial sector could pick up a lot of use in November, December, January, and February with a little use in March and October, but we don’t think the you would be so keen on that time of the year.

Will the registration be done on the phone? The internet? The DEIS doesn't say. Will the interested party be given a coupon, assigned an electronic number? How will the information be transmitted to their outfitter of choice? The DEIS doesn't say. If they want to add another member to their party several months later, do they have to go through that same process all over again? Does each member of a party have to register, including minors? Can one person register for others, and if yes, how many? The DEIS doesn't say.

If the interested party is interested in a commercial trip now, but would certainly hop on a friend's private trip if the opportunity presented itself, how is that interest recorded? The DEIS doesn't say. Page 653 of the DEIS ostensibly addresses "adverse impacts and disadvantages" of their proposal, but nowhere do they mention (a) administrative burden on the Park (phone lines, computers, personnel, training, budget), (b) inconvenience and confusion pressed upon the public (e.g. not all are computer adept), (c) artificial deflation of interest/demand because people either can't be bothered or they simply don't trust "big brother," (d) safeguards against "gaming" the system by either or both sides. Coupled with the weighted lottery private permitting system, the system actually encourages private users to register their interest, even if their TRUE interest is not for a few more years. (They may wish to allow more time to learn to row, for their children to grow up, or whatever.) Entering the private permit lottery (registration is required first) will increase their odds of gaining a permit in future years (because it's weighted to favor prior year "losers"). Unlike commercial guests, many privates have learned to "play the system" and that registering their, and others', interest will increase the chance of building the numbers to support the split-allocation falling more to their favor over time. Did the CRMP Team really do a credible job thinking through and communicating the adverse impacts and disadvantages of the split-allocation approach and the all-user registration system? We don't think so.

Can this system be fixed? We think not, for all the adverse reasons cited above. So what might an alternative system look like? We don't know. But we are putting thought into a private sector or non-governmental institute demand study conducted periodically (every five years?) and the request for proposals, contractor selection, and scientific methodology decided on with input from a advisory group representing all stakeholders (which would probably have to be professionally mediated). This could cost, who knows, $400,000? If so, 37 cents per user day (all users) could pay for it.

2. September and October under Preferred Alternative H.

You may have heard of "temporal wilderness" before. If you haven't, juxtapose that with "spatial wilderness." Instead of setting aside a chunk of landscape for no motors and very few people, create that same opportunity by keeping motors out and reducing the number of people during a specified time of year and you have temporal wilderness. Because motorized vehicles frequently render a landscape unsuited for wilderness, temporal wilderness works best in the context of river travel.

Alternative H's moving the no-motors period from September 15 up to August 31 tends to eclipse the fact that the Park's Preferred Alternative H substantially reduces commercial launch opportunities after September 1 for ALL commercial access, motor and oar, by more than half. September would cap commercial non-motor trips at 1 ½ per day (two one day, one the next, etc.) and October would allow one launch every other day (compared to one/day now). These restrictions, coupled with some other variables such as reduction in group size, will force more launches into March and April (e.g. 10 March/April launches for AzRA/Discovery under one mock scheduling exercise, half taken right out of September).

In our estimation, the CRMP Team has overdone what would be required to meet the needs and values of "temporal wilderness" users, failing to identify the adverse impacts to the outfitted public being restricted from September and having instead to go in March or April. September and October are our favorite times on the river. So why reserve September for so few people?

Temporal wilderness is a good idea and some of our non-motor guests chose to go after September 15 because of it, but is there a workable compromise? We think so. For example: motor launches through September 7 and TWO non-motor launches each day thereafter (including through October 15) instead of just 1 ½ non-motor launches per day in September and one every other day in October. This suggestion would add 21 motor launches (all the first week of September) and increase non-motor launches from 60 to 80 during September/October, cutting off commercial launch access two weeks earlier (October 15 instead of October 30). Commercial access could resume on March 15 because we wouldn't need to schedule commercial motor trips beginning March 1.

3. AzRA/Grand Canyon Discovery's one-boat motor trips are at risk.

Like Hybrid trips and All-Paddle trips, one boat motor trips-with an extra day two for discretionary time-is a signature program at AzRA. (Discretionary time is the DEIS buzz word for less time moving down river and more time poking around in side canyons and relaxing in camp.)

Why is this program at risk? Primarily because Alternative H focuses on trip launches instead of user-days from Lees Ferry as the primary "gate keeper" mechanism for controlling downstream visitor contacts. This means that AzRA/Grand Canyon Discovery will have fewer numbers of launches while still have the same user-day cap. Therefore, each motor launch will have use more user-days than before. This is most easily accomplished by putting more people (and therefore boats) on each motor trip.

The one-boat motor trip is not just about AzRA. It's about the public who get so much out of these quality trips. AzRA/Discovery, GCE, Western, and Colorado River and Trail run 90% of the one boat motor trips, totaling about 200 trips last season. Most of these trips will be gone under Alternative H … and we believe the public is the loser for it.

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Don't simply announce that "xyz stinks," or "xyz, is a really bad idea." That's not helpful to the Park. The most important element of your comments are the "WHY's." For example, (a) I have concerns with [whatever] BECAUSE____________, (b) [whatever] would work if you made the following changes; here's WHY, and/or (c) [whatever] will not work BECAUSE _____________ AND here's what I recommend instead, and WHY.

Page references are nice, but appropriate reference to a given topic will suffice. You will likely be commenting on "the Lees Ferry Alternatives," unless you know the lower gorge, have reviewed that part of the DEIS, and you wish to comment. We suggest you use the same terminology the document uses whenever you can, for example, when referencing the split-allocation approach, or the all-user registration system, etc.

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On February 23, 2000 after three years of activity, then Superintendent Robert L. Arnberger of Grand Canyon National Park temporarily suspended work by his staff on the ongoing revision of the National Park Service's Colorado River Management Plan. Also known as the CRMP, this is the National Park Service's planning document that governs access to and activities within the Colorado River corridor within Grand Canyon National Park. Last formalized by the National Park Service in 1989, the plan was under active government review beginning in the fall of 1997 until the Superintendent's decision to suspend this effort.

In making his decision, Superintendent Arnberger cited limitations of funding and personnel, federal requirements for strategic planning which he felt the agency could not meet given these budgetary and human resource constraints, his consideration of the park's other pressing priorities, unresolved user conflicts with a stark lack of public consensus on various fundamental river management questions, and twenty years of inaction by the U.S. Congress on the Grand Canyon National Park wilderness recommendation.

Frustrated by the Superintendent's decision, a group of individuals and another group of advocacy organizations joined by individuals, each of whom had long planned to use the CRMP revision process to advance one particular political agenda or another, each sued the government in federal court challenging the decision. The first case was filed on March 9, 2000 in the Tenth Circuit in US District Court in Albuquerque, New Mexico. The second case was filed in the Ninth Circuit on July 5, 2000 in US District Court in Phoenix, Arizona. Because of the potential for conflicting judgments on substantially similar issues, the government asked the Arizona court to consolidate both cases in New Mexico. On the 14th of February, 2001, the court denied the government's motion, clearing the way for this case to proceed.

On January 17, 2002, the National Park Service (NPS) and Plaintiffs to announced that a voluntary, negotiated settlement had been reached between the parties in litigation concerning NPS planning for the management of the Colorado River within Grand Canyon National Park.

Under the terms of the settlement agreement, the NPS agreed, within 120 days, to restart work on the Colorado River Management Plan (CRMP) revision process first initiated in 1997, but suspended by the agency in February of 2000.

The Grand Canyon river experience is one of the most renowned and sought after visitation opportunities available within the entire National Park system. Demand for the experience far outstrips the available supply, which is limited by the NPS to protect the resource and the quality of the trip. Each year, roughly 22,000 visitors enjoy a world class whitewater river adventure in this spectacular and unique area.

The settlement agreement further required the NPS to implement a new Colorado River Management Plan no later than December 31, 2004. So that new river running concession contracts can be quickly issued that incorporate the outcome of the planning process, the NPS extended the current contracts through December 31, 2005.

The central questions that the NPS must answer in the course of the upcoming river management planning process include:
· How can the resource best be protected and what is the appropriate level of visitor use for the Colorado River corridor within Grand Canyon National Park, given paramount resource protection requirements and very high visitor experience quality goals?
· How should the recreational river use made available be apportioned among competing user groups, including those who seek the services of a licensed river outfitter and those who wish to self-outfit, or conduct their own private Grand Canyon river trip?
· How should private river running permits be distributed? The current "waiting list" system has resulted in excessive and highly unpopular wait times for trip leaders seeking to obtain a permit for their private party. Should forced waits continue as the primary means used by the NPS to ration such permits, or is there a better way? The waiting list system and its attendant controversy are unique to the Grand Canyon. All other permitted rivers that support multi-day trips in the western United States use some form of a lottery system to distribute private river running permits.
· What is the appropriate spectrum and mix for the various river trip types or styles to be made available? To what extent should motorized river trips continue to be offered? Motorized trips have been publicly available in the canyon for over the past five decades. Three out of four of today's professionally outfitted river trip participants choose the motorized trip option.
· How should river trips be scheduled and otherwise directly managed to protect the resource and to produce the best possible on-river experience for the visiting public?

In late summer of 2002, the National Park Service initiated a 90 day public scoping session in order to hear the public's voice on what the CRMP should entail. From the comments out of this process, and hours upon hours of Park staff time, comes the DEIS of the CRMP. For the upper section of the Colorado River, from Lees Ferry to Diamond Creek, the plan considers eight alternatives, including a no-action alternative (A) and a preferred alternative (H) representing different mixes and limits of group size, trip lengths, launches per day, user days, seasonal variations, motorized and non-motorized use, commercial and non-commercial use, and other factors.

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Links
Grand Canyon River Runners Association
Grand Canyon River Outfitters Association
National Park Service Information on the CRMP

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