By now you've probably heard a lot of things about the alternatives listed in the Grand Canyon Management Plan, which were good, bad, or downright incendiary.

The surprising truth is that the Grand Canyon Management Plan (http://www.nps.gov/grca/crmp/index.htm) is actually a really good start with some really strong ideas that are worth pursuing. All of the alternatives are improvements over the status quo, and the Park has come out with a solid proposal that gives a little something for everybody.

American Whitewater has deliberately taken two months to review the plan in order to consider the ramifications of each alternative for our members, park visitors, and the environment. We have also made a special effort to talk with the Park to understand the more confusing aspects of the plan, worked with the Grand Canyon Private Boaters Association to evaluate the impacts on private boater access, spoken with the commercial outfitters about the effects on their operations, and met with wilderness advocates to talk about resource protection.

In our judgment, Alternatives H and C have the most to offer in terms of improving access and protecting the environment. Alternative H is the Park's preferred alternative, and alternative C is a strict no-motors alternative. After considering the ramifications, logistics, and nature of both alternatives, we are leaning towards supporting a modified Alternative H because we believe it is the most viable, and comes closest to achieving the goals that we have heard were important to our members: resource protection, diverse visitor opportunities and experiences, and improved access.

We have not prepared a form letter for you to fill out since the Park is looking for unique ideas and comments. However, we will provide some guidance below on the items that we think are important and would like to suggest some areas that we think you should comment on. We are also providing links to three questionnaires that the Park put forth, which should make submitting your ideas easier.

Here are clear topics that AW strongly encourages you to comment on:

Allocation (pg 651-653)

Allocation refers to the division of use between private and commercial visitors. The Park has proposed the following options:

1. No Change Option (Split Allocation) - use is allocated between commercial and private in an inflexible system; the Park "appears inflexible and unresponsive to changes in demand between user groups".
2. Common Pool - people interested in commercial or private trips would apply for launches through the same permit system. The park would distribute permits based on applications.
3. Adjustable Split Allocation (Park preference) - adjustments would be set for each sector as in the split allocation system, and future adjustments would be made to the allocation to reflect measured demand. All visitors would register with the Park and then be instructed to contact a commercial outfitter or private system.

Each of these alternatives poses significant challenges; therefore AW is considering two modifications to the Parks' proposals, these are:

1. A split allocation (#1, above) with use divided 50:50 between private and commercial. The allocation would be measured by either launches (easiest) or user days (confusing).
2. Adjustable Split Allocation (#2, above) with all unused launches permanently passing to private boaters via a cancellation system until a ratio of 50:50 launches is achieved.

In addition, AW is considering our position on the following recommendation from our members, which would raise the number of private launches under Alternative H from 428 to 563 (under the current system, privates are awarded 194 to 240 launch permits annually);

1. Asking the Park to raise the number of private launches during the summer from 1.5 per day to 2 per day, including one large or normal size launch per day and one small launch per day for an increase of 60 launches;
2. Balancing the number of launch opportunities between commercial and private, and adding launches for private trips including one additional launch each day in March (30), and one on every other day in April (15), September (15), and October (15) for an additional 75 launches to achieve this goal; and
3. Reducing the total number of commercial launches in the summer by 0.5 launches per day to allow the increased private use since the commercial outfitters can not use all their launches (643) and also maximize trip size or length within their user day limits under the Alternative.

Wait List Transition to New System (pg 663-4)

The Park has suggested three options for distributing private boater permits, AW does not yet have an opinion on which to recommend. Here is a simplified description of each alternative:

1. No Action Option - waitlist members would continue to be allocated 240 launches per year on the same launch pattern as current; all other launches would be divided as described under Permit options.
2. Encourage People to Leave Current Waitlist and Reduce Waitlist Allocation Option - Existing waitlist members can 1) remain on the waitlist or 2) accept payment or other incentives to voluntarily move to the new permit system. Incentives include:
   1. $250 transferable bac kcountry credit for use in next 5 years;
   2. Immediate refund of $150;
   3. Cash refund and increased chance of getting permit in new system;
3. Same as "#2 Encourage People to Leave Current Waitlist and Reduce Waitlist Allocation Option" with the wait list to be abandoned after 5 years. Those people who have not accepted any of the incentives in #2 and remain on the list would be given a refund and the list would be terminated.

Permit Options (pg 654-663)

The Park has suggested the following options for distributing boater permits. The GCPBA supports a dual system with 200 permits distributed under the Wait List and the remainder under the Pure Lottery.

1. No Action Option - Waitlist

2. Waitlist for Groups Option - All members of a group would register; the groups who have waited the longest would get permits. AW thinks that this option is unworkable and poses significant difficulties for visitors. Life events (births, weddings, etc) will occur faster than permits can be awarded.

3. Pure Lottery for Groups Option - Similar to the system on Salmon River. An individual can apply for a single launch date, or the individual can join a group and every person in the group can individually apply for the same dates and increase their chances of getting a permit on the desired date.

4. Weighted Lottery for Groups Option (Park preference) - People who apply for the lottery get an extra chance every year they fail to win a launch.

5. Points-Based Auction for Groups Option - Another example that AW thinks is unworkable and unnecessarily bureaucratic.

AW's first choice is for the Park to implement a dual system in which people can sign up for the Wait List (#1) or a Pure Lottery (#3). If the Park opts not to use a dual system, then AW's second choice is for the Park to move to a weighted lottery.

Trip Composition

The Park has suggested that trip leaders would have to list all trip participants one year in advance. AW believes that this is both impractical and unreasonable because people's lives change in the course of a year, it is unnecessary from the perspective of a trip planner, it does not benefit the visitor, is simply a bureaucratic hoop to leap through, and adjusts one part of the existing system that works. AW believes that identification of the trip participants should not be required until 90 days in advance as required under the existing system, the existing system should be continued.

Helicopters

AW opposes helicopter transfers in the Grand Canyon, due to experiential impacts, noise, and safety concerns; AW intends to request that the Park stop helicopter transfers for these reasons. In the event that helicopter use is allowed to continue, AW will request that helicopter transfers be limited solely to the hours between 9 and 11 AM. This will allow visitors the opportunity to plan to avoid the disturbance of the helicopters.

Resource Protection & Cultural Sites

The Park is very concerned by the impacts of visitors on environmental and cultural resources and has introduced a new measure of "User Discretionary Time" to help manage for those impacts. The Park's concerns can be addressed largely through the full implementation of mitigation alternatives. Additional mitigation tools that AW is considering in our recommendations include: limits on campfires to address air quality and resource protection concerns, campsite restoration trips, and implementation of smaller and/or faster trips.

Group Sizes or Number of Boaters

The Park proposes a continuation of the 16-person limit on "large" private trips as well as the creation of a new "small" 8-person trip for privates. AW is very interested in the opportunities that the smaller trips offer to increase the number of launches, reduce visitor impacts, and offer faster trips more suitable to kayakers and raft-support kayak trips. One group of rafters among AW's membership recommends limiting the small trips to two rafts in order to reduce the footprint of the trip and to address park concerns about campsite access, mooring impacts, and crowding.

Cancellations

The Park does not currently include a recommendation to offer private boaters the ability to pick up trip cancellations under the new plan. AW will propose that the Park extend the existing cancellation system under the new plan and continue the policy reallocating unused commercial launches to privates within the same calendar year. Finally, AW will recommend that privates be given a user day capacity sufficient to take advantage of the launches.

Trip Length

In Alternative H, the Park proposes a two-day reduction in maximum trip length during the summer to 16 days. The Park's trip length reduction is designed to control visitor impacts. AW is considering recommendations to offer longer trips to groups who volunteer to adopt-a-beach, help with trail maintenance, or otherwise help mitigate visitor impacts.

Common Elements (pg 30-32)

Repeat Use: The park proposes a limit to one trip per person per year. AW is considering a recommendation to lift this restriction. At present, repeat use is very low. Individuals who have visited regularly have incredible knowledge of the trails, logistics, routes, campsites, and historic lore of the canyon that substantially increases visitor enjoyment. If the park is going to implement a reduced trip length, it will be even more important to have knowledgeable boaters who are familiar with the canyon and can make rapid, informed decisions.

Generator Use: Generator use will be limited to emergency situations and pumping rafts. AW strongly supports this restriction as it increases the visitor's opportunity for a wilderness experience.

Commercial Operator Responsibility for Passengers: Commercial passengers must be accompanied by an NPS approved guide on all trip-related hiking, including exchanges. AW supports this restriction as a mitigation for large group visitor impacts and ensuring visitor safety.

Guides: Guides are indistinguishable from other users regarding social and ecological impacts.

Site Restrictions: Tapeats and Kanab Creeks will be restricted to day use only.

Little Colorado River: No boats will be allowed to enter the LC and swimming will be limited to the lowermost 300 feet; the restriction is designed to protect the endangered humpback chub.

Diamond Creek Takeout: The Hualapai, who own the takeout, have requested that the public not use the landing between 7 and 9 AM.

Minimum Trip Length to Phantom Ranch: A minimum trip length to Phantom Ranch of three nights will help to spread out use.

Commercial Guides on Private Trips: Commercial guides may not be hired to assist on private trips.

Administrative Use: Administrative use will be measured and is considered as an addition to the recreational use allocation.

Monitoring and Implementation: The Park affirms that it will develop a monitoring and implementation plan; AW will request that the park create a budget for implementing the plan and secure funding for full implementation of all monitoring and implementation components.

Lower Gorge

The Lower Gorge is an overlooked treasure. The views and climate are far different from the Canyon. However, the Park in cooperation with the Hualapai tribe is proposing a significant increase in use. The alternatives are described on page 79 of the Plan.

Park Service Questionnaires

Here are three questionnaires that the park would like you to help them by answering. Be sure to describe how or why a change would affect your experience or enjoyment of the Grand Canyon.

Weighted Lottery Comment Form: http://www.nps.gov/grca/crmp/documents/handouts2/Station6WeightedLotteryCommentForm.pdf

Transition Comment Form:

http://www.nps.gov/grca/crmp/documents/handouts2/Station6TransitionCommentForm.pdf

Adjustable Split Allocation Form:

http://www.nps.gov/grca/crmp/documents/handouts2/Station6AdjustableSplitAllocationCommentForm.pdf

Comments

The park has provided guidance on submitting comments to them on the plan at http://www.nps.gov/grca/crmp/public/index.htm. Comments on the Draft EIS can be submitted in one of the following ways:

• mailing address for comments: CRMP Project, Grand Canyon National Park, PO Box 129, Grand Canyon, Arizona 86023
• fax number for comments: 928-638-7797
• web address for submitting comments electronically: www.crmpcomments.com (the comment boxes in the electronic form will expand to accomodate as much as you want to write)
• hand-deliver comments to Grand Canyon National Park or provide comments at one of the seven public meetings

Please email a copy of your comments to American Whitewater so we can consider your comments as we craft our own.