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AW Comments on Grand Canyon

Posted: 01/31/2005
By: Jason Robertson

Jason D. Robertson

Managing Director

American Whitewater

1424 Fenwick Lane
Silver Spring, MD 20910

Joseph F. Alston, Superintendent

Grand Canyon National Park

P.O. Box 129

Grand Canyon, AZ   86023

Fax: 928-638-7797


RE: Grand Canyon DEIS Comments, January 31, 2005


Dear Superintendent Alston:


Thank you for providing this opportunity to comment on the "Draft Environmental Impact Statement for the Colorado River Management Plan for Grand Canyon National Park," released on October 1, 2004.

American Whitewater (AW) is a non-profit 501.c.3 public interest group that works to conserve and restore America's whitewater resources and to enhance opportunities to use and enjoy them safely.  American Whitewater represents nearly 8,000 members worldwide and an additional 80,000 boaters through our 115 local or regional affiliate canoe and kayak clubs.  American Whitewater has represented the boating public on issues related to Grand Canyon River running for nearly 50 years.  Many of our members have visited or seek to visit the Colorado River within the park and are currently on the non-commercial permit "waiting-list."

American Whitewater submits these comments as an addition to the January 25, 2005 "Joint Comment" statement submitted on behalf of the Grand Canyon River Outfitters Association, the Grand Canyon Private Boaters Association (GCPBA), American Whitewater and the Grand Canyon River Runners Association. This Joint Comment is attached as an appendix to this letter.

When I first started working on Grand Canyon issues 7 years ago, the private permit wait list was only a decade long, now it stretches nearly 25 years into the future.  In addition, the commercial outfitters, private boaters, and even the Park Service were at loggerheads and would barely speak with each other after decades of frustration.

I'm happy to observe that we've come a long way in 7 years and note the most fundamental shift in our relationships with the park and other interest groups.  We have built bridges and pulled the majority of the river running community together by focusing on common interests, communicating, and agreeing to work in cooperation with each other. We have succeeded at building bridges with the outfitter community while continuing to fulfill our core mission in a climate of mutual respect.

 On January 25, 2005 American Whitewater joined the GCPBA, the Grand Canyon River Outfitters Association and Grand Canyon River Runners Association in making a historic joint recommendation to the Park Service that includes equal annual allocations of commercial and non-commercial use, the continuation of an appropriate type and level of motorized and non-motorized recreational opportunities, seasonal adjustments that would result in fewer river trips happening at one time, and improvements to the non-commercial river trip permitting system. 

 From AW's perspective, the two most significant outcomes of this compromise for the private boating community are an increase in the number of user days equal to the number of commercial user days, and an increase in the number of launches that is closer to the number of commercial launches.

 We are optimistic that you will accept our joint recommendations as they are based largely on the park's preferred alternative H and are designed for the greater good of the visiting public, park administrators, and environment. We've reached a responsible and historic compromise that we believe truly achieves something for everyone. 

 This agreement was made possible by the high regard that boaters of all stripes and backgrounds place on the environment.  Over the past 30 years since the first and second management plans were implemented, boaters have embraced leave no trace practices, which are central to leaving a minimum footprint on the environment. The beaches and water of the Colorado River are cleaner now, ash rings and campfire scars are largely a thing of the past, and boaters have developed a deeper appreciation and respect for protecting historic artifacts and sites.  By being good stewards of the environment, we have demonstrated that a moderate increase in use is acceptable. For that, every park visitor deserves a pat on the back.

 Most importantly, this agreement provides breathing room for the park to fully implement the recommended changes to the management plan and demonstrates the visitor commitments to responsibly protecting this national treasure.

 Our hope that that our joint recommendations will be fully implemented and that individuals will be able to fulfill their dreams of visiting the Canyon in a timely manner whether they wish to explore the canyon for themselves in a self-guided trip or as a guest of an outfitter.





Jason Robertson

Managing Director, American Whitewater



American Whitewater comments, January 31, 2005

Joint Comment, January 25, 2005


 American Whitewater comments, January 31, 2005

American Whitewater comments, January 30, 2005. 3

Introduction. 3

Glen Canyon. 5

Beaches. 5

Resource Protection & Cultural Sites. 6

Water Quality. 7

Allocation (DEIS, pg 651-653) 7

Cancellations. 8

Gauging Demand. 8

Use Seasons and Daily Launch Rates. 9

Additional Ideas for Launch Allocation. 10

Wait List Transition to New System (DEIS, pg 663-4) 10

Non-Commercial Permitting System (DEIS, pg 654-663) 11

Identification of Trip Participants. 12

Group Sizes or Number of Boaters. 12

Visitor Exchanges. 12

Helicopter Use. 13

Generator Use. 13

Trip Length & User Discretionary Time. 13

Minimum Trip Length to Phantom Ranch. 14

Repeat Use. 14

Commercial Operator Responsibility for Passengers. 14

Guides. 14

Commercial Guides on Private Trips. 14

Administrative Use. 15

Privately-owned Boats on Commercial Trips. 15

Site Restrictions. 15

Little Colorado River 16

Diamond Creek Takeout 16

Funding for Monitoring and Implementation. 16

Fuzzy Numbers?. 16

Navigability. 16

Tethering. 17

Impact Analyses. 17

Carrying Capacity. 17

Lower Gorge (DEIS pg 79) 17

Conclusion. 18


On behalf of American Whitewater (AW), please accept our thanks for making a really great start with the "Draft Environmental Impact Statement for the Colorado River Management Plan for Grand Canyon National Park," (CRMP) released on October 1, 2004. The document includes some powerful ideas that are worth pursuing and that we believe provide a foundation for a final statement.  All of the alternatives are improvements over the status quo, and the park-preferred alternative H is a solid proposal that provides a good start for our comments.

American Whitewater has deliberately taken the full comment period 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 park employees and representatives 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.

The CRMP's essential purpose is to identify the specific means by which the park will preserve unimpaired the natural and cultural resources and values present in the Colorado River corridor within the Grand Canyon, while providing opportunities for responsible use and enjoyment of the area by the public.  Further, the CRMP defines and protects the quality of the various visitor experience types that the park deems appropriate for the resource. 

AW has worked on issues related to environmental protections on the Colorado River in Grand Canyon for almost 50 years. AW has also worked on issues related to the CRMP for over 25 years due to the importance of the river management to our membership. The two major reasons that AW helped to initiate legal action to restart the CRMP were to conserve and protect the resource, and to repair the private permit wait list. We wish to express our support for a modified version of the park-Preferred Alternative H with these purposes in mind.

In our judgment, Alternatives H has the most to offer in terms of improving access and protecting the environment.  AW supports a modified Alternative H, as described in the Joint Comment, 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,

§         Equity and fairness,

§         Diverse visitor opportunities and experiences, and

§         Improved access.

However, our support is contingent upon implementation of the following critical modifications:

§         Remove the "all-user/adjustable split allocation" element and replace with traditional fixed allocations capped at an annual user-day level of 115,500 each for the commercial and non-commercial sectors, for a total annual recreational user-day allocation of 231,000.  Non-commercial use opportunities would occur year-round.  Commercial use would continue in the summer months and in part of the shoulder seasons.

§         Modify the Alternative H river use seasons to:  (1) begin the commercial use period on April 1st instead of March 1st, (2) end the summer season on September 15th instead of August 31st, (3) redefine the no-motors period as September 16th through March 31st, instead of September 1st through February 28th, and (4) authorize the addition of two "small" non-commercial launches per day in March.

§         Replace the "weighted" lottery non-commercial permitting system proposal with a "multiple pathway" system to include two separate but complementary avenues of permit application and award:  (1) a conventional, "pure" lottery under which all applicants would have an equal mathematical chance of winning a river trip opportunity, and (2) a reservations system that would allow a limited number of applicants to reserve a launch date up to three years in advance, along with the ability to register to receive a cancelled permit on short notice.

As described in the Joint Comment, AW is offering additional, individual Colorado River management policy recommendations that lie outside of the scope of the joint recommendations.  These comments are intended to clarify or develop ideas described in the Joint Comment. In the event that the park perceives any contradiction between the Joint Comment and AW's comments, please refer to the Joint Comment as the prime position of AW.

NOTE: Throughout this document, AW uses "privates" and "non-commercial" visitors interchangeably to mean the same user group; likewise, we use "outfitter" and "commercial" to refer to the same group.

Glen Canyon

AW recommends that the park work for the removal of Glen Canyon Dam, which the park correctly identifies as having throughout its past and future existence, the greatest negative harm on the river, with negative impacts to water quality, endangered species, beach quality, visitor experiences, and spread of invasive species.

As one AW member observes, "It is not possible to make a meaningful distinction among the alternatives without holding the effects of Glen Canyon Dam constant and making an assumption that the effects of river users on the ecosystem can somehow be compared with the cumulative effects of the dam.  The long-term effects of river users on most elements of the Canyon ecosystem within the river corridor can never rise to the level of significance of the effects of Glen Canyon Dam."

The park's introduction to the DEIS makes the misleading statement that the construction of Glen Canyon Dam "resulted in a steady flow of water in the river and made river running feasible on a year-round basis."[1]  While the steady flow might make river running commercially feasible for marketing purposes, the steady flows likely have little effect on private boating as witnessed by river trips during historic high and low flows. AW asks that this language be changed.  Further, Glen Canyon Dam was operated with more variable flows in the 1960's to 1980's and this variable flow regime had no apparent affect on visitor demand.


The DEIS makes repeated references to the demise of the beaches as a result of the operations of Glen Canyon Dam.  AW asks that the park work to obtain the removal of Glen Canyon Dam to mitigate this problem.  As long as the dam is allowed to continue its harmful operation and negatively affect the environment, then AW asks the park to research and act on implementing the means of rebuilding the beaches through natural processes and manipulation of flows based on historic seasonal flows prior to construction of the dam. 

Additionally, AW asks the park to begin testing a variety of smaller launch sizes now, so that the park will have data in the future on a reasonable range of access opportunities. We feel that this is very important given the uncertain future condition of the beaches.

Resource Protection & Cultural Sites

Understandably, the park is very concerned by the impacts of visitors on environmental and cultural resources.  However, the park's concerns can be readily addressed through the full implementation of mitigation alternatives, which are described throughout the DEIS. 

Additional mitigation tools that AW recommends include: limits on campfires to address air quality and resource protection concerns, campsite restoration trips, and implementation of smaller and/or faster trips.

Study after study on rivers around the nation demonstrate that most visitor impacts occur in the first period of use at new trails or campsites (see research and bibliographies by recreation ecologist Dr. Jeff Marion, a scientist at the U.S. Department of Interior and adjunct professor at Virginia Tech).  Though the DEIS mentions a concept put forth in the 1970's by Steve Carruthers regarding "rest" periods for canyon, there is not a single shred of evidence that a rest period is necessary.  As a theory, this concept is untested and is not supported by research on other river environments except in the most highly impacted areas.

A survey of the research literature on this topic generally shows that biological impacts occur early when visitors first trample and compact vegetation. The fact is that hundreds of users staying on trails have limited impacts, but it only takes one party with bad practices to spoil a spot. After campsites and trails are established, the best means of controlling and limiting impacts is through education for all visitors in order to make sure that everyone knows what actions and practices are expected of them.

AW recommends developing a web-based interface for visitors to access that describes the park's concerns and how visitors should interact with the environment and natural resources. A good example for implementation in the Grand Canyon is the one used by the Bureau of Land Management at Paria ( ).

AW recommends consideration of environmental friendly signage or trail markers in areas that are especially sensitive to trampling.

AW recommends working with the Hualapai or other tribal governments to provide cultural seminars for visitors at the Lees Ferry launch point.  When supervised, these types of seminars have proven effective on the Middle Fork Salmon, which is managed by the US Forest Service. Though some visitors had concerns about the effectiveness of the seminars, we have found anecdotally that there is nearly 100% recall that the seminar was provided, whereas there was much less recall of seminars provided by Forest Service staff.

Over the past 30 years, since the first and second management plans were implemented, boaters have embraced leave no trace practices, which are central to leaving a minimum footprint on the environment. The beaches and water of the Colorado River are cleaner now, ash rings and campfire scars are largely a thing of the past, and boaters have developed a deeper appreciation and respect for protecting historic artifacts and sites.  By being good stewards of the environment, we have demonstrated that a moderate increase in use is acceptable. For that, every park visitor deserves a pat on the back.

Water Quality

What is the park doing to improve water quality and reduce impacts from the Page water treatment facility?

As one AW member writes, "An increasing number of river users are becoming sick despite treatment procedures that are better today than in the past. According to your examination, the Page water treatment plant is at least sometimes responsible for contaminating the water. There is no plan for continued monitoring and no plan for remediation. This is a serious matter. Sickness in a wilderness setting is far more problematic."

AW recommends that park be far more aggressive in protecting the water quality from illness causing pathogens, and in providing ongoing monitoring.

Allocation (DEIS, pg 651-653)

As described in our Joint Comment, "A fundamental purpose of the CRMP revision process, because it is a fundamental complaint with the status quo, is to return a 'feeling of fairness' for all Colorado River users in relation to each other, while protecting the resource.  We believe our proposal will accomplish this key objective as it provides for equal commercial and non-commercial allocations on an annual, but not seasonal basis."

Allocation refers to the division of use between private and commercial visitors.  AW supports an equal (50:50) split allocation between commercial and private use. We believe that this is fair, easy to administer and describe to visitors. For the purposes of the Joint Comment, user days are the primary measure of equality.  Although not equal in number, the distribution and availability of launches provides the second measure of fairness in terms of proximate number, and seasonal scheduling. The final point of comparison is in number of people.

The park has proposed three options to allocate use: No Change Option (Split Allocation), Common Pool, Adjustable Split Allocation (park preference). Each of these alternatives poses significant challenges; however AW recommends continuing a split allocation with user days divided equally (50:50) between private and commercial.  The allocation would be administered by either launches (easiest) or user days (confusing); however, the measure of fairness would be in user days.

In our Joint Recommendation, we have proposed new user-day allocations of 115,500 each for both the commercial and non-commercial sectors, for a total annual recreational user-day allocation of 231,000.

Under our Joint Recommendation, non-commercial use would continue year round in a manner very similar, but not identical, to the seasons and launch scheduling outlined in the park Alternative H proposal presented in the DEIS.  Commercial use would continue to be concentrated in a redefined summer use period, with some taking place in some shoulder months.  Notably, the collaborating groups are proposing an overall recreational river use level that is less than that proposed by the park in its Preferred Alternative H.    

This equal division of the available recreational use, even, as we propose, on an annual but not a seasonal or day-by-day basis, would serve several key purposes.  The park would escape the heavy administrative, financial, and controversy burdens that would undoubtedly flow from any attempt to craft, implement, and operate a registration or demand-quantifying system on which the award of recreational allocation would be based.  Moreover, continuing to rely instead on fixed allocations would relieve both user sectors from any temptation or pressure to seek to manipulate "demand" over time, in efforts to protect or enhance their interests, position, or opportunity. 


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

Gauging Demand

Visitor demand for access can, and should, be measured through much less costly or bureaucratic processes than the "all-user/adjustable split allocation" system proposed by the park. AW recommends using a variety of administrative measures that do not needlessly burden visitors or potential visitors. Low visitor and administrative impact alternatives for gauging demand include: collection of data on failed lottery applications, online reservation system visitor counts for comparison to successful reservations, percentage counts of filled launches for private and commercial use, etc. 

AW opposes the park proposal to adopt and implement an "all-user/adjustable split allocation" system. As we understand it, this system is designed to measure relative commercial to non-commercial "interest" or "demand" for river trips and to adjust the allocation ratio accordingly on an ongoing basis.  However, after careful consideration of what would necessarily be such a system's inordinate complexity, heavy administrative burden and cost, polarizing effect on Grand Canyon river constituency groups, and most importantly, the overwhelming likelihood that implementation of such a system would unnecessarily exacerbate and perpetuate conflict between the commercial and non-commercial Colorado River user sectors, we feel that it would be best for the park to abandon this management concept. We strongly urge the park to abandon this proposal.

Use Seasons and Daily Launch Rates

AW supports the use of a launch-based system to distribute launches evenly across days and seasons throughout the year. AW believes that it is appropriate to reduce the maximum number of launches per day to 6 during the summer peak season.

As described in our Joint Recommendation, the collaborating groups recommend a small number of critically important modifications to the park Preferred Alternative H Colorado River use seasons and their associated daily launch rates, as outlined in the attached chart. 

Under our proposal, the number of non-commercial trip opportunities would be increased by adding two "small" trips a day in March.  What had been March commercial use under the original Alternative H proposal would be moved to the first two weeks of September.  The start of the no-motors season would be moved from September 1st back to its historic start on September 16th.  The no-motors period would be lengthened, however, by two additional weeks over the original Alternative H scenario, by including the entire month of March.  Hence, the mixed-use (motorized and non-motorized) period would run from April 1st through September 15th and the no-motors period would run from September 16th to March 31st each year.  In addition to being important elements of our proposal to address allocation issues, these recommendations could reduce potential impacts on vegetation and wildlife during part of the critical spring reproductive months.

Commercial use would continue to be concentrated in the summer period with some occurring in some shoulder months, while non-commercial use would continue to take place on a year round basis.  This necessarily results in a situation in which, while annual allocation levels would be the same for both sectors, seasonal allocation levels would vary.  While some will always continue to desire more use, the collaborating groups are committed to this approach as a fair and equitable distribution of the available Colorado River recreational use allocation, which we understand the park to believe to be fully appropriate and acceptable under the park's resource protection mandates and requirements. 

Our preference is for the park to maintain a healthy variety of trip offerings as proposed in Alternative H, while discarding any river management scenarios that would require all trips to be of an identical type and/or itinerary.  The seasons we propose and recommend (please see the chart below for our recommended daily launch rates and daily trip types for each season) are:

Summer:                                   May 1 - September 15

Spring Shoulder:                       March 1 - April 30

Fall Shoulder:                           September 16 - October 31

Winter:                         November 1 - February 28


Mixed-Use Period:                   April 1 - September 15

No-Motors Period:                   September 16 - March 31

Additional Ideas for Launch Allocation

Through the lifetime of this management plan, AW asks the park to periodically re-evaluate whether the total number of private launches in the summer, late spring, or early fall might be raised from 1.5 per day to two per day, including one normal size launch per day and one small (8-person) launch per day. The summer months are most desirable from a visitor standpoint because of the ease of planning family vacations, and overall comfort of the climate.

AW asks the park to consider providing additional launches or longer trips during the summer, spring, or fall for non-commercial launch groups seeking to provide the park assistance with supervised: trail management, beach clean-ups, resource protection activities, etc.  We believe that this is a viable means of mitigating the larger footprint of adding or extending launches.

AW asks the park to reallocate unused commercial launches to private use as they become available during the course of the year in order to allow the non-commercial user day allocation to be used fully.  We believe that this is fair, that it is a current practice that the park has been able to perform successfully in recent years, and does not impede the commercial visitor experience.

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

As one AW member observes, it is important to treat wait list applicants with respect, "Transition to a new system is difficult. Many users have been waiting more than a decade. Many, especially those who would have received a permit in the next few years, will be upset. Most of us are on the list.  It is important to strike a balance between the new and old system transition and treat list participants fairly." However, AW feels that it is important to move quickly to full implementation of a new system and suggests completing the transition with three years.

AW supports the park's recommendation for encouraging people to leave the current waitlist and terminating the wait list after three years. Under this recommendation about 200 of the total non-commercial launches would be allocated to reducing the wait list annually.  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 that AW believes should be included are:

§         $250 transferable backcountry credit for use within 5 years;

§         Immediate refund of $150, this would also allow the individual to apply for a permit under the new distribution system described in the Joint Comment;

§         Cash refund and increased chance of getting permit in new system; or

§         Extra lottery chances for the first two years of the lottery, with the number of extra chances based on time on wait list; and

After three years, those people who have not accepted any of the incentives and remain on the list would be given a refund and the list would be terminated.

Given the immense length of the current wait list, AW recommends against allowing people to defer launch permits from one year to the next.

Non-Commercial Permitting System (DEIS, pg 654-663)

AW supports a dual system with 200 permits distributed under the Wait List and the remainder under the Pure Lottery.

The park has suggested the following options for distributing boater permits.

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.

As noted in the Joint Comment, AW's first choice is for the park to implement a dual or "multiple pathway" system in which people can apply for a permit via either a reservations system or a Pure Lottery.  If the park opts not to use a dual system, then AW's second choice is for the park to move wholly to a weighted lottery, though we recognize potential problems with this system as described by the GCPBA in their comments. Fundamentally, any new system must be efficient and affordable for both user and administrator, fair and equitable, and easily explained and understood. 

Under the "pure" lottery all applicants would have the same chance to win, and the system would start fresh each year. The second path would be an on-line reservations system where available launches would be secured through an application process that would include identifying participants and paying fees in advance.  Under both access pathways, cancellations would appear as available launch dates in the on-line reservation calendar.

AW defers to an AW affiliate, the Grand Canyon Private Boaters Association (GCPBA), for recommendations and discussion on the manner in which the two pathways would be administered.

Identification of Trip Participants

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, and appears to be nothing more than a bureaucratic hoop for visitors to leap through. Furthermore, this would unnecessarily adjust one part of the existing system that we think 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.  One idea for consideration by the park would be to offer incentives to trips that list a significant percentage of the trip participants; however, we do not think that should be a prerequisite for securing a permit.

As one AW member observed "It is extremely difficult to coordinate schedules more than a year in advance.  It would be more reasonable to make a trip leader commit to a number of participants a year in advance."

Group Sizes or Number of Boaters

The park proposes a continuation of the 16-person limit on normal 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 and a maximum of 8 kayaks or canoes, in order to reduce the footprint of the trip and to address park concerns about campsite access, mooring impacts, and crowding.

Visitor Exchanges

The park has allowed visitor exchanges at Phantom Ranch, the junction of the Little Colorado, and Whitmore Wash for many years.  These exchanges provide many visitors an opportunity to participate in abbreviated trips, which they would not otherwise be able to attend given work or family obligations. However, these exchanges also create an obvious increase in use on trails that service the river, and can change the social dynamics of trips as people come or go for good or bad.

AW encourages the park to continue allowing visitor exchanges as long as the visitor impacts to trails and park resources are acceptable, with the exception of allowing helicopter exchanges at Whitmore Wash. An administrative record should be kept documenting the number and location of allowable exchanges.

Helicopter Use

AW unconditionally opposes helicopter transfers in the Grand Canyon, due to experiential impacts, noise, and safety concerns; AW requests that the park do everything in its power to stop helicopter transfers for these reasons. 

In the unfortunate event that helicopter use is allowed to continue, AW requests 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.

Generator Use

AW strongly supports the park's recommendation to limit generator use to emergency situations and pumping rafts. AW strongly supports this restriction as it increases the visitor's opportunity for a wilderness-type experience.

Trip Length & User Discretionary Time

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 by limiting "user discretionary time[2]."

AW strongly recommends not using discretionary time as a determinant for inclusion in the Final EIS. AW requests that the park provide further detail on how user discretionary time is calculated for the alternatives, and the scientific justifications for this unit of measurement as a research or management tool.

AW has reviewed the literature and believes that the concept of discretionary time is fundamentally flawed since there is no data to support the park's premise. The park does not know what visitors have done or will do with that discretionary time. Will visitors hike, cook, swim, sleep, or eat?  What are the likely impacts of those activities? How can those impacts be controlled through other means such as education? Further, the concept was not referenced during scoping, which poses serious legal concerns for using the term as a management criterion. 

A 16 day trip length is certainly possible; however, it leaves little room for layovers or rest days for weary visitors, and leaves even less room for trips to accommodate weather-related problems such as sustained upriver winds or storms that have the real potential to significantly delay downriver progress.  Certainly individual AW members have expressed great personal concern for a reduction in summer trip length from 18 to 16 days. If the park chooses to reduce trip length from 18 days, then AW requests that the park research effects on visitor experience and document environmental impacts in comparison to the existing 18 day threshold.

At a minimum, AW recommends offering longer trips to groups who volunteer to adopt-a-beach, help with trail maintenance, or otherwise help mitigate visitor impacts.

If visitor impacts reach a level of concern for the park, they can be controlled largely through education as described previously.

Minimum Trip Length to Phantom Ranch

AW agrees that a minimum trip length to Phantom Ranch of three nights will help to spread out use. However, as described in recent publications of the American Whitewater Journal, some people would like to be able to move faster or slower. These trips are uncommon and AW strongly encourages the park to limit the 3 day minimum trip length to Phantom to motorized trips. AW does not believe that the limitation should apply to non-motorized trip length to Phantom.

Repeat Use

The park proposes a limit to one trip per person per year. AW asks the park to reconsider this restriction. At present, repeat use among commercial and non-commercial visitors is very low. However, individuals who visit the Canyon regularly have an incredible wealth of knowledge of the trails, logistics, routes, campsites, and historic lore of the canyon that substantially increases visitor and group 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. AW does not believe that repeat use is a problem or that it requires management. If a regulation is crafted regarding repeat use, it should apply equally to commercial and non-commercial visitors.

Commercial Operator Responsibility for Passengers

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


AW supports the DEIS statements that guides are indistinguishable from other users regarding social and ecological impacts. Guides provide important education services, but they still have impacts as visitors.

Commercial Guides on Private Trips

AW agrees that commercial guides should not be hired to assist on private trips. However, AW encourages the park to allow private trips to hire non-guide professionals to provide essential services such as health care.

Administrative Use

AW approves of the park's recommendation for measuring administrative use for consideration as an addition to the recreational use allocation. AW requests that the park publicly report this level of use annually along with data on levels of use by other visitor groups including commercial, non-commercial, and research or science trips.

Privately-owned Boats on Commercial Trips

AW asks the park to work with outfitters to offer guided trips in which individuals can bring their own boats (rafts, kayaks, or canoes). Some outfitters offer kayak support trips now, and it is very popular in the Spring and Fall. Unfortunately, if a visitor wants to take a commercial trip where he rows his own raft he is turned away due to the Commercial Operating Requirements (COR) placed on the outfitters by the park. This would offer a type of trip not currently available, and reduce demand for access under the private permit system. It would also allow unsuccessful lottery participants an alternative access path, and would offer many rowers (with their own gear and experience) an active trip rather than sitting in a raft while a first year boatman rows.

Specific rules could include: a minimum of 2 licensed guides per trip, non licensed boatmen would be allowed to carry family members or long time friends in their boat but only after signing a liability release (currently the regulations require all passengers to be rowed by a licensed boatman and do not allow liability releases from commercial passengers), previous rowing experience in the Grand Canyon, or additional demonstrated skills.

Insurance is unlikely to be an issue, as outfitters on other rivers offer this service, and kayak support trips already occur on the Grand Canyon in the Spring and Fall.

Site Restrictions

AW supports the use of site restrictions based on clear environmental concerns. In the event that a site or sites need to be closed for mitigation of endangered species, AW recommends instituting temporary seasonal restrictions (rather than permanent) around breeding seasons or other sensitive developmental periods.   AW recommends that the park review a publication by the Access Fund, "Raptors and Climbers: Guidance for Managing Technical Climbing to Protect Raptor Nest Sites". This publication provides guidelines on how to manage climbing in areas with cliff-nesting raptors. Produced in consultation with biologists and land managers this publication has been widely distributed to public lands managers and climbing organizations. This project is an initiative aimed at raising understanding on climbing management and wildlife protection. The document provides valuable guidance specific to climbing areas that correlates closely to management of riparian zones.

The proposed camping closures at Tapeats and Kanab are significant to the non-commercial users. Both of those river reaches have limited campsite options. In addition, the Tapeats camp is in the flash flood zone and therefore subject to regular, natural disturbances that rejuvenate the site. The Kanab hike is highly valued by a number of users and without the option of camping at the confluence, this hike will be severely limited.

Little Colorado River

AW understands that in order to protect the endangered humpback chub no boats will be allowed to enter the Little Colorado and swimming will be limited to the lowermost 300 feet. 

AW asks the park to consider the effects of this total ban on possible downstream navigation of the Little Colorado. While kayaking use is uncommon on the Little Colorado, there are historic precedents and there is continuing visitor interest. 

It would also be useful for the park to offer a description of the spawning habits for the chub and to describe what impact limits on swimming upriver of the junction on the Little Colorado will have directly on the Chub. AW would like the park to consider a seasonal closure limited to a scientifically supported area rather than closing the entire Little Colorado further than 300 feet upriver of the confluence year-round.

Diamond Creek Takeout

The DEIS explains that the Hualapai, who own the takeout, have requested that the public not use the landing between certain hours. However the hours that are listed in multiple places are inconsistent. Please clarify and correct all references in the DEIS for when Diamond Creek Takeout will be closed.

Funding for Monitoring and Implementation

In the DEIS, the park affirms that it will develop a monitoring and implementation plan; AW requests that the park create a budget for implementing the plan and securing funding for full implementation of all monitoring and implementation components.

AW is very concerned that the DEIS recommends numerous management actions, but does not provide a budget or estimate of the expense of implementation of those actions. Virtually the only discussion of budgetary needs is in administration of the non-commercial permit system and the collection of fees from non-commercial visitors. AW requests that the park prepare a budget for implementing the plan and include it in the final EIS. Further, we request that that park avoid instituting administrative actions or bureaucratic administration that would necessitate an increase in non-commercial visitor fees.

Fuzzy Numbers?

Table 2-2, pg 36 and Table 4-1, pg 223 lists an 8,985 maximum number of passengers at one time under alternative G. This is an order of magnitude higher than any alternative. However, the value is given as 895 on page 49. Which number is accurate, and which number was used in the decision making process or comparative calculations?


AW submitted a request during scoping to clarify the navigable status of the Colorado; this request does not appear to have been addressed. AW requests that the park respond on the navigable status of the Colorado. Is there a navigability assessment in the DEIS? How does state or federal navigability law affect use and management of the Colorado?


Data on impacts of tethering on beaches was conducted in 1976, is there more recent data or data from other rivers about the effects of tethering on beaches?

Impact Analyses

As described by an AW member, the impact summaries in Table 2-4 are essentially useless for comparison of effects, with a similar range of conclusions, i.e. "regional and local", "short- to long-term", "seasonal to year-round", "adverse minor to beneficial moderate", and "negligible to major." How were these conclusions developed, what research or assumptions were the conclusions based on, and what was the relative importance of each in reaching a decision?

What role did concern over campfire use pose in selection of the preferred alternative?  The statements regarding campfire use on beach and air quality appear to be short sighted and too narrowly constructed.  The fact is that campfire use is controllable and easily mitigated.  Campfires can be replaced by regulation with clean burning gas camp stoves, the number of fires that visitors make can be regulated, and campfires can be restricted in parts of the canyon that have poor air circulation or turnover. If campfire use played a significant role in a determination of alternative preference, or is likely to play a larger role in future management planning, then the park should prepare to quantitatively research the effects of campfires on the visitor and resource and the park should consider mitigation to reduce measurable impacts.

Carrying Capacity

            What is the carrying capacity of the canyon?  The DEIS does not make a clear determination of capacity, maximum use levels, or provide clear explanations that provide a basis of comparison between the different alternatives.  All descriptions are generic and appear to be based on management expectations or assumptions rather than fact, science, or quantitative measurement. 

Lower Gorge (DEIS pg 79)

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. 

Of the various alternatives, AW grudgingly supports the park-preferred alternative.

AW strongly opposes all other alternatives since we feel that they will have a terribly negative impact on visitor experience and the environment.  While we recognize the authority of tribal partners to manage use as independent governments, AW does not feel that the proposed management alternatives are in the best interest of American citizens.

AW opposes any increase in the number of overflights or air tours in the Lower Gorge as these dramatically disturb the visitor experience. 

AW opposes any increase in the number of up-river trips in the Lower Gorge and strongly opposes any increase in the amount of up-river motorized traffic from Lake Mead.  An increase in up-river travel will certainly increase competition for limited campsites, negatively affect visitor experience, and may provide a dangerous safety concern on blind curves of the river or in rapids.  Visitor experiences on other rivers, such as the Snake and Salmon with up-river motor use have demonstrated that this practice is dangerous to non-motorized watercraft and visitors.


The best course for the future management of the Grand Canyon is one that avoids confrontation between the various user groups and instead builds upon a cooperative effort of these groups to set aside their differences and to support the park in its efforts to advance its often difficult mission of preserving the park's resources while at the same time providing quality opportunities for public enjoyment of those resources. 

It is our intent to simplify these efforts and to support the park in its critical mission by providing joint and individual recommendations that will help produce a management plan that is acceptable to the river corridor's major user groups, and that at the same time is consistent with the park's obligation to preserve the park's resources and values. 

Our recommendations are in the best interests of the park and the overall public.  It is our hope that the park will give them serious consideration and ultimately adopt them as part of the final CRMP.

[1] 2004 DEIS, pg 3, para 2.

[2] 2004 DEIS, pg 28, para 3 and 2004 DEIS, Table 2-2, pg 36.

Jason Robertson

635 Joseph Cir

Golden, CO 80403-2349

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