AW's Grand Canyon Comments for CRMP Scoping

Posted: 10/29/2002
By: Jason Robertson
Links to AW's comments are provided below. Our comments were over 100 pages in length and were intentionally exhaustive. We wanted to cover as many of the points that our members have expressed to us as possible with the Park.

If you have some thoughts or ideas that you'd like to share with us, our staff and volunteers would love to hear them. Please send them to Access@amwhitewater.org



CRMP Project
Grand Canyon National Park
P.O. Box 129
Grand Canyon, Arizona 86023
grca_crmp@nps.gov

Dear Superintendent Joe Alston,

Thank you for working with American Whitewater and giving us the opportunity to comment on the Colorado River Management Plan. Executive Director Risa Shimoda and I very much enjoyed meeting with you and your planning team at the scoping meeting in Baltimore, MD.

American Whitewater (AW) is a national non-profit dedicated to protecting the nation's whitewater rivers and opportunities to enjoy them. AW has 8,000 members as well as 165 affiliates that represent an additional 80,000 citizens. Many of AW's staff, board, members, and volunteers have worked on and floated through the Grand Canyon; many more are on the private boater permit Wait List. Therefore the Colorado River Management Plan (CRMP) is of great interest to our membership.

AW supports the ability for all to obtain, on an equal and timely basis, an opportunity to experience a float trip through the Grand Canyon while protecting the resource.

Attached are our detailed comments on many river management issues of interest to our membership.

Sincerely,

{Signed October 20, 2002}

Jason D. Robertson
Access Director
American Whitewater
1424 Fenwick Lane
Silver Spring, MD 20910
301-589-9453


We are now ready to start on our way down the Great Unknown. Our boats, tied to a common stake, are chafing each other, as they are tossed by the fretful river. They ride high and buoyant, for their loads are lighter than we could desireā€¦.

We are three quarters of a mile in the depths of the earth, and the great river shrinks into insignificance, as it dashes its angry waves against the walls and cliffs, that rise to the world above; they are but puny ripples, and we but pigmies, running up and down the sands, or lost among the boulders.

We have an unknown distance yet to run; an unknown river yet to explore. What falls there are, we know not; what rocks beset the channel, we know not; what walls rise over the river, we know not. Ah, well! we may conjecture many things. The men talk as cheerfully as ever; jests are bandied about freely this morning; but to me the cheer is somber and the jests are ghastly.

-John Wesley Powell, The Exploration of the Colorado River, August 13, 1869


American Whitewater's Scoping Comments on the Grand Canyon CRMP:

Table of Contents: Chapters (More detailed info)

Note that some of these chapters are as large as 140KB and will take several seconds to download. A comprehensive copy of our comments is also available for download as a zip file (167KB).

I. Introduction 6
II. Effect of the 2002 Lawsuit Settlement 8
III. Desired Visitor Experience and Unique Qualities 10
IV. Guiding Principles 12
V. Visitor Use and Logistics 15
VI. Access and Allocation of Use 31
VII. Distribution, Supply, Volume of Use, and Carrying Capacity 35
VIII. Permits 48
IX. The Wilderness Act, Wilderness Management, and Motors 67
X. Resource Stewardship and Protection 79
XI. Native American Tribal Sensitivities 85
XII. River Management and Administration 86
XIII. Fees 90
XIV. Safety 106
XV. A Member Survey and What We Learned 110
XVI. American Whitewater Consulting 113

Table of Contents: Detailed

I. Introduction 6
II. Effect of the 2002 Lawsuit Settlement 8
III. Desired Visitor Experience and Unique Qualities 10
IV. Guiding Principles 12
V. Visitor Use and Logistics 15
A. Private Use 15
B. Commercial Use and the Spectrum of Outfitter Trips and Services 16
1. Advertising and Marketing 17
2. Spectrum of use 18
3. Deadheads 20
4. Cautions 20
C. Park Service or Administrative Use 21
D. Institutional Commercial Use 21
E. Watercraft 21
F. Fads: The "River Wild" Effect 22
G. Kayaking 22
H. New Technology 22
I. Education 23
J. New Uses 23
K. Drought Effects 23
L. Scheduling Launches 23
M. Campsites 24
N. Crowding on river 24
O. Upstream Travel 25
P. Backcountry Use 25
Q. Age Restrictions 25
R. Trip Length 25
S. Trip Size 26
T. Repetitive Use Visitors 27
U. Passenger Swapping and Exchanges 27
V. Handicapped & Physically Disabled Visitors 27
W. Use Seasons 28
X. Matters of Courtesy and Etiquette 29
Y. Alcohol 30
VI. Access and Allocation of Use 31
A. Background 33
B. Priority of Access for the Public 34
C. Gauging Demand 34
VII. Distribution, Supply, Volume of Use, and Carrying Capacity 35
A. Launches 38
B. Increasing People 39
C. AW Access Policy on Carrying Capacity and Use Allocation 39
1. Fairness 39
2. Unnecessary regulation of access 40
3. Split Allocation 41
4. Case Studies 42
D. Alternatives to "User Days" for Monitoring or Allocating Use 44
1. The F. Yates Borden's Capacity Study 45
2. Campsites Are the Limiting Factor on Use 46
E. Common Pool Allocation 46
VIII. Permits 48
A. Wait List 55
B. Lottery Systems 56
C. Reservations 57
1. Simple Reservation System 57
2. Reservation-Based System Reflecting Travel Industry Procedures 58
3. First Come, First Serve 58
D. Cancellations 59
E. Length of Wait for a Permit 59
F. Monitoring for "failed" permit applications 59
G. Leaping on a Permit 60
H. An Alternative Private Permit System 61
1. Institute a Reservation System for the shoulder seasons. 64
2. Maintaining the Wait List for peak season permits. 65
3. Implement a Transition Plan 66
IX. The Wilderness Act, Wilderness Management, and Motors 67
A. Compliance with the Wilderness Act 68
B. Opportunities for Solitude and the Wilderness Character 70
C. Construction of New Facilities 71
D. The Hatch Amendment 71
E. Motor Use by the Park Service and "Minimum Tool" Compliance 71
F. Commercial Services Are Consistent with Wilderness 72
G. Motor-powered Rafts 73
1. Campsite Competition & Division of Launch Groups 75
2. Speeding & Wakes 75
3. Noise 75
4. Fumes 76
5. Water Contamination 76
H. Jet SkisĀ® and other Personal Water Craft (PWC) 76
I. Generators 77
J. Overflights and Helicopters Passenger Exchanges 77
K. Phasing Out Motor Use 78
X. Resource Stewardship and Protection 79
A. Leave No Trace 79
B. Environmental Limits on River Access for Environmental Protection. 79
1. Explanation: 80
2. Case Studies 80
C. Education 81
D. Non-Native Plants 81
E. Flood Control and Beach Restoration 81
F. Historic or Archaeological Sites 81
G. Trail Maintenance 82
H. Campsites & Beaches 82
I. Waste 83
J. Firepits 83
K. Livestock 83
L. Endangered Species 83
XI. Native American Tribal Sensitivities 85
XII. River Management and Administration 86
A. Navigability 86
B. Glen Canyon Dam 86
C. Whitmore Wash (River Mile 187.5) 86
D. Lower Colorado River Gorge 86
E. Lake Mead 86
F. Little Colorado Access 86
G. Creating an Advisory and Peer Committee on River Issues 87
H. Volunteers 88
I. Ranger Patrols & Enforcement 88
J. Wild & Scenic River Status 89
K. Buying Commercial Concessions for the Private Pool 89
L. Open Houses and Comment Period 89
XIII. Fees 90
A. Deposits 93
B. Refunds 93
C. Use of Discriminatory Economic Disincentives 93
D. Using the Fees 93
E. AWA Fee Policy: 93
1. Explanation 93
2. Case Studies 95
F. Search and Rescue: A Privilege for the Saved or Public Burden? 96
1. Introduction 96
2. The 1999 National Search and Rescue Plan 97
3. The suitability and feasibility of recovering river rescue costs. 97
4. Insurance Coverage Requirements 102
5. Conclusion 104
G. The Colorado River Fund (CRF) 105
XIV. Safety 106
A. Explanation 106
B. Case Studies 107
XV. A Member Survey and What We Learned 110
A. Summary of American Whitewater Membership Responses 110
B. Summary of All Responses (AW members and non-members) 111
XVI. American Whitewater Consulting 113

Jason Robertson

635 Joseph Cir

Golden, CO 80403-2349

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