n mid-December, the Park published the draft copy of the Commercial Operating Requirements (cor's) for the year 2000. Over the past few months, both Grand Canyon River Guides (gcrg) the Grand Canyon River Outfitters Association (gcroa) have been going over the changes in the cor's that we feel are important to address. Through phone conversations, meetings, and some very productive discussions, we have been able to work together to reach a better understanding of the cause and effect of the proposed changes.
Grand Canyon River Guides feels there are three areas that need to be looked at more closely. They are:
1. Guide Sponsorship Letter
2. First Aid Requirements
3. Supplement G

Guide Sponsorship Letter
Under the current system, as it stands right now, anyone can walk into the ranger's station at Lees Ferry and take the guides' certification test regardless of actual experience. All that is needed is a good understanding of the cor's. There is no real way presently to prove that a new guide has the needed river experience to become a certified guide and this makes the system weak. In an effort to tighten up this loophole, the Park has suggested that all new guides wishing to take the certification test have a sponsorship letter from an outfitter stating that the guide in question does indeed have the required six trips needed to become a certified river guide.
Gcrg agrees that the current system needs to be improved upon. However, we feel that placing the responsibility of guide sponsorship into the hands of the outfitters gives them control over who can and cannot become guides. Our suggestion is that new guides interested in becoming certified would carry the responsibility of trip verification in the form of a letter—a letter that would prove experience. For each trip completed, this letter would be signed and dated by a qualified guide, company, private trip leader, or the Lees Ferry Ranger, thereby providing verification of the required six trips needed to become a certified river guide in Grand Canyon. In order to become a certified trip leader, one would need the signatures and trip dates to verify that the ten commercial trips needed to become a trip leader had been completed. This suggested system would put the responsibility for trip verification in the hands of the guides, while at the same time strengthening the system.

First Aid Requirements
As stated in the Draft cor's for 2000, the nps is interested in raising the minimum first aid requirement to Wilderness First Responder (wfr). Higher emergency medical certifications above wfr would also qualify (emt, wemt, or Emergency Medical Doctor). Over the next three years each guide would need to renew his or her first aid by taking the 72-hour, nine-day wfr course, take an emt class, or become an Emergency Room Doctor. One might think this is all well and good, if we are sincere about attaining the highest standards of professionalism. But before we agree to this, let's take a closer look at it. After all, we are talking about the minimum requirement. The first questions that come to mind are, “Why do we need to change the minimum first aid requirement? Are we lacking in the level of skill or professionalism with the current system? Do we have a track record of mishandling emergency situations on the river? Are we doing a bad job?” The answer, of course to all of these questions, most emphatically, is “No”. We are, in fact, doing an excellent job under the current system. So, if the system is not broken, then why try to fix it?
A large number of older, more experienced guides are certified in Red Cross First Responder or the forty-hour Wilderness Advanced First Aid (wafa) course sponsored by Wilderness Medical Associates. Both of these courses have been specifically designed for on-river emergency situations. The Red Cross First Responder course, taught for the past several years by Patty Ellwanger and Dan Dierker, teaches how to set up a landing zone for a helicopter evacuation, which is one of the most important parts of any emergency situation on the river. Another interesting fact about the Red Cross course is that the fee paid for the course stays in the local community rather than ending up in someone's pocket. Upgrading the first aid requirement would most certainly put a hardship on older guides who have much more experience at handling emergency situations. It would also be a mistake to ignore the time and hard work of the many people who made the effort to improve the existing courses to meet the needs of the working guide. Under the present system there is no way to “bridge” between the Red Cross First Responder and Wilderness First Responder certifications. There is also no mechanism in place to upgrade from a wafa and wfr. Lastly, there is no “grandfather clause” to give credit for years of experience or other first aid certifications.
We see this as a very costly change, not only in terms of money but also in the time it would take to re-train a large number of guides. It could easily result in the loss of experienced guides who will choose early retirement over re-training. We strongly urge the Park not to change, but rather to maintain the current standards for First Aid certification as defined in the 1999 cor's. Trust the individual guides to voluntarily upgrade their first aid training. Gcrg certainly feels that the proposed changes would not improve the system.
If you would like to become wfr certified, the best course of action would be to contact Wilderness Medical Association for information. Check out www.wildmed.com, call 1-888-945-3633, or talk with your outfitter about sponsoring a wfr course. As for emt or Emergency Room Doctor certifications, contact a college or university in your area for available classes. If your card is about to expire, you will need to renew the certification you currently hold or find a wfr class offered near where you live. The wfr class is a good way to cya (cover your…).

Supplement G
The draft copy of the proposed year 2000 cor's also includes a new item called “Supplement G”. This attachment moves “regulatory items” out of the main body of the cor's (such as restricted or permitted areas, conditions for public use, as well as regulations pertaining to natural, cultural, and archaeological resources). Most importantly, Supplement G also includes applicable Codes of Federal Regulations (cfr). This is a little more difficult to understand. But to do so we must go back a few years to the days of the debate between the Coast Guard and the National Park Service as to who had control over the Colorado River in the Grand Canyon. Many of you may recall, in 1996 the Coast Guard and the National Park Service squared off over river regulation in Grand Canyon, with the matter being resolved in favor of the nps continuing to assume their regulatory responsibility for Grand Canyon National Park. It was a tough fight, but in the end the Park Service won by proving that that they could do a better job of managing the river than the Coast Guard. However, by law, the Park is now, and always has been, required to enforce the Codes of Federal Regulations. The fact remains that Coast Guard and cfr regulations are “codified”. In other words, even though not specifically stated in past cor versions, these regulations are mandated by federal law and the Park must abide by them. There are a lot of cfr's. This book is thick. Rather than incorporating them into the cor's, the Park has gone through the cor's and pulled out the reg's that are in fact duplicated in the cfr's . They have put these cfr's into Supplement G as an f.y.i. In doing so, the Park has been able to shorten the cor's by about five pages. Good news, bad news. Bad news is, Supplement G adds about six pages to the cor's. Gcrg feels that some of the cfr or Coast Guard regulations (as summarized by the nps in Supplement G) are vague and open to broad interpretation. We would like to see the regulations rewritten to be more concise and easier to understand—an interpretation of law written specifically for the Colorado River in Grand Canyon.
So there you have it in a nutshell. Hopefully, this has cleared up a few things for you. It is important to point out that the Park is showing a great deal of interest in working towards improving the Commercial Operating Requirements. It is also important to mention that cor's need not be rewritten every year. We certainly appreciate the fact that the Park has presented the cor's in draft form and offered us the opportunity to comment. For now, it looks as though we will be operating under the 1999 cor's until otherwise notified.

Bob Grusy