COR Update

Following is a letter written by gcrg to Patrick Hattaway and Allen Keske of gcnp on January 31, 2000.
Thank you for asking our input regarding the draft copy of the year 2000 Commercial Operating Requirements (cor). After careful examination of the draft 2000 cor and comparison with the 1999 cor, we have found several significant changes that we believe need further discussion and revision before incorporation in the final cor. They are: [1.] Supplement G in general and the inclusion of us Coast Guard (uscg) regulations in particular (see pages C-33 thru 35) and [2.] changes in the level of emergency medical training required of guides (see page C-7, III.B.e.) and [3.] sponsoring by outfitters to apply for certification (see page C-6, III.B.1.).
[1.] Supplement G (see pages 33 thru 35)
Five years ago Grand Canyon River Guides (gcrg) joined forces with the nps to properly determine that the Coast Guards' jurisdiction did not extend to whitewater boating in Grand Canyon or whitewater boating in general in the United States. Therefore, gcrg must firmly object to the application, by the nps, of uscg rules anywhere in the draft cor. We feel that all regulations governing boating in the Canyon should be clear, concise, understandable, reasonable and crafted by the nps, the guides and outfitters, not borrowed from other agencies. We also feel that “Supplement G” should be abandoned in favor of the 1999 cor format because it is redundant, unclear, and difficult to understand.
[2.] Changes in the level of emergency medical training required of guides (see page C-7, III.B.2.e. and III.B.2'.c.).
This change is from “Must possess a valid emergency medical certificate equivalent to or higher than the American Red Cross Emergency Response or Department of Transportation (dot) First Responder”, to “Must be certified as a Wilderness First Responder (wfr) through a program sponsored in the United States. Higher emergency medical certifications obtained in the United States above wfr will also qualify (emt, wemt, Emergency Medical Doctor).” While gcrg is, in principle, in favor of maintaining a high standard of emergency response training, we must question the justification for such a change on the part of the nps. In other words, what specific incidents/evacuations have occurred recently that have caused concern that the current requirements are not adequate? If the justification exists, then we feel strongly that such a change needs to be phased in, allowing currently accepted certifications to expire or be bridged to the new standard. Certainly, any changes to this regulation cannot be made in 2000 from both a practical and logistical standpoint. Gcrg is going forward with our Wilderness Advanced First Aid (wafa) course as well as our Review course (re-certifies wafa, wfr and wemt) scheduled for this spring. Our courses were planned months ago based on the 1999 cor and exceed the dot standard. We also believe that bridge courses to upgrade existing certifications need to be developed and implemented. Most importantly, though, we understand that at the present time there is no national standard for this type of emergency response course. This is a serious concern. According to the Draft language, any course that calls itself a “Wilderness First Responder” course and is offered in the United States would qualify regardless of actual content. Clearly a national standard for wilderness medicine needs to be established.
Gcrg proposes that the current (1999 cor) wording be retained until such time as a national standard for a wilderness emergency medical course curriculum is established. In the interim, we are committed to working together with the nps and current wilderness medicine course providers to determine an appropriate licensing agency to work towards that goal. In addition, we will also continue to offer wafa and wfr courses and encourage guides to voluntarily upgrade their certifications to wafa or higher.
For the above reasons, two related items need to be removed from the Draft cor. They are page C-4, II.B.2., which states that, “There will be a wfr for every 18 passengers or portion of 18.” (on each trip?) and page C-11, IV.F., which states that, “Hikes involving distances more than one mile from the river should have a wfr or higher qualified individual with the group”.
[3.] Sponsoring by outfitters (see page C-6, III.B.1.)
It reads, “Any individual wishing to become a new commercial guide or trip leader must submit a nomination letter to the Lees Ferry Ranger from a licensed outfitter sponsoring their certification.” Gcrg vigorously opposes this requirement on the grounds that it creates a bias against individuals wishing to become freelance guides not associated with a particular outfitter.
In conclusion, we suggest that, in light of the magnitude of the changes proposed in the Draft 2000 cor, more discussion is needed. We also would appreciate the opportunity to meet with River Sub-district personnel and go over the entire document. Since the initial authoring of the cor over 25 years ago, new regulations have been added as needed, however, no regulations have been removed. It seems probable that at least a few of them could be outdated and the cor could benefit from a reassessment with a historical perspective. We also have some suggestions for changes in the cor that could significantly reduce crowding at certain key attraction points along the river.
We look forward to hearing from you and meeting with you soon. Thank you again for asking our input.
*****

The following is a letter written to J.T. Reynolds (Acting gcnp Superintendent) by gcrg on November 9, 2000.
It is with a sense of grave disappointment that we again write to you concerning the latest version of the “Commercial Operating Requirements,”—originally the “Draft 2000 cor's” and now apparently being adopted without changes as the “2001 cor's.” The Officers and Board of Directors of Grand Canyon River Guides Inc. responded in good faith to the park's request for comment on the Draft 2000 cor's twice by mail (January 31, 2000 and March 22, 2000) and once in person (February 24, 2000). After considerable discussion at the February meeting at Grand Canyon National Park, you personally stated your intention of reviewing the specific regulations in question, getting clearer definitions, opening discussions with Sherry Collins and articulated your desire to find reasonable solutions to the issues we raised. It was also clear at the meeting that gcrg would be appraised of any changes and would be offered further opportunity to work towards solutions with Grand Canyon National Park.
To be honest, we weren't entirely surprised at the lack of response last spring. At that same February meeting between gcrg and the Park, Superintendent Arnberger informed us of the halting the crmp process. Soon after that, lawsuits were filed and changes were happening fast and furious in the park with major shifts in the Superintendent's office and the Ranger Division. Timing wasn't entirely conducive to working on regulations that might not be in effect until 2001. However, we fully expected the opportunity to begin work with the Park on these issues again this fall.
We were taken aback when Wilderness District Ranger Michael McGinnis announced at gcrg's Fall Meeting on November 4th that gcnp planned to propose the “Draft 2000 cor's” as the “2001 cor's”. A November 6, 2000 phone call from Ranger McGinnis to Lynn Hamilton at gcrg further confirmed that the draft had been signed with no changes by the Superintendent and the Chief Ranger and would be presented at the outfitters meeting at the Park the next day. It was also clear that Ranger McGinnis, being new to the position of the newly formed Wilderness District, had no knowledge of gcrg's comments or efforts in this regard and was merely relaying the information.
We, as the Board and representatives of the gcrg guiding membership, feel very strongly concerning our previously transmitted opinions on the “cor” changes, specifically: [1.] Supplement G in general and the inclusion of US Coast Guard (uscg) regulations in particular (see Pages C-33 thru 35); [2.] changes in the level of emergency medical training required of guides and trip leaders (see page C-7, III.B.e.); and [3.] sponsoring by outfitters to apply for certification (see Page C-6, III.B.1.). We have again attached our full comments here for your review.
Our input and concern are nothing new. Rob Arnberger became Superintendent in September 1994. In March of 1995 and after several requests, gcrg finally received the “1995 cor's”. At a Constituency Panel meeting, attended by gcrg Representative Jeri Ledbetter and current gcrg vp Richard Quartaroli, among others, and after complaints about changes and some discussion, Superintendent Arberger concluded that the “1995 cor's” would not be implemented and the “1994 cor's” would remain in place with no changes for the 1995 season. He stated at that time that there was no need for the Commercial Operating Requirements to be changed annually and that he felt further input and discussion were needed before he authorized any changes. He reiterated this position at the spring 1995 gcrg annual meeting and Guides Training Seminar. Revising a gcnp position on cor changes is not unprecedented.
At that time gcrg stated “... we feel that denying the input of those with the most continuous and in-depth experience is folly. We are here, we are anxious to be part of the solution, and we look forward to helping create a workable set of ‘cor's' for 1995.” History seems to be repeating itself. Weighing in on the Commercial Operating Requirements to make them balanced, clear, concise and achievable for guides working in the unique environment in Grand Canyon is something gcrg has always tried to accomplish. Each new regulation should be carefully evaluated for merits or flaws and should be in response to a problem or a direct need. Pursuant to our goals of protecting Grand Canyon and the river experience, gcrg and the guiding community have a tremendous commitment to the resource and to safety. An average of ten years experience on the river allows us in-depth knowledge of the canyon and what makes a safe river trip. Our collective knowledge, conscientious professionalism and stewardship role in Grand Canyon should be considered for decisions directly involving the guiding community. As an organization, gcrg has always held open communication with Grand Canyon National Park as our operating philosophy. It is something for both organizations to remember. We would like to schedule a meeting with you at your earliest convenience to discuss these issues and will be contacting you shortly in this regard.
With close to 2,000 members and representing 770 guide members, Grand Canyon River Guides must firmly protest the adoption of the new Commercial Operating Requirements in this form. We respectfully request continued input into any changes that may be proposed now and in the future. And again, “We are here and anxious to be part of the solution….”