Draft Environmental Impact Statement—
Colorado River Management Plan

After four years, two starts, a couple lawsuits, numerous public meetings, thousands of written comments, a couple million dollars spent, and a lot of controversy, the “Draft Environmental Impact Statement, Colorado River Management Plan” (henceforth called deis) is here at last. A monumental 813 printed pages, with eight appendices in electronic form on a cd-rom, which still lacks much of the information needed to understand it. It is gargantuan, contradictory, opaque, political, redundant, pedantic, “scientific to a fault,” and in places nearly incomprehensible. And there are some new ideas and new approaches to old problems.
Attempting to appease everyone, it will please no one. With all due respect to the intense efforts of the many good folks who sacrificed a couple years of their time and hard work trying to walk on water, reverse the flow of time, and save the canyon even as they deliver it in to the hands of the hordes who would devour it, we need to ask if it’s “good enough for government work.”
The answer, I think, is “not yet.” But we are on the way, and with your help—and more effort from the Planning Team—we can fill in the blanks, trim out the glitches, fine tune some new ideas, and come up with something that might actually work.
If you are on the Colorado River Management Plan (crmp) mailing list, you should have received a copy in the form of a cd-rom. If not, it’s available as a download from the crmp web site in pdf format. (See the sidebar on getting and understanding the plan.)
Before launching into a description of the various details of the preferred alternative, and discussing some questions and speculations about how they might work in practice, I should mention a couple significant omissions from the deis. First, although you are left with the impression that there is a reason why the preferred alternative was developed, and chosen over the other contenders, the reasoning behind the choices that were made often is not to be found in the draft plan. Second, the plan is long on intentions but short on details about how they are to be realized.
By the time you’ve received this issue of the boatman’s quarterly review, another (final?) round of public meetings will have been held. As explained to me by Mary Orton, the mediator who hosted the last set of public meetings, these sessions will provide an opportunity for interested members of the public to discuss various aspects of the plan with members of the planning team, get more details, and learn the reasoning behind the decisions that were made. The object is to educate interested stakeholders so that their written comments will be based upon a true understanding of the reasons for, and intent of, the various features of the management plan.
As for the lack of specific details, the following statement from the Executive Summary is worthy of attention:
Monitoring and Implementation Plan
Subject to the availability of necessary funding, the National Park Service will develop a monitoring and implementation plan once a revised Colorado River Management Plan has been approved.
If I read this correctly, they are saying, in effect, “When the final plan is approved, we’ll know what we want to do, but we’ll need more time and money to figure out how to make it work.”
Here is a quick review of the crmp, and how it addresses various issues raised in public scoping comments:
Appropriate level of visitor use consistent with natural and cultural resource protection and visitor experience goals.
Nps proposes a whopping 27.5 percent increase in total user days, with the increase going to non-commercial (“private”) boaters. The impact of this on resources is “reduced” by requiring smaller maximum group sizes, allowing fewer trips on the river at one time, and “mitigation” actions like closures, enforcement patrols, education, etc.

Allocation of use between commercial
and non-commercial groups.
Commercial allocation remains unchanged, but non-commercial use increases 77 percent as measured in “probable” user days. Commercial allocation remains controlled by user day counts, but has new restrictions on when and how many launches can be scheduled. Non-commercial use is controlled by launch allocations, one per day year-round, plus a small (eight person or less) trip every other day during the summer season. Non-commercial user days are not controlled directly, but are limited by trip size (still sixteen), trip length (shorter in all seasons) and whether or not all launches are used, and what proportion of them are full size trips taking the maximum length of time.

Administrative use.
Administrative use, which includes law enforcement, trail work, vip vacations, research, “trout chipping,” education, tribal trips, and anything else the nps decides to do on the river, is not regulated in the Draft crmp—although they say they are sensitive to the impact (25 percent of all actual user days) of these “non-recreational” activities.

Non-commercial permit system.
A new access system, in the form of a “weighted” lottery, is proposed to replace the wait list for non-commercial permits. During the transition, a dual system will exist—waitlisters can stay on the list, or accept incentives to switch to the lottery system.

Appropriate levels of motorized and
non-motorized use.
The current nine month motor season will be shortened to six months (March through the end of August) and the number of commercial motor launches will be reduced.
Levels of helicopter use to transport river passengers to and from the river.
Helicopter exchanges are limited to the four month summer season (May–August) and maximum passenger counts are slightly reduced from current limits.

Appropriate levels and types of upriver travel from Lake Mead.
There’s a separate plan for the canyon below Diamond Creek, which I have not examined in detail, since I’m not familiar with trips that routinely go across thelake. If you are familiar, please take a close look and let the gcrg Board of Director know what you think.

Quality of river trips (including crowding, trip length, group size, visitor experience, and
scheduling issues).
A mixed bag of scheduling improvements, restrictions on maximum group size, reductions in trip lengths, questionable approaches to crowding, and some negative ideas about closures, additional law enforcement presence, more rules and regulations, etc.
* * *
Grand Canyon River Guides is a non-profit organization dedicated to:
• Protecting Grand Canyon
• Setting the highest standards for the river profession
• Celebrating the unique spirit of the river community
• Providing the best possible river experience
Our comments on the plan will be based on these objectives; however, we also recognize that each of us has our own perspective on the meaning of these goals and how they can be best achieved in practice.
In no particular order, here are some of the proposed changes and some of the questions that they raise.

Carrying Capacity
The nps decided that there is a large amount of unused carrying capacity. It’s interesting that all of the alternatives, except for the “no-action” alternative, involve increased use levels (as measured in user days), with only one alternative (B—one of two no-motor scenarios) in the same ballpark as the status quo; five of the other alternatives would have allowed for even higher use levels than the preferred alternative (H—an increase of 27.5 percent); Alternative C contemplated an increase of 65 percent.
Is such a large increase in use consistent with the park’s responsibility to protect the resource? Where is the evidence that shows that such a large increase in winter and spring shoulder season use won’t have a permanent, and negative, impact on the ability of the canyon to recover from the impact of the high summer season use levels? How is it that as beaches shrink, campsites disappear, and more restrictions are placed on activities at scenic attractions, that carrying capacity can continue to increase with each new management plan?

Adjustable Split Allocation
Full utilization of non-commercial launches (all available launches taken, most trips near maximum size and length) could mean that non-commercial user days would actually exceed commercial use, although the nps estimate of “probable use” is that commercial use would be 53 percent and non-commercial use would be 47 percent of the total.
The deis proposes to measure relative demand for commercial and non-commercial recreational use by requiring all would-be boaters to register with the park before seeking a spot on a commercial or non-commercial trip. Furthermore, the information gathered would be used to “adjust” the split allocation, switching up to two launches a month from one sector to the other, with the safeguard that no sector could end up with less than forty percent.
Members of the “expert’s panels” convened in Phoenix a couple summers ago seemed to agree that they had no idea how demand could be measured, and some experts ventured that “demand” for commercial and non-commercial trips was a case of “apples versus oranges,” in which direct comparisons would be inappropriate and misleading. Other experts testified that given the impossibility of measuring relative demand in the different sectors in a meaningful way, any division of the allocation would be arbitrary.
How does the deis justify the proposed changes from the existing allocation initially assigned by Alternative H ? Won’t this registration system be a cumbersome burden on all recreational users, not to mention an administrative nightmare for the nps? What information will they collect, how will they use it to determine “demand,” and how will they insure that neither sector can scam the system to produce results in their favor? Can this registration process settle the questions about relative demand, and—if not—why bother?

Trip Size Reductions
Maximum commercial trip size is reduced to 32 people, including crew, but the crew does not count towards the user day allocation. The reasoning is that members of the crew do count in the sense that they influence total group size, but subtracting user days for the crew on a trip would provide an undesirable incentive to send out trips with minimal crews to maximize revenue.
Trip size reductions, in conjunction with a reduction in the number of summer season motorized launches, will make if difficult for outfitters to use all their motorized user days without substantial changes in their operations. The deis projects 68,636 motorized user days for 369 summer launches, an average of 186 user days per trip. If trip lengths average seven and a half days (similar to today), trips would have to average 25 passengers plus crew to consume these user days. This means that the typical summer motor trip, under Alternative H, would be a two boat trip with a group size of up to 32 people—a large group, seeking a large campsite every night. Currently, more than one out of three motorized trips are one boat trips; when the crew sleeps on the boat (typical), they have the same footprint on the beach as a private trip, and don’t need a large campsite every night.
According to the deis, it’s the size of the group that you’re are traveling in that has the most effect on perceived crowding. But Alternative H seems to mean that one boat motor trips, with their smaller group size and greater campsite flexibility, will be rarely seen during the summer months. No doubt some outfitters will opt for offering at least some longer trips, with smaller group sizes, to increase customer options and also use up their allotment. But these longer trips will certainly cost more than shorter ones, and be within the reach of fewer people; many outfitters will probably feel more comfortable selling larger trips of the same length as those they offer today.
How should we suggest that the nps address this issue? Is a reduction in the size of the largest trips worth a commensurate reduction in the availability of smaller trips? Should there be more summer motor launches, or a longer motor season, to make at least some smaller trips likely? Or should we just cross our fingers, pray for the best, and hope this all works out as an improvement?

Trip Length Reductions
Maximum trip lengths decrease overall, as follows: summer season non-motorized trip maximums are reduced from eighteen to sixteen days, while motorized trip maximums are reduced from eighteen to ten days regardless of season. Shoulder season non-motorized trips are reduced from 21 to 18 days, and winter trips are reduced from 30 to 25 days.
A significant number of commercial passengers as well as majority of non-commercial boaters would like even longer trips than are available today, yet the deis opts for more people, having shorter trips. There’s an acknowledged trade off here.
Shouldn’t we support “the best possible river experience”—including options for trips that are no shorter than those currently available, even if it means “carrying capacity” can’t increase 28 percent? We advocated longer minimum trip lengths in our comments during the public scoping sessions—shouldn’t we oppose any movement towards a “one size fits all” river experience?

Crowding, Congestion, and
Competition for Campsites
The nps plans to address these issues with tighter controls on launches, which are based in turn on the projections of the River Trip Simulator model. The River Trip Simulator (rts) was developed several years ago and is based upon numerous reports of actual trips and their interactions, as well as interviews with trip leaders about what they would do in certain interaction situations. However, the rts model was based on current rules regarding activities at attraction sites, campsites, etc.
Won’t new rules and restrictions invalidate rts projections of trip interactions as guides make different decisions about campsites and daytime activities than they did when the information upon which the rts is based was collected?

Campsite Competition
A new “small” non-commercial trip is proposed (eight people or less), with one launch every other day from May through August. These trips would be required to camp in small campsites, as identified and mapped out by the nps. Buried in the details of mitigation possibilities are similar proposals to designate medium sized camps for medium sized trips, and large camps for large trips.
Isn’t this a step in the direction of assigned campsites, which most boaters vehemently oppose? Is it reasonable to expect that non-commercial boaters, who have waited for years, will cooperate and bypass places they intended to stop? Won’t some get “lost” and end up where they aren’t expected, complicating things for everyone else? Why wouldn’t you add another crew member to a 24 person trip, changing it to 25 and qualifying for all the large camps? Would you be banned from fitting a large group into a medium or small camp, if you wanted to hike or visit an attraction site there? Won’t small trips be excluded from many attractions by this rule? Isn’t the point of the revised launch schedule—and fewer “trips at one time”—a reduction in campsite competition, and—in that case—why do we need yet another cumbersome and onerous rule to address the same problem?

Visitor Experience
Some aspects of visitor experience, such as perceived crowding, will be improved under the plan, while others (availability of longer trips, increased restrictions on activities) will suffer. The attitude towards visitor experience in the plan seems ambivalent, at best. On the one hand, they are allowing for increased visitation (measured in number of people, or user days—for non-commercial users). Yet they are proposing a number of restrictions on what people can do on a Grand Canyon river trip—how long you can stay, where you can camp, and what you can do in some places.
Overall it looks like we are moving in the direction of a “one size fits all” approach, rather than attempting to maintain (or increase) the variety of options and choices available to recreational river runners, commercial and non-commercial alike. Under the plan, the longest available trip will be shorter, and the shortest trip longer, than is currently the case. While there will be less crowding (at least some of the time) during the summer, and particularly in June, the desirable spring shoulder season will see a noticeable increase in trips, congestion at attraction sites, competition for campsites, etc. Meanwhile, the desirable fall shoulder season will be available to fewer people, due to reductions in launch opportunities during September, including the end of motor launches on August 31st. Under the plan, nobody will get to choose an eighteen-day trip during the summer, a 21-day during the shoulder season, or a thirty-day trip during the winter. And nobody will get to choose a motor trip longer than ten days, ever.
Won’t the reduced options for types, sizes, and lengths of river trips detract from, rather than enhance, the quality of river experience available to recreational users? Given the uncertainly about demand levels, is it reasonable that quality of experience suffers so that the number of recreational users can increase so much? Won’t a shorter motor season mean more research trips that require motors will have to run during the busy summer season?

Changes Common to All Alternatives
Include the Following
• One trip per year limitation on recreational use, whether commercial, or non-commercial.
According to the parks’ own information, only 0.68 percent of non-commercial boaters averaged one or more trips a year between 1998 and 2002. No similar information is available on commercial repeat users, but it’s probably in the same ballpark. What is the problem with repeat use, and won’t the enforcement of this regulation, which will require checking the identification of nearly 150 people a day at Lees Ferry, be an absurd waste of time and effort?
• A guide will accompany passengers on all trip-related hiking, including exchanges into and out of the canyon.
Since passengers will hike at very different rates, a group that starts together at the rim or river will be spread out several hours apart at the other end of the trail. Will it really make any difference if there is a guide that starts out with the group, if the guide could be separated by as much as several hours from some of the hikers? Or is this just another attempt to shift legal responsibility onto the outfitters who allow and/or encourage hiking exchanges?
What happens if someone wants to hike in a day early and spend the night at Phantom Ranch, hike out a day later, or use the North Kaibab trail? Won’t even more people who shouldn’t be attempting a hiking exchange be encouraged to do so if they know there will be a guide with “the group”?
• Day use only (no camping) at the mouth of Tapeats and Kanab creeks.
All side streams are sensitive environments, many are already protected by other restrictions (lcr, Elves, Matkatamiba, Havasu, etc.) or campsite location (Nankoweap, Clear Creek, Monument Creek, Stone Creek etc.) Wouldn’t a single rule limiting all perennial side streams to day use only and “no camping at the mouth” be more appropriate than an ever increasing list of specific closures?
• Swimming and wading at the Little Colorado River restricted to the lower 300 feet of the confluence from March 1st to August 31st, no boat parking in the lcr.
The deis says “the effect of river running on humpback chub is unknown” and suggests that roiling of substrates may adversely affect young fry. But humpback chub have evolved to live in extremely muddy water, and the increased turbidity caused by recreationists could be just as easily considered an advantage for fry, in that decreased visibility would reduced the likelihood of predation by trout and other non-native species.
Wouldn’t it be more reasonable to consider the impacts of researchers, who have repeatedly captured, tagged, clipped, implanted, and handled Humpback Chubs as a significant factor in their decline, if one must seek possible human caused impacts above and beyond the effects of Glen Canyon Dam?
Won’t this regulation, based upon the flimsiest of speculations, discourage respect for regulations in general? Furthermore, won’t this also introduce uncertainty into the interpretation of the “trout chipping” experiment that has been underway for several years? If some of the lcr is to be set aside for swimming, why not the vicinity of the rapid upstream that is a popular attraction for river runners? Wouldn’t swimming there be less likely to have adverse impacts on eggs and fry than the proposed swimming area near the confluence?

• Commercial guides may not be hired on non-commercial trips.
How is this an improvement over the wording of the “Non-commercial Use Affidavit? The current Non-commercial Use Affidavit reads:“...2. The purpose of the trip must be for its recreational value. The trip will not be conducted for the following reasons: a) Monetary gain for any trip participant...3. Collection of a set fee (monetary compensation), payable to a trip participant, individual, group, or organization, for conducting, leading, or guiding a non-commercial river trip is not allowed.”
What does this rule “clarify”? Does it mean you can hire someone who is not a commercial guide on a non-commercial trip?
• Minimum trip length to Phantom Ranch will be three nights and part of four days.
Won’t this change, and the proposed restriction on activities at the lcr, result in more crowding at other sites between Nankoweap and Phantom, which aren’t modeled by the River Trip Simulator?
• Generator use will be restricted to emergencies and pumping rafts.
This is to control noise. Why not a more general requirement, limiting other optional sources of noise as well (drums, boomboxes, etc.), setting special rules for when camping withing hearing of other trips, and/or establishing “quiet hours” at camp, starting some length of time after sunset? How about a “recommendation” to “please be quiet so your group and others can appreciate the natural soundscape of the canyon”?
Changes in the Non-commercial Permit System
In addition to allocation and launch changes discussed above, the waiting list will remain closed and will be phased out. A new “weighted lottery” is proposed to distribute launches not distributed through the waiting list. Incentives will be proposed to induce people on the waiting list to switch to the new system, but staying on the list (under the new rules) will also be an option. People staying on the waiting list, as well as people entering the lottery, will have to identify all the people in their group, and nobody can be in more than one group at the same time.
Some of our members do non-commercial trips, others don’t. To what extent should Grand Canyon River Guides be concerned with the details of the non-commercial access system?
Won’t a weighted lottery, in which participants get an additional chance for each year they have participated and lost, eventually end up as the waiting list all over again? It would appear that as repeat losers accumulate extra chances, the odds of a new participant winning a permit diminish; eventually, almost all permits would go to people who had been in the lottery for many years. How is this an improvement? Few details of the proposed system are clear; will these changes reduce, or inflame, the controversy over non-commercial access to Grand Canyon river trips?
Adaptive Management
Recognizing that things may not work out as expected, or produce the desired results, the deis mentions “adaptive management” to fix things before the next plan revision, yet provides no details of how this would work.
Will feedback from the public—guides, outfitters, passengers, non-commercial boaters, and other stakeholders—have a say in determining when changes need to be made, or will the park decide? Will there be any consultation with stakeholders about proposed changes, or will they be arbitrarily imposed by the nps?
This is not an idle question; many “adaptive” changes occurred under previous management plans. The waiting list is a good example. In recent years the folks in the river permits office made a number of changes to make it work more smoothly and fairly, but the basic problem that the list grew longer each year was not addressed in a timely fashion. It was allowed to grow to the point that phasing it out now—when people have lined up for trips that may not happen for twenty years—is a major problem in the transition to a new system.
Mitigation Proposals
These include proposed closures at Vasey’s and Elves Chasm (for the snails, which have been introduced at Elves), limits (or perhaps a ban) on collecting driftwood on winter trips (important scorpion habitat?), increased numbers of patrol trips (to better enforce new rules), more guide “education,” etc.
Much of the success of current Colorado River management depends on the cooperation of boaters, commercial and non-commercial alike, who do a good job of following the existing rules because they recognize the need for them, and that by and large they make sense.
Won’t we be further ahead if we have fewer rules that make more sense, rather than an ever increasing number that address specifics (“no generators” rather than “please be quiet”)? The nps can’t be behind every bush, or check every camp—why create a climate that depends on cops, rather than cooperation?
Grand Canyon River Guides has been a leader in guide education, with our popular Guides Training Seminar, an annual river trip featuring guides from many companies, and this popular publication.
Is it unreasonable to ask that education work both ways, and that all of us—guides, outfitters, recreational boaters of all kinds, and the nps continue to learn from each other how we can best:
• Protect Grand Canyon
• Set the highest standards for the river profession
• Celebrate the unique spirit of the river community, and
• Provide the best possible river experience?

Drifter Smith