he past quarter has been a busy one for the officers, board members, and volunteers who have been working on the Draft Environmental Impact Statement for the Colorado River Management Plan (deis). In November, a number of us attended the series of public meetings held by the nps to explain details of the plan and answer questions. In early December, based on what we learned, we put together a draft version of our proposed comments and posted them on the gcrg website, just in time to get caught up in the usual holiday distractions.
Then, the nps announced an extension of the public comment period from January 7th until February 1st. Given the complexity of the plan and the distractions of holiday activities, they thought a less rushed schedule could result in better comments.
Consequently, we were able to take a break, during which we heard from some of our membership about our draft comments. We resumed working on our comments in January, submitting 39 pages worth to the nps at the end of the month.
The public meetings, held in a number of cities during November, were in an open house format, with exhibits arranged around the room to explain different aspects of the plan, and a member of the planning team at each station to answer questions. There was also a brief introductory video running in another room which presented background information on the planning process.
This format seemed to work pretty well. I think I learned almost as much about the plan from other people attending the meetings as I did from the nps. Everyone, it seemed, had focused in on different aspects of the proposed plan, and asked somewhat different questions. After awhile, a lot of information and questions were being shared by people who had already talked to members of the planning team, while others were busy asking new questions.
In January, after another Board Meeting in which we talked about the deis, we recruited volunteers among the board and officers to take a section or two of our draft comments, review them for clarity while making additions and subtractions as needed, and shipped them all back to Lynn at the gcrg office. During the last week of January, Lynn hammered it all back together, circulated the results, and—eventually—shipped the final result off to the nps. The full text of our comments should be available on the Grand Canyon River Guides website at www.gcrg.org.
I’d like to thank everyone who pitched in to make our comments as good as we could make them. Rather than try to name everyone—I’m sure I’ll leave someone out—I’ll just mention that Lynn Hamilton, Executive Director of Grand Canyon River Guides, did a fantastic job of co-ordinating the effort, taking notes on the ideas that were flying thick and fast, and trying to make sure they ended up somewhere in the final product. Thanks again, Lynn!
I think we did a pretty good and comprehensive job of critiquing the deis. The primary focus of our remarks had to do with protecting the resources of the Grand Canyon, and maintaining the quality of the river experience. It’s easy to get the impression that most of the other stakeholder groups were focused on narrower objectives: getting something new (private boaters, wilderness advocates) or keeping something they already had (outfitters, passengers) etc. We tried to be advocates for the canyon and stay focused on the big picture: protecting the resource, and upholding thebelief that the quality of the experience available on the river in Grand Canyon comes first, and everything else comes afterwards.
Consequently, we opposed a massive increase in use levels as a politically driven, but irresponsible, “easy way out” that ignores the fragility of already declining canyon resources and turns a blind eye to the cumulative nature of many of the impacts of recreational visitation. While we agreed with the nps that a reduction in maximum group sizes could reduce some impacts, we felt that insufficient attention was being paid to other impacts that are directly related to the numbers of people and trips.
We also found inconsistencies between the park’s official policies which say that when there is a conflict between resource protection and recreation, resource protection comes first, and a plan that seems to put increased recreation above all else. We were very disappointed that no alternative, other than the “no action” status quo, contemplated holding the line on overall use at or near current levels.
We also took exception to many of the particular features of the plan that were designed to allow for additional use, but which would decrease opportunities for recreational boaters and the quality of the experience available on the river in the canyon. We opposed short trip lengths for several reasons, noting that their own research indicates many boaters would like even longer trips. We noted that the reduction in motor launches during the summer season, in conjunction with limits on trip lengths and trip sizes would probably result in a sharp decrease in the number of one boat trips, and an increase in the numbers of large trips, looking for large campsites. We approved of the longer no-motor season, but agreed with outfitters and passengers that it made more sense to continue allowing motors in September, and that it was unrealistic to expect that outfitters shift a significant chunk of their motor seasons to the month of March. We suggested that motor trips longer than ten-days—hiking trips, or kayak support trips, for example—should be “grandfathered” in under the final plan to the same extent that they exist under the status quo.
We did not like the idea that non-commercial trips would be limited to sixteen-days in the summer season, and pointed out that there would be a serious conflict with longer commercial oar trips, which might find themselves on the same schedule as one or even two private trips from the launch ramp all the way to Diamond Creek. We pointed out that there’s a big difference between contacts with trips that quickly get ahead or fall behind, and repeated contacts with the same trips every day, each hoping to go to the same places you are, on the same schedule.
Our biggest concern, overall, had to do with the lack of a plan to monitor the effects of all these changes. According to the nps, monitoring impacts and mitigating them depends upon “additional funding” at a time when this appears unlikely. Many of us can remember a wonderful General Management Plan to get cars and congestion away from the rim, now stalled (if not forgotten) for lack of funding.
We believe that the bottom line on any changes must be the ability to track results, and make corrections if the objectives are not achieved. The proposal to modify the “limits of acceptable change” (lac) based on the management plan, rather than base the plan on the lacs, is exactly backwards. Under previous plans, checking up on the results has been somewhat hit and miss, and we were not reassured by the statement that if more use creates problems, they could cut it back. Experience suggests that will never happen.
We asked that any changes be conditional on funding for monitoring and mitigation, and that the final plan should say what will happen if there’s no money. Giving up on resource protection because it’s too expensive, or politically inconvenient, is not acceptable.
At the last minute, before the end of the comment period, there were a couple of new developments. One was the announcement that: “Grand Canyon River Groups Achieve Historic Breakthrough Settlement.” Another was an Op Ed piece that I wrote about the management plan for “Writers on the Range” that appeared in some Western newspapers, including those in Phoenix, Aspen, and Los Alamos. (That article is reprinted in this issue on page fifteen.) The focus of my piece was the pressure to increase use in the management plan, despite declining resources.
The “Historic Breakthrough”—called a “Historic Breakdown” by some environmental groups—may have achieved somewhat more publicity. The so-called “Grand Canyon River Groups”—not to be confused with “Grand Canyon River Guides”—was the latest incarnation of “firewalk”—an informal discussion group organized several years ago by Mark Grisham (Executive Director of Grand Canyon River Outfitter’s Association); I was one of the original participants.

The intent was to discuss and explore ideas that might represent a middle ground among outfitters, private boaters, guides, the nps, and the environmental community for resolving the most critical issues faced by the Colorado River Management Plan: use limits, allocation, etc. Mark had decided that representatives of the “Wilderness faction” were not likely to be responsive, and they were not invited to participate. But there were representatives from the outfitters, the environmental community, the private boater community, the guiding community, and an observer from the nps.
None of the participants—except Mark—were there in an official capacity. As soon as it became clear that the object of the discussion was to find a way for the outfitters to “have their cake and eat it too” while appeasing the private boaters, and cramming the Grand Canyon with more users in a “scientific” manner that could be sold to the nps and the environmental community as well, I bailed out.
I’m not sure how long the other environmentalists stayed in the swamp after I left, but eventually some Wilderness advocates got wind of what was going on, firewalk was outed, and everyone (except Mark and the private boater community) fled to higher ground. Time passed, the ashes cooled down and blew away, and the nps continued to grind away at the Colorado River Management Plan.
All was not lost, however: under the auspices and sponsorship of the outfitters, a new organization was formed last fall (just as the deis was released) to represent the interests of commercial passengers: the “Grand Canyon River Runners Association.” Together with Grand Canyon River Outfitters Association, Grand Canyon Private Boaters Association, and American Whitewater, these self-appointed representatives of three stakeholder groups involved in the planning process banded together to assert their “authority” over the final plan in a way that would assure that they each got what they craved most.
Under the Park’s preferred alternative in the deis, outfitters would retain their current user-day allocation, and private boaters would get a greater number of launch opportunities. Both groups, however, were upset by the Park’s planned registration system and the prospect of an “adjustable split allocation.” Other groups, including Grand Canyon River Guides, were skeptical as well, and the nps itself seemed to have but a ghost of an idea about how the system would work.
In any event, outfitter, private boater, and passenger advocate groups had one thing in common: the fear that the proposed system would fail to confirm the claims they had made about demand, and that it would show that the allocation for their sector was too large, and needed to be reduced.
They, as well as gcrg, agreed with the nps that there would be a high incentive for interests competing for allocation to attempt to stack the results in their favor, and that consequently the results, whatever they might be, would continue the controversy over allocation rather than resolve it. Meanwhile, some wilderness advocates that had sought a “common pool” allocation system saw the proposed “adjustable split allocation” as a mixed blessing, far short of a “common pool” but their best hope to prove their belief that the commercial allocation is far larger than is appropriate.
The “Historic Breakthrough” was an agreement to “settle” the allocation controversy by saying there should be equal access for commercial and non-commercial boaters, as measured in user days, and that commercial use would predominate during the popular summer season, while non-commercial use would have the upper hand in the shoulder and winter seasons. Furthermore, due to the different trip lengths and sizes in the two sectors, it was agreed that “equal access” did not mean parity in numbers of launches. But the most significant aspect was that now there would be no need for the proposed registration system and an “adjustable split allocation.”
Oh—and one more thing: the commercial allocation would remain at 115,500 user days, and the non-commercial allocation would rise to the same level, bringing the total “recreational allocation” to 231,000 user-days, up from the 218,000 proposed by the nps. In other words, recreational use would jump 35 percent over the current level, not the piddling 28 percent jump “scientifically” proposed by the nps in Alternative h.
In our comments on the deis, Grand Canyon River Guides challenged the nps to accept this 50/50 split in allocation, but hold the line on additional use to meet their responsibility of protecting the resources of Grand Canyon. And we agreed that they should forget the idea of an “adjustable split allocation” and registration system.
The proposed 50/50 split allocation is mostly symbolic, in any event: under Alternative h commercial use is based upon a user day system, with some additional restrictions on launches. But non-commercial use is based on launches, not user days. During the scoping meetings, there were many comments on the “apples versus oranges” nature of any comparisons between commercial and non-commercial demand. The park’s preferred Alternative h, with a user day system for the commercial allocation, and a launch based system for the non-commercial allocation, would write “apples and oranges” into the regulations.
The “Historic Breakthrough” in short: three of seventeen stakeholder groups agree to take what they want from the canyon, and worry about the consequences (and other stakeholder interests) later. We’re asking the National Park Service to have better vision than that.
The full text of our comments on the deis is available on our website at www.gcrg.org. Some of our positions support ideas advanced by outfitters, private boaters, and other environmental groups, while on other issues we had different opinions. In all cases, we tried to stick close to our objectives: protect the canyon and the quality of the river experience. We argued that new rules should be kept to a minimum, and that they should make sense, and not appear arbitrary. We advocated an emphasis on education and cooperation, and less emphasis on enforcement, as a means of accomplishing management objectives. We tried to say what we liked about ideas advanced in the management plan, and not focus entirely on the things that we thought needed improvement.
What’s next? The nps will take several months to tabulate the comments they received and—hopefully—find some worthy ideas about how the management plan can be improved. A final plan will be drafted, and with a little luck we may see it sometime around the middle of the year. I believe there may be another opportunity to comment on the final plan before the official Record of Decision is announced, but it’s not likely that additional comments will have any impact on the final result.
Once the Record of Decision has been made, the nps will turn to the complicated task of implementing all the changes. I suspect it will be too late for bidding on new commercial contracts before the beginning of next season, when the existing contracts will have expired.
It’s likely that it will take awhile before all the changes actually occur: many details may still remain to be worked out even after the Record of Decision.
Our job of “Protecting Grand Canyon, Setting the highest standards for the river profession, Celebrating the unique spirit of the river community, and Providing the best possible river experience” will continue under the new plan, in ways that we can’t yet imagine.

Drifter Smith