he Final Environmental Impact Statement of the Colorado River Management Plan (crmp) has been published and the new management directives will be implemented in 2007. The exact details of the transition are not in, but we understand that the Commercial Operating Requirements for 2006 will not entail any substantive changes. While there will be no further opportunities for official public comment, Grand Canyon River Guides feels it behooves us to outline our understanding of, and position toward the new management plan for the river corridor.
The Final Environmental Impact Statement (eis) of the Colorado River Management Plan reflected several changes from the Draft eis that resulted from the Park’s consideration of “substantive comments.” Drifter, Lynn and the entire team of folks that help put our comments together deserve a big round of applause. Many of Grand Canyon River Guides’ comments were considered substantive and were given due consideration. We also applaud the efforts of all gcrg members who commented on the plan. Your thoughts clearly demonstrated how much you care about this precious resource, and your efforts made it a better document.
Positive changes from the Draft to the Final eis include the continued allowance of day-use at the Little Colorado, the abandonment of the single point all-user registration system as well as the rejection of the adjustable split allocation of user days between commercial and non-commercial groups. Apparently there was not much sense in closing access to our beautiful swim rapid on the Little Colorado. However, be aware of a gerrymandered off limits area around the mouth. There should be a map forthcoming showing where the closures are. The single point all-user system suggested in the Draft eis was removed. The idea was unworkable and the two sectors will continue to be administered separately. Also, the allocation of user days between commercial and non-commercial sectors will remain constant at the levels set by the crmp. The Board of gcrg encouraged both of these decisions. Commercial and non-commercial permits are, in Drifter’s words, “apples and oranges.” Lastly, one enormous step forward is the eventual transition from the Private Waiting List to a weighted lottery system for privately outfitted trips. This development along with the 50/50 split between private and commercial use should really help dispel much of the contentiousness that has plagued Grand Canyon for years.
The following reflect our views on portions of the plan that did not change in response to gcrg’s comments on the Draft crmp:

Increased Use
Increased use and the timing of such use will be the most significant and potentially impactful changes in the management of the river corridor. Although there has been some discussion among gcrg board members as to the possible ramifications of increased use, and whether or not the current quiet winter months are truly needed to help the Canyon rest, the overall consensus is that we should keep a close watch on Canyon resources to prevent their degradation. We have discussed possible ways to quantify impacts to visitor experience (especially crowding) and are interested in helping the Park to develop these plans.
In response to comments on the Draft eis regarding the increase in use, the Park points to its plan to spread peak use so as to lower the total use at any given time. The Park contends that it is the intensity of use that contributes the most considerable wear and tear on the resource. This seems debatable especially in light of the non-renewable nature of cultural resources and the increase in user discretionary time. In any event, we will want to keep our eyes peeled down there, as always, for signs of negative impacts.

The River Guides, although opposed to the increase in overall visitor use, are nevertheless committed to help make the new plan a success. Our position is that user education is always the best way to prevent any degradation to the resource, either natural or cultural. We are hopeful that the Park will reduce resource problems through communication and cooperation. Education and interpretation, in our opinion, are more effective, and more in keeping with the spirit of the National Parks, than any attempt to rely on enforcement against violations after the fact.

Monitoring
Inadequate funding for monitoring is a reality that the Park recognizes. In response to comments regarding the lack of definite funding sources to thoroughly monitor changes stemming from the increase in use, the Park states that possible funding may come from many sources. Gcrg feels that sufficient and stable funding sources coupled with clearly delineated plans for the monitoring of Park resources should be integral to the overall plan. While this is not the case, we recognize the increasing importance of monitoring both natural and cultural resources and, as above, are interested in the development of Park plans to monitor for negative impacts.

Adaptive Management
There are references to the use of “an adaptive management approach” to altering the management plan if and when changes are deemed necessary. Gcrg encourages the Park to change its management of the river corridor to adapt to conditions on the ground. Although the form of this approach is not clear, we trust that Park management will use this caveat to protect the Park from negative impacts. River guides may have an important role to play in this approach. As the largest group to run the Canyon on a consistent basis, we have the ability to see changes as they are occurring and can inform Park management.

Glen Canyon Dam
The draft and final eis contain references to Glen Canyon Dam and the recognition of its inherent and overwhelming effects on the river corridor. Separating management of river and river corridor use from Park involvement in the Adaptive Management Program of Glen Canyon Dam is viewed by the River Guides as an expediency used by the Park in order to produce the final plan in a timely manner. Discussion amongst gcrg members indicates that we may feel inclined to encourage the Park to engage more actively in promoting dam management actions that produce effects closer to the wild and primitive conditions for which Grand Canyon National Park was established.

This is by no means an exhaustive list of issues covered by the management plan or our positions on those issues. Grand Canyon National Park deserves praise for the completion of the gargantuan task that produced the new crmp. We encourage the Park to continue to develop clearer plans for funding of monitoring activities as well as educational programs that will help forestall damage to any of the precious resources in and around the Canyon corridor. Grand Canyon River Guides looks forward to working with the Park to protect and preserve our natural and cultural resources over the long term.

Joe Pollock
President gcrg