Gaylord Staveley
former guide, outfitter: Canyoneers, Inc.

   I note that GCRG is restricting manuscripts to "an ecosystem management” theme. That's unfortunate: ecosystem management would only be one element of the whole river gestalt that the CRMP has addressed and will undoubtedly again address; it's only one element of river management. The Overview [which accompanied GCRG’s call for submissions to this publication] creates the impression that ecosystem management is the overriding- or the only -CRMP issue, yet even the agencies and environmentalists that are espousing "ecosystem management” don't agree on what it is, or how it's accomplished or evaluated...

   ...[contrary to popular opinion] There was no “dramatic leap in recreational use" in 1980; the 1980 CRMP gave commercials a 6% increase and distributed it primarily to small companies who had prevailed in an "economic base'' argument with NPS Regional Director Howard Chapman. The “dramatic increase"(s) in recreational use had occurred in the late '50's, the 60's. They stopped when carrying capacities were set and allocations were imposed.

   ...In 1972 the commercial allocation was 105,000 [user-days]. Actual commercial use through October that year was 88,271 plus a bit more that resulted from some “pooling'' in November and December. Across the commercial spectrum, 1972 commercial use varied widely from a company that used 116% of their allocation to one that used 30%.

   In 1973 the overall commercial allocation (not “allotments" as the Overview states) was set at 89,000, (not 96,000). The intent was to lock it into the calendar year 1972 level because of the nearly exponential increases in both the numbers of passengers and number of outfitters that had begun in the late 50's.

   The "mere” 7,600 user days allocated to the private trippers was the level of their historical use, which in 1972 was 8%. (By at least 1966 NPS had begun counting private use. From 1966 to 1972 private use was: 1966 - 3%; 1967 - 4.8%; 1968 - 4.3%; 1969 - 3%; 1970 - 4.3%; 1971 - 4.5%; 1972 - 8%. The CRMP revision [1981] subsequently increased the privates’ portion of the overall allocation to 30%.

   Your discussion of research and scientific user days says that total use increased to 181,000: " a far cry from the original 105,000,” implying that outfitter use was responsible for the increase. It was not: the commercial allocation was never increased after 1981. At one time NPS was consuming some 11,000 user days each year- more than the largest commercial outfitter at that time. They later modified their operations to lessen that considerably, but their management reductions then blended into research user days which, as you pointed out, reached 20,000 per year before dropping to 14,000.

   Thanks for the opportunity to present this information. I am very concerned about GCRG offering a forum for manuscripts with one specific theme, I'm concerned about the relevance of that theme, and about framing the theme in the way your Overview leading into this publication did.