Grand Canyon Hikers and Backpackers Association
Brief Summary of Key Positions on Proposed Backcountry Management Plan
6 February 2016
Let the Park Service know your thoughts on these important issues! National Park Service Public Comment Site
Grand Canyon National Park is visited annually by about 5 million visitors. Many of these visitors hike, bike, backpack, climb, run, packraft, canyoneer, or otherwise enjoy the vast backcountry areas of the park. All these activities are governed by the park’s Backcountry Management Plan (BMP). For the first time since 1988 the park is undertaking a complete review and revision to the BMP. In November 2015 a set of proposed revisions were released in the form of a Draft Environmental Impact Statement (DEIS). This 618 page document addresses a multitude of issues affecting many aspects of park backcountry visitation and recreation use.
Grand Canyon Hikers and Backpackers Association has undertaken a detailed review of the proposals and will provide formal public comment to the National Park Service (NPS). In order to assist our members and supporters in reviewing the plan, and to help them understand the proposals, we have prepared the following summary of some key issues, and our position on those. Comments are welcome and may be directed to firstname.lastname@example.org.
From the DEIS Executive Summary:
This Grand Canyon National Park Backcountry Management Plan / Draft Environmental Impact Statement (plan/DEIS) evaluates the impacts of a range of alternatives for managing backcountry use in Grand Canyon National Park in a manner that protects and preserves natural and cultural resources and natural processes and provides a variety of visitor experiences while minimizing conflicts among various users.
This plan/DEIS evaluates the impacts of the no-action alternative (Alternative A) and three action alternatives (Alternatives B, C, and D). Alternative A would allow backcountry use levels to remain similar to current, commercial use would not be capped and would continue to be managed under commercial use authorizations, and emerging uses such as canyoneering and extended day hiking and running (rim-to-rim) would not be managed. Under all action alternatives (B, C, and D) an adaptive management process would be used to manage climbing, canyoneering, extended day hiking and running, Tuweep day use, Use Area management and human waste management, and commercial overnight backpacking would be managed through concession contracts instead of commercial use authorizations. Alternative B, the NPS preferred alternative, would reduce group size for overnight backpacking in the two most remote backcountry zones, manage river-assisted backcountry travel using 31 route-based river sections, and limit commercially guided services; overnight use in the backcountry is expected to decrease by 1%. Alternative C would manage river-assisted backcountry travel using 11 river sections, allow greater access to the backcountry through retention of large groups and development of campsites in the Corridor, and limit commercially guided services; overall, overnight use in the backcountry is expected to increase by 5%. Alternative D, the environmentally preferable alternative, would concentrate backcountry use in non-wilderness areas, reduce group size for overnight backpacking in all zones outside of the Corridor, and limit commercial use and only allow it in non-wilderness areas; overall, overnight use in the backcountry is expected to decrease by 3%.
The Park Service is hosting two additional public meetings this week at which you can ask questions about the Plan/DEIS. See our event notices on Facebook:
Monday, February 8, Webinar
Wednesday, February 10, Public Meeting in Phoenix, Arizona
Summary of Key Issues
The following topic areas are addressed in this summary:
- Day Hike Permits
- Commercial Guided Hiking
- River Zone/Human Waste
- Great Thumb Access
- Boundary Road
- River Assisted Backcountry Travel
- Deer Creek Narrows Closure
- Adaptive Management
The following topic areas are still under review:
- Backcountry Use Areas
- Apache Point Access
- Point Huitzil Access
- Pasture Wash West
- River Runner Camp Conflicts
- Adjacent Lands
- Toroweap Overlook
- Remote Area Day Hiking
- Runners in Grand Canyon
- Road Zone
- Bicycles in the Park
Day Hike Permits
Under all action alternatives (B, C, and D) day use permits would be required seasonally for hiking beyond three defined locations:
- Bright Angel Trail: East Tonto Trail junction.
- South Kaibab Trail: Tip-Off
- North Kaibab Trail: Manzanita Resthouse
The expected cost of the day use permit is at least $5 per person per day.
In addition, this policy will be subject to Adaptive Management with future changes to include possible limitations to group size, daily total use limits, designated days for groups, year-round permit requirements, and expanding the policy to include additional trails.
Visitor use monitoring has estimated during busy spring and fall weekends 400 to 600 people hike or run Corridor Zone trails rim-to-rim or rim-to-river.
The highest impact from extended day hiking and running is localized and narrowly time-focused. The response should be similarly narrow. As proposed, only Corridor trails are affected, and we agree with this recommendation; however the permit requirement should be enforced at or near the location of the impacted area (Phantom Ranch) rather than miles away at the Tonto junction, Tip-off, or Manzanita locations. Furthermore, the permit should be required on weekends and holidays when the problem is greatest, not throughout a broad season including many days on which there is no documented adverse impact from these activities.
The added cost of a day-hiking permit will increase usage of other trails not subject to the permit fee and create adverse impact to soils, vegetation, wildlife and visitor experience in those areas. This could create a domino effect within the Adaptive Management process whereby those impacts are used to justify user fees on those trails, with an end result of environmental degradation and an increased cost to hikers.
Other elements of the proposal include increased hiker education. This is already being undertaken (see, for example http://www.nps.gov/grca/planyourvisit/courtesy.htm) . GCHBA supports these efforts to promote trail courtesy and Leave No Trace practices. There is nothing in the proposal to support a conclusion that the effectiveness of education outreach will be increased in the presence of an extended hiking permit or fee.
Since the stated objective of the day hike permit is to reduce impact on Phantom Ranch facilities, the permit should be required for day hikers crossing the river (from the south) or passing the Clear Creek trail junction from the north rim. Permits should be required during spring and autumn weekends and not during naturally uncrowded times. This change will reduce the burden on the park to manage and administer a permit program.
The park should implement a “frequent hiker” pass for day hiking. Frequent hikers are actually a resource in the canyon rather than a burden; they can and do help the park by providing assistance and information to other visitors.
There should be no permit required for day hiking outside the Corridor. No information is presented in the DEIS to support this, even as a potential area for Adaptive Management. Those non-Corridor trails cannot logically be impacted by the documented traffic increases or system strains present in the Corridor and which form the basis for the proposed permit regime.
Commercial Guided Hiking
The DEIS makes many changes to the way hiking guide companies (“Commercial Overnight Backpacking Services”) are regulated. Most notably, the park will grant concessions to selected guide companies in addition to continuing the existing Commercial Use Authorization (CUA) program. Concessioners will be reserved a specified number of user-nights and will no longer be required to apply for permits on an equal footing with hikers who are not using guide services. A number of other changes include:
- Commercial use not allowed in Wild zone
- Caps on groups per night
- Concessioners allowed to reserve trips one year in advance
- Limitations on CUA holders (as distinct from concessioners)
In the past the GCHBA has opposed the creation of a concession for commercial hiking guides for the very reason that it arbitrarily divides the pool of available “user-nights” into separate commercial and private categories. This predetermined reservation of “commercial nights” has the potential to shortchange either hikers who prefer guided hikes (if it is too low) or hikers who prefer to hike without guides (if it is too high). We believe that commercial guided hiking, whether managed by concession or by CUA, should compete fairly for the limited pool of permits with non-commercial hikers.
In the DEIS, the park uses the phrase “visitors that prefer to travel independent of commercial services” to describe DIY hikers. In alternatives B and C, user-nights of backcountry camping are removed from availability to DIY hikers and reserved for commercial concessionaires. The user-nights thus transferred fall primarily within the high-demand Corridor management zone. A smaller number of user-nights are removed from commercial use (in other zones) and freed up for DIY hikers. Not only is the number of nights unbalanced, with more nights taken away than freed up, but the nights taken are in use areas with high demand, in which DIY hikers consistently have difficulty obtaining permits, while the user-nights “freed up” are in use areas with limited competition in which arguably all demand is already being met. Furthermore, the reduction in available user-nights falls during the most popular hiking season, as indicated by the park’s permit success rate information.
River Zone / Human Waste
The DEIS proposes to adopt the River Zone identified in the 2006 Colorado River Management Plan. The River Zone essentially consists of the shoreline along the Colorado River up to the historical high water line. I will include beach campsites such as Granite, Hermit, Hance Rapids, and South Canyon. Under all action alternatives (B, C, and D) the new plan will require human waste to be carried out from River Zone backcountry sites. Furthermore, commercially guided backpacking trips will be required to carry out human waste from use areas without toilets.
The Human Waste policy will be subject to Adaptive Management, with possible future actions to include replacing or removing existing toilets, installing toilets at additional sites, or a year-round waste carry-out requirement at all, or specified, use areas or zones.
There is no question that proper human waste practices are particularly acute in the river zone (i.e. beach camps). Based on previous experience with human waste carry-out requirements, GCHBA believes that composting toilets are more likely to be effective in reducing adverse impact due to poor practices at high traffic sites. Hance Rapids is a site at which a composting toilet could be justified, as is the case at Tanner Beach.
Specific to Hance Rapids, there is a documented problem with damage to the aeolian dunes behind the beach. Extensive social trailing is evident and is undoubtedly made worse by efforts to use or cross the area in search of suitable “toilet” locations. Since this dune area falls outside the River Zone, we are concerned that the recommended policy will not protect the area.
A new composting toilet at Hance Rapids should be incorporated into the adopted Plan in all action alternatives (B, C, D) rather than waiting to be addressed through the Adaptive Management process.
Great Thumb Access
The DEIS proposes to permit ten groups of no more than six hikers each to access hiking routes off of Great Thumb each year. These permits will be limited to the months of March, April and May, groups will be limited to two vehicles, and must be accompanied by a tribal escort from the Havasupai tribe.
This proposal does not conform to the Act of Congress which expanded the Havasupai lands to include Great Thumb. No information or analysis is presented in the DEIS to support the seasonal limitation or the group size limitation. The requirement for a tribal escort does not fulfill any objective for protecting park resources, since the escort is across tribal, rather than park, lands.
The rim of the canyon around Great Thumb (the one-quarter mile from the rim) is within the Park and not within the tribal lands, and should be open to backcountry visitors. Areas below the rim fall within existing Use Area definitions and no change to visitation or permit limits is needed.
Under alternatives B and D, the Boundary Road will remain closed. Under alternative C, the road will be opened.
The Boundary Road should be reopened. GCHBA endorses Alternative C on this point. Opening this road will improve safety (since the Pasture Wash Road can be impassable). The proposed Plan states that this road could be used occasionally for emergency vehicle access. Additionally, the Boundary Road would allow access to more trailheads between Hermit’s Rest and the Grand Scenic Divide, and would thus reduce traffic on Hermit Trail (by spreading use over a wider area). Opening the road would also take pressure off the adjacent lands of the Havasupai Tribe, by allowing hikers to travel to and from South Bass without encroaching on tribal lands.
River-Assisted Backcountry Travel
Under all action alternatives, portable, personal watercraft used on the river for RABT would be carried in and out by the user on the itinerary where RABT takes place. A limited number of permits would be issued for day hikes involving river travel, excluding certain closure areas. Maximum group size would be six. Maximum trip length varies by individual Alternatives B, C, and D.
- Alt B: provides 31 specified zones, based primarily on canyoneering routes.
- Alt C: provides 11 specified zones.
- Alt D: establishes a distance limit of 11 miles.
A zone-based approach is preferable to a distance-based approach as it better matches the real world experienced by backcountry travellers. The larger zones in alternative C are preferable to the smaller, more numerous zones in alternative B and should be adopted.
The current prohibition on day use is unjustified (not supported by any information or analysis) and GCHBA is pleased that it is not included in any of the action alternatives.
Since there is little information to support an analysis comparing alternatives B and C, the final Plan should incorporate the less restrictive 11-zone recommendation from alternative C while information is gathered on river-assisted backcountry travel patterns. If needed, a tighter zone system such as alternative B’s 31-zone system, can be adopted following analysis and a public comment period.
Deer Creek Narrows Closure
Under alternatives B and D, the existing closure of Deer Creek Narrows will be made permanent. Under alternative C, the Narrows will be open and unrestricted.
On April 17, 2012, Grand Canyon National Park released the 2012 Superintendent’s Compendium. It stated “Deer Creek Drainage, river mile 136.9, right bank of the Colorado River… Rappelling or ascending and descending on ropes, webbing, or other climbing and rappelling devices, whether natural or man-made, within Deer Creek is prohibited. This restriction extends from within the watercourse of the creek beginning at the Patio (northeastem-most part of the Deer Creek Narrows) and extending to the base of Deer Creek Falls. (This restriction is a necessity for the protection of a significant cultural resource).”
This closure was very contentious and the Superintendent at Grand Canyon noted in a letter discussing the issue “When I made the decision to put the restrictions in the Superintendent’s Compendium, neither I nor park staff believed the restriction would be controversial in nature. However, based on the number of letters and emails we have received since implementing the restriction, the number of participants on the conference call last week, and the content of the conversation on the conference call, it is clear that the decision to restrict access to Deer Creek is more contentious than we initially understood.”
The DEIS does not explain the basis for the present recommendations to either close or open the Narrows.
Deer Creek Patio is visited by over one hundred river runners daily in the summer season via a trail on the ledges of the upper Narrows. This trail passes sensitive archeological resources, and adversely impacts vegetation. In all alternatives in the DEIS the “Patio section of the Deer Creek area would continue to be open to visitation; during peak river use season this area receives high levels of visitation.”
The DEIS states that “Ethnographic resources located in the narrows are disturbed by trailing and vandalism, crowding, inappropriate behaviors on-site and altered access to traditional use locations” (DEIS pg 380). While this is a true statement for the upper narrows where over 100 river runners frequent daily in the summer months, this is incorrect as applied to the watercourse in the bottom of the Narrows, where canyoneering activity occurs. There are no trails in the bottom of the Narrows, no crowding, no vandalism and no inappropriate behaviors. These activities may occur along the river runner trail and the Deer Creek Patio, but not in the Deer Creek Narrows.
Grand Canyon should embrace a solution other units of the National Park Service have implemented with regards to the cultural collisions between First Nations, and the general public that finds significant spiritual appreciation for nature and wilderness in places like the Deer Creek Narrows. The NPS allows climbing on Devil’s Tower in Devil’s Tower National Monument part of the year, and promotes a climb-free season as well. See http://www.nps.gov/deto/planyourvisit/climbing.htm for details. Devils Tower National Monument has incorporated a seasonal permit system, combined with a strong climbing education component, to sensitize climbers to First Nation concerns. We encourage NPS to explore an approach involving voluntary seasonal limitations on canyoneering in Deer Creek Narrows.
Develop and implement an adaptive management process that includes monitoring natural, cultural, and experiential resource conditions and responding when resource degradation has resulted from use levels. This process allows the park to address increasing demand for access and uncertainty of how different recreational uses impact park resources.
The adaptive management process would be applied to
- Extended day hiking and running o Tuweep day use
- Use area management
- Human waste management
GCHBA advocates for public input and user group dialog for any Adaptive Management changes. Any future management actions involving the implementation of Table ES.1b “Implement as Needed Through Adaptive Management” should go through a public comment period of no less than 30 days.