Mike Rogers’s Draft Comments on Proposed Backcountry Management Plan

GC 2015 - Tanner to Grandview MR DSC_0891

See the GCNP Backcountry Management Plan and Draft Environmental Impact Statement

Mike’s Draft Comments, 19-Feb-2016. Note to Myself and Others: Comment period extended through April 4, 2016

As an avid hiker and backpacker, and frequent visitor to the Grand Canyon National Park, and U.S. citizen, I have reviewed the November 2015 Backcountry Management Plan and Draft Environmental Impact Statement (Plan/EIS), and I am respectfully submitted comments.

I support the goals and objectives delineated in the Plan/EIS. There are several worthwhile elements listed in the Alternative Plans. However, none of Alternatives as listed are acceptable. Each contains serious problems, as spelled out below. Because of the significant reworking that would need to be done, the National Park Service (NPS) should discard the proposed Alternatives and substantially redraft the Plan. With the revisions needed, the redrafted Plan should be submitted to another round of public review and comment.

Following are some of the major issues with the proposed Plan/EIS along with alternative recommendations.

RABT (Packrafting)

NPS Plan/EIS Proposal:

Under all proposed 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” would be permitted. A limited number of permits would be issued for day hikes involving river travel, excluding certain closure areas. Across all proposals, maximum group size would be six. Maximum trip length varies by individual Alternatives B, C, and D.


The zone-based approach, taking into account realist routes for backcountry travellers is certainly preferably to the arbitrary current limit of 5 miles. The zones in alternative B are smaller and may prevent reasonable crossings on very reasonable itineraries. While I’m not in favor of the 11-mile limit on Alternative D, some hybrid approach with a total river travel limit may be needed to balance reasonable use by backcountry hikers using RABT on genuine backcountry hiking routes with those on traditional river trips.

Proposed Revision:

The final Plan should use the Zones in Alternative B, but modifying the last four zones to allow exit on the north side of the river rather than via tribal land.

Great Thumb Access

NPS Plan/EIS Proposal:

Under Alternatives B, C, &D, the Plan/EIS proposes to permit ten groups of no more than 1-6 hikers per group to access hiking routes off of Great Thumb each year.  These permits would be limited to the months of March through May. Groups would be limited to two vehicles, and would have to be accompanied by a tribal escort from the Havasupai tribe.


This proposal does not conform to the Act of Congress, signed into law by President Ford, which expanded the Havasupai lands to include Great Thumb, but maintained a park boundary and imperative to maintain public recreational use and access. Per the Act, 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. NPS has presented no information or analysis in the Plan/EIS to support either the seasonal limitation or the group size limitation as proposal.  Further, the requirement for a tribal escort does not fit within any objective for protecting park resources, since the escort is across tribal, rather than the Grand Canyon National Park.

Proposed Revision:

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.

Boundary Road

NPS Plan/EIS Proposal:

Under Alternatives B and D, the Boundary Road would remain closed.  Under Alternative C, the road would be reopened.


The Boundary Road should be reopened. The proposed Plan/EIS states that this road could be used occasionally for emergency vehicle access, and this is true. Opening the Boundary Road, however, would also allow access to more trailheads between Hermit’s Rest and the Grand Scenic Divide. This could potentially reduce traffic on Hermit Trail, spreading use over a wider area. In addition, opening the road would allow access to areas of the GCNP such as the South Bass trailhead, and by allowing hikers to travel to and from South Bass without encroaching on Havasupai tribal lands, would alleviate impact of these tribal land.

Proposed Revision:

Open the Boundary Road to provide access within the GCNP boundary all the way to the South Bass trailhead. You can consider keyed/gated access as a way to help monitor and control traffic.

Commercial Guided Hiking

NPS Plan/EIS Proposal:

The Plan/EIS offers many possible changes to the way hiking guide companies (“Commercial Overnight Backpacking Services”) are regulated.  One of the most significant changes would grant concessions to selected guide companies. Concessioners would 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)


This change seems to hurt both self-guided hikers and those who prefer guided hikes alike by dividing the potential user nights into bifurcated commercial and private categories. Commercial guided hiking, whether under the CUA or with selected concessionaires, should compete fairly for the limited pool of permits with hikers who prefer to go on their own.

The Plan/EIS uses the phrase “visitors that prefer to travel independent of commercial services” to self-guided independent hikers.  In Alternatives B and C, independent hikers would lose availability for user-nights of backcountry camping in some areas as these would be 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 independent 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 independent hikers already have difficulty obtaining permits. These areas, including the Corridor are areas where many independent hikers would like to gain the experience and confidence to hike own their own. Limiting the user-nights here risks potentially shutting independent hikers out of these popular areas not only denying them the opportunity but also potentially pushing first-time hikers into more remote areas. This potentially increases the impact in Wild areas, and also may raise safety concerns as more inexperienced hikers are in effect encouraged to go where traffic, ranger patrols and park services are far less prevalent by definition.

Proposed Revision:

All hikers should have equal opportunity to get permits for Corridor and other high use areas, including during the popular Spring and Fall hiking seasons.

Day Hike Permits

NPS Plan/EIS Proposal:

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.

The Plan/EIS indicated that 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.


From available data it appears that during busy Spring and Fall weekends an estimated 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 concentrated l the Corridor trails and Phantom Ranch during Spring and Fall weekends. Any mitigation strategy should thus be focus on these areas and times.

As proposed, only Corridor trails are affected, and I agree with this recommendation. However, it seems many people hike only a couple miles down the major trails. Subjecting all of these hikers to a paid day-hiking permit would likely push them to use other trails not subject to the permit fee. These could very predictably adversely impact to soils, vegetation, wildlife and visitor experience in those areas, and potentially create safety issues as less experienced hikers increasingly venture into more wilderness areas.

As the worded in the Plan/EIS, through the Adaptive Management process the NPS could than significantly and continuously increase affected areas and costs with little or no public input. This is addressed more below.

Proposed Revision:

Because 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.

River Zone/Human Waste Management

NPS Plan/EIS Proposal:

The NPS proposes to adopt a River Zone consisting in essence of the shoreline along the Colorado River up to the historical high water line.  Under Alternatives B, C, and D the Plan/EIS would require human waste to be carried out from River Zone backcountry sites.  Commercially guided backpacking trips will be required to carry out human waste from all 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.


The intent to mitigate the impact of proper human waste in the river zone, and in beach camps like Hance Rapids in particular, is much appreciated and necessary. However, the carryout provision is fraught will challenging management and enforcement problems, especially in “at-large” camping areas. I’d prefer to see some of the more accessible, high-use, high-impact areas have designated hiker campsites with composting toilets rather than pack out rules, which I feel serve both the public and the resource better (given the enforcement and compliance issues).

Hance Rapids is a site at which a composting toilet could be justified, as is already the case at Tanner Beach. Hance Rapid might benefit even further from designated campsites within something like ¼ mile of the river to prevent social trailing to creative camping just to avoid pooping in the River Zone. Some additional mitigation might also be warranted outside of the River Zone. For example, Hance Creek has seen a big increase in obvious toilet paper blossoms, from too much pooping, and too little packing out toilet paper. (Evidence of why pushing more hikers out of the Corridor and further into the backcountry might not be a good idea.)

Proposed Revision:

A new composting toilet at Hance Rapids should be incorporated. A proposal for designated campsites within ¼ mile of Hance Rapids should be considered. A composting toilet for Hance Creek should also be considered.

Deer Creek Narrows Closure

NPS Plan/EIS Proposal:

The draft Plan/EIS proposed different treatments of the Deer Creek Narrows. Under Alternatives B and D, the existing closure of Deer Creek Narrows will be made permanent, while under Alternative C, the Narrows will be open and unrestricted.


The 2012 Superintendent’s Compendium effectively closed the Deer Creek Narrows. “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 was a contentious decision, as was acknowledged by the Superintendent. And yet the Plan/EIS does not explain the basis for the present recommendations to either close or open the Narrows. Further, the Plan/EIS mistakenly indicates 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”. Certainly as “The Patio” is a stop for as many as 100 river runners frequent daily in the summer months, it is almost just as certainly incorrect in the lower Narrows, accessible only be technical canyoneering techniques. Closing the Narrows does not provide significant additional protection to the area.

Proposed Revision:

A revised Plan should mirror a an effective solution the National Park Service has used elsewhere 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. For example, 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.


NPS Plan/EIS Proposal:

Definition of fixed anchors not given.
Webbing color requirements not given.

Proposed Revisions:

To avoid confusion, NPS should define a fixed anchor as an anchor that is left in place after use. NPS should also make a distinction between removable fixed anchors that do not alter rock surfaces (for example, webbing around a rock) and permanent fixed anchors that require alteration of the rock where the placement is to occur (for example, a bolt).

With regard to authorization for placement of new permanent fixed anchors, we propose that Grand Canyon NPS take a programmatic approach, as provided in Director’s Order #41, p. 15-16: Authorization may be issued programmatically within the Wilderness Stewardship Plan or other activity-level plan, or specifically on a case-by-case basis, such as through a permit system.

An example of a programmatic approach is the anchor policy in use at ZION NP, which has been in place since 2007 and is working well. NPS should programmatically authorize canyoneers to place and remove permanent and removable fixed anchors, with a strong emphasis on clean canyoneering techniques and practices. Likewise, the Plan/DEIS should define a process for making park-level decisions regarding the placement or removal of fixed anchors. (See further comments in the Adaptive Management section, below.)

A black webbing rule should be included in the canyoneering anchor policy. Black always works due to the universal presence of shadows, cracks, mineral streaks and other black features, independent of rock color, and avoid the mismatched color issue. This simpler, more specific approach has a greater chance of success than the traditional color-matching plan, and thus greatly limiting the visibility and impact on other users. 

Dividing Boysag Use Area (LB9)

NPS Plan/EIS Proposal:

This has not been addressed in the plan/EIS, although it was requested in the public scoping prior to the plans release.

Use area LB9 in the western Grand Canyon is needlessly large under current use limits, and even moreso under proposal that would limit the area to two small groups of 6 within the area. For example, as defined, hikers in 150-Mile (SOB) Canyon can be blocked from access by hikers in Tuckup Canyon 14 river miles away. The chance of overlapping in the current use area is practically zero. This can also create a safety issue in that canyoneers descending 150 Canyon may try to get through the entire canyon and across the river in one day to avoid needing a permit to camp in LB9 when it would be safer to allow more time and camp within the canyon.

Proposed Revision:
LB9 should be split into two use areas with a new boundary between the two at Cork Spring Canyon. Both of these use should be designated Wild.

Adaptive Management

NPS Plan/EIS Proposal:

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

  • Climbing
  • Canyoneering
  • Extended day hiking and running
  • Tuweep day use
  • Use area management
  • Human waste management


I understand and agree with the need for the Superintendent of GCNP to adapt to both new information and changing use patterns in the park to best meet the goals and objectives outlined in laws, regulations, and the Plan/EIS. In some cases, it will be necessary for the Superintendent to make quick reactive decisions to this end.

However, such decisions should wherever possible include an opportunity for public input and user group dialog for any Adaptive Management changes as the default rule.

The 2012 closure of the Deer Creek Narrows provides one good illustration of why this is necessary. The Deer Creek closure was very controversial, and a variety of users would have been able to flag relevant issues very quickly. And yet the Superintendent 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.” Exactly. There was no imminent threat or emergency situation. And yet the Superintendent issued a ruling that was very controversial and well beyond the understanding of the Superintendent or park staff.

The public deserves an opportunity to provide input wherever possible.

Proposed Revision:

Any future management actions involving the implementation of the elements of Table ES.1b “Implement as Needed Through Adaptive Management” should go through a public comment period of no less than 30 days, with due notice given.

Further, included more generally in the plan any additional measures should be subject to the same level of public comment, with all final decisions made in full consideration of these comments. The Superintendent may from time to time need to put in place immediate measures to fulfill the duties of the NPS to comply with laws, regulations and meet the goals of the management plan when time is of the essence. However, even these emergency decisions should be in effect for a short time only, three to six months, during which, the decisions can be offered for a public comment period as described above before long-term adaptive management policies are established.



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