Introduction
The NPS administration at Grand Canyon National Park has published an updated Back-Country Management Plan (BMP) with its Draft Environmental Impact Statement. The documents are available now, during the public comment period, here. The comment period runs until the 4th of March, and the website has links to the summary and to the full DEIS, as well as to the page where the public can send in comments.
The 25-year (and more) period with no updated BMP included a tangle of political and administrative actions, misfires, and egos. A devoted reader can get a sketch of events by checking out the Index references in my Hijacking A River: A Political History of the Colorado River in the Grand Canyon. (See Vishnutemplepress.com)
Needless to say the years since the Park boundary was expanded in 1975 have seen many changes in the amount and character of Canyon visitation. The BMP, for instance, deals with hiking along the Canyon by hopping on and off boat trips, canyoneering, and speed-tripping across the Canyon. There are thousands more experienced individuals now who feel they have a stake in and a sound basis for commenting on the rules NPS wants to promulgate to guide backcountry users’ impact on the Canyon.
The overwhelming bulk of such experience is personal. Unlike the “hijacked” river traffic, there has been little commercial activity in hiking, backpacking, and its expansions, variations & offshoots. One most important NPS recommendation is to begin carving out a committed segment of hiking spots for commercial outfits. I believe this is a mistake, and an unnecessary one. I set forth my reasoning in one comment I sent in to NPS, and I reproduce it below.
I have also made two other comments, on crucial matters arising from the 1975 addition to the Havasupai Reservation. That addition was legislated as the outcome of hard-fought campaigns by the Havsupai and Park System advocates, and involved substantial compromises on all sides. Continued unimpeded access to the National Park, where that access involved adjacent Havasupai lands, was one condition that the Havasupai accepted as part of the compromise package. For whatever reason, such access has not gone unchallenged. Moreover, the Park Service seems not to be aware of its role in protecting such access, a lack of awareness obvious in several places in the BMP and its DEIS.
My position on these matters was sent to NPS in two comments, one on the Park boundary crossing at the upstream end of Beaver Falls in Havasu Canyon, and the other dealing with Park access over Great Thumb Mesa and plateau lands west of Havasu Canyon labelled variously Tenderfoot/WI Gasala/Yumtheska. I have posted these as two separate comments following this one.
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Comment on Grand Canyon National Park Backcountry Management Plan, pertaining to commercial services, and in particular, Appendix G “Commercial Backcountry Services Analysis” December 27, 2015
Jeffrey Ingram
Tucson, Arizona
email: canyon-stuff@cox.net
(Note: My comments are in regular type. Materials in italics are taken from the Plan for purposes of clarity and discussion.)
My final conclusion re “Use of commercial services in Grand Canyon Backcountry”: No such services should be permitted.
The time-honored and traditional way of experiencing the Canyon and its “Backcountry” should be perpetuated and strengthened, where individuals have the chance in their own way to formulate and carry though their visit to the Canyon, up to and including the optimum exposure and absorption of Grand Canyon (and Wilderness) values.
Conclusion of App. G Analysis
The IDT determined commercially guided backpacking and day hiking trips enhance opportunities for fostering or improving understanding of Wilderness values, particularly for participants who are backcountry novices.
In fact and from experience, “commercially guided” operations decrease opportunities for such understanding, PARTICULARLY for those who are backcountry novices. It is a well-known and demonstrated phenomenon that commercial guides, whose primary reason for being on a trip is monetary, will fall into well-worn grooves of “showing” and “pointing out” elements of the Grand Canyon “experience”. This blunts the “novice” visitor’s perceptions by directing them to a limited set of objects, and works against that visitor’s experience of coming upon aspects of the Grand Canyon, and “discovering” them in his or her own unique way.
Basically, playing upon an inappropriate evocation of the dangers of the Grand Canyon for their justification, commercial operations narrow and limit the chance for fresh and personally unique discovery & adventure by the novice hiker and backpacker. Commercial services should be restricted to the above-rim mass-tourism activities appropriate to heavily developed facilities & roads.
Limited commercial backcountry service opportunities will be available in Corridor, Threshold, Road Natural, and Primitive Zones; no commercial backcountry services will be permitted in the Wild Zone.
This is a tendentious and fractious division of the Grand Canyon experiences that ought to be available to all visitors, novice and experienced. The Canyon provides an immense spectrum of possibilities for individual discovery and immersion in all the zones. It is quintessentially a place where commercial services degrade and limit individual experience.
Detailed answers to three questions on criteria:
1. Is the commercial service appropriate in the park’s backcountry and Wilderness?
Current uses appropriate in Grand Canyon’s Wilderness and non-wilderness backcountry have been determined by laws, regulations, policies, park purposes, and plans to protect Desired Conditions for resources and visitor experiences.
It would have been worthwhile to have included “Park System and Visitor” EXPERIENCE as a determinant of use appropriateness. In particular, the history of the distortions in potential visitor experience and environmental education present due to the administration of Grand Canyon National Park’s River Management Plan make abundantly clear that commercial services are, in fact, inappropriate for all but a tiny segment of Colorado River users.
The first set of criteria applied evaluates whether or not a commercial backcountry service is an appropriate use in a national park. An appropriate commercial backcountry service must meet all of the following criteria.
Appropriate commercial backcountry services
• are consistent with purposes and values for which the park was established, as well as applicable laws, regulations and policies
• are consistent with purposes and values for which the park was established, as well as applicable laws, regulations and policies
• will not
o compromise public health, safety, or well-being
o compromise public health, safety, or well-being
Commercial services have a history of compromising health just because they contact people over multiple trips and thus spread undesirable vectors.
o cause unacceptable impacts to park resources
Commercial services have a history of having to be forced to behave environmentally well. Backcountry use is the chance for Park Service personnel to deal one-on-one with visitors and get the environmental message across without being diluted or routinized by commercial considerations.
o unduly conflict with other authorized park uses and activities
Commercial services are, in their nature, parasitical on the experience of previous visitors, and thus conflict with use by those visitors whose primary aim is their own satisfactory experience in the Canyon.
o conflict with other services outside the park
o monopolize recreational opportunities at the expense of the general public
Commercial services are inescapably based on a belief in maximizing their size and income. This monetary predatory nature of such services tends toward a continuing effort to control all activities within the purview of their services. Again, the history of river traffic management in the Grand Canyon is germane to this point.
It is manifest that commercial backcountry services are NOT consistent with Grand Canyon values. Although above the rim, in areas accessible by railroad and automobile, the move for developed commercial facilities was in the minds of those who promoted and believed in the basic values the Grand Canyon is iconicized for, that is not true for the entire rim and most especially for lands below the rim. In essence, the Park was established 1) for conservation of itself as a natural (what we might call primitive, wild, wilderness) place and 2) to allow the public to visit and view the Canyon. It was never intended that the Canyon should be violated by development of and provision for commercial services. This was demonstrated early on when a tramway down into the Canyon was deemed not appropriate, necessary, or acceptable by the then Secretary of the Interior.
The Park Service has had a difficult time living up to the ideals and standards of the NPSystem’s organic Act and the fundamental environmental values of the Grand Canyon. That is no justification for current NPS administrators to degrade by commercialization the act of walking — in all its varieties —, that most natural and fundamental act of our peripatetic species.
The answers to these questions assist in determining if the activity is appropriate in the backcountry and/or wilderness. The answers are not necessarily a yes or no decision but a piece to consider within the totality of the decision making process. For example, if impacts from certain activities are unknown, additional monitoring or information may be needed to make the determination before allowing the commercial service. Table G.1 outlines the determination of appropriate commercial services.
The experience over many decades of monitoring and public reporting of aspects of river traffic in the Canyon does not give one much hope that “additional monitoring” will ever be adequate.
2. Is the commercial service necessary in the park’s backcountry and Wilderness?
If a commercial backcountry service meets the criteria for an appropriate commercial service, the next step is to determine whether or not the commercial backcountry service is necessary. Necessary commercial backcountry services must meet one or more of the following criteria.
Necessary commercial backcountry services will
• meet backcountry visitor needs
• meet backcountry visitor needs
Commercial services operate in opposition to visitor needs by limiting visitor experience through fossilization of guiding activity.
• assist the park in educating visitors on safety and appropriate skills for backcountry travel
Commercial services should not stand in the way of encouraging park personnel to deal with visitor education.
• assist the park in educating park visitors about the park’s natural and cultural resources • enhance visitor understanding and appreciation of park mission and values
Commercial services distort the information park personnel should want to be encouraging the visitor to obtain.
Table G.2 outlines the process for determining if the commercial service is necessary.
3. To what extent are commercial services necessary in Wilderness?
Because most of Grand Canyon’s backcountry is proposed for Wilderness designation and managed accordingly, an additional filter is applied. As described in NPS Management Policies (NPS 2006), necessary and appropriate commercial services in Wilderness must meet all of the following criteria
Wilderness necessary and appropriate commercial services will
• realize a recreational, scenic, scientific, educational, conservation, or historical use of the Wilderness
• realize a recreational, scenic, scientific, educational, conservation, or historical use of the Wilderness
This is not a meaningful, or even coherent, statement.
• protect and enhance wilderness character desired conditions
This is just what park personnel should be doing; if there is a justification for a PARK SERVICE, it is in this aspect. Commercial services have a different set of goals. The visitor does not NEED to be subject to the contradictions inherent in commercializing the natural objects of the park.
• If the first two criteria are met, apply Minimum Requirement Analysis (see Chapter 4, Wilderness Character)
Tables G1 & G2
The “Yes” entries in the following two tables are contradicted by history and experience, and by the fundamental definition of how commercialization operates in a setting to which it is basically inimical and harmful.
In particular for commercial services: public health has been compromised; there have been unacceptable impacts; they do conflict with authorized activities as well as user satisfaction; and the tendency to monopolize is inherent. The Park Service should be administering the Park, not policing profiteers.
Additionally, for table G-2, commercial operations will blunt and distort visitor education and understanding. The Park Service should be looking for ways to enhance its contact with visitors, rather than turning the vital matter of park and environmental education over to commercial entities.
(The headings for the table below are: Criteria Overnight backpacking Day use Extended day use
Canyoneering River/Hiking(RABT) Climbing Bicycling Vehicle tours)
a. Service consistent with purposes and values for which park established, and applicable laws, regulations, and policies
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
b. Service will not compromise public health, safety, or well-being
|
Yes
|
Yes
|
Requires monitoring
|
Yes
|
Requires Monitoring
|
Yes
|
Yes
|
Yes
|
c. Service will not cause un-acceptable impacts to park resources
|
Yes
|
Yes
|
Requires monitoring
|
Requires monitoring
|
Yes
|
Requires monitoring
|
Yes
|
Yes
|
d. Service will not unduly conflict with other authorized park uses and activities
|
Yes
|
Yes
|
Requires monitoring
|
Yes
|
Requires monitoring
|
Requires monitoring
|
Yes
|
Yes
|
e. Service will not conflict with other services outside the park
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
Yes
|
f. Service will not monopolize recreational opportunities at the expense of the general public
|
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a. Service required to meet back-country visitor needs
|
Some visitors
|
No
|
No
|
No
|
No
|
No
|
No
|
No
|
b. Service will assist park in educating visitors on safety and appropriate backcountry travel skills
|
Yes
|
Yes
|
Maybe
|
Yes
|
Maybe
|
Yes
|
Yes
|
No
|
c. Service will assist park in educating visitors about the park’s natural and cultural resources
|
Yes
|
Yes
|
Maybe
|
Yes
|
Maybe
|
Maybe
|
Yes
|
Yes
|
d. Service will enhance visitor understanding and appreciation of park mission and values
|
Yes
|
Yes
|
No
|
Maybe
|
Maybe
|
Maybe
|
Maybe
|
Yes
|
In sum, the Park Service should determine for the Grand Canyon National Park that the history, evidence, and multiple individual experiences of backcountry activities all show that these activities, fundamental as they are to personal human enjoyment of the Canyon in its most iconic presentation, should be protected from the distorting pressures of commercialization. It is manifestly evident to anyone with an iota of experience in the Canyon and with Canyon visitors that backcountry visitation is THE quintessential individual experience, and it does not benefit from nor require services for hire. Indeed, that experience is enhanced where there are no such services, and degraded when they are introduced.
"My final conclusion re “Use of commercial services in Grand Canyon Backcountry”: No such services should be permitted." Jeff Ingram. Really?? Seems someone has forgotten that guiding at Grand Canyon was established in 1540!!!! From the first Hopi guides to the many Grand Canyon legends such as William Bass, John Hance, Louis Boucher, David Rust, "Uncle Jim" Owens, etc… all guided below the Rim. Even Teddy Roosevelt used guides while visiting Grand Canyon.
ReplyDeleteThe public should maintain the right to hire a guide who is more knowledgeable about the fragile desert ecosystems, proper waste disposal, respect for cultural heritage sites, respect for other hikers, Leave No Trace ethics, safe desert hiking, etc…then they themselves presently obtain. All of which are beneficial to the park, the park service and all other visitors.
ReplyDeleteReplying to both of anonymous comments: As far as 1540 goes, what was the result of the Spaniards being guided to the rim? They went away, and never came back! Some guide; some great experience.
DeleteMaybe if someone gets a permit, he or she should able to hire a guide. But NPS is trying to reserve some of an already tight resource for guiding services, and that locked-in commercialization does not seem right or necessary to me.