Draft Comment, FINAL

Indo - Jesse Waitz

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English

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Informations

Publié par	Indo
Nombre de lectures	26
Langue	English

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National Park Service Grand Canyon P0 Box 129
U.S. Department of the Interior National Park Grand Canyon, AZ
86023-0129 USA
www.nps.gov/graca/crmp 928-638-7797 fax

Comment Form
Draft Environmental Impact Statement
Colorado River Management Plan

Name: Grand Canyon River Guides, Inc.
Address: P. O. Box 1934
Flagstaff, AZ 86002

E-mail address: gcrg@infomagic.net

Do you want to be added to the CRMP mailing list? Yes

Thank you for taking the time to comment on the CRMP. In the final EIS, every substantive
comment we receive will have a response. In order to be considered substantive, your comment
should (1) not just express agreement or disagreement with the analysis or conclusions in the
document, but also explain why you feel that way, and (2) be in reference to some part of the
EIS, or something you feel should have been in the EIS but is not. The more detail you give us,
the more substantive and useful your comments will be. Please include page numbers with your
comments, where appropriate. Comments must be received by January 7, 2005. This version of
the comment form is designed to be printed and mailed or faxed, not to be electronically
submitted. Instructions for submitting comments electronically can be found at
www.nps.gov/grca/crmp.
Do you have any substantive comments or suggestions on any or all of the following? Yes

LEES FERRY ALTERNATIVES

Range of Alternatives (group size, motor use, trip length, launch
schedule, etc.) (Chapter 2 pp. 36-54)

Grand Canyon River Guides feels that the Range of Alternatives (TABLE 2-2: SUMMARY OF
ALTERNATIVES: LEES FERRY TO DIAMOND CREEK, Chapter 2 page 36) should have
included at least one action alternative with use levels at or below current use levels. All
alternatives, except the "no action" Alternative A, call for an increase in use levels, as measured
in user days; no "action" alternative at current or lower use levels was examined.

As we pointed out in our comments to the scoping sessions,

1 "The Colorado River may have reached carrying capacity in terms of the total number of
people currently using the river corridor."

This assertion is based on long-term observations of the deterioration of resources and
cumulative increase of human impacts along the river corridor by our members, many of whom
have been guiding Grand Canyon river trips for a quarter of a century or more. Similar impacts -
but different conclusions about their importance - are noted in the DEIS.

The NPS has ignored the cumulative impact of previous management plans and use level
increases. Grand Canyon River Guides believes the range of alternatives is seriously deficient:
by examining only alternatives that call for increased use levels, the NPS has ignored its primary
responsibility to protect and preserve resources in Grand Canyon for the enjoyment of future
generations. As Section 1.4.3 of the National Park Service's Management Policies 2001 states,

"When there is a conflict between conserving resources and values and providing for
enjoyment of them, conservation is to be predominant." (NPS 2000d)

The level of use proposed in this plan is nearly 2.5 times the use level set by the NPS thirty years
ago when resources along the river, including beaches and campsites, were in much better shape
than they are today. The steady, incremental increase in use with each new management plan is
in direct conflict with the management objective stated in the 1995 General Management Plan to

"manage the Colorado River corridor through Grand Canyon National Park to
protect and preserve the resource in a wild and primitive condition."
(General Management Plan, page 7)

Grand Canyon River Guides believes that the final plan must face up to the reality that increased
use means increased cumulative impacts, and accelerates further degradation of the resource the
NPS is legally bound to preserve. The alternative implemented in the final plan must address the
park's responsibility to "protect and preserve the resource in a wild and primitive condition" and
not accelerate degradation of the resource by another politically expedient increase in use.

Preferred Alternative H (Chapter 2 pp. 51-52)

Grand Canyon River Guides believes that preferred Alternative H is not based on a realistic
analysis of recreational impacts in Grand Canyon, but rather is a politically driven attempt to
appease the various groups wanting access to a Colorado River trip. Alternative H will have
serious negative impacts on natural and cultural resources, visitor experience, and park
operations compared to the current operations. Alternative H is not acceptable in its proposed
form and needs to be modified to better protect park resources and better meet the objectives of
the Colorado River Management Plan.

INCREASED USE
P. 52, “March-to-October User-Day Limits,” “Winter Use”
2 Grand Canyon River Guides’ primary concern about Alternative H is the significant increase in
overall use (nearly 28%) that it proposes. It is clear that an overall increase in use could have
serious negative impacts on natural resources (including the old high-water zone, trails,
campsites, wildlife, water sources such as seeps, springs and tributaries, and vegetation), on
irreplaceable cultural resources, and on the quality of the visitor experience. The draft EIS
contends that Alternative H will have fewer impacts on these resources than the no-action
Alternative A, due to smaller group sizes, smoothing of the use “spikes,” and appropriate
mitigations. As outlined below and detailed in our comments on the impact analysis portion of
the draft EIS, GCRG believes that this assessment overlooks a number of crucial considerations.

Foremost, while reducing group size may reduce the effect that any one group might have on its
surroundings, many impacts to resources are cumulative. Increased overall use is likely, for
example, to accelerate the erosion of beaches, the degradation of archaeological sites, and
damage to vegetation. The draft management plan suggests that these impacts will be managed
through monitoring and mitigation; but the monitoring and mitigation are not specified or
guaranteed by the plan, and rather depend on funding yet to be quantified and granted. How can
we rely on unfunded and unspecified mitigation measures to protect resources from accelerated
degradation when even the current level of use is acknowledged to be damaging those resources?

Several other factors related to the overall increased use are worth noting. The preponderance of
the increased use as proposed in Alternative H occurs in the winter season. Probable user days in
the winter will increase from the current 6,159 to a staggering 33,828. There are no data
concerning the impacts of wintertime use on the various resources simply because the use during
that time period has been so negligible to date. There is reason to suppose that vegetation,
wildlife, trails, and campsites in particular might benefit from a break during the winter to
recover from high use during the rest of the year. Guides have noted, for example, that they
observe a difference in appearance of campsites and trails early in the spring, versus at the end of
the high-use summer season.

It should also be considered that the overall increase in use, as proposed in Alternative H, is
entirely in the non-commercial sector – a user group that may cause adverse impacts simply due
to lack of education and understanding of the inherent value of irreplaceable cultural sites, for
example. Even with the implementation of education measures, it is not possible for non-
commercial boaters as a population to reach the level of stewardship and understanding exhibited
by commercial river guides, simply because they lack the training and repeat experience in the
canyon. Because the new non-commercial use occurs mostly in the winter season, it will also
necessitate far more monitoring and enforcement, and therefore more time, money, and staff than
the current level of use requires.

Additionally, administrative use is not considered within this plan, although it now constitutes a
very significant 25% of all current use. The DEIS numbers of people or trips at one time in the
canyon do not account for this at all - all the more reason to question the feasibility and
workability of this alternative. Furthermore, there is no clarity on whether the no-motor season
would apply to science trips, although we understand that minimum tool rules apply in most
cases where feasible. But for those research trips that must use motors due to their nature, will
3 the heavy use season where motors are allowed be inundated with even more science trips,
possibly launching on the same schedules and increasing contacts and congestion throughout the
river corridor? The ramifications of this are enormous in terms of congestion on the river and
ultimately negative impacts to the river experience. These questions must be answered, and
accountability must be built into the plan as it relates to administrative