Sierra Club National Outings Response to Grand Canyon National Park Backcountry Management Plan and Draft Environmental Impact Statement, March 2016
Sierra Club National Outings applauds the substantial efforts of Grand Canyon National Park to continue to actively pursue the dual goals, as set forth in the 1916 Organic Act, to “conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” We also support the Park managing the backcountry as wilderness until Congress acts to possibly designate lands within the Park as Wilderness as defined by the 1964 Wilderness Act.
We recognize increasing pressures on the Park’s natural resources, and we support efforts by the Park Service to carefully preserve one of America’s most iconic Park’s and a UNESCO World Heritage Site. We have some recommendations regarding the alternatives proposed in the draft environmental impact statement, that we believe allows the Park Service to preserve the Park while also allowing Sierra Club to continue to offer commercial backcountry outings to anyone capable and interested.
Background
Part of the largest grassroots environmental organization in the country, Sierra Club National Outings provides environmentally friendly outdoor adventures for people of all ages, abilities, and interests. For more than a century we have guided people to places worthy of protection, ever since Sierra Club founder John Muir said in 1901, “If you want people to go to bat for the environment, you've got to get them into the wilderness.” and "If people in general could be got into the woods, even for once, to hear the trees speak for themselves, all difficulties in the way of forest preservation would vanish."
Sierra Club National Outings has run backpacking and wilderness trips in Grand Canyon National Park for more than 50 years. For the past 10 years, we have offered about 10 Grand Canyon trips a year, each typically lasting 7-8 days, with an average of about 10 people per trip. In terms of user days, this equals roughly 700 to 800 user days per year. We also offer trips in areas contiguous to Grand Canyon National Park on BLM, Forest Service, and tribal lands. Some of these trips use the Park for a portion of their itinerary.
The Sierra Club has a long and distinguished history in preservation efforts to protect the wildness and natural grandeur of Grand Canyon National Park and the greater Grand Canyon ecosystem. We are particularly proud of our successful opposition efforts in the 1960s to the proposed Bureau of Reclamation Bridge Canyon and Marble Canyon dams.
Since that time, we have worked on many issues around the Park, including natural quiet; air quality; restoration and protection of native plant and animal species; the operation of Glen Canyon Dam to protect downstream resources; and uranium mining, to name a few. Some of these issues needed legislative action and/or administrative help from other government agencies. We are a strong and reliable partner for the Park and have been happy to promote its primary interests as a participating NGO. In some instances, for various reasons, we have acted independently on behalf of the Park.
Conservation and preservation are central to Sierra Club National Outings and to Grand Canyon trips in particular. Our participants leave our trips with a much better understanding of the ecology and many threats to the Canyon. Our leaders are steeped in conservation issues, outdoor leadership, and experiential education. Many have lifelong backgrounds in conservation and citizen advocacy organizations and are active in local Sierra Club chapters, The Wilderness Society, Grand Canyon Trust, The Nature Conservancy, Search and Rescue Teams, and the National Outdoor Leadership School among others.
Sierra Club National Outings trips are usually run with the maximum allowable group size; in the Grand Canyon, it is currently 11 people. There are two primary reasons for this. The first is safety and the second is that conservation discussions are an integral part of our efforts to educate and empower participants to advocate for the protection of the Grand Canyon and other natural places. These discussions—which include current topics specific to the Grand Canyon (the Escalade project, lead in ammunition and its impact on condors) as well as more global topics (climate change, renewable energy, fracking)—are livelier and more engaging with a larger group since more perspectives are represented.
Sierra Club National Outings are staffed entirely by volunteer leaders. The leaders receive no payment for leading outings and the National Outings program, on average, roughly breaks even. One of the primary reasons our leaders guide people into the Canyon is to share their appreciation of the Canyon, in hopes that their participants will be as committed to preserving the Canyon as they are. Sierra Club National Outings are considered “commercial” in the Grand Canyon National Park and other areas. The reason is that we charge for our outings to cover the salary of a few paid staff in San Francisco and to cover overhead costs for insurance, equipment, etc.
Grand Canyon backpacking, by its very nature, is challenging and our trips are indeed challenging due to their remoteness (Jewels, Kanab, N Bass, etc.) and duration (a week or more). We take the safety and well-being of all participants on our backpacking trips very seriously and take numerous steps before and during each trip to ensure that safety.
Concerns and Solutions for Commercial Overnight Backpacking and Day Hiking
Sierra Club National Outings reviewed the alternatives proposed in the Draft Environmental Impact Statement (DEIS) with an emphasis only on the impact to commercial overnight backpacking and commercial day hiking since these are the activities in which we engage. Following are our concerns and recommendations. Importantly, as it relates to the proposed alternatives in the DEIS, our trips have been located predominantly in what are currently called Primitive Zones with occasional nights in Threshold and Wild Zones.
We recognize the need to evolve policies to better protect the backcountry of the Grand Canyon. However, Alternatives B-D represents giant changes to the current commercial backpacking activities, especially in Primitive Zones, and, without significant revisions, would severely impact, change and/or eliminate a Sierra Club National Outings program in the Grand Canyon.
Contracts/CUAs. Under Alternatives B, C, and D, commercial backpacking will be permitted using 3-5 10-year contracts and a limited number of Commercial Use Authorizations. We recommend the Park Service continue using only CUAs to permit commercial backpacking.
Under the proposed Alternatives B, C, and D, future CUA holders are limited to a maximum of 3 trips per year per operator. Currently, there are 10-15 CUA holders offering more than 3 trips per year. So under Alternatives B, C, and D, these 10-15 current CUA holders will somehow have to “collapse” into 3-5 contracts. Doing so will create 3-5 controlling businesses and may likely destroy the small guide businesses. It is suggested in the DEIS that future CUA holders could “charter” additional trips with the businesses holding the contracts. For various reasons, we think this outcome is unlikely. There is no incentive for a contract holder to share user nights in our opinion. We recommend, instead, that the Park Service continue using only CUAs to permit commercial backpacking.
Also, we strongly believe that, in the spirit of fairness, all commercial backpacking companies, both contract holders (if that materializes) and CUA holders, should have access to permits at the same time. That is, we strongly oppose the proposal of allowing contract holders access to permits in advance of CUA holders or private parties.
Allowed Zones. We disagree with the Park Service’s continued use of designate “zones” in the Park. The Park Service is required to protect the backcountry as if it were already designated as wilderness which we support and applaud. Thus, all of the areas should be managed to the same high level. (Exception is the Corridor area that is not proposed as wilderness.) Designations of Threshold, Primitive and Wild Zones imply that some areas of the Park are wilder than others or are more deserving of wilderness protection than others and could lead some very pristine areas being excluded when Congress does take up designating Wilderness in Grand Canyon under the Wilderness Act.
Backpacking in the Corridor is a good place for people new to the Grand Canyon to start backpacking, but this area cannot provide the deeper true wilderness experiences possible in more remote areas. Commercial guiding opportunities in all areas will allow visitors to experience these remote areas in the safety of a group led by a trained and experienced guide. We believe that commercial guiding in these more remote areas will allow for a greater diversity of people experiencing these areas.
The Park Service can manage use in the backcountry (we are not talking about the corridor area) with management units or use areas similar to the ones in use today when applying for a Backcountry Permit (e.g. BP9 Ruby Use Area or AU9 Blacktail Use Area). These use areas can be of different sizes and allow different numbers of groups in the use area at any one time.
Overnight Backpacking Group Size. We suggest the maximum commercial group size remain 11, allowing for 2 leaders per trip, thereby providing a safer experience in these more remote areas. We fully understand the potential impact of larger groups on Park resources and believe that one of the best approaches for reducing impacts is to continue developing, employing, and educating participants about gentler ways to travel, such as following Leave No Trace principles and using human waste collection systems. A group of 11 adhering to gentle wilderness ethics is consistent with the delicate balance described in the Organic Act of protecting resources and providing enjoyment for today’s and future generations. Also, conservation discussions are livelier and more engaging with a larger group since more perspectives are represented.
Caps on Commercial Backpacking. Alternatives B, C, and D introduce caps on number of nights per month for commercial backpacking. The reason for these caps is to ensure the public has adequate access to permits for private trips which we agree is a reasonable goal. The Park’s goal is for commercial backpacking to use about 10% of all available permits. According to data from the Park, this has been the case for each of the years from 2000-2012. That is, commercial backpacking is naturally taking 10%. It may be more than 10% in some zones and less than 10% in other zones from year to year, but across all zones, commercial backpacking has used 10% of the permits for 13 years. Commercial backpacking outfitters offer trips where their clientele demands it, that is, commercial backpacking is offered where the public wants it. We believe it better to let the public demand determine where commercial backpacking trips occur without extra controls or restrictions imposed. In summary, we recommend there be no caps on number of nights for commercial backpacking trips in each zone. If commercial groups did start exceeding the historic 10% use of available permits then we suggest limits be set via Backcountry Permit Requests. For example, for any given month when commercial requests exceeded 10% then no more Backcountry Permits would be provided to commercial groups for that month.
Limits on Trails for Commercial Day Hiking. Occasionally, Sierra Club National Outings offers week-long basecamp trips based out of Mather Campground with daily hikes along or off the South Rim. Also, we have considered offering basecamps off the North Rim using BLM and Forest Service camps with day hikes into the Park.
Alternatives B, C, and D limit commercial day hiking to specific trails and depth allowed on each trail, trails and depths varying by alternative. All of the depth limits proposed fall severely short of a reasonable day hike.
We recommend depth be limited down to, and including, the Tonto Platform and that all the main trails (Tanner, Grandview, S. Kaibab, Bright Angel, Hermit, and Boucher on the South Rim and N. Kaibab, Bill Hall, and N. Bass on the North Rim) be available for commercial day hiking.
An advantage to allowing commercial day hiking groups deeper into the Canyon is that commercial hiking groups have at least one guide (two guides for larger groups) trained as a Wilderness First Responder or higher. Guides with this training hiking on the trails helps to keep the main trails safer for all, since guides can offer assistance to any party, commercial or private.
Requirement to Dispose of Human Waste. We fully support the use of human waste collection systems on all main trails by commercial and private parties to keep these well-used trails cleaner, and to reduce the impact to vegetation and creation of use trails caused by people trying to dig cat holes.
For overnight commercial trips, instead of requiring the use of WAG BAG® or RESTOP® at all use areas without toilets, we suggest requiring the use of human waste collection systems if within ½ mile or a 20-minute brisk walk, whichever is greater, of water (either a stream or the Colorado River). Allowing cat holes, if farther than ½ mile and a 20-minute brisk walk from water, will move human waste away from water. This approach will likely result in a more broadly distributed camping impact since many backpackers will opt to camp away from water rather than carry solid waste. Moving human activity away from water also reduces the human impact on animals and riparian plants.
Please note that, when evaluating whether to implement human waste disposal systems for private trips, we postulate that this combination approach of allowing cat holes away from water and requiring waste collection close to water will achieve a higher rate of compliance than requiring human waste collection systems everywhere.
Conclusion
We recognize the need to evolve policies to better protect the backcountry of the Grand Canyon Park. However, Alternatives B-D represent enormous changes to the current commercial backpacking activities and, without significant revisions, would severely impact, change and/or eliminate a Sierra Club National Outings program in the Grand Canyon. Sierra Club National Outings respectfully requests that the Park Service consider our proposed revisions to Alternatives B-D. In summary, these revisions are:
- Continue using Commercial Use Authorizations (CUA) for commercial backpacking activities.
- Allow commercial backpacking in all areas.
- Allow maximum commercial backpacking group size of 11 in all areas.
- Do not impose limits on number of nights per use area per month for commercial backpacking activities. Let demand determine where commercial backpacking is offered and if necessary impose a 10% limit on commercial backpacking by limiting Backcountry Permits.
- Allow commercial day hiking on all main trails down to and including the Tonto Platform.