Comment on Gunnison Gorge Preliminary Alternatives

December 2002. Gunnison Gorge National Conservation Area (GGNCA) has released preliminary draft alternatives for public comment, due by Tuesday, December 17. This stretch of the Gunnison River flows through a double canyon (2 rims) below Black Canyon of the Gunnison National Park. The Bureau of Land Management-administered area includes a variety of scenery, land uses and recreational opportunities divided into zones for different administration. Of particular concern to river runners is 14 miles of the river as it flows through the small inner canyon Wilderness Area of about 17,000 acres called Zone 1. River runners must hike to the launch area down the 1 mile Chukar Trail and either backpack their gear in or arrange with the approved horse packing outfitter to have it brought down. Consequently, this run is more popular with non-commercial kayakers than rafters. The take out is outside the wilderness boundary on BLM land at Gunnison Forks.

Extensive public and focus group meetings were held during the spring and summer. The GGNCA has released preliminary draft alternatives for its management plan revision. This is an opportunity for the public to be involved before the draft alternatives, usually with a "preferred alternative" chosen by the agency, are released. Current comments will be considered for incorporation into the draft alternatives which are scheduled for release in February, 2003.

Four preliminary draft alternatives are presented. Concerning Zone 1, Alternative A is the "status quo", or keeping most management aspects as they are now. Currently, there is no formal permitting system for noncommercial boating use and fishing use. Commercial boating outfitters are limited to 2 launches per day, divided among several permitted companies (not concessions). Boating group size is limited to 12 people, regardless of trip type. Currently, a noncommercial trip must pay a small trip fee, read the regulations and sign the self-issued form on behalf of the trip at the Chukar launch site. This applies to non-commercial recreational boaters and fishers.

Carrying capacity has been determined to be 75 people per day in the small canyon. This number is exceeded about 10 days during the stone fly hatch in May and/or June. The group size maximum of 12 has been determined by the size of the existing designated campsites (no camping in non-designated sites). Self guided fishing visitors, when boating, are lumped with recreational boaters, and with backpackers and hikers if they are not using a boat.

Alternative B would keep commercial group sizes at 12, including guides, and would keep commercial launches at 2. Noncommercial groups would be reduced to 8 participants. A non-commercial permit system would be implemented and would allow 4 trip launches per day with a maximum of 6 boats per trip. Non-commercial trip participants would be subject to education of the requirements for travel in the canyon. Fees were not addressed in this alternative. This alternative would establish "use indicators" and monitor user satisfaction levels, resource degradation and use adaptive management techniques to change policies and procedures to accommodate necessary changes.

Alternative C would use the same adaptive management techniques. Commercial launches would increase to 2 overnight plus 1 day use trip. All group sizes increase to 16 people (including guides for commercial trips). Unlimited guide training trips would be allowed. Two noncommercial trips would be allowed in addition to unlimited day use. Fees were not mentioned.

Alternative D deviates from specific prescriptions for recreational use, and instead creates an opportunity for deeper study and a longer, more intensive process for administering that use. This would be achieved by analyzing current visitation, existing resources and the present outfitter system. Needed changes would be identified and considered to shift allocation of use between trip types and between outfitters. Methods of assessing and monitoring visitor satisfaction and resource protection over time would be developed. A "friend's group" would be formed to assist in management, trail and facilities work, user education and to provide feedback to the BLM.

RRFW believes rules should be applied evenly wherever possible between commercial and non-commercial trips. Therefore, disparities in group sizes, boat limits, and user fees are not justified. The scale of the canyon and river within it are small, and GGNCA has made a good case for establishing the group size of 12 people; an increase for any trip type is not justified. It also is difficult to justify limiting non-commercial use via a permitting system while a substantial amount of commercial allocation goes unused, as happens now. Similarly, noncommercial boaters have not been shown to cause a disproportionate level of resource abuse, making the proposal to require educational programs an unnecessary burden to noncommercial boaters and BLM administrators. Furthermore, few permitting systems in use today are fair or satisfactory to do-it-yourself boaters.

Alternative D creates some exciting opportunities, but at the same time, provides no safeguards that the outcomes will be appropriate. Budgetary and legal concerns could make this a difficult process, and clearly, it will take longer. It appears to be a new concept in draft alternatives, and the GGNCA should be applauded for including it.

The current situation, Alternative A, works nicely for non-commercial boaters. Admittedly, there are resource issues stemming from the increased fishing use during the stone fly hatch season, but boating logistics limit access far more than agency obstacles. RRFW urges GGNCA to postpone formal permitting of non-commercial boaters as long as possible to avoid the substantially increased administrative overhead and dissatisfaction among non-commercial boaters.

The alternatives include much more than the boating issues covered here, we urge you to go to the GGNCA Management Plan website at www.gunnison-gorge-eis.com. To get a detailed Excel spreadsheet of each alternative's boating-related elements, reply to this message and you will receive it as an attachment. Comments are due tomorrow, Tuesday, December 17, 2002. Send them to Angie Nelson at Tetra Tech, Inc. (acting as a contracted agent to the BLM), by email: angie.nelson@tetratech.com or by fax: (720) 406-9114.