A proposal for substantially increasing river running fees on the San Juan River in southern Utah has been released for public review and comment. The deadline for comment submissions on the “Draft Business Plan for the San Juan River” is Friday, January 25, 2013.
The draft plan was published by the Bureau of Land Management’s Monticello Field Office just before Christmas and allowed a 30 day window for public consideration, particularly short given the busy holiday season. The 35 page PDF file of the plan can be found here: http://www.blm.gov/ut/st/en/fo/monticello.html by clicking on the “Draft Business Plan for the San Juan River” link.
Fees were originally instituted in 1983, and were increased substantially in 2001. The proposed fees would nearly double for all segments of the trip and institute a $6.00 nonrefundable fee for entering the lottery, which is currently free. Full trips (Sand Island to Clay Hills) would be increased from $18 to $30 per person, with Sand Island to Mexican Hat per person fees increasing from $6 to $10 and Mexican Hat to Clay Hills charges raised to $20 from the current $12 per person.
The plan also calls for using an online payment system administered by the Department of the Treasury for collection of application information and fees. The BLM cites a reduction in processing time and savings in paper and postage costs by making this change.
Also proposed is a shortening of the lottery permit season, which currently extends from April 1 to October 31, to instead begin on April 15 and end on July 15. The planners have determined that lower visitor demand and the high rate of cancellations seen before April 15 and after July 15 make a lottery inefficient and unnecessary outside of the peak demand weeks as outlined in Table 5 at the bottom of page 16 of the plan.
The plan purports to correct what it says is operational underfunding from decreased fees. Despite declaring that visitation is not expected to increase, the additional revenue is to be used for keeping reserve balances higher, to build another toilet at Sand Island, ranger services and administrative purposes.
River Runners for Wilderness (RRFW) is concerned with several elements of the plan from its problematic holiday timing and short deadline, to several of the underlying assumptions and justifications offered as evidence of a necessary fee increase. Among these is the unsupported statement that since noncommercial boaters may have a higher income than other visitors, they are therefore not greatly impacted by higher fees. The BLM also makes the assumption that since lines do occasionally form at the existing Sand Island toilet, fees should be collected to build an additional unit (though the BLM fails to state if the people in the lines are day-trip river runners who pay no fees); and that river runners require more ranger supervision.
RRFW also takes issue with the touted “beneficial secondary effect” of discouraging applicants due to the higher fees. The plan advocates for a shorter high-use season, which would reduce costs of administering the lottery. However, an argument could be made that with flat or decreased visitation throughout the season and the shortening of the high use season, fewer funds will be needed.
The plan also points out that the San Juan is one of the few rivers that currently does not charge a fee for entering an application. Some of the new revenues would be used to replace the current staff-intensive permit system with a more modernized and efficient system.
Kitty Benzar of the Western Slope No-Fee Coalition (WSNFC) has released a comprehensive comment letter questioning the several aspects of the plan’s request. Her complete letter can be found at their website: http://www.westernslopenofee.org/pdfuploads/SJRiver_WSNFC_Comment.pdf.
Although the agency contends that ample notification of the plan’s release through river running websites, social media, press releases to Utah print and broadcast media, a meeting of the Utah Guides and Outfitters, and commercial permit holders via phone and email, River Runners for Wilderness is concerned that many river runners are unaware of the proposal. RRFW letter of, comments and questions on the plan can be found at our website: https://rrfw.org/sites/default/files/documents/SJComments1-2013.pdf
Your comments should be sent to the Monticello Field Office by mail to:
Or via e-mail at blm_ut_mt_comments@blm.gov with “San Juan Business Plan” in the subject line.