Grand Canyon National Park has proposed four changes to the 2006 Colorado River Management Plan (CRMP) lottery system and how self-guided river runners get to float through Grand Canyon.

This was announced in an eight year review of the Lottery system in November

(http://www.nps.gov/grca/planyourvisit/upload/River_Stats_8_Year_Update.pdf)

The National Park Service (NPS) is proposing the following changes:

1) Modify lottery site to show cancellations when they occur to give advance notice before lotteries are announced.

2) Schedule Lotteries at regular times each month (e.g. every 2nd Tues -Thurs)

3) Encourage the listing of Potential Alternate Trip Leaders (PATLs) by doubling points on lottery applications that list PATLs. According to NPS figures, currently only 18% of applicants list PATLs.

4) Shorten the noncommercial maximum trip lengths from 21 to 18 days for the last half of April and increase the maximum trip lengths from 18 to 21 days for the last half of September beginning in 2015. This proposal to being made to “help with TAOTs” [Trips At One Time] and exempts trips already scheduled. Please see below to understand what a TAOT is.

The NPS also noted in the review that during the four winter months, November through February, the CRMP has missed its target goals of do-it-yourself public river trip user days by 40%, number of do-it-yourself passengers by 50% and number of do-it-yourself public trips launching by 25%. The NPS did not identify this as a problem. The review did not mention that in the 2008 through 2012 seasons, do-it-yourself public river runners have fallen short by 151 trips.

What do YOU think about this?

Here are some points to consider about these proposed changes:

1) Modify lottery site to show cancellations when they occur to give advance notice before lotteries are announced.

Anything Grand Canyon National Park can do to alert river runners that cancelled trips are available is a good idea. River Runners for Wilderness (RRFW) supports the NPS in this change, and would even like to see an email opt-in allowing individuals who have created a lottery profile to receive an email, should they so choose to do so, announcing the cancelled trip.

2) Schedule Lotteries at regular times each month (e.g. every 2nd Tues -

Thurs)

RRFW is not sure this a helpful change, and would rather see lotteries happening as soon as cancelled trips happen, even daily, versus waiting for a set day of the month. Increasing lead time by announcing and allowing a lottery immediately as a launch date is cancelled would be ideal to maximize time for trip planning and logistical arrangements.

3) Encourage the listing of Potential Alternate Trip Leaders (PATLs) by doubling points on lottery applications that list PATLs. Currently only 18% of applicants list PATLs.

Grand Canyon National Park has never released any data showing how many trips that signed up a PATL actually needed one, or have not launched because they did not identify a PATL. It would be very helpful to see this data and RRFW encourages the National Park Service to release this information. The present system sets the total lottery chances to the person with the lowest possible lottery points. RRFW encourages the NPS to allow adding a PATL up to 30 days prior to launch. By the time most trips are within thirty days of launching, their trip participant list is set, and identifying a PATL would be much easier.

4) To help with TAOTS, shorten the noncommercial maximum trip lengths from 21 to 18 days for the last half of April and increase the maximum trip lengths from 18 to 21 days for the last half of September. Exempt trips already scheduled.

RRFW notes that TAOT is the acronym for Trips At One Time and is the number of river trips between Lee’s Ferry and Diamond Creek at any one time. The 2005 Final Environmental Impact Statement, Colorado River Management Plan, Vol 1, pg 32, stated "Camping at the same site or at nearby sites within sight or sound of another group becomes necessary in some places when there are 70 trips at one time, about the maximum current level."

Grand Canyon National Park has only provided one year's worth of TAOT data, the 2013 use levels. In 2013, the maximum TAOT for the year is 64, and this occurs only three days in a row. Over one seven day period when this 64 TAOT level is achieved, the average TAOT for the week is 62.

RRFW would like to point out that there is a spike in commercial launches during the time period the NPS notes a Trips At One Time (TAOT) number above the "aimed for 60 TAOT maximum." It should also be noted that the chart showing 2013 TAOT's indicates TAOT levels are exceeding 60 trips per day at various times throughout the summer. It is very possible this summertime overrun is solely based on concessionaire river trip scheduling variability.

RRFW would like to see TAOT data for the last 8 years before even considering such a drastic change in self-guided trip lengths in the spring. If the TAOT spike is a result of excessive concessionaire trip launches, it would make more sense to rearrange the concessionaire schedule to avoid a cluster of concessionaire trips launching in the first two weeks of May.

Of the four proposed changes, this is the most perplexing. Since 2006, RRFW has not heard of a single self-guided river trip that wanted the length of their spring river trip to be shortened, or that they were encountering too many other trips in the 280 mile canyon trip. Besides the fact that the flowers are in bloom and the weather is finally warming up, in the spring upstream winds can seriously slow river travel.  The NPS proposal to shorten noncommercial trip lengths could seriously impact trips.

With the shorter spring trips, the NPS proposes to impact 30 do-it-yourself river trips for an overrun of only 16 trips in the NPS identified period of concern. It seems completely unreasonable to impact twice the number of do-it-yourself river trips required to achieve a desired outcome to a problem possibly caused by the river concessionaires.

The NPS offers to lengthen river trips in the second half of September, the start of the motor-free season. Trip length was identified as a very important aspect of the river experience in Grand Canyon (CRMP Technical Memorandum, Shelby and Whittaker, pg 67). Overall lottery applications for do-it-yourself river trips throughout the year peak in the summer in a bell shaped curve, with an additional spike in applications, even greater than the summer peak, beginning on the first day of the motor free season starting September 15. In fact, demand for the first and second dates after the motorized watercraft cease operations has risen to over 500 applications for one launch (2012). The NPS has not explained why there is a need to increase demand for these dates, already at a maximum.

As to underutilizing the winter months, since 2007, River Runners for Wilderness has been encouraging Grand Canyon National Park to make these winter river trips more attractive and consider included elimination of the one-river-trip-per-year rule for self-guided river runners in the commercial-free winter months, removing the lottery point "reset" for participating in a winter river trip, and returning winter trip lengths to the pre-2006 winter trip length of 30 days to Diamond Creek from the present 25 days.

RRFW encourages you to look at our recent letter sent to Grand Canyon National Park:

https://rrfw.org/sites/default/files/documents/CRMP_Comments_Final_12_20...

Then, send Grand Canyon National Park your thoughts on these changes. We encourage you to cc your Congressional Representatives to be sure you receive a response. Please send your comments and concerns to:

Superintendent David Uberuaga

Grand Canyon National Park

PO Box 129

Grand Canyon, AZ 86023-0129