Defining common pool and split allocation systems
Adapted from text prepared by Doug Whittaker and Bo Shelby
Confluence Research and Consulting

Stakeholder and Public Workshops, June 24-25, 2003

Basic Allocation definitions

Split: commercial and non-commercial users compete for permits in separate pools with different distribution mechanisms.

Common pool: all users compete for permits in the same pool and in the same way. 

More detailed definitions

Split allocation. Under a split system, recreational use is distributed within two basic sectors, commercial and non-commercial. Grand Canyon use allocations have traditionally been based on user days (one recreation user in the canyon for any part of one day) and commercial crew are not counted. However, it is also possible to use the number of recreation participants or launches as the unit of analysis.

In the commercial sector, the total commercial allocation is further allocated among individual outfitters. Concessioners generally control how they use their allocation, and can adjust their number of trips, group sizes, trip lengths, and scheduling as long as they dont exceed other components of the use limit system (people launching per day, group size limits, etc.). 

In the non-commercial sector, the allocation is distributed via launch permits to permit applicants or groups of boaters. The permit system is managed by NPS. Under current management, individual groups make their own decisions about trip length and group size, so considerable administrative attention is required through the year to release an appropriate number of non-commercial permits. The goal is to release enough permits to meet but not exceed the non-commercial user day allocation. 

Common pool allocation. Under a common pool system, all recreational use would be distributed through the same process. People interested in either commercial or non-commercial trips would apply for launches through the National Park Service, and if they were successful they could choose to 1) organize their own trip with others in the system,; 2) contract with an outfitter to provide a charter trip (with others in the system), or 3) join a prospectively scheduled commercial trip (which may require other passengers to also obtain permits for the trip to go). Regulations defining differences between commercial and private trips would no longer be relevant, as all users would be competing in the same pool. 


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[Code of Federal Regulations]
[Title 36, Volume 1]
[Revised as of July 1, 2001]
From the U.S. Government Printing Office via GPO Access
[CITE: 36CFR7.4]

[Page 56-57]
 
	TITLE 36--PARKS, FORESTS, AND PUBLIC PROPERTY
 
	CHAPTER I--NATIONAL PARK SERVICE, DEPARTMENT OF THE INTERIOR
 
PART 7--SPECIAL REGULATIONS, AREAS OF THE NATIONAL PARK SYSTEM--Table of Contents
 
Sec. 7.4 Grand Canyon National Park.
	. . . . 

	(iii) An operation is commercial if any fee, charge or other compensation is collected for conducting, leading, guiding, or outfitting a river trip. A river trip is not commercial if there is a bona fide sharing of actual expenses.
	. . . .

[34 FR 14212, Sept. 10, 1969 as amended at 36 FR 23293, Dec. 8, 1971; 42 
FR 25857, May 20, 1977; 43 FR 1793, Jan. 12, 1978; 52 FR 10685, Apr. 2, 
1987]


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DRAFT
EXAMPLES OF CARRYING CAPACITY CONSIDERATIONS
COLORADO RIVER MANAGEMENT PLAN
Prepared for Stakeholder and Public Workshops June 24-25, 2003

The following excerpts are provided to illustrate the complex analysis necessary to determine carrying capacity of the Colorado River corridor in Grand Canyon National Park:

Excerpts from VERP, The Visitor Experience and Resource Protection (VERP) Framework, A Handbook for Planners and Managers, U.S. Department of the Interior, National Park Service, Denver Service Center, September 1997. [Source: http://planning.nps.gov/document/verphandbook]

The concept of carrying capacity is intended to safeguard the quality both of the park resources and the visitor experience. Park resources in this context encompasses all of the biophysical, aesthetic, and cultural elements and features contained in a park.
	As it applies to parks, visitor carrying capacity is defined as the type and level of visitor use that can be accommodated while sustaining acceptable resource and social conditions that complement the purpose of a park.
	Under this definition carrying capacity is interpreted primarily as a prescription of resource and social conditions, and secondarily as a prescription for the appropriate numbers of people.

	VERP is: a planning and management framework that focuses on visitor use impacts on the visitor experience and the park resources. These impacts are primarily attributable to visitor behavior, use levels, types of use, timing of use, and location of use.
	It should be noted that crowding is only a part of what contributes to or takes away from the visitor experience.

	Given the substantial demand for public use of the parks, some decline or change in resource condition and the quality of visitor experience is inevitable. But how much decline or change is appropriate or acceptable? This issue is often referred to as the limits of acceptable change (LAC) and is fundamental to addressing carrying capacity.
	All of these frameworks include a description of desired future conditions for park resources and visitor experiences, the identification of indicators of quality experiences and resource conditions, establishment of standards that define minimum acceptable conditions, the formulation of monitoring techniques to determine if and when management action must be taken to keep conditions within standards, and the development of management actions to ensure that all indicators are maintained within specified standards.



COLORADO RIVER MANAGEMENT PLAN
EXAMPLES OF RESOURCE CONSIDERATIONS USED IN DETERMINING CARRYING CAPACITY

Cultural Resources
*	Inventory of all known archaeological sites (historic and prehistoric) in river corridor and in river-accessible side canyons (affected environment)
*	Review and quantification of known visitor impacts on known sites in affected environment. This includes an assessment of associated archeological site integrity, damage to archeological site features, artifact displacement, number of social trails and amount of soil compaction.
*	Determination of data gaps in the affected environment 
*	Inventory of all known Traditional Cultural Places in the affected environment
*	Review of available literature on visitor impacts in the affected environment
*	Review of literature on visitor impacts and carrying capacity from selected parks
*	Review of visitor impact data from existing archeological site monitoring program in river corridor
*	Review and determination of Park resources spent on visitor impact mitigation. 
*	Solicitation of site-specific use restriction recommendations (with accompanying justifications) from Park staff and various agencies and Tribes for sensitive resource areas.
*	Research on correlations between group size and visitor impacts to cultural resources
*	Research on the efficacy of mitigative efforts (data recovery, site hardening, social trail obliteration, rerouting of trails, trail delineation, campsite delineation, revegetation, soil stabilization, erosion control, site closure, and behavior restriction) at sites with visitor impacts
*	Review of Tribal documentation of resource concerns
*	Consultation with Hualapai, Havasupai, Hopi, Navajo, Paiute, Zuni, and White Mountain Apache 
*	Review of public comments 
*	Development of impact thresholds for cultural resources
*	Work with Hualapai Tribe to determine physical carrying capacity of Diamond Creek and associated road
*	Review of data on impacts from Helicopter vibration on archaeological sites


Natural Resources
*	Inventory and/or baseline measurements of all known natural resources in river corridor potentially affected by river use. These include threatened, endangered and sensitive wildlife species as well as significant non-listed native wildlife species, cave resources including paleontological, geological, biological and hydrological resources, seeps and springs and their associated microenvironments, native riparian vegetation as well as exotic plant species, pre-dam and post-dam soils, geologic formations, air quality, water quality, and natural quiet. 
*	Review and quantification of known visitor impacts on known sites in affected environment. This includes an assessment of biophysical impacts such as number of access and social trails, percent vegetation damage near beach and in the old high water zone, amount of human waste, amount of litter, intrusions into old high water zone including number of campsites in old high water zone, number of vegetation islands, number and type of habituated animals, and amount of soil compaction
*	Determination of data gaps in the affected environment 
*	Review of available literature on visitor impacts in the affected environment
*	Review of literature on visitor impacts and carrying capacity from selected parks
*	Review and determination of Park resources spent on visitor impact mitigation. For example: the cost to implement the river site revegetation, trail obliteration, erosion control/soil stabilization, exotic species removal, trash and human waste removal program. Also the endangered wildlife species, water quality and air quality monitoring programs.
*	Solicitation of site-specific use restriction recommendations (with accompanying justifications) from Park staff and various agencies and Tribes for sensitive resource areas.
*	Examination of correlation between visitor use intensity and site condition as well as creation of a mixed resource map to examine reaches of the river with high use/high impact sites.
*	Research on the efficacy of mitigation efforts (data recovery, site hardening, social trail obliteration, rerouting of trails, trail delineation, campsite delineation, revegetation, soil stabilization, erosion control, site closure, and behavior restriction) at sites with visitor impacts
*	Review of public comments on all of the natural resource issues
*	Development of impact thresholds for natural resources
*	Review of data on impacts on wildlife, soils, water quality and natural quiet from helicopters and motors
*	Review of data on impacts of human recreational activities, numbers of people and groups size on wildlife habitat and behavior including significant native and threatened, endangered and sensitive species such as humpback chub and other native fish; birds such as bald eagles, condors, Mexican spotted owls, peregrine falcons, Yellow-billed cuckoos, SW willow flycatcher and native breeding birds; leopard frog tadpoles; Kanab Ambersnail; various species of bats; and bighorn sheep.
*	Review of data on impacts of human recreational activities on water quality, air quality natural quiet, and paleontological resources
*	Review of research on physical carrying capacity of river corridor, specifically diminishing campsite beach size and limited campsite availability in bottlenecks
*	Examination of low water alternatives for river runner takeouts including the physical carrying capacity of Diamond Creek and low water navigability of river in lower gorge to access Lake Mead.
*	Examination of physical carrying capacity of Lees Ferry launch ramp.

 
COLORADO RIVER MANAGEMENT PLAN
EXAMPLES OF SOCIAL/VISITOR EXPERIENCE CONSIDERATIONS USED IN DETERMINING CARRYING CAPACITY


*	Number of trips/launches per week
*	Number of human encounters on river per day/trip
*	Number of attraction site encounters per day/trip (i.e., Little Colorado River, Elves Chasm, Deer Creek, Havasupai Falls, etc.)
*	Probability of meeting another group per day/trip
*	People leaving Lees Ferry per day/week/month/season/year
*	Time in sight or sound of other groups on the river per day/trip
*	Percent of attraction sites with group encounters
*	Average number of people seen at attraction sites at one time, per day/trip
*	Perceived level of crowding per person/group/trip
*	Waiting time at the launch sites/ bottle necks/attraction sites
*	Number, type and size of other parties met per day while traveling
*	Reported user conflicts
*	Change in accident rate or enforcement action
*	Number of incidents or violation notices issued
*	Number of incident reports
*	Number of incidents of vandalism
*	Evidence of damaged vegetation, archaeological sites, etc.
*	Artifact displacement at archaeological sites
*	Archaeological site surface disruption, disturbance, or vandalism
*	Number of social trails to attraction sites, campsites, etc.
*	Amount of erosion, soil compaction, etc. at attraction sites, campsites, trails, etc.
*	Degree of erosion/compaction
*	Type and rate of change of beach erosion per season/year
*	Campsite condition (i.e., size of campsite, percent of erosion, number of trails, etc.)
*	Number of Law Enforcement Officers on the river per day/trip/season/year 
*	User group conflicts per group type
*	Number of conflicts between different types of users (i.e., anglers and boaters) 
*	Availability of campsites
*	Campsite density per river segment/mile/segment/corridor
*	Number of sites occupied at one time
*	Number and size of campsites per river mile/segment /corridor
*	Number of distribution of campsite per area
*	Number of camps by season of use
*	Number of campsites within sight or sound of each other
*	Number of human encounters by campsite
*	Number of days per primary season a site is occupied
*	Number and density of campsites
*	Evidence of use
*	Evidence of human waste
*	Percent of beaches and river corridor free of human waste
*	Percent of campsite free of litter
*	User group types
*	Frequency of group encounters
*	Number of encounters per day/trip between shore to float groups
*	Number of encounters per day/trip between shore to shore groups
*	Number of encounters per day/trip between shore and other shore groups
*	Number of encounters per day/trip between float and other float groups
*	Number of contacts per day/trip with non-recreation parties (i.e., Park personnel)
*	Types of use encountered
*	Ratio of visitors to outfitters/guides
*	Percent of time in site or sound of other boating parties
*	Return visitation
*	Quality of experience
*	Tolerated noise levels
*	Number of visitors per year who complain about noise caused by motors, other visitors, etc.
*	Perceived and recorded social conflicts and incidents of resource damage
*	Perceived level of solitude reported per day/trip
*	Number of people at one time (PAOT) per acre
*	Percentage of days per season that the level of use exceeds the capacity
*	Average number of visitors per day/trip
*	Average number of encounters per day/trip
*	Density of people 


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Current Use Level/Allocation Information
Adapted from draft text by Bo Shelby and Doug Whittaker

Group Size

Type of trip		Currently allowed	Current average
2 boat commercial motor	36 (44)			22 (26)
1 boat commercial motor	36 (44)			15 (17)
commercial oar		36 (44)			18 (23)
non-commercial		16			15

	In recent years about 50 out of 500 total commercial motor trips have had 31 or more passengers, while about 150 have had 25 to 30 passengers. Nearly all oar trips have less than 25 passengers. 

Trip Length

Season			Allowed		Average
Summer (May  Aug)		
 Commercial motor	18		7
 Commercial oar		18		14
 Non-commercial		18		17
Fall non-motor 		21		19
Winter 			30		26
Spring 			21		20


Social impact standards

Summer (May  Aug)
Impact						Current typical range
average river encounters per day		3 to 6
average time in sight (min) per day		20 to 40
Number of people seen at top 5 attraction sites	35 to 50
% of other attraction sites with encounters 	35 to 45
% of nights in sight or sound			10 to 20


Shoulder seasons (Mar-April & Sept-Oct) 
Impact						Current typical range
average river encounters per trip		2 to 4
average time in sight (min) per day		15 to 30
Number of people seen at top 5 attraction sites	15 to 35
% of other attraction sites with encounters 	15 to 35
% of nights in sight or sound			10 to 15

 
Winter (Nov  Feb)
Impact						Current typical range
average river encounters per trip		1 to 2
average time in sight (min) per day		5 to 20
Number of people seen at top 5 attraction sites	0 to 20
% of other attraction sites with encounters 	< 5
% of nights camping in sight or sound		< 10

Type of trip		High		Average
commercial motor	5 to 6		3.5
commercial oar		1 to 2		1.0
non-commercial		1 (or 2)	1.1
total			7 to 8		5.6


Peak summer daily launches
Type of trip		High		Average
commercial motor	5 to 6		3.5
commercial oar		1 to 2		1.0
non-commercial		1 (or 2)	1.1
total			7 to 8		5.6


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Summary
Public Scoping Issue Analysis
Grand Canyon National Park
Colorado River Management Plan and
Environmental Impact Statement


Prepared for 
Grand Canyon National Park
Grand Canyon, Arizona

By
SWCA Environmental Consultants
June 2003


Public Scoping Issue Analysis Summary
Grand Canyon National Park
Colorado River Management Plan and
Environmental Impact Statement
June 2003


INTRODUCTION

On June 13, 2002, the National Park Service (NPS) issued a Notice of Intent (NOI) in the Federal Register for the preparation of an Environmental Impact Statement (EIS) for the Colorado River Management Plan (CRMP).  As stated in the NOI, The purpose of this EIS/CRMP is to update management guidelines for the Colorado River corridor through Grand Canyon National Park.  During a public scoping period from June 13 to November 1, 2002, the NPS sought public input to reaffirm previously identified agency and public issues and to identify any new public issues and concerns.  Previously identified agency and public issues were compiled in the Summary of Public Comment from the 1997 Colorado River Management Plan Scoping Process, April 1998, which is posted on Grand Canyon National Parks (GRCAs) CRMP Internet site (www.nps.gov/grca/crmp).  Information about the 2002 scoping process was disseminated to the public, and input was solicited, through GRCAs CRMP Internet site, press releases, mailings, and public meetings.

Public Scoping

Scoping is required for National Environmental Policy Act (NEPA) compliance documents, including EISs, to determine the scope of the document; that is, what will be covered and in what detail.  The scoping process must be open to the public; state, local, and tribal governments; and affected federal agencies.  The objectives of scoping are: 

 Involve as many interested parties as possible in the environmental review process.
 Provide clear, easily understood, factual information to potentially affected parties.
 Provide meaningful and timely opportunities for public input.
 Identify, consider, and evaluate significant issues raised by interested parties to assist in the preparation of the Grand Canyon CRMP/EIS.
 Identify and eliminate from detailed study the issues that are not significant.
 Consider public comments throughout the decision-making and review process.

Public Meetings

As part of the 2002 scoping process for the CRMP/EIS, GRCA retained a consultant, The Mary Orton Company, to help organize and manage a series of public meetings.  More than 1,000 people attended a total of eight such meetings, which were held on the dates and in the communities listed below.  

August 1, 2002	Denver, Colorado 
August 6, 2002	Sandy, Utah (suburb of Salt Lake City)
August 8, 2002	Flagstaff, Arizona
August 13, 2002	Las Vegas, Nevada
August 15, 2002	Mesa, Arizona (suburb of Phoenix)
September 3, 2002	Peach Springs, Arizona
September 30, 2002	Towson, Maryland (suburb of Baltimore)
October 2, 2002	Oakland, California

The meetings were structured as open houses.  Information about the CRMP/EIS process was presented through posters, handouts, and a large map of the project area.  National Park Service personnel were available to answer questions, and rooms were provided for facilitator-led discussion groups.  Attendees were invited to write comments on flipchart tearsheets and the map, provide comments orally to a court reporter, and submit written comments.  A form and a permit-related questionnaire were provided for that purpose.  Comments made during the discussion groups were recorded by the facilitators on flipchart tearsheets. 

PUBLIC INPUT TO THE GRAND CANYON CRMP/EIS PROCESS

Written public comments were submitted to GRCA by e-mail, U.S. mail, and hand delivery, as well as at the open house meetings.  Organization and analysis of the submissions were completed with the assistance of SWCA Environmental Consultants, a firm retained by GRCA to help develop the EIS.  The submissions were organized into ten categories to facilitate handling, analysis, and archival storage.  These categories are listed below.  

Letter (L)
Form Letter (FL)
E-Mail (E)
Form (F)
Permit Questionnaire (P)
Boaters Questionnaire (B)
Open House Flipchart Tearsheets (T)
Discussion Group Flipchart Tearsheets (D)
Map (M)
Recorded Transcript (R)

In all, 13,770 submissions were received, cataloged, and reviewed.

REVIEW AND EVALUATION OF SCOPING COMMENTS

Members of the CRMP/EIS team read through every submission.  They identified specific comments within each submission and coded them according to criteria developed for the process.  When the initial review process was completed, a total of 55,165 comments were identified within the 13,770 submissions.  Comments were screened again to summarize observations, opinions, concerns, and recommendations.  This process resulted in the summary table of comments appended to this document.  Almost every major comment received in 1997 (see Summary of Public Comment from the 1997 Colorado River Management Plan Scoping Process, April 1998) was reiterated in 2002, plus several more.  Given the number of comments received in 2002 (over 55,000), the variations in detail are boundless.  The major issues stand out, however, and are consistent with those raised in 1997.  They are encapsulated in the statements provided below.  Many very detailed proposals and discussions were received, several greater than 50 pages.  It was not possible to adequately summarize every specific suggestion offered in some of those longer submissions; however, they have been and will continue to be carefully considered in developing the plan and EIS.

Major Issues Raised in the 2002 Scoping Comments

Access and Visitor Services
 The NPS should not implement any management action that would reduce opportunities for the public to experience a Grand Canyon river trip.  A wide range of river running opportunities should be provided (including educational trips) for people with different skill levels, time constraints, levels of income, physical needs, and for those who desire different kinds of experiences.
 The NPS should provide more equitable access for different kinds of river use (see issues related to allocation, permits, and level of use).
 Repeat use should not be limited for non-commercial trips.  Experience is gained through repeat use, and having experienced users on trips adds to safety and enhances the experience.  
 Non-commercial trips should be allowed to use paid guides and/or rental services.
 Non-commercial trips should not be allowed to use paid guides and/or rental services.
 Infrastructure should be improved, both physical facilities on the river and technological communications with the public (web communication with users, e.g., calendar of launches, research results).  The ramp at Lees Ferry should be improved; facilities at Phantom Ranch should be increased; facilities like Phantom Ranch should be added at other locations (but kept unobtrusive); a channel should be dredged in Lower Granite Gorge to restore more natural river flow.
 Additional riverside facilities should not be permitted.

Motors and Aircraft Use 
 Use of motorized craft should be reduced or eliminated because it is incompatible with the wild, backcountry character of the river.  Motorized craft disturb natural quiet, impair air quality, and/or detract from the quality of what should be a primitive recreational experience.  The non-motorized season should be extended and/or redefined (several suggestions).  Quieter motor technology should be encouraged or required.  Personal watercraft (jet skis) should not be allowed upstream of the Grand Wash Cliffs. 
 Use of motorized craft should not be reduced or eliminated because it allows access for the maximum number of people, including 1) special populations (e.g., disabled, elderly, physically unfit), 2) people too inexperienced to mount a private trip, and 3) people who cannot afford the time or cost of a non-motorized trip.  Motors allow convenient short trips and reduce congestion on the river.  Current motor technology is quiet, does not contribute to noise or air pollution, and does not detract from visitor enjoyment.  
 Helicopters (including helicopter exchanges at Whitmore) should be eliminated from within Grand Canyon except for emergencies.  They are incompatible with the wild, backcountry character of Grand Canyon, disturb natural quiet, impair air quality, and detract from the quality of the recreational experience.  They introduce mechanized, frenetic, stress-inducing activity, which many people take Colorado River trips to avoid.  Helicopter exchanges allow short, hurried trips that are inappropriate for Grand Canyon.  
 Helicopter exchanges should not be eliminated because they increase access (particularly for special populations) by providing shorter trips and a way to get in and out of the Canyon without having to hike, ride a mule, or traverse long, primitive roads (especially onerous during hot months).  Reintroducing mules at Whitmore would cause different environmental impacts, including odor and flies.  Helicopter use provides essential income for the Hualapai Tribe, and its elimination without commensurate compensation would result in undue economic impact on the Tribe. 


Allocation and the Non-Commercial Permit System
 The current allocation between commercial and non-commercial use is unfair and should be made equitable (a 50/50 split was commonly recommended), or non-commercial use should have the larger allocation.  The long wait by non-commercial users and limitations on repeat use cannot be justified while commercial passengers can go on short notice and as often as they want.  It is also unfair that guides are not counted in the commercial allocation.  Suggestions for remedy include increasing the non-commercial allocation by decreasing commercial use (various levels recommended) or by increasing overall use (various levels recommended).  Guides should be included in the commercial allocation.
 The current allocation is appropriate and should be maintained, or commercial use should have an even larger allocation.  Compared to non-commercial use, outfitters serve far more potential users, allow greater public access, offer more and better services (e.g., expertise, safety, education), and provide better stewardship of the Canyon and its resources.  Commercial guides act as an enforcement arm for the NPS, while non-commercial users are less likely to obey the rules.  Respondents taking this position often recommend that non-commercial use should be further restricted, eliminated, or better regulated by the NPS.  Non-commercial permit holders should meet certain minimum qualifications (e.g., previous rafting experience, knowledge of Grand Canyon, demonstrated knowledge of regulations).
 Commercial use should be reduced, eliminated, or better regulated (especially fees charged customers) because it exploits the Canyon for profit, inappropriately dominating use of a public asset to financially benefit a handful of private companies.  Small companies should replace large ones; outfitters should be phased out as their contracts expire or they sell; Incidental Business Permits should be allowed to supplement or replace the current concession system. 
 Allocation between commercial and non-commercial use should be abandoned in favor of a common pool system so that all interested people have an equal chance to run the river, whether they want the assistance of an outfitter or not.  Several suggestions were offered about how to implement such a system.  
 A common pool system should not be implemented because it would be unmanageable for commercial outfitters, preventing them from providing essential services.  Under a common pool system, applicants who want a commercial trip might swamp non-commercial applicants, further reducing their ability to get on the river.
 The current non-commercial permit system is unfair, cumbersome, costly, and subject to many kinds of abuses.  The waiting list is far too long and should be reduced or eliminated.  Those currently on the list, especially those who have already waited many years, should not be penalized if the system is changed.  Many suggestions, some very detailed, were offered for revamping the current system to eliminate or reduce these problems.  
 The permit system should be replaced by a lottery or reservation system.  Several variations were offered, including weighted lottery or reservation systems and hybrid systems incorporating elements from the existing system.  
 A lottery should not be instituted because some people would never win a permit.  

Level of Use/Crowding, Trip Length, Group Size
 Overall use should be increased to provide more access, particularly for non-commercial users.  Crowding can be avoided by extending the primary season into spring and fall; increasing winter use; evening out launches over the week, season, or year; or by scheduling use of campsites and attraction sites.  
 Existing use levels should not be increased because crowding and impacts on the environment would be a problem.  Scheduling use of campsites and attraction sites should be avoided because it would be unworkable and would detract from the spontaneity of a backcountry river experience.  Also, use levels should be decreased to reduce excessive crowding and/or impact on cultural and natural resources. 
 Trip length maximums should be decreased to allow more access for others.  
 Trip length maximums should be increased to provide opportunities for a richer experience (e.g., slower pace, more hiking).  Trip length minimums should be increased to preclude quick, hurried trips, particularly above Diamond Creek.
 Group size maximum should be decreased to provide a truer backcountry experience, increase opportunities for solitude, reduce noise and social interactions, reduce crowding, and reduce impact on resources.  
 The group size maximum is fine or should be increased to increase access opportunities. 

Resource Protection, Tribal Issues, NPS Regulations
 Protection of natural and cultural resources should be the NPSs first priority.  The NPS should use an adaptive management approach, improve monitoring, and increase/facilitate research activities to better conserve and restore natural conditions.  
 NPS should eliminate adaptive management, reduce the number of research trips, and place more restrictions on research activities (e.g., who can participate, when they can launch, type of craft used, where they can camp).  
 Natural resource concerns expressed in comments include protection of wildlife, preservation/restoration of endangered or rare native species (notably native fish), reintroduction of extirpated native species, and eradication of non-native species (notably tamarisk).  Excessive social trailing is a problem; trails should be established and maintained where erosion, trampling, and multiple trails are evident.  Loss of camping beaches should be addressed through Glen Canyon Dam operations, artificial infusion of sand below the dam, and/or by removal of invasive vegetation.  Impacts on air and water quality due to motor use should be addressed.
 Non-native trout should be conserved for angling opportunities.  Trails should not be established and maintained; the NPS should use a minimum tool philosophy, keeping management intervention to a minimum.  Use of herbicides to reduce invasive vegetation should be reconsidered. 
 Specific cultural resource concerns include damage to archaeological sites, with suggestions for restricting access to some sites.  
 Access to archaeological sites should not be restricted.
 Access to Native American sacred sites should be prohibited and access to adjacent tribal lands restricted to specified areas under specified conditions.  The NPS should better enforce these regulations and should coordinate and collaborate with tribes to manage river use; support tribal needs (particularly at the Diamond Creek take-out); provide more opportunities for tribal participation in river use upstream of Diamond Creek; and generally respect tribal sovereignty.  Tribal use of the Grand Canyon should be held to the same standard as non-tribal use.
 NPS personnel should step up enforcement, increase river patrols, restrict alcohol use, extend drug testing, and prohibit nudity to better protect the environment, increase safety, and reduce unruly behavior that detracts from the quality of the river experience for others.  They should provide more information about regulations, proper river etiquette, and the Canyon (geology/ biology/history) before launch, at launch, and on-river (e.g., join all trips or visit camps more often).  They should make better use of the Internet, particularly in regard to launch schedules, research activity, and permit cancellations.  
 The NPS should reduce their presence on the river, be less confrontational, never visit camps, and never carry firearms.  NPS should eliminate drug testing for commercial guides.

SCOPE OF THE CRMP/EIS 
The purpose of the CRMP is to provide direction for resource preservation and visitor experience as they relate to visitor use of the Colorado River corridor.  According to the Notice of Intent published in the Federal Register on June 13, 2002, the CRMP/EIS will include, but not be limited to:
 appropriate levels of visitor use consistent with natural and cultural resource protection and preservation mandates;
 allocation of use between commercial and non-commercial groups;
 the permitting system for non-commercial users;
 the level of motorized versus non-motorized raft use; 
 the range of services and opportunities provided to the public; and
 the continued use of helicopters to transport river passengers to and from the Colorado River near Whitmore Wash (in consultation with the Hualapai Tribe and other appropriate parties).

Issues Raised in Public Scoping Determined to Fall Outside the Scope of the CRMP/EIS 
Some issues that were raised during public scoping are outside the scope of the CRMP/EIS because 1) they do not directly address management of visitor use; 2) they are the subject of separate planning processes; and/or 3) they are beyond GRCAs management authority.  Comments included in this group include positions both for and against the following:
 Decommissioning or regulating Glen Canyon Dam.
 Designating the river corridor as a Wilderness and/or as a Wild and Scenic River.
 Eliminating overflights.
Park boundary issues also fall within this group.

Another set of issues raised by the public are outside the scope of the CRMP/EIS process because they concern activities that are administrative in nature.  These comments include the following:
 A specific allocation should be established for GRCA administrative use, and that allocation should be included in a total user-day cap.  This suggestion is considered out of scope because management-related administrative use enables GRCA personnel to fulfill their mandated responsibilities. The level and timing of NPS presence on the River, therefore, must remain flexible.  GRCA will continue to permit administrative activities based on resource protection, safety, and information needs with appropriate restrictions and an approval process.  Uses such as education, however, are subject to consideration in the CRMP/EIS.
 Several comments address detailed operating requirements for both commercial and non-commercial use.  Included in this category are specific suggestions for managing repeat use, private trip cancellations, launch schedules, sanitary waste disposal, fee structures, etc.  These comments are outside the scope of the CRMP/EIS because they concern specific measures that may be subject to change based upon new information or improved practices.  As such, they more properly relate to operating requirements, which are detailed instructions implementing CRMP guidance.  Operating requirements may be changed administratively as long as they are consistent with CRMP guidelines.  In contrast,  the CRMP is intended to provide overall guidance for the management of recreational use of the Colorado River corridor in the Park.  Changes to the CRMP would require a NEPA document and a major planning effort. 

Lastly, elimination of both commercial and private river uses of the river was recommended during public scoping.  Neither suggestion will be considered in the CRMP/EIS because GRCA has determined that some level of commercial and private river operations are necessary and appropriate to meet GRCA General Management Plan goals. 


Summary of the 2002 Public Scoping Comments

ACCESS
 A broad cross section of the population should have access to the river.  Access should not be limited any more than necessary to protect resources.
 Increase access for special populations (disabled, elderly, juveniles, low-income).
 Ensure access for Native Americans with a traditional affiliation with Grand Canyon.
 Prioritize or restrict access to protect resources.
 Allow access only for U.S. citizens.
 Repeat use should be restricted because demand exceeds supply.  Multiple suggestions were offered for restrictions (number of trips per time unit).  
 Restrictions on repeat use should be equitable for both non-commercial and commercial users.
 Repeat use should not be limited.

ADMINISTRATIVE USE & NPS MANAGEMENT
 Current river management is satisfactory.
 The Park should receive more funding to better manage recreation and resources.
 NPS should base management decisions on scientific research (e.g., evaluate motor-use impacts on resources, conduct carrying capacity study).
 NPS should use minimum tool criteria when managing the river.
 River and backcountry management should be coordinated to prevent campsite conflicts between river runners and hikers.
 NPS patrols for conformance to regulations should remain the same or be increased; more effort should be made to enforce regulations.
 NPS patrols negatively affect visitor experience; should be reduced; should be eliminated.
 Administrative use trips (including educational trips) should be counted within overall use limits and the schedule of trips made public.  Such trips should have specific allocations.
 Non-working NPS staff and non-researchers on NPS/research trips and educational trips under the guise of administrative use are an abuse; they should use outfitters.
 Expand drug testing among all river users.
 Eliminate drug testing for commercial guides.
 Restrict and/or prohibit alcohol use, smoking, and nudity.   Rowdy behavior is offensive to other river users and impairs their river experience.
 Non-commercial use should be better regulated (e.g., more stringent qualifications, including licensing of trip leaders; more in-depth orientation for trip participants).
 Required qualifications for commercial guides should be increased.
 Some outfitters abuse their privilege by charging excessive rates, making excessive profits, and providing luxurious services inappropriate for a backcountry experience.
 NPS should increase activities to instruct all users about Canyon resource protection, river etiquette, and regulations (e.g., more guide training, better orientation at Lees Ferry, more camp talks, accompany trips).
 NPS should offer a wider variety of educational opportunities to river users (e.g. signage, interpreters, website).

ALLOCATION
 Base allocation on demand; conduct a demand study.
 Maintain current commercial/non-commercial allocation.  It works well; reflects relative demand. 
 Make the commercial and non-commercial allocations equitable (suggestions: 50/50 split; 40/40 split with 20% administrative use).  Current allocation is unfair to non-commercial users, forcing applicants to wait many years while all commercial users have a short wait.  Current allocation does not reflect large and growing demand by those who most value river running (devote the most time, effort, and resources to it).
 Give larger allocation to non-commercial use than to commercial use (various percentages suggested).  
 Increase non-commercial allocation but do not decrease commercial user days (i.e., increase total user days).
 Increase non-commercial allocation by decreasing commercial user days.  Some suggested eliminating commercial use altogether (various phase-out, buy-out options suggested) because it is inappropriate exploitation of a public resource for the financial benefit of a few entrepreneurs.
 Reallocate commercial motorized use to non-commercial, non-motorized use.

ALLOCATION (CONT.)
 Increase commercial allocation. Outfitters provide more access and services (see also Visitor Services section) for the general public.  Some suggested decreasing or eliminating non-commercial use altogether, primarily because private parties are less likely to care for the environment, abide by regulations, or cooperate with other river users.
 Transfer some commercial user days to educational uses.
 Commercial crews should be counted within the commercial allocation.
 Ensure that all unused user days are reallocated within the same sector or to the other sector.
 Eliminate allocations; replace with a common pool system.  Multiple suggestions were offered for how to implement such a system.
 Do not consider a common pool (e.g., would group strangers on a private trip, make planning difficult for commercial outfitters currently doing business in the Canyon, commercial market would swamp pool further reducing non-commercial access).

COST
 Commercial trips should include more affordable options; high costs limit access to the wealthy.
 Commercial rates are not excessive; they do not limit access.
 Maintain current non-commercial fee structure.  It works well.
 The current non-commercial fee system is unfair, unaccountable, and confusing and should be changed (multiple suggestions offered).
 Non-commercial fees are too high and should be decreased.
 Non-commercial and commercial fees should be equivalent.
 Increase current non-commercial fees to discourage non-serious applicants and reduce wait list.
 Change or eliminate the Colorado River Fund; the fee demo.
 Park needs to be more accountable for what is done with fee income.  Multiple suggestions were offered for how it should be spent, including subsidies for special populations, research, recovery of native species, Park maintenance, more NPS presence on river, buy-out of outfitters for reallocation to non-commercial use.

LEVEL OF USE 
 Instead of user days, manage use by launches and/or number of people.
 Continue user days system to measure and limit use.
 Maintain the current level of use.  There are no apparent negative impacts.
 Reduce the current level of use to reduce negative impacts.
 Eliminate all use until native habitats can be restored.
 Increase the current level of use to allow greater access (particularly for non-commercial use); confine increase to the secondary season; consider making the river corridor a high use zone.
 Do not increase the current level if it will degrade resources and quality of visitor experience. 
 Mitigate impacts rather than restrict use.
 Reassess the rivers carrying capacity (crowding, impacts to resources).
 Crowding is a problem, especially at attraction sites; multiple suggestions were offered for how to reduce crowding and encounters with others using trip scheduling, trip length, levels of use, launch dates. 
 Crowding is not a problem; crowding at attraction sites is not a problem.
 Fewer and smaller beaches reduce carrying capacity, increase crowding; increase the number and size of beaches to increase access.

MOTORS
 Allow motor use to continue at existing levels or increase.  Motorized trips allow more people to experience the river because of shorter trips and larger group sizes, allow access for a broader cross-section of the population (e.g. disabled, elderly, juveniles), reduce crowding by allowing faster trips and varying speed, reduce contact time with other groups, and afford a higher level of safety to all river users.
 Motorized trips result in an acceptable level of environmental impact; noise levels are low because of 4-stroke motors; air pollution is not a problem. 
 Eliminating motors would increase hiking and associated problems.
 Eliminate/phase out or reduce motor use.  It produces air, noise, and water pollution and promotes fast, hurried trips, violating the natural sound, pace, and tranquility that should characterize a river experience.  Motors are incompatible with wilderness.
 Motorized trips negatively affect non-motorized trips.
 All non-commercial trips should be non-motorized.
 Extend and/or reschedule the no-motor period (multiple suggestions for duration and timing).
 Ensure quiet or non-polluting motor technology; offer incentives (user days, fee reduction) to commercial operators who incorporate low-noise/pollution motor technology.
 Environmental effects of motors cannot be mitigated through technology.
 No personal watercraft (jet skis) should be allowed upstream of Grand Wash Cliffs.

AIRCRAFT
 Keep helicopter exchanges. They increase access by allowing less expensive, more convenient shorter trips; allow access for those who cannot, should not, or who would rather not hike; add another adventurous element to the river experience; eliminate long, hot, dusty rides over primitive roads; permit quick trips between airports and the Canyon.
 Helicopter exchanges at Whitmore reduce the load on take-out facilities at Diamond Creek and provide essential income for the Hualapai Tribe.
 Helicopter exchanges do not impact the wilderness experience.  They are confined to a small area and operate for only short periods and at times when few other trips are in the vicinity. 
 Decrease or eliminate helicopter use except for emergencies.  Helicopters are highly intrusive on the natural quiet and splendor of the Grand Canyon backcountry.  They introduce the noisy, mechanized, rushed attributes of the urban world that people come to the Inner Canyon to avoid.  They detract from the quality of the river experience for others.  
 Ending a river trip by a helicopter fly-out is abrupt, shocking, and inappropriate.
 Helicopter exchanges exist mainly to financially benefit outfitters by breaking up what should be single trips into multiple short trips that are profitable and easy to market.    
 Substitute less intrusive modes of transport at Whitmore (e.g., mules/hiking/ airship).
 Mules should not be used at Whitmore; they create unsanitary conditions, foul odors, and flies. The trail is too difficult and hot in the summer to be hiked safely.  The road from the trailhead is long, rough, and hard on vehicles and passengers.
 Require quieter helicopters.
 The heavy use of helicopters below Diamond Creek is inappropriate and offensive.

NEPA / PLANNING PROCESS
 The CRMP should be based on ecosystem management.
 The CRMP should incorporate adaptive management to allow future flexibility; provide for an ongoing advisory committee (e.g., similar to the AMWG); provide for frequent review and adjustment of Plan.
 The scope of the CRMP should include tributaries.
 Increase public participation in the CRMP/EIS process beyond the local region; include stakeholders in planning; make relevant scientific information available to public.
 Open house forum at public scoping meeting was an improvement over past public scoping methods.  Open house was enjoyable.

PERMITS 
 Maintain the current permit system; it is adequate.
 The current permit process is discouraging, complicated, inequitable, and the waiting time is far too long.
 The current permit system is rife with abuse (e.g., a small number of people take advantage of the system to make frequent repeat trips; some names are just placeholders, cancellations are excessive).
 The permit system should be simplified and made fair/equitable.  Multiple, detailed suggestions were offered for modifying the current permit system (e.g., make permits transferable, allow more repeat use, provide more equal access among all non-commercial users, institute comparable wait times for commercial and non-commercial users).
 The waiting list should be made shorter (multiple suggestions offered).
 Transition to a different system other than the wait list should give priority to those already on the wait list.
 Replace the existing permit system with an auction.
 Replace the existing permit system with a lottery (multiple variations suggested).
 Do not consider a lottery (some people will never win a trip).
 Institute a reservation-based system (multiple variations suggested).
 Institute a hybrid permit system (multiple variations suggested).

RESOURCES
 Protection of ecological and cultural resources should be NPSs first management priority.
 Resources should be monitored for impacts.
 NPS should consider closing areas experiencing excessive impacts.
 Noise is a problem (large, motorized rafts; helicopters).
 The impact on air quality by motorized rafts is a problem.
 Social trailing is a problem and should be reduced; NPS should mark and maintain trails.
 NPS should modify terrain (e.g., do trail work) only where habitat preservation is necessary.
 Vegetation should be protected, including in the old high water zone and side canyons.
 Wildlife (e.g., bighorn sheep, condors) should be protected.  River users chasing and catching wildlife is a concern.
 Visitor impacts on beaches are a problem (e.g., litter, urine, erosion).
 Beaches show little evidence of visitor impact.
 Restore beaches by sediment infusion, stabilization, reduction of encroaching vegetation.
 Near-river springs and seeps are valuable resources and should be protected.

RESOURCES (CONT.)
 Tributaries are an exceptional resource, should be managed and protected from visitor impact.  Pollution from chemicals (sunscreen, shampoo, etc.) and human waste may be a problem.
 Visitor use of tributaries may increase native fish food supply by stirring up substrata.
 Protect, restore endangered species, including native fish (e.g., humpback chub, razorback sucker, Colorado pikeminnow).
 Re-introduce extirpated species, such as the otter and muskrat.
 Take management action to eliminate or reduce non-native species (particularly tamarisk); find means other than herbicides to control non-native plants.
 Keep species that have adapted to the dam-altered river (e.g., trout).
 Cultural resources, sacred sites, Indian lands are valuable and should be protected; install unobtrusive signs about site protection.
 Continue to allow public access to cultural resources.
 Close cultural sites if they are being impacted.
 Protect natural visual quality.  Reduce trash; keep Canyon clean.
 Protect water quality.
 Maintain or increase scientific study on the river, increase communication of research results with public; allow increased motor use to facilitate research; simplify research permitting process, use consultants as much as possible.
 Be more stringent in determining which research projects are allowed; reduce the number of research trips; make more use of volunteers in the river running community; require research trips to camp at small campsites.
 Several suggestions were offered for resource research, monitoring, and management (e.g., study impact of group size, increased levels of use).

SCHEDULING
 Use the computer simulator to schedule use.
 Several suggestions were offered for redistributing launches (daily, weekly, seasonally, evenly over a year) to achieve fair scheduling for commercial and non-commercial trips, reduce crowding, allow more trips.
 Use shoulder seasons and/or winter season to increase use (commercial and/or non-commercial) or better manage existing use.
 Do not extend commercial use into winter months.
 Offer incentives for off-season use.
 Assign campsites, assign all or some attraction site stops to reduce crowding and/or increase access; require some shared use of campsites at pinch points.
 Do not assign campsites or attraction site stops.  That would remove spontaneity, reduce the quality of the river experience, and may not be possible to achieve.
 Continue to allow layovers.  They allow a slower-paced trip with more opportunities for solitude, quiet, and a chance to explore more of the Canyon.
 Reduce/eliminate layovers, particularly during the summer and at high-use camps.  That would reduce crowding and conflict between trips.  
 Reduce/eliminate all exchanges.  They increase crowding above Phantom and promote quick, more superficial trips.
 Maintain or increase exchanges to provide a wide range of trip experiences and access for more people.
 Each exchange should be counted as two user days; each exchange should be counted as one user day.

TRIBAL ISSUES
 Respect tribal concerns and authority regarding river management.
 Allow tribes (specifically the Hualapai) to have a concession at Lees Ferry; allow the Hualapai Tribe to operate a concession from Lees Ferry; facilitate hiring of Native American guides; coordinate with tribes for economic development.
 A percentage of fees should go to neighboring tribes to help them accomplish shared tribal/Park objectives.
 Help the Hualapai Tribe with take-out facilities.
 NPS should assist in controlling trespass on tribal land and sacred sites and increase education of river users about tribal authority.
 Maintain income for the Hualapai Tribe by keeping the Whitmore exchange.
 Work with the Hualapai Tribe to preclude helicopter use and up river travel above Diamond Creek.
 Multiple suggestions were offered for improving the Diamond Creek area (e.g., more ramadas, better toilet facilities).
 The Hualapai Tribe should abide by the same standards/regulations as other users; should work with the NPS to avoid uses of tribal land incompatible with national park values; should reduce operations below Diamond Creek to reduce noise and crowding.
 Diamond Creek Road condition and need for more facilities along the road and at Peach Springs.

TRIP LENGTH / GROUP SIZE 
 Do not manage group size and/or trip length.
 Trip lengths should remain unchanged; the system works well as it is.  Various trip lengths should continue to be allowed to provide a variety of experiences.

TRIP LENGTH / GROUP SIZE  (CONT.)
 All trips should be the same length.
 It is important to allow short trips (week or less) for those who are limited by time and/or money.  Shorten trip length by increasing the allowable speed of motorized craft, by allowing and encouraging exchanges. 
 Reduce non-commercial trip length to allow more access for others.  
 Increase the allowable length of trips (commercial and non-commercial) to permit more hiking, a slower pace, a more contemplative experience; reduce the number of short trips.
 Maintain the current maximum commercial and non-commercial group sizes.
 Group size limits should be the same for all users.
 Decrease the maximum commercial and non-commercial group sizes.  Large group sizes and large boats increase a sense of crowding; provide less opportunity for solitude and quiet; require large camping beaches that are limited in number.  Large groups and double camping result in greater resource impacts. 
 Number of boats on large non-motorized trips creates on-river congestion (more difficult to pass) and crowding at attraction sites.
 Increase or maintain opportunities for very small groups to provide a greater range of experiences.
 Eliminate small groups to allow more use.

VISITOR EXPERIENCE
 Thousands of comments were received that described valued attributes of a river trip experience but did not raise issues or concerns.

VISITOR SERVICES
 Provide a wide range of river running opportunities for people with different skill levels, time constraints, levels of income, physical needs, and for those who desire different kinds of experiences.
 Opportunities for river users should include educational trips.
 Allow access and egress at any point for inflatable kayaks.
 Allow commercial operations to continue (at existing level or increase). They permit greater access and provide valuable services (e.g., education, safety for both passengers and non-commercial trips, camp hygiene, stewardship of resources, supervision to constrain behavior, environmental awareness).  They share provisions with non-commercial users and allow repeat use for clients.
 Commercial outfitters run more responsible trips than non-commercial users because of concession contract requirements. Non-commercial users lack supervision and are less safe, clean, protective of resources, considerate of other users, more likely to impact off-river resources from more hiking.
 Commercial trips provide opportunities for shorter trips.
 Commercial and non-commercial passengers need better education about river etiquette. 
 Eliminate or reduce commercial operations. Profit making is inconsistent with national park purposes and values; advertising inflates demand for commercial use.  
 The concessions as currently managed violate NPS policies and mandates (e.g., minimum tool requirement, wilderness management, providing public access at reasonable prices).  NPS should reform the system (e.g., enforce strict adherence to NPS regulations, limit profit, do not give preference to current concession holders when contracts expire, consolidate all companies into one, break up large companies into smaller ones).   NPS should reassess the level of commercial services needed on the river before renewing contracts.
 The ratio of commercial guides to passengers seems right and should remain the same.  The ratio should increase to provide better supervision.
 Non-commercial trips should be allowed to use paid guides and/or rental services.
 Non-commercial trips should not be allowed to use paid guides and/or rental services.
 Permit bonfires below Diamond Creek.
 Do not permit additional riverside facilities.
 Improve infrastructure, both physical facilities on river and technological communications with the public (web communication with users, e.g., calendar of launches, research results); improve ramp at Lees Ferry; increase facilities at Phantom Ranch, including an ice machine and a water line down to the boat beach; add more facilities like Phantom Ranch at other locations but keep them unobtrusive; dredge channel in Lower Granite Gorge to restore more natural river flow.
 Improve human waste disposal procedures and facilities; provide waste disposal at termination points.
 Provide better emergency communications.
 Commercial river running represents a historic use/livelihood that needs to be protected and preserved.  

PUBLIC COMMENT ISSUES OUTSIDE OF SCOPE
Wild and Scenic River Designation
 The river should receive Wild and Scenic River designation.
 Changes to the character of the river corridor and water quality (color and temperature) due to dam operations make the river ineligible for Wild & Scenic designation.

PUBLIC COMMENT ISSUES OUTSIDE OF SCOPE (cont.)
Wilderness
 The river corridor should receive Wilderness designation to protect and enhance its wilderness values.  The NPS should recommend designation as part of the CRMP process (the scope of the CRMP should include Wilderness designation).
 The NPS has been remiss in not following up on the Wilderness proposal before now.
 Designate the river corridor as Wilderness but exclude the Phantom Ranch area; consider removing the structures at Phantom Ranch.
 The river should not receive Wilderness designation.  The corridor is not wilderness because of dam operations and high recreational use.  Wilderness designation would reduce public access.
 If Wilderness is not designated, at least manage the Colorado River as wilderness (allow a wilderness experience).
Glen Canyon Dam
 The scope of the CRMP should include effects of Glen Canyon Dam.
 Glen Canyon Dam should be operated in the most environmentally and recreationally (e.g., minimum safe flows) sensitive manner possible; NPS should have more influence on dam operations.  
 Multiple suggestions were offered for improved operation of Glen Canyon Dam (e.g., lower fluctuations, beach-building flows, drawing warmer water from top of reservoir).
 Dam-caused changes are unnatural and unacceptable (e.g., loss of native fish, loss of wilderness, disruption of sediment flow, loss of camping beaches, cold water temperatures).
 Glen Canyon Dam should be removed to restore the natural river system.
 Glen Canyon Dam should not be removed; preserve species, such as trout, that have taken advantage of the altered river.
Overflights
 Restrict or eliminate overflights.
 Continue overflights.
Miscellaneous
 Comments concerning effects of automobile exhaust and power plant emissions on air quality at Grand Canyon.
 Comments concerning facilities on the South Rim.
 Comments concerning use of mules and conditions on the Bright Angel and Kaibab Trails.
 Comments concerning Diamond Creek Road condition and need for more facilities along the road and at Peach Springs.
 Comments concerning management of Lake Powell and Lake Mead beyond the GRCA boundary. 
 Comments concerning tribal boundaries with the Park.
 Comments on proposed federal actions in other locations.


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Colorado River Management Plan
Handout for Expert Panels, January 29 and 31, 2003
And Stakeholder Workshop, June 24  25, 2003

Summary of the Existing Recreational Systems: Allocation and Use Limitation
Information from the 1989 Colorado River Management Plan (CRMP)

User Day Allocations
One user day equals one person on the river for any portion of one day. The Park currently allows .5 user day assessments for exchanges. No user days are assessed for the reach below Diamond Creek. Note that the seasons are defined differently for the two use sectors.

Commercial Sector:
	Primary Season (May 1  Sept 30)			106,156
	Secondary Season (Oct 1  April 30)			9,344
				Subtotal			115,500 (68%)
Noncommercial Sector:
	Primary Season (April 16  Oct 15)			43,920
	Secondary Season (Oct 16  April 15)			10,530
				Subtotal			54,450 (32%)
Total Recreational User Days					169,950 (100%)

Maximum Group Size
	Commercial passengers:		36
	Noncommercial trip participants:	16

Maximum Trip Length 
Trip Length between Lees Ferry and Diamond Creek for both use sectors:
	April 16  October 15			18 days
	October 16  November 30		21 days
	December 1  February 29		30 days
	March 1  April 15			21 days

Non-motorized Use Season
Motorized trips may not launch from September 16  December 15.

Non-recreational Use
Administrative Use
*	Administrative user days are not currently part of an allocation system. 
*	Administrative use includes research, NPS patrols and resource management, and partnership/educational trips. 
*	For 1998-2001, administrative use averaged 10,000 user days annually.

Commercial Crew/Guide Use:
*	User days are not allocated, but are regulated for trip type and crew/passenger ratio.
*	For 1998-2001, crew use averaged 28,000 user days annually.
 
Seasonality
Temporal Recreation Opportunity Spectrum (ROS)  1989 CRMP 
*	Primary Season  High Density Use Period (June 1  August 15)
*	Primary Season  Shoulder Seasons (May 1  30, August 15  September 30)
*	Secondary Season  Low Use Period (October 1  April 30)


			People/day	People/week	Launches/day	Launches/week
	
High			166*		1000* 		3-8 		35-42 
	commercial	150* 		800+	 	2-6	 	30-35
	noncommercial	16*		100+	 	1-2*	 	7-8
Shoulder 		166* 		700* 		3-6 		20-35 
	commercial	150*	 	600+	 	1-5	 	12-28
	noncommercial	 16*		100+	 	1-2*	 	7-9
Low 			52* 		332* 		2* 		12* 
	commercial	36*		140+	 	1*	 	5-7
	noncommercial	16*		100+	 	1*	 	5-7


Notes:
*	All numbers with an asterisk (*) indicate a prescription from the 1989 CRMP.
*	Note that the daily launch limit units differ for use sectors. So, for the high season: 
	*	The commercial sector limit is 150 passengers/day 
	*	The noncommercial sector limit is one launch/day + one additional launch/week
*	The low use season allows up to 12 trips per week with no more that two trips per day, one commercial and one noncommercial.
*	All launches are dependent upon available user days/season/sector.


Selected actual use statistics
Calendar Year 2001: Recreational Launches
		Commercial	Noncommercial	Total
May		126		35		161
June		147		33		180
July		138		34		172
August		118		32		150
September	66		24		90
 Subtotal	595		158		753
October		15		19		34
November	0		12		12
December	0		10		10
January		0		7		7
February	0		8		8
March		2		12		14
April		23		28		51
 Subtotal	40		96		136
 TOTAL	635		254		889


Calendar Year 2001: Motorized and Non-Motorized Recreational Use
		Trips				People				User Days
		Motor		Non		Motor		Non		Motor		Non
Commercial	470 (77%)	165 (26%)	14,406 (77%)	4,215 (23%)	74,445 (66%)	38,678 (34%)
Noncommercial	19 (7%)		235 (93%)	n/a		n/a		n/a		n/a


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Guiding Principles for the Colorado River Management Plan

1.	The CRMP will address resource management and visitor experience along the Colorado River corridor in Grand Canyon National Park within the framework of current NPS laws and directives.
2.	Until the Administration and Congress act on the Grand Canyon National Park Wilderness Recommendation, this section of the Colorado River will be managed as potential Wilderness according to NPS Management Policies and the Grand Canyon National Park Wilderness Recommendation as updated in 1993.
3.	The NPS will include and consult with Native American tribes in the planning process.
4.	River use will be regulated to ensure that the level and types of use is sustainable and that resource impacts are within acceptable limits for long-term resource preservation.
5.	Methods to manage and distribute use along the river will be based on meeting objectives for resource protection and visitor experience.
6.	Public access to river recreation opportunities (use allocation and permitting processes) will be evaluated based on current and desired future conditions.
7.	The spectrum of desired opportunities will be evaluated and implemented through future river-outfitter contracts and river use permits.
8.	The NPS will seek to reduce noise that detracts from Grand Canyon's natural quiet.
9.	The NPS will seek to minimize the impacts of administrative use.


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Information on Alternatives Development 
for an Environmental Impact Statement
Source:  Council on Environmental Quality
http://ceq.eh.doe.gov/nepa/regs/40/1-10.htm

1a. Range of Alternatives. What is meant by "range of alternatives" as referred to in Sec. 1505.1(e)? 
A. The phrase "range of alternatives" refers to the alternatives discussed in environmental documents. It includes all reasonable alternatives, which must be rigorously explored and objectively evaluated, as well as those other alternatives, which are eliminated from detailed study with a brief discussion of the reasons for eliminating them. Section 1502.14. A decisionmaker must not consider alternatives beyond the range of alternatives discussed in the relevant environmental documents. Moreover, a decisionmaker must, in fact, consider all the alternatives discussed in an EIS. Section 1505.1(e). 

1b. How many alternatives have to be discussed when there is an infinite number of possible alternatives? 
A. For some proposals there may exist a very large or even an infinite number of possible reasonable alternatives. For example, a proposal to designate wilderness areas within a National Forest could be said to involve an infinite number of alternatives from 0 to 100 percent of the forest. When there are potentially a very large number of alternatives, only a reasonable number of examples, covering the full spectrum of alternatives, must be analyzed and compared in the EIS. An appropriate series of alternatives might include dedicating 0, 10, 30, 50, 70, 90, or 100 percent of the Forest to wilderness. What constitutes a reasonable range of alternatives depends on the nature of the proposal and the facts in each case. 

2a. Alternatives Outside the Capability of Applicant or Jurisdiction of Agency. If an EIS is prepared in connection with an application for a permit or other federal approval, must the EIS rigorously analyze and discuss alternatives that are outside the capability of the applicant or can it be limited to reasonable alternatives that can be carried out by the applicant? 
A. Section 1502.14 requires the EIS to examine all reasonable alternatives to the proposal. In determining the scope of alternatives to be considered, the emphasis is on what is "reasonable" rather than on whether the proponent or applicant likes or is itself capable of carrying out a particular alternative. Reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the applicant. 

2b. Must the EIS analyze alternatives outside the jurisdiction or capability of the agency or beyond what Congress has authorized? 
A. An alternative that is outside the legal jurisdiction of the lead agency must still be analyzed in the EIS if it is reasonable. A potential conflict with local or federal law does not necessarily render an alternative unreasonable, although such conflicts must be considered. Section 1506.2(d). Alternatives that are outside the scope of what Congress has approved or funded must still be evaluated in the EIS if they are reasonable, because the EIS may serve as the basis for modifying the Congressional approval or funding in light of NEPA's goals and policies. Section 1500.1(a). 


More information on the National Environmental Policy Act and its regulations can be found at http://ceq.eh.doe.gov/nepa/nepanet.htm.


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ISSUES TO BE ADDRESSED IN FUTURE PLANS OR PROCESSES

We understand there are many issues related to Grand Canyon National Park, and we want to hear your concerns and opinions about these issues. However, the scope of this particular EIS concentrates on visitor use issues and the associated impacts to natural and cultural resources, and we must maintain that focus to achieve our required timeframes. The following issues, while influential and related to the CRMP, are considered to be outside the scope of this EIS. These are being addressed or will be addressed through alternate plans or processes.

 Glen Canyon Dam operations
The CRMP/EIS is expected to reveal relationships between recreation goals and dam operations that may have implications for dam releases. We would submit any recommendations about dam operations to the Adaptive Management Workgroup for their consideration.

 Commercial Overflights
The CRMP/EIS will not propose changes to aircraft routes over the river corridor. This will be addressed in a separate planning effort. Our plan will define resource conditions and desired visitor experiences along the river corridor, and where noise impacts are stated, that input can be forwarded to the subsequent planning effort. This CRMP/EIS will address the Whitmore Wash Helicopter-landing issue (in cooperation with the Hualapai Tribe) because it directly affects the river.

 Wild and Scenic River Designation
Although there is some overlap between the scope of a wild and scenic river study and this CRMP/EIS, there are many key issues within the Plan that are well outside the scope of a wild and scenic river study. Therefore, the EIS will not directly focus on the designation issue. The CRMP/EIS will provide information and management direction that can contribute to a future wild and scenic river suitability study.

 Wilderness Designation
Decisions made through the CRMP/EIS may influence future wilderness status for the Colorado River, however this process does not presume reconsideration of the wilderness proposal for the entire park. This EIS will evaluate a reasonable range of alternatives, including a "no motors" alternative.

 Backcountry Operations
This EIS will not evaluate alternatives for resource protection or visitor use alternatives for the entire Grand Canyon backcountry. Management of the backcountry wilderness will be addressed in a separate process to be initiated in 2005.

 Allocation of Administrative Use
The NPS will continue to permit administrative activities (i.e. research) based on resource protection, visitor safety and science needs. The amount and level of administrative use will be included when evaluating the human use impact to resource conditions.


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Grand Canyon National Park
Purpose, Vision, and Management Objectives

Source:  Grand Canyon National Park General Management Plan

Park Purpose
The purpose of Grand Canyon National Park is based on the legislation establishing the park and the legislation governing the National Park Service.

As a place of national and global importance, Grand Canyon National Park is to be managed to
*	preserve and protect its natural and cultural resources and ecological processes, as well as its scenic, aesthetic, and scientific values
*	provide opportunities for visitors to experience and understand the environmental interrelationships, resources, and values of the Grand Canyon without impairing the resources

Vision:  Undeveloped Areas
Over 90% of the park is proposed for wilderness. These areas offer visitors opportunities for solitude and primitive recreation. The management of these areas should preserve the wilderness values and character. Nonwilderness undeveloped areas should continue to serve primarily as primitive thresholds to wilderness.

Visitors traveling through the canyon on the Colorado River should have the opportunity for a variety of personal outdoor experiences, ranging from solitary to social. Visitors should be able to continue to experience the river corridor with as little influence from the modern world as possible. The river experience should help visitors to intimately relate to the majesty of the canyon.

Management Objectives (Selected)
The management objectives for Grand Canyon National Park, which are based on the park visions, set the direction for future park management. The objectives describe desired conditions to be achieved.

NATURAL AND CULTURAL RESOURCES
	Preserve, protect, and interpret the park's natural and scenic resources and values, and its ecological processes.

	Preserve, manage, and interpret park cultural resources (archeological, ethnographic, architectural, and historic resources, trails, and cultural landscapes) for the benefit of present and future generations.

	Preserve, protect, and improve air quality and related values such as visibility.

	Manage visitor use, development, and support services to protect the park's resources and values.

	Preserve and protect the genetic integrity and species composition within the park, consistent with natural ecosystem processes.

	To the maximum extent possible, restore altered ecosystems to their natural conditions. In managing naturalized ecosystems, ensure the preservation of native components through the active management of nonnative components and processes.

	Manage ecosystems to preserve critical processes and linkages that ensure the preservation of rare, endemic, and specially protected (threatened/endangered) plant and animal species.

	Protect the natural quiet and solitude of the park, and mitigate or eliminate the effects of activities causing excessive or unnecessary noise in, over, or adjacent to the park.

	Preserve natural spring and stream flows and water quality. Withdraw only the minimum water necessary to meet park purposes. To the maximum extent feasible, strive to meet increases in water demand by conserving and reusing water.

	Provide opportunities for scientific study and research focused on the Grand Canyon, consistent with resource protection and park purposes.

	Inventory, monitor, and maintain data on park natural and cultural resources and values, and utilize this information in the most effective ways possible to facilitate park management decisions to better preserve the park.

	Clearly delineate and maintain the park boundary to protect park resources and values.

	Identify and evaluate all cultural properties within the park for inclusion on the National Register of Historic Places.

	Collect ethnographic data and develop ethnohistories for the Havasupai, Hopi, Hualapai, Navajo, Southern Paiute, and Zuni peoples concerning their associations with the Grand Canyon, as appropriate, in order to preserve, protect, and interpret park resources and values important to diverse American Indian cultures, including significant, sacred, and traditional use areas.

WILDERNESS AND WILD RIVER MANAGEMENT
	Manage areas meeting the criteria for wilderness designation as wilderness. Actively pursue the designation of these lands as part of the national wilderness preservation system.

	Manage the Colorado River corridor through Grand Canyon National Park to protect and preserve the resource in a wild and primitive condition. Actively pursue the designation of eligible segments of the Colorado River and its tributaries as part of the national wild and scenic rivers system.

VISITOR EXPERIENCE
	Provide a diverse range of quality visitor experiences, as appropriate, based on the resources and values of the Grand Canyon, compatible with the protection of those resources and values.

	Provide access that is appropriate and consistent with the character and nature of each landscape unit and the desired visitor experience.

	Consistent with park purposes and the characteristics of each landscape unit, preserve and protect the maximum opportunities in every landscape unit of the park for visitors to experience the solitude, natural conditions, primitiveness, remoteness, and inspirational value of the Grand Canyon.

	Provide equal access to programs, activities, experiences, and recreational opportunities for individuals with disabilities, as appropriate and consistent with the levels of development and inherent levels of access in areas within the park.

	Provide a wide range of interpretive opportunities and information services to best assist, inform, educate, and challenge visitors.

	Educate and influence the public through positive action to preserve and protect the world they live in, including but not limited to the park.

	Provide a safe, efficient, and environmentally sensitive transportation system for visitors, employees, and residents, consistent with management zoning and resource considerations. Emphasize nonmotorized modes of transportation wherever feasible.

	Develop visitor use management strategies to enhance the visitor experience while minimizing crowding, conflicts, and resource impacts.

	Provide visitor and employee facilities and services, as necessary and appropriate, in or adjacent to areas dedicated to those uses or in appropriate disturbed areas.

REGIONAL ISSUES
	Understand, assess, and consider the effects of park decisions outside the park as well as inside.

	Upon request, work cooperatively to assist local American Indians in planning, developing, and managing lands adjoining the park in a mutually compatible manner.

	Work cooperatively with appropriate entities to encourage compatible, aesthetic, and planned development and recreational opportunities outside park boundaries, and to provide information, orientation, and services to visitors.

	Carry the NPS concern for the environment beyond the boundaries of the park, including the protection of park resources and values from external influences.

UNDEVELOPED AREA MANAGEMENT OBJECTIVES
Undeveloped areas are considered to be all areas within the park boundaries not within the areas described for the South Rim, North Rim, Tuweep, or corridor trails. The following objectives are in addition to the overall park objectives.

	Manage and monitor visitor use and park resources in the park's undeveloped areas to preserve and protect natural and cultural resources and ecosystem processes, and to preserve and maintain a wilderness experience or, where an area is not proposed for wilderness, a primitive experience.

	Establish indicators and standards for desired visitor experiences and resource conditions, monitor the condition of those indicators on a regular basis, and take action to meet the standards if they are not being met.

	Provide a variety of primitive recreational opportunities consistent with wilderness and NPS policies on accessibility. In deciding which opportunities would be provided in the undeveloped areas of the park, consider recreational opportunities available outside the park, as well as opportunities available in developed areas of the park.

	Conduct administrative activities, including research, search-and-rescue, emergencies, and fire management, in a manner that is consistent with NPS policies regarding wilderness management and the use of the minimum tool in wilderness areas.

	Maintain roads designated open to public or administrative motor vehicle use in undeveloped areas in an unpaved condition without major improvements. Only consider improvements that reduce resource impacts in keeping the road minimally open for vehicle use. Revegetate all roads not designated for vehicle use, or convert them to trails as appropriate.

	Consistent with the above goals, reduce conflicts among undeveloped area users, including river, hiker, stock, motorized and nonmotorized users.

	Provide a wilderness river experience on the Colorado River (this objective will not affect decisions regarding the use of motorboats on the river).


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[NOTE:  This document is a sample of the more than 300 pages of solutions and rationale that the park received on the allocations issue alone during the 2002 public scoping period for the CRMP.   Park staff prepared this for the June 2003 workshops to provide more detail on the range of scoping comments than is available in the summary of public comments posted on the park's website at http://www.nps.gov/grca/crmp.  However, due to the volume of comments received, it is a draft sample, so it does not necessarily represent every comment received on this issue.]

DRAFT 
Sample of Public Comments:  Allocation Solutions

I.	The Current Allocation Between Commercial And Non-Commercial Use Is Unfair And Should Be Made Equitable

Comments include:  The long wait by non-commercial users and limitations on repeat use cannot be justified while commercial passengers can go on short notice and as often as they want; Unfair that guides are not counted in the commercial allocation; Current allocation does not reflect large and growing demand by those who most value river running by devoting the most time, effort, and resources to it; Commercial guides have a place in the canyon, but should not have a protected status; Provide equal access for everyone; Introduce an allocation-free access system.  Solutions include:

A.	Offer Split Allocation Systems
	1.	Equal 50/50 Split Allocation Between Commercial and Non-Commercial Trips
		a.	Evenly spread summer allocation equitably month to month during the primary season, so that approximately one-sixth of all trips are used per month (with a maximum of 20%, or one-fifth, used in any one month)
	2.	40/40 Split Allocation Between Commercial and Non-Commercial Trips with 20% Allocation for Administrative Use
	3.	30/70 Split Allocation Between Commercial and Non-Commercial Trips
		a.   Change allocation split from 70% Commercial / 30% Non-Commercial to 30% Commercial / 70% Non-Commercial Use  
	4.	Adjustable Split Allocation Between Commercial and Non-Commercial Launches (not user-days to keep supply and demand for both types of trips in reasonable balance over time)
		a.	Limit the number of launches to 5 per day throughout the year.  Offer 3 commercial and 2 private trips on one day; then 3 private and 2 commercial trips the following day
		b.	Limit the number of launches to 4 per day throughout the year.  Offer 2 commercial and 2 private launches every day   
		c.	Limit the number of launches to 6 per day throughout the peak season.  Offer 3 commercial and 3 private launches every day of the peak season.  Offer 4 per day throughout the shoulder season, with 2 commercial and 2 private launches per day.
		d.	Reallocate unused slots rather than forfeit them
		e.	Provide launch windows (periods of time, including a portion of prime river time) during which commercial traffic congestion will be limited to levels which do not effectively exclude self-guided boater use
		f.	Increase the number of private permits issued so that the wait to paddle the Canyon is under 5 years
		g.	Extend the private rafting season and adjust permit allocations
		h.	Include guides Should Be Included In The Commercial Allocation
		i.	The launch calendar on the NPS website should be available to everyone and should be supplemented with trip length information (currently its a secure website only accessible by outfitters)

B.	Increase Overall Use, But Do Not Decrease Commercial User Days
	1.	Increase the total number of boaters allowed on the river
	2.	Take advantage of motorized trips efficiency by extending the motor season to September 30th and make the non-motor season October 1 through March 31
	3.	Evaluate the possible increase in river corridor capacity to alleviate pressure from non-commercial rafters


C.	Implement A User Formula That Emphasizes Private Trips
	1.	Lottery Systems
		a.	True Lottery System  - an applicant drops their name in a bowl with all other applicants and then one name is drawn
		b.	Dated or Seasonal Lottery System  applicants submit their name for one or more launch dates in a pool with other applications for the same date(s)
		c.	Weighted Lottery System  1) applicants who apply time and time again have an increased chance of winning a permit or 2)  should be in favor of private trips and not based on how much money one can afford
		d.	Group Size Lottery System  multiply the trip leader factor times the number of applications to get the number of times a trip leaders name is added to the pool
		e.	Longer or Shorter Trip Lottery System  reward applicants applying for longer or shorter trips depending on the management objectives in the planning process
	2.	Reservation Systems
		a.	Simple Reservation System  payment costs are capped and the only limit on access is being the first to successfully register for a launch opportunity
		b.	First Come, First Serve System  visitors are given a permit in person at the launch point or some other appropriate location immediately prior to the launch time (i.e., Lees Ferry, Flagstaff, Lake Mead)
	3.	Hybrid Systems
		a.	Institute a Simple Reservation System for all permits issued in the shoulder season  Accept applications on a first-come first-serve basis for reservation launch dates via an automated  system on the web and allow applicants up to two years in advance of any given launch date to register
		b.	Maintain the wait list for peak season (June to August) 
		c.	Do away with the wait list entirely and manage summer use under a lottery system and initiate a reservation system in the shoulder seasons
		d.	Evenly spread summer allocation equitably month to month during the six-month primary season so that approximately one-sixth of all trips are used per month (with a maximum of 20%, or one-fifth used in any one month)
		e.	Allow private trips to hire a cook, guide, interpreters, etc. if they want to because over 70% of the public comments from the 1997 CRMP Scoping Process that spoke to expanding the spectrum of concessions services asked for some form of consultant services
		f.	Evenly spread use out across the four seasons (i.e., 3 to 4 launches per day year-round) would greatly alleviate campsite competition and attraction site crowding
		g.	Group sizes should apply equally to all recreational river runners and should be capped at 16 individuals (passenger and guides included)
		h.	Trip contacts should be limited by only allowing 4 trips to launch daily from Lees Ferry, for a total maximum of 1,460 launches per year
		i.	The registration systems should be available 24 hours a day, seven days a week throughout the year
		j.	A person wanting to register for a trip should be able to contact the GRCA website, select an available launch date, identify at least 25% of the people who intend to go on the trip, and pay all the user fees for the trip
		k.	Establish new launch seasons 
			1)	Spring: March 1-31 (maximum trip length: 21 days)
			2)	Summer: April 1  September 30 (maximum trip length: 18 days)
			3)	Fall: October 1  November 30 (maximum trip length: 21 days)
			4)	Winter: December 1  February 28 (maximum trip length 30 days)
	4.	Bidding or Rolling Registration Process
		a.	Registration would be open all the time and, once registered, a person does not have to re-register in subsequent years.
		b.	People could not take more than two recreational trips in a year, apply more than twice per calendar year, nor apply for more than one trip date at a time

D.	Eliminate Allocations and Replace With A Common Pool System

Comments include:  This would require visitors to first obtain a permit and then choose whether to organize their own trip, hire a guide service, or join a previously scheduled commercial trip; There would be no real allocation between user groups, since regulations defining differences between commercial and private trips would no longer be relevant; All users would be competing in the same pool, be treated the same, and must comply with the same regulations; Everyone should have an equal chance to run the river.  Solutions include:
	1.  Year-Round Common Pool System
	2.  Seasonal Common Pool System (i.e., winter months when demand is lower)
	3.  Trial Common Pool System for A Small Proportion of Use (i.e., one launch per day for a specified period of time)

II.	The Current Allocation Is Appropriate And Should Be Maintained Or Commercial Use Should Have An Even Larger Allocation

Comments include:  Outfitters serve far more potential users, allow greater public access, offer more and better services (i.e., expertise, safety, education), and provide better stewardship of the Canyon and its resources;   Commercial guides act as an enforcement arm for the NPS, while non-commercial users are less likely to obey the rules.  Solutions include:

A.	Non-Commercial Use Should Be Further Restricted, Eliminated, Or Better Regulated By The NPS 

Comments include:  Private parties are less likely to care for the environment, abide by regulations, or cooperate with other river users.

B.	Non-Commercial Permit Holders Should Meet Certain Minimum Qualifications 

Comments include:  Private boaters should have previous rafting experience, knowledge of the Canyon, demonstrated knowledge of regulations.

III.	Commercial Use Should Be Reduced, Eliminated, Or Better Regulated 

Comments include:  Having a larger commercial allocation than private allocation is an inappropriate exploitation of a public resource for the financial benefit of a few entrepreneurs; the allocation system needs to be reformed by increasing private launches even if commercial launches need to be decreased; the fees charged to customers is ludicrous; Non-commercial access has been stifled unfairly since at least 1972 and immediate steps are required to stop injustices and prevent them in the future; Three primary variables that affect a wilderness experience on the Colorado River are: Group size, encounters with other groups, and motorboats, helicopters, and mechanized equipment.  Solutions include:

A.	Small Companies Should Replace Large Companies

B.	Outfitters Should Be Phased Out As Their Contracts Expire Or They Sell Their Business

C.	Incidental Business Permits Should Be Allowed To Supplement Or Replace The Current Concession System

D.	Phase Out The Recreational Use Of Motorboats, Helicopters And Other Motorized Equipment In Accordance With The Wilderness Act
	1.	Protect wilderness resource
	2.	Focus on high-quality wilderness-dependent trips
	3.	Provide wilderness recreation opportunities to a diverse spectrum of the public
	4.	Remove the use of helicopters for exchanges and motorized watercraft from all river concession contracts
	5.	Motor rigs, if allowed, should be completely non-polluting, as silent as possible, and limited to certain times of the year
	6.	Commercial trips that are allowed should be oar powered only
	7.	Limit commercial trips to those that provide a wilderness river running experience for the members of the public without the skill to raft the river on their own
	8.	Apply the minimum tool requirement for all management decisions affecting wilderness, including commercial service contracts
	9.	Discontinue motor powered watercraft by January 1, 2006

E.	Reallocate Un-used Commercial Motorized Use To Other Uses 
	1.	Reallocate Un-used Commercial Motorized Use to Non-Commercial, Non-Motorized Use (within a timeframe that allows them to sell trips and plan their operations on a timely basis) 
		a.	Allocate User Days by Sector
			1)	Private Sector:  Allocate 115,000 privates (including passengers and crew) to launch 670 days per year (600 during the primary season and 70 during the secondary season); up to 6 launches per day; up to 42 people per trip.  At the end of the primary season, any unused allocation should be forwarded to the commercial sector for use during the secondary season.
			2)	Commercial Sector:  Allocate 54,000 (including passengers and guides) to launch 252 days per year (221 during the primary season and 52 during the secondary season; 2 launches per day except Wednesdays during the primary season and 1 launch per day during the secondary season; up to 16 people per trip.
		b.	Transfer Some Commercial User Days to Educational Use
		c.	Transfer Some Commercial User Days to Tribal Use
		d.	Transfer Some Commercial User Days to Special Populations 

F.	Commercial Crews Should Be Counted Within The Commercial Allocation

IV.	A Common Pool System Should Not Be Implemented 

Comments include:  It would be unmanageable for commercial outfitters, preventing them from providing essential services; applicants who want a commercial trip might swamp non-commercial applicants, further reducing their ability to get on the river; would group strangers on a private trip; commercial market would swamp pool further reducing non-commercial access.  

V.	A Lottery System Should Not Be Implemented 

Comments include: If a lottery system was implemented, some people would never win a permit.

VI.	The Waiting List Is Far Too Long And Should Be Reduced Or Eliminated

Comments include:  The process for gaining access to the private wait list and subsequent trips in the canyon needs a major overhaul; a 20-year or even a 5-year wait is ludicrous.  Solutions include: 

A.	Implement A Transition Plan For The Wait List If There Is A Change In Managing Allocation Through The Permit Process 
	1.	Notify all Wait List participants about how the new system will work and how it will benefit permit applications
	2.	Offer a direct refund of prior permit application fees
	3.	Offer a transferable refund credit to anybody on the Wait List who voluntarily removes themselves from the list by March 2005, with the understanding that the credit can be applied to the new system and that they will be eligible to apply under the new system
	4.	Give no preference in the new application process to anybody from the Wait List or any other pool of applicants
	5.	Conclude the transition option quickly for people currently on the Wait List
	6.	Offer a full cash refund to anybody who is currently on the Wait List who will voluntarily remove themselves from the Wait List in order to give the new system the best chance of success
	7.	Impose a temporary moratorium on new Wait List registrants until the CRMP is finalized and a new system is developed
	8.	Require trip leaders to turn back unused permits and maximize the user-days on the river
	9.	Once the transition plan is in operation, allow no new additions on the Waiting List
	10.	Anticipate phase out of the Waiting List to be completed between 2010 and 2016

B.	Turn The Private System Into A User-Day System Instead Of A Launch-Based System
	1.	 Allow several smaller trips to leave Lees Ferry in a day, as long as the number of user days didnt exceed the limit


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[NOTE:  This document is a sample of the more than 300 pages of solutions and rationale that the park received on the motors issue alone during the 2002 public scoping period for the CRMP.   Park staff prepared this for the June 2003 workshops to provide more detail on the range of scoping comments than is available in the summary of public comments posted on the park's website at http://www.nps.gov/grca/crmp.  However, due to the volume of comments received, it is a draft sample, so it does not necessarily represent every comment received on this issue.]

DRAFT
Sample of Public Comments: Motor Solutions

I.  Two Main Solutions: Keep Motors or Eliminate Motors

A. Keep Motorized Raft Trips 
The Pros or advantages: they are essential to provide access to special populations (physically challenged, older, young, mentally challenged, medically ill, disabled veterans); provide a full Grand Canyon trip in one weeks time; allow a full spectrum of services; reduce crowding; clients become advocates for the Canyon; safer and can carry more medical supplies and fresh water; provide guides to educate users; too grueling to row a boat in 110 degree heat; the Canyon is Gods gift for everyone to see and no motors would shut out many people; tool to accomplish NPS mission; shorter trips spend less time on shore so create fewer impacts; travel faster and relieve pressure for competition for campsites; most families cant afford to take off more time from work than their one week vacation; allow more people to gain access to an incredible place; carry a surplus of food and other supplies to help oar boats when they flip; some people cant physically handle a trip longer than three days; failure to have a motorized craft would have endangered my life; help children become less jaded by allowing children an educational and inspirational vacation as opposed to going to Disneyland; whole family can go together in one boat; the preference of the vast majority of visitors and the only way most of us will have a chance to see the canyon at river level; oar rafts with a greater number of boats per trip spread out more across the campsite beach; less annoying when passing than a strung out swarm of smaller rafts and kayaks; provide 80% of the excitement with 20% of the danger; some people wouldnt go because they are too afraid to get into an oar boat; four-stroke motors are now quiet and pollute less; the Dam has done more damage than motor boats ever will; large motor tours are able to afford the caliber of guide needed to provide the appropriate level of service; Park doesnt just belong to those individuals who can endure the added rigors of an oar powered trip; water already polluted by motor boats at Lake Powell and Lake Mead; essential to continued tourism income necessary to maintain the Park as well as the livelihood of many small businesses and their families; an historical piece of the puzzle; better than having a tram that goes through the canyon; if all trips were oar trips there would be too much congestion; provide support for kayak trips; surrounding towns like Fredonia and Page depend on motor trip businesses; minimize wait time to schedule a trip and may reduce any bartering for time slots; different types of trips offer something different to the clientele; move a lot of people through the Canyon with minimal impact; reduce congestion because motor trips are more flexible in their schedule; cant leave my family for 18 days; provide back up safety for us in the non motor boats!; open the Canyon to a broad swath of our society; for us senior citizens after the 5th day of being unable to shower or sleep in a comfortable bed, we were ready to go home; there are ways motors and oars can co-exist; benefits of motors far outweigh their negative points; allow variety of trips for variety of types of people; no person should expect to be guaranteed a wilderness experience or solitude; all same length trips create congestion, the mix is better; eliminating motors would reduce the number of outfitters available; banning motors would violate the Americans with Disabilities Act; an entire class of explorer would become extinct without the motor powered rafts; total oar traffic would increase foot traffic on trails because they take a longer time to run the river; the brief, benign encounters our paddle boats had with motor trips hardly justifies banning motor use in the Canyon; can carry out the trash and human waste left on beaches by private oar trips; inappropriate to eliminate this method of mass transit when in reality it should be encouraged; they allow more time to go see Indian ruins; big rigs with more people equals more fun; motor trips are the best way I can think of to ensure our children see why we must protect the environment; longer trips without a motor would not necessarily increase the quality of a passengers experience and dont signify a better trip; sensitive areas are less impacted by shorter trips; the roar of the river made hearing the motor a non-issue, while winds and the freshness of river spray made experiencing fumes from the motor a non-issue; we couldnt be out of communication for more than seven days.

B. Phase-Out Motorized Raft Trips/Totally Eliminate Motorized Raft Trips
The Cons or disadvantages: they are contradictory to proposed Wilderness designation; disruptive to wildlife in general (Condors) and wildlife habitat; disrupt peacefulness and quiet of the Canyon; create air and water pollution (oil and gas leaks, hydrocarbon emissions); contradictory to protecting the river; dont allow for retreat from noisy society; contribute to further decline of native species; limit the ability to have a primitive experience; counter to the Parks legal obligation to protect natural quiet; help create the Grand Canyon smog haze; incompatible with wild character of the river; not safer than oar boats; not as safe as oar boats; create more crowding; increase demand for a resource where demand exceeds capacity; the Park is not a mechanized theme park; attraction sites are more heavily impacted by larger group sizes on motor trips; huge groups clog access to attraction sites; disruptive to the ecosystem; like chainsaws in an opera; neglect the natural, primitive, primordial, quiet nature of the resource; detract from our nations premier and most cherished window to the world as it existed prior to mans presence and subsequent impact; hearing loud sounds produced by motors is like traveling thru downtown Manhattan; invade river stops and campsites so that their visitors have enhanced experiences; encourage Americas obsession with the drive-through window; used for convenience and financial gain; inappropriate in a Wilderness park; impacts cannot be monitored; noise of the motors can be heard for miles and echoes off walls of canyon; motors churn up the water, scare wildlife and leave petroleum pollution; not a sustainable and smart way to approach protecting this wild and scenic river; larger groups are more loud and obnoxious; only accessible to those at the top 15% of the national income; plenty of places to buzz around with a motor in the U.S., but very few where you can escape it; motorized rafts have no place on the river; they simply generate higher profits for the concessionaires; protection of some wilderness areas as wild places; motor trips do not provide economical trips; most disabled people can be accommodated in oar rafts; commercialized motor trips have monopolized and damaged the river experience for too long; huge size of those monster motorized rafts with all those passengers on board is totally out of place in the Canyon; I want to be able to hear the rushing water, the birds, my companions voices, and the other sounds that nature, not industry, provides; motors are a disgraceful contamination of the Canyon which utterly destroy its essence; people see more in one mile without motors than 50 miles under motor power; seeing a huge raft motor by with hordes of orange life jacketed people reminds me of the rides at Disneyland; GCNP should provide recreational opportunities consistent with the preservation of the rivers natural and cultural resources and wilderness character; they take away from everyones enjoyment of the river; commercial motor trip passengers dont have the level of experience, commitment, understanding, or determination required to run the river; there are no such things as eco or environmentally-friendly motors, since they all pollute by their fumes, their leaks and their noise.

II. Alternate Solutions   

A.  Motor Technology
Utilize new motor technology: quiet electric motors, battery-powered motors with solar rechargers, photoelectric motors, motor designs that are more environmentally oriented.  No motors over 10 HP.  Use alternative fuels like propane, natural gas or white gas as fuel for internal combustion engines.  Mandate that motor trips continue to find ways to lessen the noise and pollution aspects of their effects.  The latest and best technology should be required by the NPS.  Sixty-five percent of all commercial trips should be allocated for motorized craft with the provision that the percentage could rise incrementally to 70% as commercial outfitters improve their motorized propulsion systems to the point where they are always at the cleanest, quietest, and highest efficiency level available.  I have literally been hiking along the river at Tanner and not heard a raft approaching, because they are quiet and pollute much less.  Have motor trips carry two types of motors: gas engines for rapids and electric for smoother less violent water.  Small zero-emission electric battery, solar cogeneration, or other zero-impact transportation system should be phased in over 20 years.  Well-tuned, non-polluting 4-stroke motors with river operators that follow the mandates well and carefully.

B.  Solve Noise Issue
Dont eliminate motors, just manage the noise.  Solve the noise problem and you have solved 60-70% of the complaints.  Perhaps the carrot would be an exclusive contract for all the outboard motors used in the Grand to the manufacturer with the quietest engine.  People who feel the periodic noise of a motor boat is offensive can travel during the non-motorized season.  Require least noise motor practicesmotor raft pilots will operate a significant portion of each day at less than full throttle and will float some portion of most days.  Quieter motors should be required with a 50% noise reduction every three years.

C.  Use Motors for Special Uses
Use motor boats for emergency operations only (rescue).  Motor trips should only be used for the physically challenged.  Motorized vessels should be used for research only.  Totally eliminate the use of motorized rigs: except of course the law enforcement, scientific research, and rescue operations.  Phase out all motorized boating with the exception of your excellent park rangers using 4-stroke motors and helicopters.  For specialized trips that need more time for hiking the side canyons, such as geological, hiking and archeological trips, the motor rigs are ideal for allowing more time on land and less time on the water.  Rationing use is a necessary evil and one way to effectively ration use is to increase difficulty accessing the resource, such as limiting motorized trips to emergency usage.  For rescue and limited patrol, maintenance and research purposes.  Motor use should be limited to life and health threatening emergencies or essential administrative imperatives.

D.  Reduce Number of Motor Trips
Decrease number of commercial motor permits.  Decrease over ten years.  Reduce over the next decade with yearly deductions.  Reduce number of motor trips to no more than 20-25% of total number of commercial trips. Reduce number to 1970 levels.  Keep number to between 5 and 10% of total commercial use.  Split commercial use 50% motors and 50% oars.  Cut number of motor craft by one half.  Total level of motorized use should equal that of non-motorized use.  Keep the number of motor trips in the spring to a minimum to avoid flushing eagles and chasing waterfowl.  Cap number of motorized trips at 1964 levels.  Allow motor trips from mid-May to mid-September, but revert the commercial allocation back to pre-1979 levels.  Limiting motor access would go a long way to decreasing the total impact from sheer numbers of visitors in terms of pollution (oil, gas and noise).  Make all private permits non-motorized.  Reduce all use 10% across the board.  Motorized trips are appropriate historically, however, they should be the minority of trips. 

E.  Keep Current Management
Do not change current motor/oar mix.  I support the usage of the Colorado River in the Grand Canyon as provided in the current management plan.  Current policy that allows the use of motors on the river is the best means of balancing access to our natural treasure without jeopardizing the natural beauty.  Leave the canyon in the condition it now is in because this seems to be the right mixture of solitude while giving many people access with both motorized and oared options sharing the river.  Maintain the current number of motorized rafting permits: low-emission, low-noise motorized rafts, unlike off-road vehicles, do not leave any trace of having been there.  Please dont make this place for those people who have excess money and time on their hands  7 to 8 day trips are perfect for many of the Canyons supporters.  It would be a mistake to curtail the number of existing commercial permits.  The current balance of power to paddle works well.
The untainted natural beauty of the Grand Canyon waterway made me feel that it is already very well managed.  We rarely saw another party.  Why change anything?  Perpetuate the levels and variety of motorized and rowing trip choices that exist in the year 2002.  The system works, lets not fix it.  

F.  Seasonal/Scheduling Options
Make at least two months of the summer season (4/30-10/1) be oar only, restrict motors to April to June.  Motor boats ought to be allowed to operate during 60% of the off-season also: say December 25th to April 29th.  Expand the motor boat river season.  Take advantage of motorized trip efficiency by extending the motor season to September 30th and make the non-motorized season October 1st through March 31st.  Motor boats should be allowed in some of the winter months and then not allowed in some summer months.  Create a non-motorized season sometime during the period of March 15 through June 15.  Expand the non-motorized season for the people who cannot stand the thought of a motor trip any where near them.  Have an all motor season if there is an all non-motor season, just to make it fair.  Limit motorized use to certain popular months.  Limit motor use by type, season and size.  Alternate two weeks motor boats, one week non-motorized throughout the summer.  Make every other month non-motorized.  Just restrict motor use to a few months during the summer.  Ban both private and commercial motor craft, and then spread commercial oar launch dates evenly throughout the year.  Have a special motor-free period at the end of the commercial outfitters season when the demand for river use is lower and weather is still warm.  Allow motors only from Memorial Day weekend to Labor Day weekend.  Allow fires and disallow motors in September.  The most important aspect of a river trip is ensuring that the wilderness experience continues by judicious scheduling of all types of trips.  Allow all commercial trips to operate all summer, plus May and September.  Eliminate all self-guided trips and increase the number of motor trips to ensure that the Canyon remains in the unspoiled condition that now exists.  Reduce their (motor) season to June, July and August.  Three months of the year is non-motorized already and that is enough.  Choice of row or motorized from April 16 to Sept 15, Sept 16 to Dec 15 only row, Dec 16 to Feb 15 choice of row or motor, Feb 16 to April 16 row only.

G.  Launch Scheduling/Launch-Based Allocation
Use scheduling at launch ramp to reduce large clusters of big motor boat trips.  Do away with launch clustering and preferred season concepts and limit the speed of motor-driven craft.  Change the way the launches go so that every trip that launches on one day has a different trip length, and keep motors so some trips can be short and some long to reduce campsite competition.  Encourage privates to use more motorized rigs to get more of them down.  An allocation based on user-days is biased toward commercial-especially motorized-trips and user-day allocation not only gives the commercial trips an advantage with their large, motorized rigs, but also is an incentive for them to cram as many people as possible in as short of a time as possible, which is an intrusion on private trips day after day.  I propose that allocations be based on number of launches rather than user-days.  Safeguard the Canyon by limiting the number of people per day who can launch.  Spread commercial motor trip launches out more evenly from April 15th to September 15th.  Have separate put-in/launch spots for privates and commercial trips at Lees Ferry.  Equally space launches, so that as many trips leave on weekdays as weekends.  Stagger launches between private and commercial, so that they are not in the same place at the same time: one week private and one week commercial.  Departure dates remain on the same numerical day each year to rotate any advantage one company has over another for day of the week departure.  Limit the number of motor trips launching any given day to a maximum of six.  Launch two private and two commercial trips per day.  Stagger access calendars so that oar rafters can experience a quiet environment and pace some of the time.

H.  Increase Motor Trip Length
Increase motor boat trip length to slow down the pace of motor trips.  Add one more day to motor trips to increase flexibility.  Motor trips should be at least 6-7 days as people need this much time to really gain the feel of a wilderness experience.  The NPS bemoans the rushed visits to our National Parks yet continues to facilitate the very same behavior they object to everywhere else in the National Park System.  I recommend that the minimum trip length be no less than 14 days.  There should be no services or exchanges between Lees and 224, including removal of passengers by helicopter if the Colorado River is to be a true wilderness.  Make access to the river limited to Lees Ferry, Diamond Creek and Pearce Ferry so no trips can be abbreviated.  Minimum trip length for commercial trips should be 10 days.  If they want a shorter trip they can go to the Salmon or Cataract Canyon.  No less than 4 days to Phantom and 7 days to Whitmore, 8 days to Diamond and 4 days Diamond to Lake Mead.  Limit exchanges to one per trip.  Motor rafts can be okay if there are more periods of quiet drifting and time to explore side canyons.  Every trip should allow time for adjusting to the experience, education, solitude and reflection.

I.  Study to Determine True Impacts from Motor Trips
Someone should do a study to really determine the impacts to resources and visitor experience from motor trips: group size, trip length, pollution, noise, size of boats, number of encounters, etc.  Evaluate the minimal impact of emissions and noise levels caused by the quiet and environmentally friendly 4-stroke engines used by these rafts.  If studies show there is a detriment to the environment and health and welfare of animals and plants, then they should be banned.  But, if they do not disturb wildlife and air quality, then they should be allowed.  I would support a ban on motors if a study were to show there that motor trips caused impacts to the fragile ecosystem.  Impacts of aircraft must be noted as a cumulatively impacting factor with motorized river craft in the CRMP EIS analysis.

J.  Redesign Commercial System 
Redesign the commercial system to reward better motor operators giving them more of the pie.  Create a system where there is no financial advantage to outfitters to do motor trips over oar powered trips.  All commercial carriers should be required to have a least a small amount of row trips in the canyon; no carrier should just have motors.  Reduce the number of commercial companies and allow only those with a tried and true record of customer service and safety, environmental protection and knowledgeable and experienced guides to operate on the river.

K.  Increase Advertisement for Oar Trips
Make commercial outfitters advertise oar trips with the same vigor as motor trips.

L.  Ensure Ethical and Considerate Conduct by Motor Operators
Motors are okay if the users exhibit ethical and considerate conduct when passing non-motorized groups.  In 1988, we experienced the loud two-stroke motors and unfriendly outfitters and hostile encounters, getting bumped into eddies by J-rigs and having our kayakers paddling for their lives.  Now when a motorized trip overtakes an oar trip, they cut their engine and drift through, making sure they do not push others around.  We truly felt alone on the river as the motorized groups went right on by; it was the non-motorized privates that did not exercise polite and appropriate behavior.

P.  Use Based On Demand
All use levels should follow true demand.  Do a demand study.  Scientific surveys should be made of commercial users to see whether they really prefer motorized trips or not.  I understand oar trips sell out much faster than motorized trips, so the current ratio of motorized launches to non-motorized launches may not reflect the true demand among commercial passengers.  If you polled people on the street corner of any city (besides Flagstaff or Moab), you would find that only 40 out of 1,000 people would want to go on a Colorado River trip and only 2 would want to do it on their own and only 8 would prefer a rowing trip over a motor trip.  Maybe the demand for motor travel truly is greater than for oar travel.  It is time to phase out environmentalists from dictating how our public lands should be managed for the majority of the people.  Making the Canyon less accessible is a good alternative for managing demand.  The nearly unlimited use of motor boats by the commercial companies is what has created and artificially inflated demand for access to the Colorado River.  Neither the Park nor the outfitters have created the current levels of commercial outfitting on the Colorado through Grand Canyon, it has been consumer demand.

Q.  Increase Demand for Oar Trips
Reduce prices for long oar-powered trips to increase the demand for oar trips.  Make demand for oar trips equal to demand for motor trips.  Make more commercial oar trips available to the public.  Improve oar boat design with the objective of greater transit speed, more passengers per boatman, and profitability for outfitters.  With better technology, better trips and greater profit, motors will be driven off the river and well have a win/win solution.

R.  Manage Camping
Manage camping better and this will allow for more use.  Motorized trips should have designated campsites where they can install toilets and have ample space for the whole group.  Private trips can use more primitive campsites.  No layovers at campsites above Pipe Creek, so large motor groups can have early morning exchanges.  Open up more campsites between Cremation and Horn Creek.  Competition for campsites would be intolerable without motor rigs which can travel faster and reduce the pressure for campsites within a given stretch.  If the Park Service would like to improve on anything at all and have more bookings, it should install better bathroom facilities, because women especially would appreciate a private facility and certainly a more sanitary one if at all possible.

S.  Reduce Group Size
Motor rigs would be okay if the group size were reduced.  There are negative effects with 40 people camping at the same campsites everyday.  Make the commercial group size equal to the private trip group size.  It does not take a wizard to recognize that smaller groups have less impact on resources.  NPS should develop for structure that encourages use by groups less than 10.  Larger motor trip groups do more damage to vegetation and trails.  The number of people on the motorized boats was overwhelming, especially at hiking destinations.  I personally believe that there should be a cap on group size and that the present number on motor trips is too irresponsible in regards to resource management.  All trips should be limited to 16 persons, including commercial guides, because larger groups require bigger campsites (which are dwindling) and concentrate abuse at large campsites.  Reducing the maximum commercial group size to less than 25 would help reduce impacts at archaeological sites, as some of the trampling and social trails are due to large groups of people trying to cluster around the guides as they give talks on the sites.  Reduce group size to 16, but extend the season on both ends.

T.  Offset Impacts with a Preservation System Fee
Install a preservation system to offset impacts where there is a one-time $100.00 for all passengers.

U.  Increase Ratio of Guides to Passengers 
Ratio of guides to passengers on motor trips should be equal to the ratio on oar trips.  Oar trips have about one guide for every four to five passengers while motor trips have one guide for every ten or fifteen people.  Passengers choosing a motorized trip are likely to be less physically fit and less experienced in wilderness and water activities and their need of guides for safety and education is greater.

V.  Hybrid Private Trips/Common Pool 
If private trips could hire guides or cooks from commercial companies, this new use might make up for the loss of some motorized permits.  Common pool with full range of services: a person who is interested applies to take a trip on the Colorado River and then chooses whether they want to go private, commercial oar, commercial motor, or hybrid.  Private individuals should hold the permit and decide how much and what type of commercial support they want.

W.  Voluntary Change from Motors to Oars
Encourage a voluntary change from motors to oars.

X.  Communication and Education
The solution to many of the problems in the river corridor is communication and education.  Trip leaders who must have a particular camp can maximize their chances by communicating with others.  Encourage leaders to talk among themselves about camps.  Communication is the key to enjoying a summer trip and this needs to be fully spelled out for private permit holders.  Teach people to control the environment without controlling motors.

Y.  Minimum Tool Analysis for All Commercial Trips
All trips, including commercial ones, should be consistent with the minimum requirement concept and must be documented in a minimum requirement analysis (RM 41 & 6.3.3).  This means that the level of commercial concessions allowed in the river corridor must be the minimum level required effectively to administer the area as wilderness.  Ensure that all management decisions reflect the minimum requirement in terms of NPS and visitor impact prescribed in the Wilderness Act.

Z.  Move Motorized Use to Lake Powell and Lake Mead
Let those who wish to use motorized transportation do so in and around the evaporation tanks known as Lake Powell and Lake Mead., I support the no motors plan.

AA.  More Supervision by NPS/Increase Guide Requirements
The answer is more supervision of commercial motor trips, not elimination. Increase guide and trip leader requirements so that only the best qualified are hired.  Make sure the outfitters properly compensate the highest qualified guides so that they have integrity and show loyalty to the company.

BB.  Public Access to Launch Calendar
Give the public access to the online launch calendar, so that they can know how many motor trips are really on the river at one time.  Make the launch calendar available to everyone, so people who hate the sound of motors can choose to go when there will be the fewest motor trips.

CC.  Separate Motor and Oar User-Day Allocations
Commercial user days should not be generic.  There should be separate motor and oar powered user days, with the minority of user days allocated to motor trips.  I suggest a 25% block of user days for private parties, a 40% block of user days for commercial oar trips, and a 35% block of user days for commercial outfits with quiet motors.

DD.  Motors in Lower Gorge Only 
I favor limiting motorized rafts to the last 50-75 miles before Lake Mead.

EE.  Reduce/Dont Increase Overall Use
There are too many people down there now, so reduce total number of visitors to 15,000 per year.  Limit recreational use in Marble Canyon from February to early March to minimize disturbance to wintering bald eagles.  Increasing the user allocation would be seriously detrimental to long-term preservation of archaeological resources in the river corridor.

FF.  Federal Permit Buyout
A federal permit buyout for companies that run only motorized trips should be explored.


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The National Park System Mission
Caring for the American Legacy

"...to promote and regulate the use of the...national parks...which purpose is to conserve the scenery and the natural and historic objects and the wild life 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." 
National Park Service Organic Act, 16 U.S.C.1.

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