Defendants deny allegations contained in Paragraph 14 on the complaint. Defendants deny, since the primary season for noncommercial users has been from April 16 through October 15 since at least 1979. Defendants admit that most recent Colorado River Management Plan was approved on September 14, 1989. Defendants deny remainder of averment. Defendants admit the first, third and fourth elements with the clarification that the 1989 CRMP also included additional specific elements.
Defendants deny the remaining allegations.
Defendants admit the allegations contained in Paragraph 19 of the complaint. Defendants deny that the estimated time for obtaining a permit ranges from twelve to twenty years. The NPS has no information indicating that anyone has waited more than ten years to obtain a permit. Defendants deny the allegations contained in Paragraph 21 of the complaint 22. Defendants deny the allegations contained in Paragraph 22 of the complaint.