# RRFW Riverwire – Court Issues Second Decision in Grand Canyon Appeal



## richp (Feb 27, 2005)

*Cliff Notes Version of RRFW Press Release*

Hi Tom,

An interesting press release -- one that fully proves the old adage that the longer and more elaborate the spin, the worse the problem is you're trying to explain away. 

For folks who can't take the time to read all the prime documents, I'll try for the Cliff Notes version: 

* RRFW lost. Lost big. Then lost bigger. 

* The facts RRFW presented weren't persuasive to any of the judges. 

* The legal precedents RRFW cited didn't apply, and its tactics didn't work. 

* When RRFW doubled down on its appeal, it managed to get an even more legally powerful refutation of its position. 

Notwithstanding all the fine quotes from your allies, one might reasonably speculate that major segments of the environmental community are pretty upset over this outcome. They now will have to deal with an even more elaborate and forceful appellate court precedent supporting agency discretion. That can't be viewed positively, no matter how it's depicted. 

Put directly, RRFW's short-term tactical pursuit of its anti-commercial, anti-motor goals, has made future strategic battles against legitimately objectionable policies far harder. 

Which takes me back to where many folks have been all along. This was never the way to pursue the issues of wilderness and motors on the river in the Grand Canyon. It's always been a legislative matter. Unless and until RRFW (and others, presumably) successfully musters a full court press with Congress, the current status will not change. 

FWIW.

Rich Phillips


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## Tom Martin (Dec 5, 2004)

*GCPBA sinks paddlers hope of access to Grand Canyon*

Hi Rich, while I appreciate your views on this issue, others don't see it as you do at all. The litigation decission gives the Agency leniency in planning. That said, all paddlers should take note that the commercialization and motorization of the Colorado River in Grand Canyon National Park is 100% supported by the Grand Canyon Private Boaters Association. The failure of this litigation is in part a direct outcome of the GCPBA interviening in the litigation against wilderness resource protection and equitable sumertime access to the river. Thanks for your thoughts Rich, have a great day, yours, tom


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## Andy H. (Oct 13, 2003)

Tom,

Your statements about the Grand Canyon Private Boaters Association (GCPBA) are misleading. In saying "GCPBA sinks paddlers hope of access to Grand Canyon" and that "the commercialization and motorization of the Colorado River in Grand Canyon National Park is 100% supported by the Grand Canyon Private Boaters Association" you conveniently omit the following: 

1) the GCPBA has greatly increased access and 

2) as a signatory to the new Colorado River Management Plan (CRMP) the GCPBA cannot legally oppose the current plan or the allocations granted under it. 

There were negotiations and neither side was perfectly happy with the outcome. They shook hands, walked away and now live with, and are required to support, the current CRMP.

Despite your life-long history dealing with Grand Canyon (GC) access issues you continue to ignore the fact that if the "no motors" stance had been adopted by GCPBA and AW, the outfitters never would have come to the table. If the outfitters had not come to the table, there would have likely been no new CRMP, and private boaters would be in the same place we were 10 years ago, if not in a diminished position due to the political clout of the outfitters and other GC concessionaires. 

*Here's the bottom line for me:*

I finally got on the Grand last March. It seems a lot more folks that have been down the Canyon since the CRMP was implemented than were going before. I was invited by permit-holding friends to go on two different trips this spring, during non-motor season, and I could conceivably go again next fall if things work out for me. 

From what I can see, *the new CRMP is not perfect but it has significantly increased access to the GC for private boaters*.

You write great guidebooks, are doubtless a skilled boatman, and I hope you are able to spend the rest of your days enjoying Western rivers. 

Please don't insult the intelligence of the boating community with your forced congeniality and misleading statements.


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## Tom Martin (Dec 5, 2004)

Hi Andy, while I appreciate your thoughts and am glad you personally are getting invited to participate in Grand Canyon river trips, that is a far cry from getting your own permit. We will agree to disagree on what could have happened had the GCPBA not sold out. 

The river outfitters trade association themselves admitted they would have to accept big changes on the river they would not like unless they could get get a small group of consituents together to agree to what the river concessionaires wanted. See

http://rrfw.org/sites/default/files/documents/Update_on_Various_CRMP_Matters.pdf

for supporting documentation. 

We do not know what would have happened if the GCPBA had not entered into a ten year agreement with the river concessionaires. You and a lot more do it yourself river runners may have had even better access to the summertime river experience. 

You can see the agreement here:

http://www.gcpba.org/index.php?option=com_content&task=view&id=50&Itemid=28

Finally, we don't know what would have happened had the GCPBA not intervened in the recent litigation seeking better self guided access to a wilderness river in Grand Canyon National Park.

Finally, I saw a great quote today you might ponder...

"Great minds discuss ideas. Average minds discuss events. Small minds discuss people."

All the best, tom


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## Andy H. (Oct 13, 2003)

Nice zinger, Tom. 

Here are some ideas for you:

The CRMP negotiated by GCPBA and AW increased annual GC private boater user day allocation from about 58,000 to about 113,400 user days, and private trips increased from about 250 to about 500 trips yearly. The commercial outfitters' allocation remained about constant. The idea here is that nearly twice as many user days and trips are available to private boaters now, thanks largely to the efforts of the GCPBA and AW.

For the private boating community to clearly understand the ideas and concepts about how the situation played out, they should know the truth about the situation. The idea here is that statements such as "GCPBA sinks paddlers hope of access to Grand Canyon" mislead the boating community by the sensationalist implication that private boaters' GC allocation is being diminished due to the failure of RRFW's lawsuit. Private boaters have exactly the same number of user days and launches in the Grand Canyon as we did before the RRFW lawsuit was decided.

The judges deciding RRFW's suit did not agree with a single charge made by RRFW. The idea here is that stating RRFW's failure in the case is due to the GCPBA's intervention seems a bit far-fetched.

A victory for RRFW could have caused the current CRMP to be thrown out and the process started all over again. The idea here is that in a renegotiation of the CRMP, there is no guarantee that the additional private boaters' allocation gained under the CRMP would have been preserved for private boaters, much less expanded into the outfitter's prime season. This is especially true considering that private boaters have not been using their full allocation of launches gained under the CRMP.

In the eyes of potential adversaries at the negotiating table when the CRMP comes up for its 10-year review, the RRFW lawsuit makes the entire private boating community appear fractured and incoherent at best. At worst, we appear incompetent and unwilling to abide by an agreement in which we are widely perceived as the big winners by nearly doubling our user day and launch allocation. The idea here is that RRFW's lawsuit and dogged antagonism of the GCPBA for "selling out" weakens the chances of success in future negotiations for private boaters.

When the CRMP comes up for its 10-year review, if the private boaters' allocation is challanged by the opposing parties the private boating community will likely need to be well organized and able to commit significant resources to the effort. The idea here is that RRFW's bitter contentiousness and misrepresentation of its minority constituency's chances for success distracts the community, drains our financial and energetic resources, and poisons goodwill among the boating community. 

-AH


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## richp (Feb 27, 2005)

*Hard to Improve on What Andy Has Been Saying*

Hi,

The subtitle says it all. But I would add a couple of things to clarify....

GCPBA is not a signator to the CRMP itself, which is a stand-alone government document. GCPBA was party to a four-way submission to the Park, which contained core elements of the compromise that allowed the CRMP to be finalized. In a separate agreement, it pledged -- along with the other submitting parties -- to support the CRMP and not squabble with each other about the CRMP's terms. 

And also, nothing GCPBA ever signed on to required it to defend against the RRFW lawsuit. GCPBA did so because it thought the CRMP represented a reasonable advance of private boater interests, and provided a foundation for further, calibrated improvements over time. 

So... Instead of a 3-page decision with the lower court ruling as an appendix, RRFW managed to inspire the Ninth Circuit to issue 35 pages of a ruling that strengthened land management agencies in their future discretion. Tom will go a long way to avoid letting people thinking about it in these terms. But RRFW’s persistence in twice pressing a bad set of facts and inapplicable law all the way to the Appeals Court, means that future challenges to government action are going to be more difficult. 

It's not GCPBA's fault that he didn't properly anticipate the consequences of the Government prevailing, or that GCPBA would defend a plan it helped originate, or how dangerous it was to twice appeal a lower court decision that so clearly showed his lawsuit was baseless.

Sorry for not being able to adequately explain this more succinctly. And again, I'm writing as a former GCPBA board member, and my views expressed here are not intended to represent those of GCPBA or its Board. 

Hope this helps a bit in understanding the background of this important case. Best to you all.

Rich Phillips


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## asleep.at.the.oars (May 6, 2006)

It would be great to have no motors, but that's what people have time for, and having more people see the canyon is what protects it. On my trip last summer, we got buzzed by a couple pontoon rigs but they motored past and were out of our hair shortly. Compare that with the political voice of thousands of people who had the trip of a lifetime on a J-rig or S-rig or whatever and I'll take the relative minimal impact of a 4-stroke outboard.

I would love to see RRFW put the same effort and intensity into getting the Green River through Deso designated wilderness - the relative impact would be far greater than a river that is already in a National Park.


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## Tom Martin (Dec 5, 2004)

*50-50? Please...*

Hi Andy, while the GCPBA and river concessionaires trade association and AW all said it's 50-50, it's not any such thing... 

The 2006 CRMP allows about 14,385 concessions passengers in the summer months and 2,270 do-it-yourselfers in the same summer months. That's not 50-50.

That's 476 commercial launches of up to 32 people compaired to 123 trips of 16 folks or less and 62 trips of 8 folks or less. That's not 50-50 either.

In the winter, when there are no concessions passengers, there are roughly 1,855 do-it-yourself river runners on 120 river trips. 

Cites above 2006 ROD pg 3

This 50-50 is like saying we'll get the middle of the road and you get the shoulders. Or, we'll take the top of the cake with the icing, you get the bottom. 

Yes, the river concessions knew full well they would fracture the boating community with the agreement. Did you read the agreement? I'll post the link again. Do you think going after your organizations members who do not support the plan helps the boating comminity? 

To quote the agreement: "The Parties will use their best efforts to discourage their respective members from engaging in any activities that would, if undertaken by the Parties, be inconsistent with the Joint Recommendations and the terms of this Agreement."

Here's the link:

http://www.gcpba.org/index.php?option=com_content&task=view&id=50&Itemi d=28

Yes, this has split the boating community, just as we said it would when we first accidentally heard about it and let GCPBA memebrs know about it. Remember, the GCPBA never announced the agreement to thier members. To say this split in the river community is RRFW's fault is missing the point, like saying the numbers above are 50-50.

Rich seems to think the National Park would not have come up with a plan if the GCPBA had not made an agreement with the Trade Association. That's rediculous. Remember, the NPS wanted to start changing allocation based on real people wanting real launches, but that was dropped after the agrement came out. 

Rich and I disagree on this as well. The 9th Circuit decission, while still unfortunate, was actually much better than the District Court's even worse decission.

We will have to move forward on this issue, but the GCPBA is in a ten year holding pattern now, while the rest of us try to move the issues inequitable access to and motorization of the Grand Canyon forward. THE Grand Canyon, of all places, deserves much better. 

Yours, Tom


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## Chip (Apr 7, 2007)

asleep.at.the.oars said:


> It would be great to have no motors, but that's what people have time for, and having more people see the canyon is what protects it.


So the ugly bulldozed heliport and the noisy back-to-back flights hauling the commercial dudes out are _protecting_ the Canyon? 

Pretzel logic, at best.


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## BackCountry (Nov 22, 2009)

The NPS has always skewed river access in the Grand Canyon strongly in favor of the commercial outfitters. A friend of mine from collage is the person in charge of permitting commercial and private groups. (Sadly this has never helped me draw a permit) I asked him why it was so difficult for private groups to pull a permit. His response was that he has been strictly instructed to make sure that commercial groups got the majority of the permits and to keep permit distribution to private parties at a minimum. The simple fact being that the government makes much more money from commercial groups.

As far as the motorized traffic goes, I could personally care less. From my point of view they come by and are gone so quickly that it doesn't bother me. Same goes for dirt bikes or snow mobiles in the back country - the momentary noise passes quickly. Public lands are supposed to be multiple use after all. It is not for anyone to say one form of recreation should have more priority or be banned over another form of recreation. That is my problem with Wilderness Areas (or land of no use). I have witnessed them proliferate around my area in my lifetime and with them I have seen the once used trials fall into disrepair and non use. Jobs in the timber and mineral industries lost along with a down turn in tourism as a result of these lands no longer being accessible by mechanical means. Deer and Elk populations become unsustainable due to lack of access for hunters and susceptible to starvation and disease. In my opinion land of no use does no one any good. Good stewardship of the land does not mean wilderness areas or a free for all of commercial utilization. It is a balance of using the resources while protecting them - something America sadly seems to struggle with.

While I would like to see a somewhat more even distribution of private to commercial permitting, I don't think it will happen. The government is too greedy and private groups can not match the easy monetary gains guaranteed by the commercial groups.


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## asleep.at.the.oars (May 6, 2006)

Chip said:


> So the ugly bulldozed heliport and the noisy back-to-back flights hauling the commercial dudes out are _protecting_ the Canyon?
> 
> Pretzel logic, at best.


Dinosaur was saved from a dam because the Hatch family and the Sierra Club got people down the river - often with motors. Marble Canyon was saved from a dam because enough people knew about the canyon that they wanted to protect it. 
There is a reasonable push being made right now by a small subset of the water buffalos to remove Glen Canyon dam because of the evaporative loss of having two half-empty lakes rather than one full one. If everyone who was helicoptered out believes that Grand Canyon is a resource worth protecting, there's that much more pressure on USBR to pull the plug. So, yeah, I think higher volumes of tourists is a good thing - especially if it gets me to float through Glen Canyon some day.


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## richp (Feb 27, 2005)

BackCountry said:


> A friend of mine from collage is the person in charge of permitting commercial and private groups. (Sadly this has never helped me draw a permit) I asked him why it was so difficult for private groups to pull a permit. His response was that he has been strictly instructed to make sure that commercial groups got the majority of the permits and to keep permit distribution to private parties at a minimum. The simple fact being that the government makes much more money from commercial groups.


Hi BackCountry,

I'm sure a lot of folks here would like to know about how that works, when there is a fixed, published allocation between private and commercial groups, and a lottery to assign private launches. Not to mention that whole system has just gone through three Federal court reviews.

[Now, inserting my tongue firmly in cheek.]

You can do something really historic here, because this is a situation both Tom Martin and I could heartily agree needs looking into.....

So if there is a system like that in place, by all means, tell us more. Off-list. Using an anonymizer. Through an Uzbekistanian server, routed via Bulgaria and Argentina. We'll protect your identity. Just tell us how....

Have a good one.

Rich Phillips


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## BackCountry (Nov 22, 2009)

What I have stated is really all he told me. This was before the recent change to a lottery system. I don't know how that has affected his job or how he now manages the permit allocations currently. I only speak to him these days once every few years or keep in contact with what is up through other friends. I will see if I can dig up any more information.

He did say that he was required to take a minimum of 3 (free) commercial trips down the Grand Canyon every year as part of his job to check up on the commercial outfitters. Sounded like not such a bad job - fully catered trips competing to make life as easy on you as possible for the chance at getting a larger chunk of the river access allocation...


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## Andy H. (Oct 13, 2003)

*Would RRFW's plan provide more private boater user days?*

Tom,

Using the number of launches, number of passengers, etc. is not an apples-to-apples comparison. Those many commercial passengers spend many fewer user days in the Canyon. The allocations are based on user days, and the current allocation of commercial to private usage is nearly 50-50.

Would I like to see the summer allocation for private boaters increased? Of course. 

Do I want to go on a mid-January trip? Not really.

I'll admit, I'm not totally thrilled with the scheduling of the private boaters' allocation, however I am glad that there's much greater allocation, particularly in the shoulder seasons when motors aren't allowed and the temperatures are below 110 degrees in the shade.

Its my understanding that RRFW's main goal in their lawsuit was to get the GC basically declared a wilderness and thus implement a ban on motorized travel. This would mean that all commercial trips would be oar powered, with many more commercial boatmen supporting trips lasting about 14 - 18 days just like private oar trips in summer. From what I understand, computer modeling using the GC Trip Simulator program revealed that *under a "no motor" scenario, the pre-CRMP user day allocations would need to have been even further reduced* to minimize the contact between trips and achieve an acceptable experience under Park guidelines. This is because, instead of passing by in 5 minutes, commercial trips would much more slowly pass by, and would be in view of private trips for a much longer period, thus making the river seem much more crowded. The idea here is that, had RRFW prevailed in their lawsuit, the user day allocations, including summer, would have been significantly reduced from the pre-CRMP level of about 58,000, rather than increased to about 113,400 user days as in the current CRMP. 

The GC would be a wilderness, yes, but there would be a substantially decreased number of people allowed to go enjoy that experience than there were even before the new CRMP allocations.

If you can tell us whether RRFW's plan would provide more private boater user days throughout the year than the current CRMP we're all ears. 

-AH

On a related note, someone recently asked the question on the GCPBA email list about the organization's position on motors. Brady Black of Moenkoepi had this response:




> From: gcpba-at-yahoogroups.com On Behalf Of brady black
> Sent: Sunday, February 14, 2010 3:04 PM
> To: gcpba gcpba
> Subject: RE: [gcpba] GCPBA position on Motors, Wildnerness and User Allocation
> ...


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## steven (Apr 2, 2004)

tried, but could not let backcountry's quote about dirt bikes and snowmobiles slip by. 
while I also do not get bothered personally by motorcycles and snowmobiles in the backcountry, the problem is the damage they do, not the inconvenience they pose to other users. I am sure that many feel strongly about having their backcountry experience diluted/disturbed by these motorized vehicles, and I understand where they are coming from, i just try and not let it bother me personally. But, no one can argue that they do damage to wilderness areas, and that some of those users couldn't give 2 craps about the signage explaining where they can and can not go. There is plenty of room for everyone, and plenty of designated space for motors, but I feel the motors should be kept out of the wilderness.


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## raftus (Jul 20, 2005)

Re: Motors in the wilderness

It is true that a small percentage of dirk bikes, ATV's, and snowmobiles in 'wilderness areas' tear them up - often causing ugly and highly visual scars on the land. However so long as we are talking about 4 stroke outboard motors attached to J-Rigs and their ilk we don't need to worry about most of the same consequences. Forrest meadows are quickly destroyed by Dirt Bikes and ATV's, but water is only minimally affected by a passing motor. 

Wilderness designation also bans bicycles. This has baffled me for a long time. Is the impact of a mountain bike greater than that of a hiker? I enjoy riding my mountain bike through the wilderness and my tire track is no greater impact than a foot print.


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## Tom Martin (Dec 5, 2004)

*Your post touches on the problems...*

Hi Andy, your note that you don't want to raft GC in mid January and you would like to see the summertime allocation increased, and that is exactly my point.

As RRFW has all along pointed out, a modified B alternative, somewhere between B amd C, has the potential to greatly increasing self guided river access year round, would balance trip starts and number of people off the ramp in the summer, all with decreased motorized use. 

For everyone who says the motorized tour boats come and go, they pass us by, well yes, and they pull into the camp you were headed for. And they increase congestion at attraction sites. 

The computer model was based on data from a motorized summer access plan. As the model was pushed to run motor-free scenarios, the model itself begain to fail. 

The GC is managed by the NPS. The RRFW litigation goals were clearly identified in the litigation. We were and still are going to be looking for ways to increase self-guided trips in the summer and decrease the use of motorized equipment on the river in the summer. The legal tool never was intended to get the river declaired a wilderness. That is Congresses job. The NPS is suposed to manage the river for its wilderness character, and the courts have said they can do a poor job of that if they want to. They have been doing that for some time. 

The NPS admits the apples to apples comparison is in trip launches. We argue it's in trip launches of similar group sizes. Given the present imbalance in the distribution of both launches and groups size, we have a long way to go. 

We can't just keep on increasing use on the Colorado in Grand Canyon. At one point we will start to have to look at redistribution of the available use. The NPS came up with a good first step at doing this, but the GCPBA and outfitters trade group scuttled that idea, for now anyway.

These issues, as you point out, are not rsoloved and are not going away anytime soon. 

All the best, Tom


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## BackCountry (Nov 22, 2009)

There are always bad apples with any group. This is one of the reasons rafters have a conflict with private land owners. Any group can cause impact. I see the damage done by mountain bikers to be equal to or surpass that of dirt bikers. The thin tires dig deeper trenches in the trail - the dirt bikes smooth and widen the trails. Locally where I live, the mountain bikers tend to cut many more trails and give back little in maintenance of these trails. Dirt bike and ATV users must pay a fee that is used locally to improve the trails and re-rout or fix the wet areas of the trails so the scarring caused in these areas are kept to a minimum. Neither is allowed in wilderness areas. ATV riders going on single tracks cause immense damage. All of the above riding wet trails or cutting new braids in the trails have serious impact. Some of the worse damage I have seen comes for horse back riders in wilderness areas. Heavily used horse trails become wide swaths of mud and almost impassable to hikers. ALL USES IMPACT OTHER USES. People simply need to be educated to take care of the land no matter what their choice of recreation is. The self centered "it's all about me, I could care less about anyone or anything else" philosophy that permeates all of America is the root to our problems.

Having 4 stroke outboards push paying tourists down the Grand Canyon is a mild inconvenience that I can live with. They pass by quickly and introduce more people to the sport. People who would previously think nothing of water diversions or private land owners closing access to rivers may remember their guided raft trip and support keeping the waters flowing for public use. 

In my opinion the motor issue should be put on the back burner and focus should be on a somewhat more equitable distribution of permits for river access.


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## Jahve (Oct 31, 2003)

Well I just had to chime on the the lies or misinformation about snowmachines.. The bunny hugger types just love to put out flat out lies or other misinformation about snowmachines...

On normal snowpack a snowmachine puts less lbs per sq in of pressure on the ground than your mtn bike or footprint for that matter.. This is a true statement backed my many independent studies.. It is also fair to say and studies have proven that the average mtn biker has more impact on the ground than the average snowmachine.. This is why snowmachines can ride the same terrain year in and year out with no, nada, or zero impact on the ground (again many studies back this up).. This is not true of any other type of recreation.. Even walkin in has more impact on the ground.....

If you dont like motors stay in a wilderness as there are no motors there.... And agian if you cant find a wilderness here in colorado pm me and I will send you a map to all of them but then again I bet most bunny hugger types are not lookin for one........

From where I sit I think the best way to keep a wilderness a wilderness would be NO HUMANS for any reason in a wilderness area as we are the ones who have the impact and it we as humans will no doubt screw it up.. 

Sorry for the hijack of the thread but the misinformation presented about snowmachines got me to speak up..

Also thanks for the info about the Grand interesting..


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## steven (Apr 2, 2004)

i agree w/ what you say about the "footprint" of snowmobiles on the ground. I was referring to the gas/exhaust fumes/particles emitted that go into the snowpack/ground/air. Not a huge issue, I know, since (i assume) all snowmachines are 4-stroke now, but just stating an opinion. I assume the term "bunny hugger" to have negative connotations? Like I said, there is plenty of wilderness for all, whether you choose to be motored around or not.


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## Andy H. (Oct 13, 2003)

Tom,

Please respond to my request about how or whether RRFW's suit would have increased private boater allocation over the year.

The issue of GCBPBA's "selling out," as you put it, to the commercials is getting batted around on the GCPBA listserve right now, and some interesting dialog has occurred. You already know everything that happened during the difficult crafting of the compromise which nearly doubled the private boater user day allocation and established the non-motor season, so for the benefit of others reading this, the following posts deal with some of the issues touched on in this thread. 

For folks that aren't familiar with the current CRMP's history, the planning process entailed long and difficult negotiations between stakeholders. GCPBA's mission was to increase private boater access from the pre-CRMP's roughly 2:1 commercial to private user day ratio to one that would give private, or "self-outfitted" boaters a better chance at floating the Grand Canyon. Rather than pursue every single thing they wanted, GCPBA and AW recognized that compromise would be required and chose their battles to get the best deal possible for private boaters. GCPBA and AW decided to let some battles go unfought (e.g. motors, increasing private summer allocation/decreasing commercial summer allocation, etc.). 

During the process, it was realized some issues with seemingly easy solutions have negative unintended consequences that would come with those solutions. Some issues that boaters dream about and want very badly (like Glen Canyon Dam removal) were simply outside the scope of the planning process and could not have been changed anyway. 

There are tens of thousands of emails on the GCPBA listserve from about 2000 to 2006 debating minute details and hashing out various points of view, with hundreds of private boaters weighing in on the various propositions, considering unintended consequences, and determining if ideas were workable within the planning process. 

In the end a delicate compromise was reached and the efforts of the GCPBA and AW resulted in a near doubling of the private boater allocation while holding commercial allocation constant and imposing new restrictions on the outfitters as well. The RRFW lawsuit, now ruled upon and with the court's opinion disagreeing with every charge, would have put the private boaters' gains in jeopardy and restarted the entire process.

*With the 2006 CRMP access to the Grand Canyon has improved greatly for private boaters, and is about to improve even more significantly*. After this year, there will be twice as many launches available to private boaters. That's because during the first five years, half the launches were assigned to people from the old waiting list, and those launches never made it into the lottery pool. This means that your odds of getting a launch in the lottey will basically double next year.

SYOTR,

-AH

Regarding the compromise reached:


> From: gcpba-at-yahoogroups.com [] On Behalf Of driftersmith
> Sent: Tuesday, February 16, 2010 8:09 AM
> To: gcpba-at-yahoogroups.com
> Subject: [gcpba] Re: GCPBA position on Motors, Wildnerness and User Allocation
> ...


Regarding equal access year round:


> From: gcpba-at-yahoogroups.com [] On Behalf Of David Yeamans
> Sent: Monday, February 15, 2010 10:43 PM
> To: gcpba-at-yahoogroups.com
> Subject: Re: [gcpba] Re: GCPBA position on Motors, Wildnerness and User Allocation
> ...


Regarding helicopter operations:


> -----Original Message-----
> From: gcpba-at-yahoogroups.com On Behalf Of David Yeamans
> Sent: Monday, February 15, 2010 6:15 PM
> To: gcpba-at-yahoogroups.com
> ...


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## richp (Feb 27, 2005)

Hi Andy,

You've done an impressive job of summarizing a lot of complicated stuff. 

If you get a simple, understandable answer from Tom on what he really wants and what it would do to private boater access, I'd be amazed. 

Throughout the duration of the litigation he refused to do that -- always saying that he'd explain his solution when the trial got past the fact-finding stage and moved to the remedy stage. Which it never did.... So he never actually told folks what his actions would produce, despite numerous entreaties to do so.

Let me add a couple of other things. Tom has taken regular shots at GCPBA for working cooperatively with commercial outfitters, commercial passengers, and AW -- saying that other groups were shut out of the process. It's not hard to see through that one.

By doing what it did, GCPBA and its partners gave the Park the foundation for a plan that broke a decades-long management logjam. At a point in time in our country when so many of us decry sharp polarization and inflexibility, that seems like a fairly decent outcome.

And of course it's absolutely untrue that RRFW and other groups were shut out of the CRMP process. They the same input opportunities with regard to the CRMP as everyone else. 

But consider this as well. Nothing kept RRFW from forming its own coalition in the DEIS/CRMP process, and submitting a coherent plan for the Park to consider. Tom is quick to cut and paste a list of all the parties that joined in the lawsuit he filed. But perhaps unknowingly, when he does that, he underlines the fact he didn't or couldn't muster that group in a constructive way when the CRMP was being developed. 

Hang in there.

Rich Phillips


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## Junk Show Tours (Mar 11, 2008)

This is one of the best threads I have read on the buzz recently. In addition to a lot of great information about the CRMP and its development, this thread illustrates how two stakeholders that are largely advocating for the same goal can strongly disagree on how to accomplish it. From my perspective, collaboration with all interested parties is the only realistic way to craft a meaningful, lasting resolution. I am excited that a lottery system has been implemented and that my chances in that lottery will double next year. I am hopeful that the allocation of permits to private boaters in optimal floating months will increase in the future. In the meantime, I encourage all of the advocates to work together to build consensus so that much can be accomplished when the time comes.


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## Rich (Sep 14, 2006)

Andy H. said:


> After this year, there will be twice as many launches available to private boaters. That's because during the first five years, half the launches were assigned to people from the old waiting list, and those launches never made it into the lottery pool. This means that your odds of getting a launch in the lottey will basically double next year.
> 
> SYOTR,
> 
> -AH


Not to be picky, but there will NOT be twice as many launches available to private boaters after this year. 
Your last sentence is correct, the underlined statement is false.


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## richp (Feb 27, 2005)

*Give Andy a Break*

Hi,

I think Andy can be forgiven for lack of precision in his choice of words in this one spot. He covered an awful lot of territory and did it quite well.

But to clarify, it's the number of launches available through the lottery that will double, not the total number of launches.

FWIW.

Rich Phillips


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## swiftwater15 (Feb 23, 2009)

That's great analysis. And it's not like the Ninth Circuit Court of Appeals is generally conservative. 




richp said:


> Hi Tom,
> 
> * RRFW lost. Lost big. Then lost bigger.
> 
> ...


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## Tom Martin (Dec 5, 2004)

*Lots to respond to...*

Hi Andy, thanks for posting the gcpba yahoogroups posts. 

I note that there is little discussion of these issues on the RRFW moderated Rafting_Grand_Canyon yahoogroup, where the GCPBA folks are free to post, but their false claims and unfactual statements are not allowed to go unchecked by folks who have a good understanding of the issues and don't let such nonsense go unchecked. 

The latest attack by a GCPBA board member on the moderator of Utah Rafters should be an eye-opener on how these folks look at compromise and building stakeholder relations...and how damaging the "Compromise" actually is to do-it-yourself river runners.

It's clear that the GCPBA was manipulated by the river concessionaires. I have cited that web link enough.

The GCPBA board is doing all they can to try to misconstrue and discredit a fairly large group of constituents that do not agree with their assumptions and claims. That is unfortunate.

The GCPBA notes there will be a doubling of available permits next year, and most of the available permits next year will be in the off season. What does that really mean?

For the 2008 year, there were 2,464 applicants for 251 permits
For the 2009 year, there were 2,749 applicants for 266 permits
For the 2010 year, there were 3,381 applicants for 284 permits

Most of the applications are for the 6 summer months while most of the available permits are in the 6 winter months. 

And yet, there is still no justification for the allocation the river concessions have.

What is of critical importance is what the Courts didn't say…

It is still clear in this case that the Park Service made arbitrary, political decisions, on both of the basic issues: It backed down from banning motors years ago, and backed down again in its current plan, without valid justifications for backing down. Regarding allocation, it came up with a phony 50-50 split of access in its current plan, with illogical support from GCPBA (because GCPBA thought it had no reasonable alternative under the political circumstances.)

Both of those decisions do indeed fall short of validity and justice. They are arbitrary, political decisions, no doubt about it. Regarding allocation, Julia Olson said it well enough at the hearing in San Francisco--that a management plan should actually fix a wrongful allocation, not just be an improvement over a previous allocation that was even worse. The claim of GCPBA through Lori Potter--that if a new allocation is better than the old one, it should be upheld--is not a matter of justice or validity. But unfortunately the current GCPBA position seems to have been fairly important in giving the courts enough of a basis for their decision to let the new management plan stand.

The present management plan is indeed arbitrary and political, even though the courts decided not to intervene at this time.

The facts remain what they are: There is still no valid reason for motorized rafts in the Grand Canyon. Motors are still wrongful in that setting, even though the courts chose not to intervene.

Regarding allocation, the split is not actually 50-50 in reality, and even if it were, 50-50 is not valid anyway. There is still no valid, lawful reason for splitting the access 50-50 and leaving it at that, even though the courts chose not to intervene. 

Actually, there is still good news in the court decisions, even though it's hard to see right now through all the GCPBA smoke. Here's the good news:

-- The courts did not declare in some fashion that motors have legal rights, or that people have legal rights to bring their motors into unofficial wilderness areas in order to make trips more convenient. The Park Service can still ban motors when it chooses to do so. The reasons why motors are wrongful in this setting, and why the Park Service should still ban them are still clearly obvious. 

-- Regarding allocations, the courts did not endorse 50-50 splits of access as being lasting solutions. They let a (phony) 50-50 split stand in this case, (with GCPBA's support,) but the Park Service can still adjust the allocations when it chooses to do so. The courts did not say that a 50-50 split should continue permanently into the future. The present allocations are not a valid way to divide the access for next season, or the season after that, or future seasons after that. 

-- Regarding the management plan itself, the courts did not say that management plans continue to be valid for the original intended life of the plan, in the face of changing circumstances. Motors should be banned, and allocations should be adjusted, starting NEXT SEASON, because it is ALREADY wrongful to continue taking motors through this wilderness canyon, and it is ALREADY wrongful to continue to allocate space without checking actual sign-ups for trips. There is no legal requirement to wait till the current management plan expires. Instead, there are valid and justifiable reasons to NOT wait until that time, to correct the current wrongful practices in the Grand Canyon.

-- The courts did not say that the Park Service rationalizations in the present plan would still be valid if the Park Service tries to carry them over into the next plan. It is wrongful to allow motors in this outstanding wilderness area, and it is wrongful to allocate space without checking trip sign-ups, and why the current Park Service rationalizations are invalid. Of course the Park Service will still attempt to ignore these changes, but we already knew that. 


In this case, the courts said that the current Park Service practices are not quite illegal. But they are still wrongful. River runners need to keep hearing WHY these practices are still wrongful, and why they should be changed, as soon as reasonably possible, like at the end of this year. 

So what are possible answers to the access equation. Many were offered during the CRMP process. I can only link you to the RRFW plan. It's here, one of many options to seeking true equity in access. 
http://www.rrfw.org/sites/default/files/documents/RRFW_Colorado_River_Management_Plan_Scoping_Comments.pdf

Hope this helps, there's lots yet to do, and right now i gotta go to bed. We are cranking at work...oh, yeah, some of us are not retired and are doing this while trying to hold down day jobs, famailies, and go boating every now and then

All the best, Tom


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## CanyonEJ (Jul 28, 2008)

I know that there is a lot more going on here, and I don't pretend to know half as much as Tom, Andy or RichP, but I do know a bit about land management. Wilderness, as in capital "W"ilderness is set aside by law. Stating that Wilderness is a place where man is a visitor right? And when a National Park is set aside, it is placed under the control of the NPS. There is no stipulation as to how they do it, but somhow they are to leave it "unimpaired for future generations" right? 

We can debate motors, mountain bikes, snowmachines, jeeps until the cows come home. I am a wilderness advocate in so many cases, but not with Grand Canyon. The more time I spend down there, the more I believe that they are doing more good than harm for the Canyon. 

But the RRFW lawsuit is essentially arguing with the most basic difference between Wilderness, and a National Park. In Wilderness, the law says no to mechanical transport. In a National Park, it is all about precedent. in the 50's when Georgie started running her boats, they didn't stop her. But they did stop the upruns, and they did stop allowing swimmers after Dagget and Beer. In Yellowstone, snowmachines were allowed and that set the precedent we see now. Canyonlands owes a huge debt to Kent Frost and his Jeep tours. 4WD's, ATV's, Moto's and mountain bikes are still there. That precedent was set early on in the Park's history. Maybe I'm wrong, but my understanding is that the NPS can manage a Park just about any way they would like. If the Grand Canyon was a designated Wilderness, then no, motors would not be allowed. 

It just seems to me that it is a very basic difference that is being fought, yet made to sound like some extraordinarily complex matter. The CRMP is very complex, running a park is very complex, and managing a Wilderness area is very comples. However it seems to me that the difference between a National Park and a Wilderness area is pretty easy to understand.

But then again, maybe I don't know what I'm talking about.


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## richp (Feb 27, 2005)

*Still No Responsive Content*

Hi Andy,

As you and everyone else can see, Tom's lengthy post has not answered -- in a direct, understandable way -- your very easy question about what would happen to private allocations in a RRFW world. 

That's because he knows the outcome of his favored plan would be reduced access, and he would lose support in the private boating community.

I note with interest that he's now invented a new legal standard for this kind of case -- "wrongful". Through all of the post, he uses that term, in order to avoid admitting the fact that the Courts found everything the NPS did to be totally "lawful".

Tom made lengthy, impassioned, and ultimately flawed arguments all over the internet for years, persuading some folks his cause was just and his rationale would prevail. He's still trying to do that. I understand that it must be hard for him to accept the fact that he was wrong in what the law allowed and required. As a matter of human nature, I have some empathy for him -- it's hard to see a treasured goal go unrealized. But his goal would have meant private boaters would have quite a bit less access to the Grand Canyon. 

I don't make that last statement lightly, because it wasn't just in user-days that we might have lost badly. And it isn't just Rich Phillips speculating. Let me give you an actual example of what RRFW's lawsuit -- if successful -- might have produced. 

There is a section of the Court decision ruling that said:

"Plaintiffs contend that this cumulative analysis should have caused the Park Service to eliminate sounds from motorized river traffic. But if a cumulative analysis were to result in the elimination of all sounds that can be eliminated by the Park Service — in this case, all sounds other than aircraft overflights, which are not within the jurisdiction of the Park Service — then all human activity in the Park would be eliminated."

If RRFW has prevailed and all human activity had to be banned from GC, how would the river community have felt then?

Have a good one.

Rich Phillips


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## Canada (Oct 24, 2006)

*Legal*

Note the make up of the ninth circuit. It is the venue of choice if you are advancing a "stretch of the law" to advance your cause. I don't have a stake in this fight. 

When the ninth circuit spanks you, you weren't going to win anywhere.

My perspective. In a battle of commercials and privates, the commercials will win. The ability to enforce against commercials has real teeth. The 1% of jerks in the privates will have little thought towards the future of the canyon or the future of privates using the canyon. We privates have alot to loose in this fight.

Rich, Tom and Andy, Thanks for educating me a little more about this.


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## richp (Feb 27, 2005)

*Tom's Counting Problem*

Hi,

One final comment. 

As I was writing that last post, something was nagging at me. I now recall that it was this paragraph:

"I note that there is little discussion of these issues on the RRFW moderated Rafting_Grand_Canyon yahoogroup, where the GCPBA folks are free to post, but their false claims and unfactual statements are not allowed to go unchecked by folks who have a good understanding of the issues and don't let such nonsense go unchecked."

But it was early in the morning, and it sort of didn't register right away that he and I had been duking it out over there too, as well as on Raftzone. 

So I went over to the RRFW Yahoogroup and found that recently there have been more than 50 posts about some aspect of this particular piece of river politics. Some of them by me, but many by others trying to sort this all out. 

Fifty posts constitutes "little discussion" to Tom. More than all of this thread and the parallel thread on Raftzone combined...

I'll let you draw your own conclusions about why he thought it was so important to add that "unfactual statement". But to me, it just illustrates the degree of skepticism folks ought to have overall about that he's saying.

FWIW.

Rich Phillips


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## sealion (Oct 13, 2008)

*Increase access-or decrease???*

under the old system- you could go as many times a year as you wanted (if you were pleasant enough for people to want you around) if you were not on the waitlist.-if on the wait list, your second trip took you off.

Now, you can only go once a year. (and my pet peeve- winter trips are shortened to the hurried pace of 25 days!!). This, I think more than any other aspect has allowed more privates to get down there. There were a few people who used to be down there all the time. and many who went at least once a year, and quite a few who were down there 2-5 times a year.

Not all private user days are being used now, many winter trips don't even use the full 25 days allowed.(so why go in the winter I wonder?)

If motors are banned, and commercial/private user days maintain parity, both will have to be reduced. Here's why that's not gong to happen-

The clout commercial companies can muster is huge- many people with money and political connections-including members of congress - take their short trips through the canyon, and want to preserve that status quo. Commercials will not lose that source of revenue, and will fight to preserve that, and have the connections to make that happen. I don't see a large enough populist uprising occuring to cause Congress to change that, hence the legal attempts by rrfw to change it in the courts.

Tom, didn't you use to do multiple trips a year down there as a private boater? Will eliminating motors somehow bring back the possibility of going more than once a year?

The only way I see to make things change is to start planning for the 10 year re-evaluation, and mustering your arguments for that. The courts don't seem willing to change anything right now.

Pet Pitch for the Day: So my plug is to start lobbying for the 30 day winter trip to be reinstated- based on from what I can see from personal experience, many, if not most, winter launches aren't even using their full 25 days. So unless the Park wants to add those unused user days to add more launches, the 30 day option should be reinstated.

Full disclosure- I was a Guide down there for a few trips, and all but one of my privates have been winter launches

Dave Focardi
Moab, UT


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## Andy H. (Oct 13, 2003)

Tom,

When RRFW filed the lawsuit, private boaters' allocation had been increased from about 58,000 to about 113,400 user days per year under the current CRMP. Please respond to my request about how or whether RRFW's suit would have increased private boater allocation over the year.

-AH


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## Tom Martin (Dec 5, 2004)

*Andy, that was our goal...*

...but now, thanks to the efforts of the GCPBA, getting increased summertime (or wintertime) access for do-it-yourselfers may never happen. 

We learned today that the GCPBA is getting donations from the GCRRA, the group representing commercial motor passengers, who's goal is to safegaurd motorized concessions river access. 

Oh great! When we look at the GCRRA web site, we see a lot of half truths there as well. Maybe that's where the GCPBA got thier play book.

Meanwhile Rich continues his blatant distortion of the truth (no people in the Canyon...where does it say that anywhere in our briefs or web site...that's the Judges stretching the sound issue beyond reason).

Dave in Moab, we have been lobbying the NPS in the last three years to relax the impediments to rafting the Grand in the winter. It makes no sense to have the same stringent hoops to jump through in the summer and the winter. Returning trip lengths to thier pre 2006 length, decreasing the trip fees, eliminating the one-trip-a-year rule, there are all options we have encouraged the NPS to adopt in the winter through the adaptive management framework. We have recently heard that the GCPBA and the concessions trade association are both against any such changes...

Sealion, it was clear to the other group not working with the GCPBA-GCROA-GCRRA-AW folks that yes, there is a modified alternative between Alternatives B and C that would have greatly increased do it yourself access across the board, and ushered in a motor free Canyon. 

RDNEK, if you are still reading this, while i personally don't own or drive a snow machine, and don't think such machines should be in Yellowstone, what i find most alarming about the Yellowstone snowmachine issue is that do-it-yourself folks can't get access without hiring a quide. 

In Grand Canyon, DIY folks can't get access in the summer unless they are lucky lottery winners, but they can buy thier way right onto a concessions river trip. 

Both of these National Park plans have chilling implications for the future of do-it-yourself recreation.

Best to you all, yours, tom


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## richp (Feb 27, 2005)

*Three Points*

Hi,

1. Tom continues to avoid providing specific, detailed answers to Andy's access questions. Unless and until he does, the logical conclusion is that his vision for the Canyon would reduce access in a way that is dramatically unacceptable to the mainline private boating community.

2. On potentially banning all human activity in the Canyon... I simply quoted the Court decision to show how reckless the RRFW litigation was. The Court itself highlighted the logical legal consequence of what RRFW was arguing. Putting management decisions for the Canyon in the hands of the courts would have been fraught with this kind of risky unintended consequence. 

3. To my knowledge, GCPBA has never received a penny from river concession holders. 

Defending against the RRFW lawsuit had phenomenal monetary costs for a small volunteer organization like GCPBA. Before I left the Board, I believe the amount already had surpassed $20,000. Tens of thousands more were projected if the case went on appeal -- as it did. (That was money, by the way that had to be diverted from a wide range of constructive programs and participation in activities benefiting private boaters in important ways.) 

A great deal of money to sustain that legal effort came from donations. Somewhere during the litigation period, GCRRA gave an unsolicited donation to GCPBA for its legal fund. GCRRA is a relatively small organization without much of a budget, and it couldn't afford to defend the CRMP on its own. So its president -- who is a private boater, GCPBA member, and occasionally contributes to the GCPBA list -- arranged a modest contribution to GCPBA to help defray the cost of the lawsuit. 

Since I haven't been on the Board for quite a while, I don't remember when it happened, or exactly how much was involved. But it would have been a small fraction of the cost of the litigation, and would likely be considered miniscule in terms of GCPBA's income over the years. 

FWIW. 

Rich Phillips


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## Junk Show Tours (Mar 11, 2008)

I really appreciate everyone's efforts to achieve greater access to the Grand Canyon for all private boaters, but litigation is not and was never the way to achieve that. The legal standard that a Court will use when reviewing the actions of a federal agency is "arbitrary and capricious". The Court will ask, "was the agency's actions arbitrary and capricious or did the agency have a reason to do what they did? That is pretty much the lowest burden there is in law. Its very easy for the agency to find a basis for their course of action and Courts won't second guess their decision. More importantly, this is not some new concept that arose during the RRFW litigation, but rather a longstanding legal principle. So RRFW had to know what what they were up against before they filed litigation. This is also the reason that collaboration is the only way to accomplish anything when dealing with public resource management.


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## benpetri (Jul 2, 2004)

sealion said:


> (and my pet peeve- winter trips are shortened to the hurried pace of 25 days!!).


25 days is hardly "hurried." Just did it last Feb with 8 layover days and tons of side hikes.

Although I agree that 30 days in the canyon would be an awesome time, trimming it down to 25 was probably a necessity with the increase in winter use. Problem with giving out 30 day launches is you would get someone (like me perhaps ) who would just camp for week straight at Nankoweap or Lower Bass and screw all of the trips behind them out of a primo attraction spot. Cutting it down to 25 forces people to move along a bit more and in general seems to promote better sharing amongst the privates.

30 days might be okay in January. Nobody goes in January...


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## Tom Martin (Dec 5, 2004)

*Three counter-points...*

Hi all, you know, sometimes, no matter how clear you are, folks just won't listen. Let's try again:

1. Rich seems to be unable to realize there were two motor-free alternatives in the last CRMP. One was a very low use alternative, one a very high use alternative. BOTH alternatives greatly increased self-guided summertime launches over what we have today. Even the low use alternative had 246 do-it-yourself launches in the summer compared to the 185 we have today. RRFW and a coalition of groups, including other recreational river running groups, encouraged the NPS to modify a motor-free alternative between B and C, that would have INCREASED do-it-yourself trips and do-it-yourself numbers overall beyond what we have today. The mainstream river running community understands that they are still getting the short end of the 50-50 stick when it comes to summertime access, thanks to the GCPBA.

2. On potentially banning all human activity in the Canyon...Rich loves to point that out, but it's a red herring. We point out a few very real facts, that the GCPBA was used by the river concessionair trade association so the river concessions, with no justification for their actual allotted use, could maintain their lock on summertime access, all couched in a bogus "compromise" where the majority of stakeholders were left out. 

3. Rich notes that to his knowledge, GCPBA has never received a penny from river concession holders. We will never know the truth to this statement. What we do know is the GCPBA received funds from a group representing concessions passengers whose #1 purpose is to safeguard their summertime allocation of use. We also do know we were very lucky indeed to stumble on the agreement the GCPBA made with the river concessions that includes this language:

"The Parties will use their best efforts to discourage their respective members from engaging in any activities that would, if undertaken by the Parties, be inconsistent with the Joint Recommendations and the terms of this Agreement"

There is much in the details here to be looked at. The issues are complex, and far from resolved. Self guided boaters are outraged that they were taken for a ride in this "compromise", especially when it comes to summertime trip access in Grand Canyon.

All the best, Tom


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## richp (Feb 27, 2005)

*Last Word*

Hi,

I'm on the verge of hitting the road, and I'm not very mobile with my internet access. So I'm going to back on out of this, and let Andy and others decide if they've got enough information.

The only thing continued discourse by Tom and me here would prove is something smart folks here already know. That both of us missed our true careers -- we should have been trial attorneys.

So on this one, you Buzzards can be our jury.....

Best to you all.

Rich Phillips


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## Caspian (Oct 14, 2003)

I am a practicing litigator. I have not had time to read the 9th Circuit's opinion, but did read the District Court decision when it came out a few years ago. I have NEVER seen a federal judge so completely obliterate arguments like was done in that decision. When I read it, I told one of the GCPBA board members that RRFW did not have the faintest prayer of a ever getting it overturned and that attempting to do so would be an absurd waste of money. The District Court judge just stitched it all up way too tightly to possibly be overturned. In my opinion, those who contend otherwise are asking you to drink the Kool-Aid. 

Imagine this - I take you to the Tallulah at 500, tell to you run the middle of Bridalveil, and you swim after the worst beatdown you've ever had. I take you back the next day at 700 and tell you to run the same line again, you can do it this time. That's what the appeal was on this case.


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## Andy H. (Oct 13, 2003)

Tom,

The statement below is very telling:



> We learned today that the GCPBA is getting donations from the GCRRA, the group representing commercial motor passengers, who's goal is to safegaurd motorized concessions river access.


It is a fact of life that unlikely parties become allies when mutual interests are at stake, especially when hard-won agreements are being threatened by litigation. It is not unheard of for this to happen while simultaneously opposing each other on other fronts or issues. This is how things happen when pragmatic leaders are involved.

If an organization such as RRFW doesn't understand this very simple fact, how can they be taken seriously at a negotiating table? And if RRFW does understand this, pointing out the above is simply pandering. None of the parties involved in the CRMP development got everything they wanted, however none want to restart the process and take chances with a new management plan. 

When the CRMP first came out, my knee-jerk reaction was that the GCPBA should file suit against the NPS. I wanted more summer allocation, no motors, and didn't want to go on the GC in the winter. Then I learned a bit more about what had transpired in the planning process, what the actual "survivability" of some of the other more attractive options (to private boaters) were, and how bad some of the other potential outcomes could have been. I also realized that nearly doubling the allocation for private boaters, with much of the increased allocation during what I consider the most pleasant time of the year in the desert, and when there won't be commercials with motors on the river any way, isn't such a bad deal after all.

So once more...

When RRFW filed their lawsuit, private boaters' allocation had been increased from about 58,000 to about 113,400 user days per year under the current CRMP. For the fourth time, I ask you to please answer my question about how or whether RRFW's suit would have increased private boater allocation over the year. 

-AH


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## Tom Martin (Dec 5, 2004)

Hi Andy, the RRFW, RTE, LR and WW litigation sought to rectify the imbalance in summertime access, an imbalance so blatant you even said you had a problem with it. While we worked hard to increase do-it-yourself allocation, it makes no sense to us to see that gain in the off season. The spring is motorized from April 1 on, and in the spring and fall there are still more concessions passengers than DIY folks. 

In a previous e-mail I noted "RRFW and a coalition of groups, including other recreational river running groups, encouraged the NPS to modify a motor-free alternative between B and C, that would have INCREASED do-it-yourself trips and do-it-yourself numbers overall beyond what we have today. The mainstream river running community understands that they are still getting the short end of the 50-50 stick when it comes to summertime access, thanks to the GCPBA."

For the fourth time, i have answered your question. All the best, yours, tom


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## Andy H. (Oct 13, 2003)

*Show us the Numbers*

Tom,

A review of the final CRMP Final Environmental Impact Statement (FEIS), which contains details about the various alternatives, raises some questions about RRFW's repeated assertions that "a motor-free alternative between B and C, that would have INCREASED do-it-yourself trips and do-it-yourself numbers overall beyond what we have today," or that "a modified B alternative, somewhere between B amd C, has the potential to greatly increasing [sic] self guided river access year round"

If one reviews the attached Alternative summary table and graphs from the FEIS (click the file name next to the PDF button at bottom of this post) that compare the various alternatives, the fallacy in RRFW's assertions become evident [for those unfamiliar with the alternatives listed, "Alternative A" is the previous system (waitlist, highly uneven allocation, etc.) that was replaced by the current CRMP system referred to as "Modified Alternative H"]. As there is no "Modified Alternative B" listed for comparison or available using a search for "Modified Alternative B" on the RRFW website, I'll assume that the RRFW numbers would be, as RRFW asserts, somewhere between the B and C Alternatives. 

So lets look at what RRFW states we would've gotten from "a motor-free alternative between B and C."

*1) User Days* - current yearly user day allocations (Modified Alt. H) for privates and commercials are 113,486 and 115,500, respectively. Under Alt. B, the proposed private and commercial allocations are 74,523 and 97,694; under Alt. C the proposed allocations for private and commercial are 115,783 and 166,814 user days, respectively. This means that private allocation would be somewhere between 74,500 and, under a best case scenario, 115,783. This is only about 2,300 user days greater than the current compromise allocation of about 113,500 user days obtained by GCPBA and AW negotiations. *Referring to an extra 2% user day allocation as "greatly increasing self guided river access year round" is quite a reach.*

*2) Trip Lengths* - current trip lengths for private boaters during the shoulder season and during winter are 21 and 25 days, respectively. In your posts above, you imply that trip lengths, particularly in the winter, might be longer under RRFW's "Modified Alternative B." Under both Alts. B & C, the maximum shoulder and winter season trip lengths are 18 and 21 days, respectively. At best RRFW's "Modified Alternative B" would result in 3 and 4 day shorter trip limits for private boaters in the shoulder season and winter, respectively, than the trip lengths allowed under the current compromise plan obtained by GCPBA and AW. *RRFW would not be "greatly increasing self guided river access year round."*

*3) Launches* - in all the Alternatives the number of launches per day vary throughout the year - you have to dig into the graphs and details in the EIS to unravel this story but here's the summary:

*Summer Launches:* Under Alts. B and C both privates and commercials have two launches each during the summer so the commercials are decreased from their previous 4 to 5 launches per day to only 2 (Note: this reduction may get a bit sticky if you're actually trying to negotiate an agreement with the outfitters at the table). Private launches under Alts. B and C go from the previous one launch daily to two launches daily. The current compromise plan, Mod. Alt. H, gives private boaters an average of 1.5 launches per day. *I'll give you this one, by obtaining a average of 0.5 launches per day more during summer, we actually see "increased do-it-yourself trips" over the current plan.*

*Shoulder Season Launches:* For privates during the shoulder seasons Alt. B has an average of 0.5 launches per day in March and April, and 1 per day in Sept. and October. Alt. C gives privates 1 launch per day for all shoulder season months. The current compromise plan obtained by GCPBA and AW gives privates 2 launches in March and an average of 1.5 in April, Sept. and October. If we can agree that the numbers 2 or 1.5 are greater than 0.5 or 1, its safe to say that *RRFW's plan does not provide "increased do-it-yourself trips" over the current plan*. 

*Winter Launches:* Alts. B and C give privates an average of 0.5 and 1 launches per day. The current compromise plan obtained by GCPBA and AW gives privates 1 launch per day. *RRFW's plan does not improve upon winter allocation for private boaters, and remember, the winter trips would be 4 to 7 days shorter under RRFW's plan.*


*In summary*: Without specific numbers associated with RRFW's "modified Alternative B" we can still deduce that, at best, it would add an average of 0.5 summer launches per day and take away motors. In the best case scenario, it might also add another 2,300 user days to the private pool (8 full 18-day trips added to about 500 trips per year), but maybe not. However RRFW's best case plan would reduce all winter and shoulder season trip lengths by anywhere from 3 to 7 days, increase the time of the year commercial trips would be on the river, reduce the number of shoulder season launches, and reduce the number of winter launches. 

One would expect that as often as RRFW states they have "a motor-free alternative between B and C" that is the the holy grail of private boater access to the Grand Canyon, details of that alternative would have been released long ago. 

*Neither I nor anyone I have ever spoken with have ever seen specific "Modified Alternative B" allocation numbers,* and I can't easily find it on RRFW's website. There are huge gaps between Alts. B and C, (i.e. would RRFW have commercial user days be about 97,700 or about 167,000? would private boaters get 75,000 or 115,000 user days?). The NPS didn't have the luxury of implementing a non-specific amalgam based on RRFW's vague pronunciation of a plan. The NPS had to make actual decisions about number of launches and user-days, length of trips, seasonal apportionment, etc. that the stakeholders could live with. 

If you just take the average of Alts. B and C, it sure doesn't increase the private boaters' access, and if you skew everything to the privates' favor, it sure doesn't look like it would be unchallenged by politically powerful and well-funded stakeholder groups with an interest in maintaining the status quo.

Please provide the link to the details of RRFW's "Modified Alternative B," preferrably its in a format that allows easy comparison to the other Alternatives. A release date prior to filing the lawsuit, or during the CRMP comment period would help RRFW's credibility in this matter. If you can't show us the numbers, then please quit asserting that RRFW would have increased private boater allocation over the current allocation had the NPS listened to you, or had the lawsuit been decided in RRFW's favor. Without specific numbers, no plan would have ever been implemented.

So for the fifth and final time, please tell us how RRFW's plan would have increased access for private boaters over the current compromise plan obtained by GCPBA and AW. 

Thanks,

-AH


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## Tom Martin (Dec 5, 2004)

*We did...here they are again...*

Hi Andy, thanks for your note. 

1) On user days, the present 50-50 allocation (that is not 50-50) lets the river concessions have the lion’s share of summertime access, the do-it-yourself river runners get the off season fall-winter-spring. The GCPBA folks say that’s 50-50. We looked at the allocations in B and C as part of the overall picture, that must include 50-50 or better summertime access. That’s what I am referring to greatly increasing self guided river access year round. User days are only one part of a bigger picture, and the present split of the actual use is bogus.

2) On trip lengths, we consistently and still support 18 day summer, 21 day spring and fall, and 30 day winter trip lengths.

3) On trip launches, yes, that was and still is the idea, more summer launches (two a day). And spreading commercial use out over a larger spread of the year makes sense to decrease crowding. 

4) Finally, you ask to see the Modified Alternative B/C compared with the other alternatives. We had this up six years ago, so you are certainly excused for not finding this on the front page of the RRFW web site. But it’s still on the web site, and here’s the link:

http://www.rrfw.org/sites/default/files/documents/River_Journal_Vol_2_No_3.pdf

Thanks for the opportunity to go over this. One thing is for sure, the issues that needed correction in the last CRMP still need correction in regard to wilderness protection and summertime access. 


All the best, Tom


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## ajpz (Mar 8, 2009)

Has the possibility of 'electric motors only' ever entered the discussion?


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## sealion (Oct 13, 2008)

looking at the RRfw alternative(the last column in the table at the bottom) I have to say I would not be for it. 4 launches a day? I am prejudiced in that I prefer my private trips to be in late winter season or early spring, and one of the reasons I go in the winter is because there are less people down there, and the only motors you see are science trips(how bout those user days? and the amount of firewood they burn motoring up and down the river collecting wood for their long days in camp if they're doing bat studies or some other night time gig?) Another reason is because it is not way f'n hot, and you can do some long hikes. Leave the summer to commercials and people who can only go in summertime-kid vacations etc. When I did guide, it was spring and fall trips only.


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## richp (Feb 27, 2005)

Hi,

I'm flying fast and low, with not much time to spend on this.

Supposing that you looked at the link Tom just provided, to RRFW's six year old chart. It's quite different than the hybrid B/C plan he advocated a few posts back. Ignore the fact it has several blanks and speculative footnoted numbers in key locations. One wonders why he first pointed readers in one direction, then another?

But you'd also find in this latest document that RRFW advocated four launches a day in the winter. That's the way RRFW achieves what it considers a superior allocation for private boaters. 

Then and now, there was/is no earthy reason to believe that this is a practical proposal. The Park can just barely fill a one-a-day launch pattern in the winter -- much less four. The Park needed a solution that actually had a chance of working -- not some fanciful construct that relied on trips that would be non-existent in the real world.

And of course there is the delicious irony of RRFW depending on four winter launches per day to make it's proposal work. In every imaginable venue, RRFW has criticized the Park and GCPBA for relying on winter trips in its "50/50" tally. If I had the time, I'll bet I could come up with a dozen quotes over the last several years, where RRFW or its supporters hammer the CRMP for over-reliance on winter trips to achieve balance. 

Thinking people think about these things -- particularly when they consider the overall credibility of RRFW's other positions.

FWIW.

Rich Phillips


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## Cutch (Nov 4, 2003)

I've been following this closely since I find it fascinating. It is very clear that the GCRRA, GCPBA, AW, RRFW and all the others have entirely different opinions as to what is the correct plan. I don't know the numbers, but I would assume that AW has the largest member base of do-it-yourself river runners looking to get on the Grand Canyon, being that it is an organization that focuses (albeit a subdivided focus) on all rivers rather than only the Grand Canyon. 

If this is the case, then I would also assume that AW worked with GCPBA and others closely and I would assume this about the majority of the American Whitewater crowd: 

Although most people aren't for motors the majority of us also aren't so completely against them as RRFW. They have a place, and I'm usually happy to avoid those places and those times of years. I am definitely against getting rid of the current motor use if it were to greatly decrease the number of user days, as others have stated. I am glad that motor use isn't year round, and can live with it. 

RRFW seems to have major issue with the allocation of days favoring privates in the off-season and not the summer months. I guess I look at it this way... As a kayaker, I have a very limited season to hit all of the amazing rivers and creeks that I want to run because most of them only have a season of a few months, a few weeks, and even a few days. That season, the on-season is usually the same spring and summer months as the Grand Canyon 'season', and therefore, when I just applied for permits, the most on-season Tina and I even attempted was August. After all, we don't want a Grand trip to interfere with all of the other sick paddling that can be had around our beautiful country. I'm not saying that I don't someday want to experience the Grand in the summer, because I certainly do. However, as a private boater the Grand is a great option because it's the Grand, and because it runs year round and affords some of the best off-season paddling anywhere. As a kayaker, rafter, and runner of all rivers, I think it's sweet that privates get the hookup in the off-season, at a time when commercials would go unused. 

I would love if privates had more launches than commercials. It would be amazing if all of our elite private boater friends could call up and get a permit whenever we want, and all of the commercials and paying lower-class citizens had to get on the waitlist or when a lottery. But that's not fair to the businesses that have been built around the Grand. I don't have any ties to those businesses, but if the raft guides can show the lay folk the beauty and value of rivers and river access, and maybe even encourage them to get more involved with rivers, then they certainly have value. From a membership standpoint alone (which is revenue to help fight the good fight) I would think American Whitewater sees the value of the commercial rafting industry as well. 

So to end, I would like to give a huge Thank You to Tom, Andy, and Rich (among others) for clarifying, these complicated issues. And another huge Thank You to GCPBA and AW for working together to create a system that gives private boaters a better chance to do the Grand. Tina and I both scored permits, Feb and Nov respectively, so as a private that has never scored a permit (and never been on the Grand) I believe that something is working. Too bad we have to cancel one.


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## Andy H. (Oct 13, 2003)

Tom,

Thank you for providing a link to a somewhat detailed description of just what RRFW means when referring to "a modified B alternative, somewhere between B and C." I would like to point out a few issues with the RRFW assertions.

*First,* RRFW apparently has a different definition of the word "between" than the one commonly accepted in the English language. A comparison of RRFW's proposed numbers of launches in different seasons, user day totals, commercial group sizes, and trip lengths, shows that many are outside the ranges set by the two alternatives referred to when RRFW describes their preferred allocation. This is at best sloppy, and at worst a misleading distraction to those trying to understand RRFW's proposal that aren't aware of the 6-year old document buried on their website and which can't be found by a search using any of the names by which the plan is referred to in public by RRFW. 

By repeatedly using phrases such as "a modified B alternative...between B and C" RRFW misleads people into thinking their plan is "between" other NPS-proposed alternatives and that any reasonable person could accept it. RRFW may state that the details of their plan were published on their website all along, but in practical terms, the details were buried so deeply as to be basically unavailable to the dialog until someone demanded to see them.

*Second,* to gain insight into the credibility of RRFW's proposed allocation scenario, merely examine RRFW's allotment of user days. This parameter is generally considered among the most important in any serious discussion of optimizing access to the Grand Canyon while also minimizing impacts to the ecosystem, attractions, and cultural artifacts, and maximizing the opportunity to get a perceived experience of relative solitude. While I have emphasized access for private boaters in this discussion, there are obviously limits to what is reasonable to expect so the resource can be protected. Under RRFW's alternative, up to about 483,900 user days are possible, compared with the current total CRMP number of about 229,000. Earlier in this exchange RRFW stated "We can't just keep on increasing use on the Colorado in Grand Canyon." How RRFW can say this while simultaneously proposing a plan with *nearly a half million user days* is truly mind-boggling. Furthermore, as Rich P notes, much of the RRFW's allocation boost is accomplished by greatly increasing available permits during the winter, which RRFW has consistently complained about in the current plan.

*Third,* RRFW repeatedly asserts that GCPBA and AW "sold out" to the commercial interests. This assertion implies that GCPBA and AW got something in return and that private boaters got a lousy deal. As for the complaint that there aren't enough summer private launches in the compromise plan, its my understanding that GCPBA studied the historical application dates for trips requested by private boaters under the old waiting list and observed that the April through early June, and September through mid October were the times that private boaters preferred. Conversely the outfitters could clearly show greater demand from mid May to the end August - a fairly good fit was identified that would be preferrable to the two major stakeholder groups. 

During the planning phases, GCPBA used the NPS's publicly-available trip simulator computer model and came up with river use scenarios that fit within the NPS requirements to minimize group contacts and provided constructive input to the NPS as they developed their scenarios. 

The opportunity to do this was not limited to GCPBA / AW, GCROA, GCRRA. Anyone could have used the NPS's trip simulator to develop scenarios that would comply with the CRMP planning criteria and lobbied the NPS for consideration of their proposals. Instead RRFW focused on scolding the NPS, splintering and destroying the support of GCPBA / AW, hinting at backroom intrigue and wrongdoing, and boasting of Congressional support for their position - support that never materialized.

The results of the GCPBA / AW approach includes the following changes from the previous system, among other things:


Nearly doubling private boaters' user day allocation,
Private boaters practically own the Canyon during the desirable shoulder seasons,
Motors are now prohibited for much of the shoulder seasons and during winter,
Privates get an additional small group launch every other day in summer,
Commercial oar and motor trips have shorter trip lengths than before,
Helicopter exchanges are limited to April through September instead of year round,
Commercial group sizes are decreased from about 40 to a maximum of 32 (guides now included),
Commercial groups are off the river for 5 months out of the year
RRFW refers to this result as a "sell out."

*Now, lets take a look at one more very important issue:* 

*What would have happened had RRFW succeeded, either in the CRMP planning, or in court, to eliminate motors from the Grand Canyon and radically cut commercial access during their preferred summer season?* 

First a little background:

Under the old plan, in the summer commercials could launch 7 or 8 trips per day with a total group size of up to 39 on oar trips and 43 on motor trips (including guides). Its easy to figure well over 100 paying custromers leaving Lee's Ferry daily. Under the RRFW scenario, commercials would be limited to two oar-powered launches of 16 members daily, all year round. This means that they'd probably be running three or four 18 - 22' oar rigs with at least one guide per boat, and each boat carrying only 3 or 4 passengers, for a total of 3 or 4 guides and 12 or 13 customers. This comes to a total of 24 - 26 customers launching per day supported by 6 - 8 guides. 

*The RRFW plan would substantially decrease the **outfitters' profitability and limit their clientele to only those able to spend the time and money to for two weeks on the river,* in addition to a few more days getting to GCNP and back.

Given this scenario, its easy to imagine a very well-funded lawsuit would be filed by the outfitters with their affiliated groups joining in. This lawsuit would have substantial public support from the large pool of folks who enjoy commercial trips and don't have more time than a week for their trip, thus requiring motors. This large, well-funded and well-connected stakeholder group could have made a very valid case that there is much more demand for week long motorized commercial trips than there is for two- to three-week oar trips, and that "the public is better served" by one-week motorized trips open to everyone, not just a relatively small group of "elite do it yourselfers" who can take 3+ weeks off work to go run the Grand. *The courts (or Congress) could have easily decided that the 2006 CRMP gave too much preferential treatment to the small group of "elite privates" and cut back the private use substantially from the old allocation. *

Anyone who assumes the commercial outfitters would just roll over without a protracted, vigorous, and well-funded fight, especially if their passenger load is cut by more than three fourths during their most popular season, is not approaching the issue pragmatically.

*I'm done debating with RRFW on this issue.* RRFW didn't approach the CRMP planning in a constructive manner, was never able to bring a nationally-recognized advocacy group on board to their cause, lost the first lawsuit badly and the appeal even worse, and in the process made future challenges to governmental agencies by the public more difficult. RRFW's goals are laudable, idealistic, and have a natural appeal to private boaters. But those goals are not practical, implementable, or likely to advance the cause of private boaters in the long run. RRFW's accusations and antagonism of successful advocacy groups splinter the boating community, distract us from more important and winnable battles, and weaken the private boating community in the eyes of potential adversaries.

My future lack of a response to whatever RRFW posts as follow-up is not, by any means, any kind of admission of defeat - I've made my case and am done with this particular issue for now.

*Kyle,*

Thank you for weighing in on this discussion. I really appreciate the way you've managed to put a number of issues into perspective for private boaters.

I think your following statement sums it up for most of us:



> Thank You to GCPBA and AW for working together to create a system that gives private boaters a better chance to do the Grand. Tina and I both scored permits, Feb and Nov respectively, so as a private that has never scored a permit (and never been on the Grand) I believe that something is working.


I don't know the GC stats for the 2011 permit lottery but if there are about 3500 applicants for about 500 launches, that's a 1 in 7 chance of getting a permit. Someone correct me if I'm wrong but it seems those odds are better than the lotteries on the Middle Fork, the Selway, Lodore, and a few other rivers.

-AH


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## lmaciag (Oct 10, 2003)

Thank you all for the on-line debate. I have gained a wealth of information and a better understanding of what happened before I became a river runner. 

Andy - Special thanks to you for the comparisons and contrasts. Can't wait to discuss further on the river with you.

And although I don't share Tom's opinion, I understand his passion.

I cannot wait to go back to The Grand. It is such a special place.

Thanks again!


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## Tom Martin (Dec 5, 2004)

*For the rest on Andy's missing info...*

Hi Andy, thanks for your thoughts. 

Yes, the RRFW plan was outside the two NPS motor free alternatives. This is not sloppy or misleading. 

It was sloppy and misleading for the NPS to not produce a workable motor free alternative. The two alternatives the NPS put out needed a lot of work. We offered a solution. You don’t like the offering. And your point in a public process is...?

Andy, a lot of these issues were gone over years ago. The allocation levels RRFW uses are based on studies of user day ceiling done in the 1970s, BEFORE we got better at cleaning up after ourselves.

To Be Very Clear, the present plan increased do-it-yourself use in the winter as a way to avoid equitable summer access. This is a real issue you and the GCPBA never address. And this is a KEY point RRFW continues to raise.

If you are saying the GCPBA and AW got nothing in exchange for a lousy deal, I will agree with you. 

Your understanding that there was data showing self guided river runners on the waiting list wanted shoulder season access and did not want equitable summertime access in incorrect. And the river concessions already HAD the lions share of summer access, given to them because they asked for it in 1972. Your claims that there is less demand in the summer season for self guided trips over commercial trips is bogus. There is no data to show this.

What we can do to look at demand, and the only data we have, is to look at lottery applications. That data is available here:
Grand Canyon National Park - Helpful Links for Noncommercial River Trips (U.S. National Park Service)

The stats from the 2011 lottery have just been run. There were 3726 applications competing for 274 launch opportunities. That may average to a one in fourteen chance, but trips in the dead of winter went unclaimed, while over 680 applicants wanted that prime launch date just after the end of the motorized season. Your chances for that date were one in 680.

This demand shows most folks want to go boating in the summer season (April through September), not the fall-winter-spring season (October-March). We have no demand figures for the concessions world. None. 

As to the computer model, we have said this before...the computer model was based on data showing how the river worked in 2000 With motors. Any modeling without models showed serious flaws in the model, not the potential to have a motor free river with equitable access. 

Yes, RRFW discovered the backroom deal, a deal the river concessions characterized as having their cake and eating it to. A deal that had it not happened, and according to the trade association staffer, would have had the river concessions going it alone "...the outfitters against everyone else."

The river community would have had real leverage to force the NPS to produce a better plan.

So now, here's what we have...

*Nearly doubling private boaters user day allocation, accessible in the winter

*Private boaters share the Canyon roughly 50-50 during the shoulder seasons, 3,221 concessions passengers (no crew numbers reflected0 to 2,926 self guided folks)

*Motors are now prohibited for much of the shoulder seasons and during winter, in a time they never ran historically

*Self guided folks get an additional small group launch every other day in summer, but still only get 123 groups of 16 people and 62 groups of 8 people compared with 476 concessions groups of 32 people

*In the summer, 14,385 concessions passengers travel the river compared to 2,270 self guided folks

*Commercial oar and motor trips have shorter trip lengths than before, as do self guided river runners even though two studies showed concessions passengers and self guided river runners alike said they wanted longer trips 

*Helicopter exchanges are limited to April through September instead of year round, thought they never ran year round, only flying April through September before the latest plan came out,

*Commercial group sizes are decreased from about 40 to a maximum of 32 (guides now included), and this was the historic average

*Commercial groups are off the river for 5 months out of the year which is the same as the last river plan

You are quite right to say RRFW refers to the result above as a "sell out."

You now head on off and seek to destroy a different view, ignoring the mess above...

In responding to your points, the river concessions would make money if they ran all oar trips. And they would still run short trips to Phantom, so folks wouldn’t have to spend a mandatory two weeks on the river, even though the only studies on trip length showed concessions passengers want LONGER trips, not shorter trips. 

Then you mention litigation. I agree with you it would have been better to have the river concessions sue the NPS, and have the court say the agency has discretion to manage the river as the Agency see’s fit... 

Instead, a self guided river running group (GCPBA) and the river concessions trade association fought against another river running group trying to get better summertime access.

I agree with you that the commercial outfitters would put up a protracted, vigorous, and well-funded fight and the river concessions admitted they would lose that fight…unless…they could get a few groups to join them…and that’s what happened.

You make an accusation that RRFW splintered the boating community. Wow. That's incredibly misguided. It was after all AW and the GCPBA and the trade association that said they would use their best efforts to "discourage their respective members from engaging in any activities that would, if undertaken by the Parties, be inconsistent with the Joint Recommendations and the terms of this Agreement. The Parties will not support any efforts by their respective members to engage in any activities that would, if undertaken by the Parties, be inconsistent with the Joint Recommendations or the terms of this Agreement." Talk about splintering the river running community. 

Bottom line, the river is still commercialized and motorized in the primary use season, and there is still huge unmet demand by real self guided river runners for real river trips in the summer. 

Thank you for this opportunity to present the "rest" of the story and to help remind folks of one more thing...we are talking about management of one of the seven natural wonders of the world. Management of the Colorado River in Grand Canyon should be the best we as a society can make it, not something that is mediocre at best, and damages wilderness character of the resource at worse case.

Happy river trails, Tom


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