Final American Canyoneers’ Proposal to NPS for Arches NP:

Comments due by July 9th. Comment at:
Arches Climbing and Canyoneering Management Plan

To:
Planning & Compliance Coordinator
Southeast Utah Group/National Park Service
2282 S. West Resource Blvd.
Moab, UT 84532

American Canyoneers
℅ Wolf Schuster
Director of the Board
2517 Hobbs View Circle
Layton, UT 84040

American Canyoneers is a non-profit, non-partisan, member-run organization focused on promoting canyon access, conservation, education, and safety. Our fledgling organization’s membership is paralleling the growth of this rapidly expanding sport and offers a reflection of those that use and love America’s canyons. Our network reaches hundreds, if not thousands of canyoneers and canyon enthusiasts via our website, two active canyoneering forums, Facebook, community service projects and through our members’ active participation in the sport.
Members of American Canyoneers have become action-oriented caretakers of the canyons and hope to set a standard of Conservation practices to preserve these environments for future generations.
To learn more, visit our website: American Canyoneers

American Canyoneers’ Board of Directors, in consultation with our members, has thoroughly reviewed the Climbing and Canyoneering Management Plan. Please review our comments below and consider our amendments to the NPS preferred Alternate (B).

American Canyoneers Position Statement:

The organization did not exist in 2010; therefore, American Canyoneers is not on the record with comments that would favor any particular option. In general, American Canyoneers supports the NPS preferred Alternative (B) for the following reasons:
1) It will reduce the environmental impact on higher traffic routes (the NPS will maintain the preferred access routes to avoid multi-trailing) using actual data to make determinations on how to manage impacts.
2) It will allow new routes to be created (new routes are currently banned).

1) Permits will be required in areas outside of the Fiery Furnace for the first time. Permits will be free and will be available outside the Visitor Center at a self-serve kiosk. Permits will also be available at the Lost Spring trailhead at the north side of the Park. Group size restrictions will be put in place. Up to 10 canyoneers can be in a group throughout the Park (except Lost Spring Canyon and Fiery Furnace). If there are more than 10 people in a group the group is required to break into subgroups of 10 or less and conduct different routes or the same route staggered in time to avoid long queuing at anchor stations. The group size limit in Lost Spring Canyon and the Fiery Furnace is 6 people.
2) Establishment of new routes that cannot be “ghosted” (descending a canyon without leaving evidence of an anchor) will require a formal application process and study period before being allowed.
3) Establishment of new anchors with fixed gear (bolts or webbing – anything that is left behind is considered fixed gear) will require advanced permission. Replacement of damaged anchors to improve safety will not require permission. Use of “ghosting” methods is required when natural features allow safe application of methods. Pitons are not allowed. If bolts are used, chains are highly preferred over webbing. Chains must be painted to match the rock. Webbing must match the rock. No motorized drills in Wilderness and only by permit outside Wilderness.

American Canyoneers Alternative B Comments:

Permits: We urge Arches National Park to provide an online permit system in addition to the planned kiosk solution. Permit compliance is likely to be higher with the improved convenience of an online system.

New Routes: Climbing and Canyoneering are completely different disciplines. The rules governing establishment of new routes are clearly drafted from a climbing point of view. The rules do not support the establishment of new canyoneering routes. Climbers can visually inspect new routes from safe vantage. Canyoneers cannot see what’s inside a slot canyon in advance. We urge Arches to make the following changes to support establishment of new canyoneering routes:
1) The descending party applies for a permit to descend a new canyon. Every attempt is made to “ghost” the canyon, but webbing can be left behind if required. Webbing will be of a color that most matches the native rock color. If a bolt is required for a safe descent it can be placed. After the descent is complete the canyoneer provides the anchor information to the NPS and an assessment of the route is undertaken. The canyoneer would be required to alter the anchors if the NPS determines a “cleaner” solution is in the best interest of the Park.
2) In Appendix G, the NPS strongly advises the use of chains at bolt anchors stations. Chains are rarely ever acceptable in slot canyons, especially sandstone slot canyons. During flash floods the chains whip around causing considerable damage to the rock. We strongly suggest that Arches require the use of webbing for all anchors inside flood prone areas to protect the environment.

Guiding: Currently, Arches National Park does not allow canyoneering commercial guiding. Canyon guides often allow members of the public to get their first technical experience. Most guides are highly skilled and can convey the proper etiquette and safety processes to new canyoneers. The user data presented by Arches National Park in the plan does not demonstrate usage levels likely to create conflict between guided and recreational groups.

Thank you for your time and consideration,

Wolfgang Schuster,
President, American Canyoneers