grand canyon

Grand Canyon Backcountry Management Plan and Draft Environmental Impact Statement

Public comments are due by April 4, 2016

After five years of work, Grand Canyon National Park has released the 628 page Backcountry Management Plan / Draft Environmental Impact Statement (plan/DEIS) for public comment. The last BCMP was released in 1988 and did not address canyoneering. This updated plan considers newer recreational activities, like technical canyoneering.

Technical canyoneering in Grand Canyon NP involves all of the activities usually found when canyoneering in other areas, but there are additional complexities unique to the Grand Canyon. The terrain is generally far more difficult to traverse than other destinations. While day use canyoneering is common in the Marble Canyon area, the big, bold classic slots all require difficult multi-day backpacking access. Many require river-assisted travel (packrafts) to complete routes. A link to the full DEIS and an Executive Summary documents is provided below.

black line


This Grand Canyon National Park Backcountry Management Plan / Draft Environmental Impact Statement (plan/DEIS) evaluates the impacts of a range of alternatives for managing backcountry use in Grand Canyon NP in a manner that protects and preserves natural and cultural resources and natural processes and provides a variety of visitor experiences while minimizing conflicts among various users.

This plan/DEIS evaluates the impacts of the no-action alternative (Alternative A) and three action alternatives (Alternatives B, C, and D). Alternative A would allow backcountry use levels to remain similar to current and emerging uses such as canyoneering and extended day hiking and running (rim-to-rim) would not be managed. Under all action alternatives (B, C, and D) an adaptive management process would be used to manage climbing, canyoneering, extended day hiking and running, Tuweep day use, Use Area management and human waste management.

In order to help understand the various elements, the Coalition of American Canyoneers has reviewed the BCMP plan/DEIS and prepared comments for each area that we feel impacts canyoneering. In general, we support Alternative B (The NPS preferred alternative). However, there are some components of Alternative B that we feel need to be modified.

Click on any topic above to go directly to that section

black line

To submit comments go to:

A few notes about the process.
1) You are welcome to use CAC’s summary, but if possible, please try to speak from personal experience.
2) State the BCMP plan/DEIS proposal, your concerns, and your suggestion with reasons.
3) You don’t have to submit everything at once. You can make as many separate submissions as needed.
4) Note that the comment period closes on April 4, 2016. Comment & comment often!

black line

Adaptive Management

BCMP/DEIS Proposal: Under alternatives B, C, and D, the NPS will apply Adaptive Management to canyoneering. The application of Adaptive Management is discussed on page 46 of the plan/DEIS. In general, the NPS believes that canyoneering is new and adequate data doesn’t exist to precisely define a regulatory regime. The idea is to observe impacts if they appear in the future, and then define a solution to the impacts based on data collected from monitoring activities. The CAC and the NPS already have an established history of working together using an informal Adaptive Management process. CAC worked with the NPS to define the interim rules and etiquette for canyoneering that were published in the Grand Canyon Technical Canyoneering Bulletin.

The Coalition of American Canyoneers has done many service projects with the NPS to ensure Grand Canyon remains pristine including:
a – rope removal at Deer Creek and Garden Greek
b – bolt removal at Garden Creek, Deer Creek, and Blacktail Canyons
c – Flash flood debris removal from Garden Creek
d – funded a trail counter to collect resource usage data at Garden Creek
e – funded ropes for use at the Indian Garden ranger station for technical rescue efforts
f – conducted an extensive multi-day technical haul project to remove garbage from 1,000’ below the Tuweep overlook.

Issue: We are concerned that canyoneers and other user groups are not expressly included in the Adaptive Management Process.

CAC Comments: An ongoing dialogue between Park management and interested stakeholders is essential to the long term success of the Backcountry Management Plan. The stakeholders will have additional ideas based on use, can provide labor for services projects, and provide or raise funding to help with solutions.

The final BCMP should provide for systematic stakeholder involvement in the Adaptive Management Process. This could include notification, a comment period, and meetings to reach solutions.

RABT • River-assisted Backcountry Travel (aka packrafts)

BCMP/DEIS Proposal: Under all action alternatives, portable, personal watercraft used on the river for RABT would be carried in and out by the user during the permitted itinerary, max. group size would be 6, resource and visitor use impact monitoring would occur and adjustments made if needed. RABT trip length varies by Alternatives: Alternative B provides 31 specified zones having to do with entry & exit points (pages 57-58), the current is limit 5 miles.

BCMP/DEIS Proposed Rule: RABT trips would be limited to one river section per permitted trip or two river sections if on different days.

1) RABT users travel in groups no larger than 6 people and can camp at many small sandbars and ledge camps unsuitable for traditional river trips. As currently formulated, RABT users could camp at large river user camps which could create unnecessary conflicts between user groups.
2) How does the transition between zones work?

CAC Comments:
1) Add language from the Noncommercial River Trip Regulations in regards to camping and visitation restrictions. (pages 11-13)
Add language similar to the Grand Canyon River Courtesy Brochure: Smaller groups have advantages and flexibility that larger groups may not have. Camp at sites suited to the size and means of your party. Please be considerate!
2) In order to not concentrate camping at zone transitions, have camping be legal within +/- 1 mile of a zone transition .

BCMP/DEIS Proposed Zone 13: Closed from the Boat Beach to Horn Creek.

The closure of Zone 13 from the Boat Beach to Horn Creek makes access to the Trinity Creek slot canyon more difficult. Trinity Creek is a technically easy and scenic slot canyon suitable for intermediate level canyoneers. With the Alternative B Zone 13 closure, legal access to Trinity Creek is by rappelling through Horn Creek with a portage of Horn Creek rapid on river left (technically advanced requiring a run of the Horn Creek tail waves) or a long off trail access route by foot from Phantom Ranch to Trinity Creek.

CAC Comments:
We suggest that Zones 13 and 14 be adjusted. Zone 13 should be closed from the Boat Beach to 1/4 Mile downstream of the Pipe Creek junction with the Colorado River. Zone 14 would then extend from 1/4 Mile downstream of Pipe Creek to Granite. This allows canyoneers to walk on river left around Pipe Creek Rapid then float to 91 Mile Canyon for access to the Tonto level above Trinity Creek. Horn Creek Rapid is easily portaged on river right, but not on river left. Adaptive Management can be used to alter access if this approach comes up short in some way.

BCMP/DEIS Proposed Zones 27 to 31:
Zone 27: Trail (219.5) to Diamond Creek (225.9)
Zone 28: Diamond Creek (225.9) to Bridge Canyon (235.3)
Zone 29: Bridge Canyon (235.3) to Spencer Canyon (246.3)
Zone 30: Spencer Canyon (246.3) to Burnt Spring Canyon (260.0)
Zone 31: Burnt Spring Canyon (260.0) to Park Boundary (277.6)

RABT Zones 28 & 29 have river left boundaries and the proposal states: Hualapai Tribal Permit required for access across the Hualapai Reservation. Currently the Hualapai tribe will not permit exits on river left (with the exception of Diamond Creek).

CAC Comments:
We propose alternative zones that allow north rim loop hikes to be completed without needing to exit on Hualapai tribal lands.
Zone 27: Trail to Separation
Zone 28: Separation to Burnt
Zone 29: Burnt to the Park Boundary
Eliminate zones 30 & 31.

Canyoneering Anchors

The freedom to place fixed anchors as necessary is essential for the safe practice of canyoneering. A fixed anchor may be simply defined as an anchor that is left in place after use. In comments below, we make a distinction between removable fixed anchors that do not alter rock surfaces (e.g. a sling around a rock or vegetation) and permanent fixed anchors that require alteration of the rock where the placement is to occur (e.g. bolt or piton, see BLM memo). Piton use is practically nonexistent in modern canyoneering and is mentioned only in passing.

CAC strongly advocates the use of removable fixed anchors in Grand Canyon. In general, such anchors are overwhelmingly preferred by canyoneers for their safety, speed and ease of placement. Experienced canyoneers generally do not use bolts except when essential because it takes at least 40 minutes to hand drill a bolt in limestone. Bolting one’s way through a slot in the Grand Canyon would almost guarantee an emergency bivy. Additionally, there is a strong tradition in canyoneering of finding creative solutions to anchor problems and using bolts as a last resort. Even so, there are situations when a bolted anchor is preferable for reasons of safety and/or to reduce environmental impacts, but such situations are relatively uncommon in the Grand Canyon.

BCMP/DEIS Proposed Rule:
1) Authorization required for placement of new fixed anchors or equipment, and replacement or removal of existing fixed anchors or equipment (p. 48, table 2.4)
2) A decision framework for new anchor placement (p. 79, table 2.14b)
3) Implementation of minimum impact canyoneering education, clean canyoneering techniques, and removable equipment and anchors such as slings that can be placed and removed without altering the environment (p. 48, table 2.4)
4) Under all action alternatives there would be a framework for assessing anchor use (p. 208-209, under Canyoneering Management)

CAC interpretation of items above:
a) A canyoneer wanting to place a permanent fixed anchor in a canyoneering route must apply for and receive approval to do so before placing the anchor. The same applies to removal of existing permanent fixed anchors. This is the “case-by-case” approach referenced in Director’s Order #41, p. 16.
b) A process will be developed to aid the park’s decision making with respect to authorizing permanent fixed anchor placement/removal.
c) Techniques that employ webbing, wire nuts, cams, fiddle sticks, sand traps, and other removable fixed anchor techniques are allowed and do not require pre-approval, as implied by reference to “clean canyoneering techniques” (p. 48, table 2.4).
d) A process will be developed to track and evaluate the use of fixed anchors in canyoneering routes, and to monitor and mitigate environmental impacts as needed under Adaptive Management.

1) Anchor and Fixed anchors or equipment are not defined in the plan/DEIS. This is a problem because a clear, common understanding of terms is required for an effective anchor policy.
2) The committing nature of canyoneering and variable conditions in slots precludes the possibility of pre-authorization for permanent fixed anchors in every case. Violent flash floods occur each season that scour the slots, destroying fixed anchors and producing other dramatic changes. Thus, there will always be unforeseen situations where bolts will be required for safe passage through the canyon.
3) Grand Canyon NPS has not defined a process to manage fixed anchors; therefore, we are unable to comment on the viability of the process.

CAC comments:
To avoid confusion and promote common understanding, the park should adopt the fixed anchor definitions given above (generic, permanent and removable).

With regard to authorization for placement of new permanent fixed anchors and the decision framework for same, we propose that Grand Canyon NPS take a programmatic approach, as provided in Director’s Order #41, p. 15-16:, p. 15-16 (as opposed to a case-by-case approach):

Authorization may be issued programmatically within the Wilderness Stewardship Plan or other activity-level plan, or specifically on a case-by-case basis, such as through a permit system.

We suggest that the Grand Canyon NPS BCMP should programmatically authorize canyoneers to place and remove permanent and removable fixed anchors, with a strong preference for removable anchors and an emphasis on clean canyoneering techniques and practices. A successful example of a programmatic approach is the anchor policy in use at ZION NP, which has been formally in place since 2007 and is working well. Informally, it can be said to have worked well since canyoneering began in the park (1970s, if not earlier).

As stated earlier, there is no way for canyoneers to know in advance when or if a permanent fixed anchor will be needed, even on established and popular routes. This fact highlights a major difference between canyoneering and rock climbing: a rock climber can usually escape from a route by retreating downwards, whereas canyoneers almost always must complete the slot in order to safely exit/escape it. This reality means that authorization of fixed anchors must be programmatic if reasonably safe canyoneering is to be allowed in Grand Canyon NPS without occasional policy violations (a pre-authorization policy would result in occasional violations). Pre-authorization is not a workable option. Because the use of bolts in Grand Canyoneering is extremely rare*, the cost/benefit would be very high.

With respect to establishing a framework for assessing anchor use (p. 209), CAC would support a program under which canyoneers placing or removing any permanent fixed anchors are encouraged to inform the park of the action, including details such as date, location, type of placement/removal, etc. CAC would be happy to collaborate with Grand Canyon NPS on creating the reporting process, educating canyoneers about the process, and assisting the park in any permanent fixed anchor placement or removal if required.

BCMP/DEIS Proposed Rule:
Potential Adaptive Management (p. 48, Table 2.4)
• canyoneering day use permit identifying route
• use limits for specific locations such as or including:
a) restrict number of groups by day or season (overnight and day use)
b) change maximum group size (decrease or increase)
c) seasonal or permanent restrictions for natural and/or cultural resource protection implemented at specific locations to protect sensitive resources including, but not limited, to sensitive wildlife and plant species or archaeological sites
• develop Canyoneering Management Plan (additional NEPA would be needed)

We are concerned that canyoneers and other user groups are not expressly included in the Adaptive Management Process.

CAC Comments:
We believe that an ongoing dialogue between Park management and interested stakeholders is essential to the long-term success of the Backcountry Management Plan. The final BCMP should provide for systematic stakeholder involvement in the Adaptive Management Process.

Additional Issue:
There is no proposal in the plan/DEIS concerning the rule of using only black webbing for fixed anchors (from the Grand Canyon Technical Canyoneering Bulletin).

CAC comments:
The black webbing rule should be included in the BCMP fixed anchor policy. Climbers and canyoneers have been asked to use “color matched” webbing for a long time, without much success. Other colors can work in some places, but black always works due to the universal presence of shadows, cracks, mineral streaks and other black features, independent of rock color. This simpler, more specific approach has a greater chance of success than the traditional color-matching plan, thus reducing visual impacts.

*Rich Rudow descended 165 Grand Canyon slots establishing 800 to 900 anchors and has placed 10 bolted anchors in the last 10 years.

Deer Creek Narrows

Background: TThe lower Deer Creek narrows, below the first waterfall, were closed by Superintendent Compendium order in April of 2012 at the request of Indian tribes affiliated with Grand Canyon. CAC, and other user groups, protested the closure on the grounds that the lawful public participation in a controversial closer did not occur. The NPS subsequently agreed to a temporary closure with the opportunity for the public to comment in the Backcountry Management Plan process. That process is now underway. Alternative C in the DEIS opens Deer Creek to canyoneering descents while Alternative B, the NPS preferred alternative, closes the lower Deer Creek narrows permanently.

With documented technical descents at least since the 1960’s (see May 1969 National Geographic Magazine, page 707). The lower Deer Creek narrows are widely considered to be one of the finest slot canyons in the World. The representative of the affiliated Indian tribes, during a call with the Superintendent and various user groups including CAC, listed many issues with Deer Creek visitation including a loud boisterous disrespectful atmosphere on the patio, impacts to rock art in the area, multi trailing, damming the water on the patio, throwing objects in the slot, and other broad based impacts. The narrows are sacred to the Kaibab Paiute tribe and they believe that their deceased descend into the slot to enter the afterlife.

BCMP/DEIS Proposal: Alternative B closes the lower Deer Creek narrows permanently, while Alternative C in the plan/DEIS opens Deer Creek to canyoneering descents.

1) The closure of the Deer Creek narrows was unlawful. Under 36 CFR 1.5(b), a controversial closure requires a public process by listing the closure in the Federal Register. Additionally, under 36 CFR 1.5(c), the NPS must state why less restrictive measures will not suffice prior to closure. Neither of these rules were followed. In October of 2012 CAC agreed to not pursue legal means for an immediate reopening of the Deer Creek narrows if the closure was temporary and public comment on the issue would occur within one year. The acting GRCA Chief Ranger agreed. This public comment period is finally open 3.5 years later. It’s disingenuous that the NPS preferred alternative is for the status quo, a permanent closure.
2) The affiliated tribes identified many issues with Deer Creek visitation that are not addressed by the closure of the Deer Creek narrows. We strongly support the right of the tribes to visit Deer Creek in a quiet and respectful environment.
3) In DEIS chapter 4, environmental consequences for Alternative C, a series of impacts are described to occur when canyoneers enter the Deer Creek narrows. These impacts include multi-trailing, water contamination from sunscreens, impacts to plant and animal species, and impacts to archaeology. The narrows are frequently scoured by enormous flash floods. There are no trails, plants, animals or archaeology in the narrows. A closure of the narrows doesn’t prevent recreational users from entering the water above the narrows contaminating the water with sunscreen. There is no scientific data presented to backup these claims. We categorically reject these claims without scientific data to back them up. Furthermore, if a proper scientific process identified an impact, Adaptive Management would be used to mitigate the issue and many options short of an outright closure would be considered. Lastly, the claim that climbing anchors in the narrows has diminished aspects of integrity of setting, materials, and feeling of this site is complete hearsay. Anchors are not visible to people who are not rappelling through the narrows. Furthermore, we believe improvements to the greater Deer Creek area to include designated campsites, trails, and a composting toilet have impaired the site for listing under the National Historic Preservation Act. Here is an example of a Deer Creek narrows flash flood:
4) The NPS faced a similar conflict between tribal beliefs and recreational users at Devil’s Tower National Monument and resolved the issue with nuance and compromise. No effort was made by GRCA to explore similar solutions.

CAC Comments:
We believe the Tribes with a deep connection to Deer Creek should be able to visit in solitude to practice their beliefs. We propose that the greater Deer Creek area be closed to visitation during times these tribal beliefs are being exercised. The greater Deer Creek area and the narrows should be open for recreational visitation, including technical canyoneering descents to the river, otherwise.

We propose that the Adaptive Management process described in the DEIS be used to determine the best way to accomplish this compromise in Deer Creek visitation. We believe that the stakeholders, to include the tribes, CAC, and others, should be part of the design to identify the best solution to better manage the Deer Creek resource. Ideas to be considered might include a permit system for Deer Creek narrows visitation, the mechanics of how to close the area when tribes want to visit, and educational options to better inform the user groups of the sensitivity of the area when they visit.

Great Thumb Mesa & Tenderfoot Rim Access

Background: President Ford signed the Grand Canyon National Park Enlargement Act on January 3, 1975 (public law 93-620). This law nearly doubled the size of Grand Canyon National Park and also appropriated a Havasupai Reservation Addition of 185,000 acres. Additionally, the Havasupai obtained the right to use 95,300 acres of the National Park as a traditional use area. The additional reservation lands included Great Thumb Mesa and Tenderfoot Rim, effectively blocking access to the National Park between roughly Forster Canyon on the east and National Canyon on the west. In order to ensure that development of rim areas could not occur, the Act maintained a ¼ mile setback from the rim around Great Thumb and Tenderfoot Rim as National Park lands. Section 10(b)(6) of the Act required recreational user access to Park lands across the newly established Reservation lands. The Secretary of the Interior, in consultation with the Havasupai Tribe, was ordered to define the access mechanics. In March of 1982 the Secretary Land Use Plan was published.

BCMP/DEIS Proposal: The Grand Canyon NPS would work the Havasupai Tribe on pilot program to permit ten small groups (1-6 people) across Great Thumb Mesa to the park’s backcountry from March to May. Permit conditions include: tribal escort, two vehicles maximum, four-wheel drive/high-clearance, and assigned parking.

Even though public access mechanics across Great Thumb Mesa were defined in the 1982 Secretary Land Use Plan, the plan was never implemented. Havasupai tribal representatives routinely deny access to the recreational public contrary to the law. The Department of Interior abandoned its authority granted under the Act to monitor and ensure implementation of the plan, again contrary to the law.

In the Act, the Secretary of Interior, in consultation with the tribe, would define the methods of public access. The 1982 Secretary Land Use Plan provides just 2 methods of access off Great Thumb because of objections from the tribe (Apache Point, Great Thumb Deer Trail). This is contrary to the law and the legislative history leading to the law. The Havasupai Tribe did not have veto power over access routes. Other routes off Great Thumb were well known and used by backpackers prior to the Act.

The Act clearly included Tenderfoot Rim, the rim lands between Havasu Canyon and National Canyon, for recreational public access. The 1982 Secretary Land Use Plan did not provide means for public access across Tenderfoot Rim, contrary to the law, again deferring to the Tribal view that no suitable access existed. Backpackers and climbers had been using various access points off Tenderfoot Rim prior to the passage of the Act.

The plan/DEIS identifies a trial program with 10 permits available per year for access across Great Thumb. The Act in no way contained such restrictions on the level of access. Currently the resource in BS9, BT9, and BU9 can support two groups of 6 hikers at a time suggesting a substantially larger volume of recreational users needing to cross reservation lands to enter the Park.

CAC Comments:
Grand Canyon backcountry use areas BS9 and BT9 envelope Great Thumb Mesa and are quite large. Access across Great Thumb Mesa reservation lands is essential to reach key destinations within these use areas including 11 slot canyons. We suggest access off the rim of Great Thumb be allowed at the following places: Apache Point, Enfilade Pt., the Cave route near the head of Fossil Canyon, The Owl Eyes route near the tip of Great Thumb, the Old Deer trail to 140 Mile Canyon, the 140 Mile Canyon slide route, the route between Hamidreek and Gatagama points, the Paya Point route, and the Towago Pt. route. A map can be found here:

Grand Canyon backcountry use area BU9 is quite large encompassing all of Yumtheska Mesa and the eastside of National Canyon. Access across Tenderfoot Rim is essential to access 8 slot canyons. We suggest access off the rim of Tenderfoot Rim at the following places: the 2-203 route, the 5909 route, the Flatiron Butte route, the Tenderfoot Route, and the Yumtheska Pt. route. A map can be found here:

We believe that 10 permits per year in the spring, as currently proposed in the plan/DEIS as a trial program, will be insufficient for the projected permit demand. We suggest that Adaptive Management be applied, with input from the stakeholder groups, to increase the number of permits if demand dictates.

Boundary Road

BCMP/DEIS Proposal: Boundary Road on the South Rim provides an alternative access to the South Bass Trail Head. Alternative C indicates that opening the boundary road will cause environmental damage resulting from road maintenance. Alternative B, the preferred alternative, keeps boundary road closed.

CAC Comments:
Boundary road should be opened and NOT maintained. There are plenty of other roads in the Grand Canyon NP system that are handled this way. There is no reason to maintain the road. The road across Havasupai lands and from Havasupai lands to South Bass are not maintained. Boundary provides alternative access to South Bass for suitable bicycles and vehicles.

Canyoneering Itinerary Requirement

BCMP/DEIS Proposal: The plan/DEIS requires a disclosure if technical canyoneering is part of an itinerary and it requires the specific route to be disclosed. These disclosures are supposed to be for information purposes only.

1) The Grand Canyon permits office is currently “red flagging” any permit where the canyoneering or packrafting check boxes are marked. This red flag then automatically requires the permittee to disclose the route on a Hiker Information Sheet (HIS). Too often CAC members are having permits refused because permit office staff are unfamiliar with the route(s) requiring substantial interaction to clear up the misunderstandings.
2) The intention of this plan/draft DEIS rule is unclear. What will the information be used for? Is the NPS assuming the responsibility of a safety contact for the permittee group? Is the information used to increase scrutiny of the canyoneering user group? Is the information used to understand resource impacts and how to potentially mitigate those impacts?
3) Canyoneering itineraries can vary substantially from the original plan while still adhering to the camping permit use area. Groups may move slower through canyons due to new obstacles or may move faster with high experience levels. It’s common for canyon technical descents to be abandoned due to the condition of the group after the rim entry or the weather situation before the technical descent begins. What happens if canyoneers don’t precisely do what they intended when filling out the permit form?

CAC Comments:
We support the collection of itinerary data to better understand resource impacts and to make better decisions to mitigate those impacts as part of Adaptive Management. We do not support the collection of itinerary data for any other reason. Most canyoneering occurs in Wild and Primitive use areas where there is a substantial expectation of solitude. The use areas are very large to allow people to roam and to preserve this important Wilderness value. The notion of providing in advance a detailed step by step itinerary flies in the face of this principle.

We encourage all canyoneering groups to have an emergency contact with a detailed itinerary and plan. Some canyoneering groups may have a means of communication with the emergency contact to check in at appropriate points on the itinerary. If the group misses a check in, the emergency contact can call the NPS with the detailed plan and any deviations from the plan that occurred in the field. We don’t believe the NPS wants the responsibility, or has the manpower, to take on this responsibility directly.

Because canyoneering itineraries can change in the field, we suggest a monitoring system that collects the actual canyoneering itinerary after the trip has completed using an online system. Death Valley National Park has proposed this in their Wilderness Plan. We believe that more accurate data will be collected after the fact and we support the Death Valley approach. The development of this online data collection system could be very simple and CAC would be willing to lead the effort, or support NPS efforts, to create it.

Commercial Filming

INTRODUCTION: BCMP plan/DEIS Summary Table page 78 Commercial Filming
Alternative A: Park policy does not specifically address commercial filming in backcountry
Alternatives B, C, D:
1) Filming purpose must meet necessary and appropriate Wilderness test
2) No commercial activity in Wild Zone
3) Wilderness commercial filming requests 
evaluated under MRA Glossary page 506 Commercial Filming that involves digital or film recording of a visual image or sound by a person, business, or other entity for a market audience (Management Policies

Additional Background Information:
“The service…shall promote and regulate the use of … national parks … [its] purpose is to conserve the scenery and the natural and historic objects and the wildlife therein and to provide for
 the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” (16 U.S.C. 1)
It is the policy of the National Park Service (NPS) to allow filming and photography when and where possible, while adhering to this mandate. Therefore, when reviewing filming applications, the primary concerns of the NPS are potential impacts to park resources and disruption of visitor use.
2) Taken from: NPS Management Policies 2006 – A permit will not be required for a visitor’s personal, noncommercial filming and photography activities within normal visitation areas and hours. (Outside normal visitation areas and hours, a permit may be required.) However, all commercial filming activities will require a permit. Commercial filming means filming that involves 
the digital or film recording of a visual image or sound
 recording by a person, business, or other entity for a market audience. This includes recordings such as those used for a documentary, television or feature film, advertisement, or similar project.
In accordance with Public Law 106-206, still photography (whether commercial or noncommercial) will not require a permit unless
– it takes place at a location(s) where or when members of the public are generally not allowed, or
– it uses model(s) or prop(s) that are not a part of the location’s natural or cultural resources or administrative facilities, or
– the Park Service would need to provide management and oversight to prevent unacceptable impacts.
Notwithstanding the above policies, commercial media coverage of breaking news never requires a permit. However, it is subject to the restrictions and conditions necessary to protect park resources from unacceptable impacts.
Performance bond and liability insurance requirements must be met, and all costs incurred by the Service in writing the permit, monitoring, providing protection services, or otherwise supporting filming or photography activities
 will be reimbursed by the permittee as a condition of the permit. A location fee will also be required as a condition 
of the permit. The amount of the fee will be based on the fee schedule current at the time the permit is approved. Neither the location fee nor the cost recovery charges may be waived.
The Service will not censor the content of any
 filming project, or require finished film products for review, files, or documentation purposes. However,
 a superintendent may review a story board or other material if requested by the applicant to help determine whether (1) the information about the park is accurate, (2) a credit line would be appropriate, or (3) it would be appropriate for the Service to actively assist a filming activity or authorize use of the arrowhead symbol.

BCMP/DEIS Proposal: The essence of Alternatives B, C, & D is to limit filming in the Grand Canyon NP. In particular commercial filming would not be allowed in the Wild Zone. Alternative B calls for the purpose of filming to meet a necessary and appropriate Wilderness test, no commercial activity in the Wild Zone, and wilderness commercial filming requests 
evaluated under a minimum requirement analysis.

The Wild Zone constitutes a significant portion of the Grand Canyon. Images of these areas should be shared with the world as with all other Grand Canyon zones.

Throughout the BCMP plan/DEIS, there is reference to the term “market audience.” However it is not specifically defined in the various documents cited above. It is possible that individual backcountry users on permit in the Wild Zone might take still photographs or video using relatively small cameras. These images might find their way into websites that ultimately could generate a profit to its owner via internet advertising clicks. The photographer might be found in violation of: “Filming that involves digital or film recording of a visual image or sound by a person, business, or other entity for a market audience (Management Policies”

CAC Comments:
The Coalition of American Canyoneers believes that images of all zones in the Park should be shared with the world. This is already in accordance with Public Law 106-206 as noted in the NPS Management Policies 2006 for still photographs. Thus currently it is legal to take a still photograph with a smart phone but a video on that same phone would be illegal. The CAC requests that the regulation be reworded such that still images and video be treated in the same manner. Obtaining and sharing these images in all Park Zones would be allowed.

The CAC recognizes that there is a significant difference between a group of six backcountry users on permit using small photographic equipment easily carried while backpacking and that of a large Hollywood style full length feature film crew. We appreciate that the large film crew could have a substantial impact on the backcountry and hence should be regulated. Technology has advanced. Individuals now can personally accomplish what large groups were required to do in the past. We believe that the term “market audience” may be at the heart of this discussion. Consequently we request that the Park either fully define “market audience” or cease use of the term. Further, we request that a concrete distinction be made with regard to a small permitted group using personal camera equipment vs. a large scale film production company.

Dividing Boysag Use Area (LB9)

BCMP/DEIS Proposal: This has not been addressed in the plan/DEIS, although it was requested in the public scoping prior to the plans release.

Use area LB9 in the western Grand Canyon is excessively large. Canyoneers and hikers in Mile 150 Canyon can be blocked from access by canyoneers and hikers in Tuckup Canyon 14 river miles away. The chance of overlapping in the current use area is practically zero. This can also create a safety issue in that canyoneers descending 150 Canyon may try to get through the entire canyon and across the river in one day to avoid needing a permit to camp in LB9 when it would be safer to allow more time and camp within the canyon.

CAC Comments:
We propose that LB9 be broken into two use areas with the new boundary at Cork Spring Canyon. We propose that both use areas be designated Wild. This is especially important now that only two groups of 6 are allowed in Wild use areas.

River Zone/Human Waste Disposal

BCMP/DEIS Proposal: The plan/DEIS proposes to adopt the River Zone identified in the 2006 Colorado River Management Plan. The River Zone is from the shoreline along the Colorado River up to the historical high-water line. It would include beach campsites such as Granite, Hermit, Hance Rapid, and South Canyon. Under all action alternatives the new plan will require human waste to be carried out from River Zone. The Human Waste policy will be subject to Adaptive Management, with possible future actions to include replacing or removing existing toilets, installing toilets at additional sites, or a year-round waste carry-out requirement at all, or specified, use areas or zones.

There is no clear definition of the exact areas to be considered, nor is it clear if this would include the area (trails or routes) between selected beaches. In addition, there is no language that dictates that you wouldn’t be able to camp along the river, yet go above the high water zone and dig a cat-hole. Specific to Hance Rapid, there is a documented problem with damage to the dunes behind the beach. Extensive social trailing is evident and is undoubtedly made worse by efforts to use or cross the area in search of suitable toilet locations. Since this dune area falls outside the River Zone, we are concerned that the recommended policy will not protect the area.

CAC Comments:
1) Define the areas to be considered on implementation of the BCMP and clarify the issue with travel.
2) CAC supports the policy that any camping within the River Zone should require that human waste be carried out of the canyon and properly disposed of (Wag Bags or similar systems). If you are camped in a River Zone, it would be illegal to hike above the high-water mark and dig a cat-hole. This requirement should not extend to hiking within the River Zone, but contain language to discourage human waste deposits in concentrated areas.

Thank you for your time and effort!