Comments submitted by Rich Rudow for the Backcountry Management Plan Scoping process in June, 2011

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Backcountry Management Plan Comments
A technical canyoneering point of view
Rich Rudow

1 – Access to GCNP through tribal lands

In general, tribes should not block access to GCNP. A right of way through tribal lands should be assured with due regard to cultural resources. The tribes should be paid for allowing or providing access. The tribes should have no obligation to maintain or improve dirt roads used for access.

Navajo Lands Access:
The Navajo tribe currently has an excellent hiking permit program that allows hiking on tribal lands and access to GCNP. It might be an acceptable model for the other tribes to consider. The NPS should encourage the Navajo Tribe to continue with their current program as discussions on the expansion of other tourist operations continue.

Hualapai Lands Access:
Contrary to some reports, the Hualapai Nation does not offer permits to hikers with the exception of a day hiking permit at Diamond Creek. When you call to inquire about a hiking permit you’re bounced around to various departments usually ending with the Fish and Game department. They eventually inform the hiker that permits are not available. Hualapai policies currently block access to the Colorado River from the south for nearly all of Western Grand Canyon, a vast area consisting of more one third of the total Colorado River distance through Grand Canyon. As enterprising as the Hualapai are with regard to tourist operations from Hualapai lands, a hiking permit program is noticeably absent. I can only assume that the tribe feels that the economics are not interesting.

Here are a few ideas that might create an acceptable economic model for all three tribes that border Grand Canyon:

1. Modestly Increase the fee charged for all backcountry permits. Provide the overage to the three tribes that control access to vast parts of GCNP: Havasupai, Hualapai, and Navajo. While most hikers use corridor trails and won’t benefit from this fee increase, it provides a way for the tribes to have a reasonable economic basis to administer a permit program. It also creates jobs for the tribes and allows them to have visibility into who is hiking on their lands and where hikers go. The $5 per night permit fee is low and a modest increase to benefit the tribes will not create a hardship for most Grand Canyon hikers.

2. Administering a hiking permit program is costly and the tribes might argue that the demand is too low to justify the cost. Another idea is for the hiking organizations to buy an annual block of permits on a “use it or lose it” basis. For example, the Grand Canyon Canyoneering Association could buy a block of permits from the tribes and administer distribution of the permits to its members. If all permits are not used annually, the organization loses out. This concept could ensure that there is enough money coming to the tribes to enable a hiking permit program. It also provides a way for the tribes to keep administrative costs low since the organizations would have the obligation to administer the permit process. In this example, the Grand Canyon Canyoneering Association would provide the tribes with information on permits issued so they know who is on tribal lands, when they will be there, and what routes (or use areas) are being accessed.

3. Another idea, especially if all backcountry permit fees are modestly raised to benefit access to tribal lands, is for the NPS to administer permit distribution. The NPS already has the infrastructure for permit distribution and management and could simply add new use areas on tribal lands.

4. The Hualapai tribe seems to be particularly sensitive to the fact that river runners hike on tribal lands frequently without a Hualapai permit. Of course, there is no way today to obtain a Hualapai hiking permit. Another idea is for the NPS to charge an additional fee above the $100 permit fee for river trip participants (private AND commercial trips) and remit that fee to the Hualapai for hiking and river left camping access. Even a modest increase in the river permit fee would bring a substantial economic benefit to the Hualapai tribe. River trips are expensive and a $5 increase in the permit fee is inconsequential compared to the cost of a river trip. This idea would bring roughly $100,000 in annual income to the Hualapai Tribe. Even if the tribe insisted on a much higher fee, like the $65 fee per person to depart at Diamond Creek, it would still only add a few percent to the cost of a river trip and would settle the issue of hiking and camping on river left.

5. The NPS could also add a very modest charge to the gate fee to enter GCNP to benefit the tribes bordering the Park. The fee could be negotiated in a way to settle many open disputes. Hiking access could be afforded as part of those “gate fee” negotiations.

Great Thumb Mesa Access:
Congress specifically created language requiring GCNP access off Great Thumb Mesa when the Havasupai acquired the right to Great Thumb in 1975. In fact, GCNP includes a ¼ mile of the rim of Great Thumb Mesa. Yet access to Great Thumb is blocked by the tribe. At times Great Thumb is patrolled by armed tribal members on horseback. At times a gate across the road on Great Thumb is locked. There is no way to get a permit to access GCNP via Great Thumb. As a result, hikers frequently sneak out on Great Thumb to access GCNP without formal tribal permission to cross tribal lands. Instances of wildlife poaching have also been reported out on Great Thumb. The tribe doesn’t know if someone on tribal lands is involved in legal (hiking) Vs illegal (poaching) activities. A formal and mutually accepted process to carry out the Congressional access mandate is required to remove confusion and allow to tribe to better police Great Thumb from illegal activities. Here are a few ideas:

1. The Havasupai tribe already manages a hiking and camping permit program for access to Supai campground in Havasu Canyon. They could simply administer a new permit for the right to drive through tribal lands to the rim of Great Thumb to access GCNP. As part of the permit process they could acquire the license plate number of the authorized vehicle to help them sort through legal Vs illegal users.
2. Policing activity on Great Thumb will incur an expense to the tribe. It’s not clear how many permits would be sold for Great Thumb access. Another way to fund a Great Thumb permit program is for hiking organizations to buy blocks of permits. For example, the Grand Canyon Canyoneering Association would be willing to purchase a block of permits on a “use it or lose it” basis. This ensures that the tribe receives meaningful income for the program without the obligation to administer it.
3. A Havasupai tribal member is often posted at the gate demarking the start of tribal lands on road 328. This road is used to access Pasture Wash and Great Thumb Mesa. The tribal member would increase gate fees if access to Great Thumb were available. Hikers that sneak on to Great Thumb already pay this gate fee, however, the volume of hikers is small due to the ambiguity of access rights. If the ambiguity were removed, gate fees would increase significantly.

Yumtheska Mesa Access:
Yumtheska Mesa is in GCNP at the Esplanade level sandwiched between National Canyon on the west and Havasu Canyon on the east. It is virtually inaccessible because the Havasupai and Hualapai tribes both restrict access by virtue of providing no way for hikers to acquire a permit to legally cross their lands to access the GCNP. GCNP includes ¼ mile of the rim starting about 5 miles south of Flat Iron Butte and running around the rim above Yumtheska Mesa through Yumtheska Point just north of Beaver Canyon. Hiking routes off the rim to Yumtheska Mesa exist at several places between Flat Iron Butte and Yumtheska Point. A road crosses Havasupai land to Flat Iron Butte and a separate road also leads to Yumtheska Point. There should be a way to obtain legal access to these two roads which both terminate inside GCNP. Numerous ideas have been presented previously to compensate the Havasupai for this access.

From inside Havasu Canyon on GCNP land there is no legal way to access Yumtheska Mesa to the east. This access is important to Grand Canyon thru-hikers and technical canyoneers. Beaver Canyon, on Havasupai lands, provides a non-technical way to escape Havasu Canyon to the west. Hikers can leave Supai village (after paying the hiking fees) and walk the Redwall rim on the west side of Havasu Canyon down to Beaver Canyon, then walk the Redwall rim above Beaver Canyon to Little Coyote Canyon where a constructed trail leads up Beaver Canyon through the Supai sandstone to the rim. Hikers can stay at the Redwall level, Supai (Esplanade) level, or on the rim to contour around a short distance to access GCNP. Hikers that are good climbers can also hike directly up Beaver Canyon to the top of the Redwall to access the same areas. Without this access, thru-hikers historically would sneak across Havasupai Lands to continue their GCNP hike. Numerous ideas have been presented previously to compensate the Havasupai for this access.

To escape Havasu Canyon to the Esplanade to the east under Great Thumb Mesa there is one legal route inside GNCP below Beaver Falls, but it is a very difficult route requiring climbing skills that are beyond most hikers. An alternate, less difficult, route is up Carbonate Canyon or School House Canyon on Havasupai lands to the Redwall (or Esplanade) level allowing contouring back into GCNP. The Havasupai should allow permitted access to thru-hikers and canyoneers needing to traverse Havasu Canyon. Numerous ideas have been presented previously to compensate the Havasupai for this access.

National Canyon area is particularly troublesome to access. Part of National Canyon is in GCNP and part is on Hualapai Lands. There should be an agreement between the NPS and the Hualapai Tribe for National Canyon access. For example, a small strip of GCNP runs on the rim for about 5 miles south of Flat Iron Butte bordering National Canyon. The GCNP boundary runs down the middle of National Canyon as it approaches the river. Hikers should be able to depart the rim above National Canyon and use National Canyon to access the river. Technical canyoneers are particularly interested in descending the two slot canyons that originate on Yumtheska Mesa and terminate to the east and west of Pocket Point at river mile 162 and river mile 164 respectively. Neither of these canyons have names on the map. A pack raft exit is required to escape these canyons. National Canyon is the logical pack raft destination. A route up National Canyon that affords access to Yumtheska Mesa exists mostly within GCNP boundaries, but there are instances where the route through National Canyon is just inside Hualapai Land for short distances on the order of a few hundred yards.

2 – Raft assisted backpacking (AKA pack rafting)

The current 5 mile pack raft rule defined under the Superintendent’s compendium is arbitrary and too short to allow many hiking, climbing, and canyoneering routes to be done. The finesse is to create improved rules governing pack rafting while ensuring river trip permits are not circumvented. Backpackers using river travel to complete routes should be required to carry all raft equipment into and out of Grand Canyon. They should be required to wear a personal flotation device. But they should not be required to carry fire pans or groovers, for example, which would make pack raft travel impossible. An effective pack raft system can weigh as little as 3.5 pounds including the pack raft, paddle(s), and PFD. The packed volume of the pack raft “kit” is smaller than many backpacking tents. The most suitable pack rafts can carry 220 pounds of weight and are quite durable while only weighing 1.5 pounds. An effective paddle system weighs less than one pound. In fact, some backpackers choose hand paddle systems that are even lighter for short river travel distances. An effective PFD can weigh as little as 9 ounces. Most pack rafters choose to portage significant rapids and the choice of PFD should be left up to the pack rafter to decide for the type of pack raft travel planned on the route. For example, the 9 ounce class 2 orange horse shoe PFD’s are effective for calm water pack rafting where rapids and riffles are portaged. A white water class III PFD should be worn if running rapids. Class III white water PFD’s often weigh 2.5 pounds and can exceed the weight of the pack raft and paddle system. Pack raft technology is undergoing a high degree of innovation and unnecessary regulations surrounding pack raft equipment could stifle innovation and quickly become obsolete. Especially since the life of the BCM could exceed 20 or even 30 years. As a result, the backpacker should decide which pack raft system is most effective for the route chosen by balancing weight to be carried with obstacles on the route. Individual choices on river gear should not be mandated by the NPS except where resource protection dictates.

More than 120 slot canyons have been descended in GCNP. The current limit of 5 miles of river distance on a backcountry permit is inadequate to allow technical canyoneers to escape many canyons after arriving at the river. For example, a descent of 36.7 Mile Canyon requires a pack raft exit of 8 miles to Eminence Break. A technical descent of Cork Spring Canyon requires a pack raft exit of 6 miles to Tuckup Canyon. A technical descent of Muav Canyon requires a 22-mile exit to Galloway Canyon, the longest pack raft exit in GCNP. In some cases, walking the shore for short distances is possible, but it’s arbitrary and requires a time consuming process of deflating the pack raft and re-inflating the pack raft when river travel again becomes necessary. In other cases exits through tribal lands could shorten the pack raft exit distances, but Havasupai and Hualapai lands are generally not accessible today.

A proposed alternative to the 5-mile rule is presented here where the backcountry permit holder’s group cannot travel in more than two consecutive zones. The zones are selected for access to hiking entrances and exits:

Zone Definitions:
Zone 1 – Lee’s Ferry to Rider Canyon
Zone 2 – Rider Canyon to South Canyon
Zone 3 – South Canyon to Eminence Break
Zone 4 – Eminence Break to LCR
Zone 5 – LCR to Red Canyon (New Hance)
Zone 6 – Red Canyon to Phantom Ranch
Zone 7 – Phantom Ranch to South Bass
Zone 8 – South Bass to Tapeats Creek
Zone 9 – Tapeats Creek to Lava Falls
Zone 10 – Lava Falls to Whitmore Wash
Zone 11 – Whitmore Wash to Diamond Creek
Zone 12 – Diamond Creek to Pierce Ferry

It’s clear that the river corridor is heavily used. Some Park managers may suggest that pack rafting distances longer than 5 miles could cause conflicts with other user groups along the river. For example, some managers might argue that beach camps are quite limited and there is no room for additional use from pack rafters. This oversimplifies the issue and ignores a long history of rafters and backpackers coexisting along the river corridor. A few ideas are offered in and effort to address this specific issue:

1. Pack rafters are almost always in small groups relative to rafting parties, by virtue of backcountry permit size restrictions, and can camp at river beaches that are unsuitable for larger rafting groups. It might be acceptable to “carve out” certain popular large river camps from pack raft camp usage. If this concept is required, it should be applied only to select specific beaches where impacts are certain and not applied in a blanket way. Backpackers can get to almost all river beaches today, legally, and further camping restrictions should be an exception, not the rule.

2. Rather than limit pack rafting to a specific distance, as it is now, instead limit it a number of nights camped at the river. For example, implement the zone system defined above but limit camping at the river to no more than two nights on a backcountry permit. This reduces the likelihood of conflicts between permitted river runners and backpackers. Pack rafters have a high degree of mobility and they can camp several hundred yards up drainages to reduce beach camp impacts.

3. Reduce the size of some wild use areas
(LB9) Tuckup / 150 Mile is excessively large. It should be split at Cork Spring Canyon to allow backpackers better access down 150 Mile Canyon and across the river to Matkat. Unfortunately, this is one of a few legal ways to access GCNP under Great Thumb due to Havasupai restrictions. And Tuckup Canyon is a destination unto itself where a group could spend considerable time and effectively block access to 150 Mile Canyon many miles away.
(AU9) Blacktail is excessively large. It should be split so that access North of Muav Saddle (Saddle Canyon, Crazy Jug Canyon, Tapeats Cave Canyon) is a separate use area from access south of Muav Saddle (North Bass trail and drainages on the south side of Powell Plateau).

4. Rim road access to GCNP
The current proposal shows the road along the rim above Scotty’s Hollow (K-37) to be closed. Scotty’s Hollow is the most direct way in or out of Kanab Creek in that area and the road should remain open to allow continued backpacker access.

The current proposal shows the roads to Flat Iron Butte and Yumtheska Point as closed inside the GCNP boundary. These short roads inside the park to the rim should remain open. Especially in light of the suggestions above to convince the tribes to provide access to the rim in this area.

The current proposal shows the road out on Great Thumb that dips into and out of Park lands as being closed. This road should remain open. Especially in light of the suggestion above to convince the Havasupai to provide access to the rim in this area. Currently, the Havasupai tribe uses this road and a closure is unlikely to change that fact. Many backpackers also use this road to access the rim even though access is ambiguous. Finally, Congress mandated hiker access in the 1975 deal to provide Great Thumb to the Havasupai. Closing this road violates the Congressional mandate.

Mountain bikes are a low impact and viable method of transportation on the dirt roads around the rim of Grand Canyon that are otherwise unmaintained. The park should allow mountain bike access on the old rim roads that have been closed to vehicles. This allows access for backpackers to remote areas of GCNP and also allows non loop routes where a mountain bike can be used to shuttle back to a car on the rim. Wilderness designation discriminates against mountain bikes but allows horse access. Horse access ensures these roads will never be reclaimed and horses do far more damage to road systems than mountain bikes.

I support maintaining mountain bike access on the Rainbow Rim trail system

5. Allow online backcountry permits – an online permit system should be available to allow backcountry users more equitable access to permits. The system should:

Display real-time use area availability

Allow cancellations to immediately reflect back into availability pool

Allow the permit to be printed on a home printer rather than rely on the mail

6. Technical canyoneering is an appropriate use of the resource
People have been descending Grand Canyon drainages with the aid of ropes and other technical gear since the Kolb Brothers in the early 1900’s. In fact, John Wesley Powell coined the term “canyoneering” and he pioneered exploration is early slot canyons like Shinumo Wash at river mile 29. The park is considering regulation specific to technical canyoneering. Technique and technology have come a long way to make technical canyoneering safe and far more popular today than in the past. Techniques to minimize environmental impacts have also evolved significantly. Canyoneering in other National Parks, like Zion for example, are very popular activities and land managers have adapted policies successfully to support this user group. A few suggestions are offered to establish a safe, but environmentally friendly, etiquette for technical canyoneering in GCNP.
a. Natural anchors should be strongly encouraged for use at all times over bolts. Grand Canyon’s slot canyons afford many opportunities to create natural anchors. Natural anchors can be removed leaving no trace. A bolt is much harder to remove.
b. Webbing used to construct natural anchors should be black in color to remain neutral or hidden.
c. Canyoneers should clean up webbing from prior parties never leaving more than one sling behind at an anchor
d. bolt policy – Exploration Vs routes with beta
  i. Bolts kits are typically carried as a matter of safety during exploration of slot canyons that have not been descended before. On rare occasions, explorers might find themselves in a bind where a bolt is required to safely exit a slot canyon. Exploration bolts are highly discouraged but appropriate if natural anchor opportunities do not exist. Explorers who place bolts must notify the NPS after the first descent is complete. If the bolt is deemed unnecessary, the NPS should reserve the right to remove it or seek help from the canyoneering organizations to remove the bolt.
  ii. No bolts are allowed in canyons with existing beta. If bolts are found to be placed in canyons with beta they will be removed.
  iii. There are certain routes within GCNP where bolts are very helpful in order to complete the route. In these cases the bolts should be maintained (if damaged by flash flooding) by the technical canyoneering community. A list of two examples follows:

    1. 150 Mile Canyon – bolts were installed in 150 Mile Canyon by George Steck 30 years ago. Later, Steck published his popular Loops Hikes book and 150 Mile Canyon is an essential route for several loops in his book. Furthermore, 150 Mile Canyon is THE essential route for legal and unfettered access to the Esplanade area under Great Thumb Mesa. Canyoneers often descend 150 Mile Canyon, cross the river on pack rafts, ascend Matkat Canyon, descend technical canyons under Great Thumb Mesa, then pack raft back to 150 Mile Canyon to exit to the rim. This exit requires ascending four fixed ropes. The anchor placement of the bolts greatly increases the odds of safe rope ascents to escape 150 Mile Canyon. Some bolts have been blown out or damaged by flash floods over the years but the canyoneering community occasionally replaces these bad bolts to keep the route open. The canyoneering community should be allowed to maintain the bolts in 150 Mile Canyon.

    2. Garden Creek – Many people travel down the Bright Angel trail past Garden Creek at the top of Devil’s Corkscrew. This access makes frequent technical descents of Garden Creek likely. After the first two rappels from natural anchors in Garden Creek, the canyoneer is confronted with a 400’ rappel down a big waterfall. There is one bolt in the schist 200’ down the waterfall out of the water flow allowing a person on rappel to clip into the wall to rig another rope for the remainder 200’ to the floor of the drainage below. This bolt allows a descent with a 200’ rope, a common length available to canyoneers.