This is An Explanation of the ZCC Comments, keyed to specific points in the text.
Backcountry Management Plan and Environmental Assessment
Zion National Park
The scoping phase of the NEPA process is the start of public input into the planning process. In theory, this takes place at the start of the planning process, and identifies the areas that the planning team should study, to develop their proposed management plan. Both the Park and the ZCC have been looking at backcountry issues for the last 3 years, preparing for the start of the planning process. This Request for Scoping Comments is that start.
The physical scope of the Backcountry Management Plan is the Backcountry District - which includes all of the Primitive and Pristine Zones, and small parts of other zones. It does not include the developed areas of the park.
...This process must look forward to the challenges of the next 20 years, and anticipate what management actions will allow continued visitation while preserving the natural environment.
The primary job of the Park Service is to preserve the parks unimpaired for the enjoyment of future generations. It is stated very clearly in the Organic Act of 1916 (the Act of Congress that created the National Park Service):
[The National Park Service] shall promote and regulate the use of the Federal areas known as national parks, monuments, and reservations hereinafter specified… by such means and measures as conform to the fundamental purpose of the said parks, monuments, and reservations, which purpose is to conserve the scenery and the natural and historic objects and the wild life 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 USC 1)
The courts have made it very clear that this means exactly what it appears to mean. This point is non-negotiable, and the ZCC fully supports the park in this duty.
We look forward to working with park staff to develop a less heavy-handed plan - and a return to a cooperative relationship between park staff and the technical backcountry visitor.
Some people have commented that this statement is a little harsh. The relationship between the park staff and the canyoneering community was vastly more amiable before the current strict quotas were imposed in Spring 2003. The ZCC considers the imposition of unduly restrictive quotas, and the manner in which they were imposed, to have been an act of bad faith that soured the environment. We consider the Request for Scoping Comments to be an act of good faith.
The dichotomy is similar to that found in Park units with extensive technical mountain climbing or rock climbing, such as Yosemite National Park, North Cascades National Park, Grand Teton National Park and Rocky Mountain National Park. We urge the planning team to look at the policies in these parks and consult with their staff in regard to managing technical activity in the backcountry.
Parks with America's best climbing have managed technical rock climbing in a variety of ways over the years. Many of these parks used a mandatory permit system similar to Zion's in the past, but dropped it because it did not make park visitors any safer, was expensive to manage, and placed an undue burden on the visitor.
1. For what technical canyons is the current mandatory permit / quota / appearance-required system appropriate?
- In most units of the National Park System, permits and quotas are only applied to the most-sought-after objectives, to mitigate over-crowding.
- The Zion General Management Plan calls for a range of experiences to be available to visitors – are there canyons where a large number of social encounters would not detract from the visitor experience?
An observation of the ZCC is that people do not visit Zion's canyons primarily for solitude, but mostly to see the canyons. Yes, most of us prefer to visit canyons with few other parties (uncrowded), but for the most part, people will tolerate some degree of crowding in the canyons in order to have access to them. The ZCC does not advocate highly-crowded canyons, instead, we advocate a nuanced understanding of the issues and the dynamics of travel in the canyons; and allowing a small amount of crowding to take place in order to allow more access for users. We also advocate a range of experiences in the canyons - not all canyons should be 'crowded' in any sense, and a few canyons could be somewhat crowded. Of Zion's 60 or so technical canyons, only six to ten are EVER in any sense crowded.
People's sense of crowding is tied closely with their expectations. As experienced Zion visitors, we do not expect to find the lower part of the Narrows without people, and I doubt many would say that their "Wilderness Experience" was ruined when they rapped down Mystery Falls in The Narrows, and found 50 people there. However, if you found 50 people at the first keeper pothole in Imlay, your day WOULD probably be ruined.
2. For the most sought after technical canyons, what is the appropriate technique to set use limits? Can limits be established statistically and scientifically, rather than arbitrarily? What criteria should be used to set limits? We suggest criteria based on both resource impacts and visitor experience.
Rather than set canyon limits arbitrarily again, at different levels, the ZCC thinks the park should develop a rational method for setting limits. We suggest setting reasonable starting limits, then conducting surveys of visitors as they complete their adventures on days when all permits are issued (most-crowded days), and see whether crowding comes up as an issue for a significant number of visitors. If it does, then the limits should be moved back until the level of crowding is acceptable to 80% of visitors on most-crowded days.
3. Can use limits be raised substantially (for instance, in the Subway to 80) to increase availability of the resource to the public, without compromising the physical resource, the visitor experience or visitor safety?
It should be noted that limits may need to be imposed for reasons other than crowding. The Subway, for instance, shows some small signs of passage, but not much. If the limits was raised substantially, and deterioration of the physical environment started occuring, then the limits would need to be tightened up to stop the physical impacts. During times of drought, the limits may need to be tightened up to diminish impacts when the canyons are more susceptible to erosion.
This ties into other aspects. A daily limit of 24 in Mystery Canyon may be appropriate while the entry trail is a mess, but if the trail is hardened, a higher limit may be appropriate.
Some canyons may need limits in the interest of visitor safety. Kolob Canyon, in particular, has long rappels near the end of the entry section that serve as a choke point and can create a safety issue. Perhaps Kolob should be limited to groups of six or smaller, or have a daily limit of 24, to avoid problems at this choke point.
5. What mechanism can be put in place for moving technical canyons into (or out of) a more restrictive management category, as conditions warrant?
Activity in the Park is likely to change drastically over the next 20 years. The ZCC encourages the park to install a flexible system that allows continuous reviews of user limits and permit procedures, so the system will adapt to the changing conditions.
6. Currently, the Park requires a personal appearance by the trip leader within 30 hours of the start of the trip at an NPS facility, to certify that the leader has looked at a weather forecast (the Express Permit System being the exception).
- Is there evidence that this contributes to visitor safety? Late starts caused by waiting in line can directly decrease visitor safety.
- Visitor safety is a concern of park management, but the park is not responsible for the safety of visitors. Is this an appropriate requirement for backcountry users?
- Is there a strong correlation between the weather forecast and flashflood activity? Can visitors obtain local short-term weather information by other means, such as simply looking at the sky?
While it is the Parks job to encourage safe practices, it is NOT the park's job to try to assure visitor safety. Part of the "Wilderness Experience" is that being out in the wild carries risks. The park is not your mother.
Flash floods are a risk for canyoneers, but not a huge risk. Recent flash flood deaths have included young men entering The Narrows to take pictures of the flash flood expected at any moment (ie, gross stupidity); and small children caught by a storm cell on a paved park trail. Canyons do flash with people in them, but people are smart enough to secure an out-of-danger position when signs of an impending flood appear.
A recent court case made it clear that the park is not liable for assuring visitor safety.
It is unclear to me that the requirement to sign an affadavit of having looked at the weather forecast has made one iota of difference to visitor safety. The NWS weather forecast does not make a good prediction of when and where flash floods will occur. People looking at the sky before they enter a canyon can and do make a much better assessment of whether their safety is at risk.
8. The permit system collects data on the use of canyons, for the sake of evaluating resource impacts and crowding.
- Can visitor use data be collected in other manners, such as by mandatory trailhead permits?
- Can resource impacts be evaluated in some other manner, such as evaluating the physical resource for impacts?
Use data can be effectively collected by using trailhead registers. While some might object because they tend to produce under-counts, the data is probably accurate enough for keeping track of little-used canyons. The current system may not be any more accurate, and is known to produce significant over-counts.
Rather than measure resource impacts by counting visitors, park staff can evaluate physical impacts by going into the field and measuring the physical impacts directly. Inexpensive digital cameras make this task considerably easier than it was in the past.
9. Off-trail backcountry travel takes place largely in canyons, on slickrock and in wash-bottoms where physical resource impacts are minimal. Access trails to and from canyons sometimes create erosion problems.
- When is active management of these problems appropriate (such as stabilizing trails, directing traffic or limiting access)?
- To what standard should backcountry social trails be stabilized?
- How can the Park utilize community organizations to help manage these resources and defray costs?
Until now, and except for The Subway, the Park has had a hands-off practice on backcountry paths-of-use (also known as social trails). We believe that the park should actively manage these trails by discretely blocking off excess social trails, and hardening specific problem areas on a case-specific basis. The ZCC is working with the Park to analyze the major problem areas, and to fund work on these problems.
1. Are the current daily backcountry use limits for canyons appropriate (Primitive Zone – 50 people per day, Pristine Zone – 12 people per day)? Why or why not?
- Use limits and permits should be applied to those canyons where they are useful for meeting Park objectives – and revised or removed from those canyons where Park goals can be met less obtrusively.
The ZCC thinks this is asking the wrong question. Rather than setting limits arbitrarily, AGAIN, the park should develop a system for setting them rationally. Thus we do not directly answer the question.
But if we did, the answer would look something like this:
| Canyon Resource | Suggested starting limit people per day |
| The Narrows | |
| The Subway | |
| Orderville | |
| Pine Creek | |
| Keyhole | |
| Mystery Canyon | |
| Behunin | |
| Kolob Canyon | |
| All other canyons |
The current permits and quota system should ONLY be applied to the most-sought-after objectives, namely The Narrows, The Subway, Mystery Canyon and Behunin Canyon; and for safety reasons to Kolob Canyon. All other canyons should use a free, trailhead permit. When trailhead permits show that a Pristine Zone canyon has become popular enough that crowding is probably an issue (trigger point - 4 days per year with usage of 24 people per day or greater), then it should be worked into the most-sought-after objectives program.
2. Are the current backcountry group size limits of 12 people per group appropriate? Why or why not?
- The park could encourage small group sizes (six or less) by allowing small groups access with fewer restrictions (cost, appearance) while applying more restrictions to larger groups.
Larger groups have a disproportionate impact on the physical resource and on other users. Large groups tend to be more focused on social interaction between members rather than interacting with the environment. Other users are negatively impacted by the loudness, crowding and social interaction of large groups. In technical canyons, large groups tend to have a lower level of technical proficiency and move very slowly, creating a safety concern for other groups.
That said, it is difficult to construct a set of rules that encourages small groups yet is still "fair". Large, proficient groups tend to create considerably less problems, but the Park cannot test for proficiency. The ZCC recognizes that this is a difficult problem.
3. Should commercial guiding be allowed in the Primitive Zone? Why or Why not?
- Commercial guiding should not be allowed in the Primitive Zone.
- Regionally, there are sufficient canyon resources available for guiding to meet the needs of the guided public.
- Excellent instruction in canyoneering technique is available locally to allow the untrained visitor to obtain the skills required to safely visit some of Zion's most-desirable technical canyons in a short period of time.
Guiding is already prohibited by the General Management Plan in the Pristine Zone, and the Backcountry Management Plan does not apply to the Developed and Transition zones, so this question is really asking if this plan should allow guiding. The ZCC position is "no".
4. Does current backcountry management allow for an appropriate level of protection for natural and cultural resources, and wilderness experience and values? Why or why not?
"Wilderness experience and values" is NPS language for "enforced solitude". "Enforced solitude" is the critic's code-phrase for the NPS tendency to limit usage to assure a minimal number of social encounters.
Critics, including me, believe the NPS has strayed from its mission in attempting to over-regulate Wilderness Visitors to assure that they have the experience in the wild that the NPS insists they SHOULD have. This is based on a deliberate mis-reading of the Wilderness Act, which says:
An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value.
The phrase: (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; is taken to mean that the managing authority should manage the Wilderness area so that every person will experience the park's definition of solitude at all times on every trip.
In addition to that annoying second part about a primitive and unconfined type of recreation;, the advocates of "enforced solitude" ignore stacks of research into how visitors experience solitude, and the rather unimportant impact of a reasonable number of social encounters on visitor's Wilderness Experience.
OK, off soapbox. The point is, be careful what you say in response to this question - know what they are asking.
A. The uniqueness and beauty of such highly sought after objectives as The Subway and Mystery Canyon mean that crowding norms at these locations are higher than at more-average backcountry Wilderness locations.
"Crowding Norms" is the technical way of saying "the point at which people will start to feel crowded". My point being, that The Subway and Mystery Canyon are SO outstanding, that peopl will tolerate considerably more social encounters in these canyons before they feel "bummed out" and "robbed of their Wilderness Experience".
Thank you for reading.
Comments should be directed to me: Tom at CanyoneeringUSA dot com, or discussed on the Canyons E-Group.
Zion National Park Scoping Letter -|- Scoping Comment Form
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