These are the official comments of the Zion Canyoneering Coalition to Zion National Park for the scoping phase of the Backcountry Planning Process. An Explanation of the ZCC Comments is available. Comments on specific points in the text are marked thusly: (Comment1).

August 25, 2005

Dear Planning Team -

Thank you for the opportunity to provide scoping comments for the upcoming Backcountry Management Plan. (Comment1)

The Zion Canyoneering Coalition (ZCC) is a citizens stakeholder group whose primary interest is the management of backcountry technical canyons in Zion. Specifically, we consider The Narrows, Orderville Canyon, The Subway, Keyhole Canyon and all canyons requiring ropes to descend safely to be our area of interest.

The Backcountry Management Planning Process allows a once-every-twenty-year opportunity to step back and examine the management practices put in place over the past 20 years, and determine how effective they were at achieving park goals. 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. (Comment2) We all expect usage of the backcountry to continue to increase – what steps should be taken now to assure that park goals are met in the future? How can the ZCC partner with the park to meet our shared goals of preserving the canyon environment and maintaining a quality experience for the visitor?

The number one comment by ZCC members is that the current system of permits and quotas for technical canyoneering in Zion National Park was arbitrary when established, and has proven to be overly restrictive. Resource protection, visitor safety and visitor experience goals can all be attained with a more careful application of management techniques that would place a substantially lower burden on both the park and on visitors. 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. (Comment3)

On-Trail Backcountry vs. Off-Trail Backcountry

In most National Park units, the terrain in the off-trail backcountry is similar to that in the on-trail backcountry, just without trails.

The adventurous backpacker, with appropriate navigation and off-trail skills, can venture out into the wilder places of the park, and enjoy a wilderness experience not found close to the trail. In these parks, the off-trail area can be thought of as an extension of the on-trail terrain, with a higher degree of wildness and solitude.

In Zion, the off-trail terrain is very different than the on-trail terrain, and often requires a new set of skills and special equipment to access safely. The group of visitors to this part of the backcountry is very different than backpackers, being more akin to technical rock climbers. The two parts of the backcountry are different recreational resources, used by different visitors with different skills, experiences, goals and objectives. Management actions appropriate to one area likely are not appropriate to the other. 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. (Comment4)

Evaluation of Current Management Practices

In response to evolving circumstances, the park developed numerous use restrictions on backcountry visitor access that may have been warranted at the time, but are not appropriate for long term management. The ZCC urges the park to objectively analyze which of these management practices are effective at attaining park goals, and suggests that many can be replaced by practices that are less burdensome on the park and visitors. The ZCC feels an inordinate amount of park and private resources are directed toward managing, dealing with and enforcing the day-use permit system, and a more focused application of a modified permit system can meet park objectives AND free up resources for more effective management of the backcountry.

The Planning Process should ask the following questions:

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? (Comment5)

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. (Comment6)

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? (Comment7)

4. For other technical canyons, how can park goals be met while placing the least possible burden on park resources and visitors?

5. What mechanism can be put in place for moving technical canyons into (or out of) a more restrictive management category, as conditions warrant? (Comment8)

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? (Comment9)

7. The permit system imposes an often impossible bureaucratic burden on visitors, especially those visiting for more than one day at a time, and those doing canyons that require an early start or a late finish. Are the bureaucratic burdens consistent with the Wilderness quality of "a primitive and unconfined recreation"? What system would meet park goals, but not intrude on the Wilderness visitor by requiring daily trips to the Visitor Center during daylight hours to meet bureaucratic requirements?

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? (Comment10)

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? (Comment11)

Scoping Comment Form Questions

In response to the specific questions asked on the Scoping Comment Form:

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?

    - The current limits are generally too restrictive and not appropriate. The park should develop a science-based method for setting use-limits on the most-sought-after objectives, rather than setting limits arbitrarily or by conducting a poll.

    - The Primitive Zone / Pristine Zone nomenclature should be viewed as a guide, not as a mandatory, cookie-cutter classification. It should be applied where appropriate – one size does not fit all. Each resource should be evaluated separately, and limits set (if appropriate) for each resource.

    - 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. (Comment12)

2. Are the current backcountry group size limits of 12 people per group appropriate? Why or why not?

    - The ZCC recognizes two conflicting forces: A. large groups have a physical and social impact out of proportion to their numbers (in other words, one large group has more impact than several small groups); and B. Social, scout, club and some Utah family groups are traditionally quite large, in the 6-12 person range.

   - The ZCC feels that the 12 people per group limit is appropriate, but suggests the park could limit the number of large parties in canyons on a particular day. For instance, it might be appropriate to limit The Subway to two, 12-person parties per day, and require that all other parties be 9 persons or less. The same kind of limits could be appropriate for Pine Creek.

   - Even with trailhead permits implemented for some canyons, the ZCC feels it would be appropriate to require Visitor-Center-Permits for groups larger than 7 persons.

   - 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. (Comment13)

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. (Comment14)

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? (Comment15)

    - Current backcountry management does a good job of protecting the natural and cultural resources and the ZCC in no way advocates less protection for these resources. The ZCC recommends more active management in the backcountry to limit and eliminate unnecessary social trails.

    - Current backcountry management applies far too strict limits on visitor access. Visitor use limits should be based on two criteria - resource capacity and visitor expectation, as measured by direct resource and visitor surveys - but should recognize several factors that suggest a higher use level is appropriate than might otherwise be the case in a Wilderness area:

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. (Comment16)

B. Only a few canyons are in any sense crowded. The vast majority of Zion canyons are rarely visited, and offer outstanding opportunities for solitude year-round.

C. The one-way nature of most canyon adventures makes for far fewer social encounters than in other Wilderness areas, given the same level of usage.

D. The terrain found in canyons is conducive to less feeling of crowding than more open terrain. In canyons, sight lines and hearing lines are short, so social encounters require far-closer physical proximity than is the case in mountainous or open desert terrain.

E. Use of the permit and reservation system has resulted in a large number of no-shows. The three-month ahead-of-time lottery system and advance reservation system result in many reservations not actually converting to permits, and many permits not actually converting to people in the canyons.

F. Canyoneers visit Zion primarily to visit the unique canyon environments present there, rather than to find solitude. There is a plentitude of canyons in Zion and the region where canyoneers can find solitude. Just as hikers placing a premium on solitude do not seek it at the Gateway to The Narrows, The Emerald Pools or Angels Landing on Labor Day weekend, canyoneers should not expect to find a low number of social encounters in all canyons all the time.

5. What other issues exist concerning backcountry management in Zion National Park?

    - We believe the Park should more actively manage physical impacts in the Pristine Zone canyons. While it may seem a contradiction to more actively manage an area to maintain its natural state, careful application of physical barriers and low-key designation of routes could go a long way toward diminishing erosion caused by out-of-watercourse social trails.

    - In the on-trail areas of the Park, campsites are designated and reserved. Many of these campsites are within sight and sound of the trail. Could some of these be moved out of site and sound of the trail, to improve the Visitor Experience of backpackers using those sites?

    - To intelligently discuss several aspects of the permit system, data on the number of permits denied and the permits issued on each day would be very helpful. Could the Park start collecting and publishing this information?

    - A method of displaying current permits issued for canyons would allow visitors to have more realistic expectations. Visitors seeking less-crowded canyons could choose canyons with fewer permits issued.

    - The ZCC believes that restoration of The Narrows to a more natural state is possible and desirable. The ZCC is willing to offer considerable volunteer labor on an on-going basis toward this effort.

    - Goose Creek Natural Research Area - Goose Creek was designated as a Natural Research Area with the General Management Plan in 2001 – with inadequate consideration of its value as an outstanding recreational resource. The ZCC would like to see either it opened to limited recreational use; or another narrow-canyon environment that would meet research needs designated, that does not remove an outstanding recreational resource from the public domain.

    - The final rappel in Echo Canyon is currently closed to public access. The ZCC requests that park staff evaluate whether this closure is based on realistic safety and/or resource impact concerns. This section of canyon is an outstanding recreational resource, and deserves consideration for opening to public access.

Thank you for the opportunity to contribute scoping comments to the Backcountry Planning process.

Tom Jones
Chairman
Zion Canyoneering Coalition