09/26/2024
Grand Canyon backcountry fee increases - excellent letter from RRFW -
RRFW Fee Increase comments
From: Tom Martin
Date: Wed, 25 Sep 2024 09:51:48 MST
Superintendent Ed Keable September 25, 2024
Grand Canyon National Park
PO Box 129
Grand Canyon, Arizona 86023
Dear Superintendent Keable,
River Runners for Wilderness (RRFW) represents a broad spectrum of river runners, wilderness lovers and American citizens who care about the wilderness resources in Grand Canyon National Park. Our members continue to have a deep concern for the future of the wilderness values of the Colorado River and Backcountry in the Grand Canyon. RRFW provides the following comments on the proposed fee increase for backcountry overnight recreation at Grand Canyon National Park.
River Runners for Wilderness does not support this overnight per person fee increase. The following issues support this decision.
The very basis of this proposed fee increase is not justified based on the lack of supporting documentation. This fee increase proposal lacks reference to any current or past business plan for, or analysis of, the existing backcountry fee structure. There is no explanation of the expenditures and accomplishments of the existing backcountry fee program.
The operational 1988 Backcountry Management Plan is 36 years old and 26 years out of date. Lacking a substantive up to date BMP, business plan, review of existing use of funds, or presentation of management goals, there is no way the public can make an informed comment on this proposed fee increase.
The Federal Lands Recreation Enhancement Act requires annual reports to Congress on how much money Grand Canyon National Park raises in backcountry fees and how that money is spent. None of this information is provided or made available for this proposed fee increase.
The Administrative Procedures Act demands that agency decisions be based in rationality and must not be arbitrary and capricious. Lacking any substantive rationale for this proposed fee increase and lacking any justification for the amount of increase, the current proposal is just that, arbitrary and capricious.
In 2011, RRFW scoping comments on Grand Canyon National Park’s proposed Backcountry Management Plan stated that a permit system for day access to elevations below Indian [Havasupai] Gardens/Tip-off on the South and Cottonwood on the North should be implemented. As Half Dome now has a permit system, so should the frontcountry corridor rim to rim activities now be permitted. While an update to the 1988 BMP has yet to be completed, the present operational 1988 BMP does not even mention Rim to Rim activities. Day use Rim to Rim Front country corridor trail activities linking the North and South Rim developed areas has exploded since 1988 and now demands a large financial expenditure annually by the NPS. Linking front country issues and expenses to backcountry user fees is misguided.
While the permit fee for backcountry overnight travel in Grand Canyon National Park has remained fixed at $10 for the last 20 years, the per person fee has increased by 200%. The proposed fee increase would amount to a 380% increase over the last 20 years while the rate of costs for goods and services over the same period has increased by 70%. All the other National Park units with backcountry overnight permits are following the rate of inflation (or are less than that) and are roughly equivalent to the $12 per person per night fee charged at Grand Canyon in 2022.
Given the information above, we repeat that we do not support this proposed fee increase for backcountry overnight use at Grand Canyon National Park. Please immediately restart the environmental impact study to update the out-of-date 1988 BMP and decrease the per person overnight backcountry fee to the 2022 level of $12 per person per night with the additional $10 permit fee.
Cordially yours,
Tom Martin
River Runners For Wilderness
PO Box 30821, Flagstaff, AZ 86003-0821
