Arches National Park Canyoneering Management Plan - Scoping Comments - Due Aug 1

my apologies for the lateness of the stimulation. Arches has started developing a management plan and they want your scoping comments. They don't give us much to work with, but...

The link to comment on the plan is:

http://tinyurl.com/archescomments

The scoping document can be found in the same vicinity.

Comments are due by August 10th, as in, Tomorrow. Please get on this if you would like a say in how canyons are managed in Arches.

My comments:

August 9, 2010

Arches National Park Planning Team – Climbing and Canyoneering Management Plan 2282 S West Resource Blvd Moab UT 84532

Zion Canyoneering Coalition Scoping Comments for Arches National Park Climbing and Canyoneering Management Plan

Dear Arches Planning Team –

The Zion Canyoneering Coalition appreciates the opportunity to provide scoping comments for the planning process of a Climbing and Canyoneering Management Plan for Arches National Park. We support the goals and objectives of the Park, including management of most of the backcountry areas as Wilderness under the Wilderness Act of 1964; and of the stated Goals of the plan. We wish to support the Planning Team in understanding the management problems associated with Canyoneering and Climbing, and in moving to develop a management plan that best meets the Park and Plan objectives while minimizing unnecessary burdens placed upon the Park Visitor.

The Zion Canyoneering Coalition

The ZCC was formed in October 2002 as the voice for technical canyoneers when working with land managers when dealing with technical-canyoneering related issues. The canyoneering community is small and politically/socially diverse, and has had few issues to organize around. The ZCC worked with Zion National Park in decreasing canyoneer impacts; establishing hardened, unofficial trails; reviewing options for social trails of most concern; and in commenting on the ZNP Backcountry Management Plan. The ZCC has also worked with BLM, Utah State Park officials, and county Sherriff/SAR organizations as a representative of the canyoneering community.

INTRODUCTION

Canyoneering in Arches National Park

Arches National Park is a key resource for canyoneering activity in the Moab area. While many people explored the canyony fins of the Fiery Furnace and perhaps established rappels, Arches was explored and opened as a technical canyoneering venue with the arrival of Matt Moore in Moab in 1997, and the founding of Desert Highlights. Self-guided canyoneering started to pick up in Arches with the posting of information to the Internet starting around 2003. Canyoneering as a sport, and use in Arches has grown steadily since then, however, usage rates are still very low and the number of participants quite modest. Use is concentrated in nine canyons in the Park, as detailed on Shane Burrows's climb-utah.com website, the primary source of canyoneering information for recreational canyoneers.

Technical canyoneering requires very specific terrain for a fun, safe and enjoyable canyoneering experience. Arches has such terrain, at least in nine specific places. Other terrain in the Moab area does not offer very many places where the required attributes come together to form interesting canyons. Arches canyons are characterized by being short (usually half-day), technically straightforward, intriguing, friendly, somewhat physical and definitely fun. Exploring canyons in Arches provides an intimate relationship with the landscape not found by hiking along the paved paths. Canyon in Arches are on the "Easy" end of the technical canyoneering scale, thus canyoneers that enjoy canyons in Arches tend toward family and youth groups, and are largely beginners and intermediates, without a high level of training or skill. These attributes of the canyons also make them ideal for first-time canyoneers, and therefore quite good for guiding. Guided visitors enhance their appreciation of the Park by experiencing the terrain on an intimacy level unavailable to the non-technical, non-guided visitor.

Canyoneers use natural terrain features where available to anchor rappels. Matt Moore has been a pioneer in applying ghosting techniques (techniques that anchor rappels but leave no human artifacts behind) to the canyons of Arches, and in teaching these techniques to other Utah canyoneers. Bolts also have a history of being used in Arches where natural anchors or ghosting techniques do not produce a good result. The Entrada Sandstone (and in some places Navajo Sandstone) of Arches is particularly soft, and shows the passage of canyoneers rather quickly. Expert application of ghosting and natural anchor techniques can minimize the impacts of canyoneer passage, but not all canyoneers are experts in these techniques, and often avoidable impacts are created. Bolt anchors can be used in certain locations to minimize the impact on the resource.

The Fiery Furnace is an interesting maze of non-technical and technical passages, some of which is considered canyoneering. The FF has been managed via a permit and quota system for a considerable time period, and the ZCC feels that the management system here is working. This does not, however, mean that the same system should be extended to all off-paved-trail travel in the Park – rather, some elements of this system could be adapted to managing canyoneering activity in the rest of the Park, AND some or all of the details of the FF current plan should be carefully considered.

GENERAL COMMENTS

Canyoneering is NOT Climbing

While it is perhaps appropriate to develop the management plan for both of these technical, Wilderness-appropriate activities at the same time, I hope it is clear that from a planning perspective, the differences between the sports (patterns of use, social impacts, physical impacts) are perhaps more important than their similarities. Canyoneers like climbers are drawn from a wide range of Americans, though the overlap between the two groups is small. Canyoneering can be done in small groups of one or two, but also easily adapts to groups of considerably large size, even twenty or thirty. Experienced veterans and first-time canyoneers will often be in the same group, and enjoy the same canyon in the same way at the same time. Families with children as young as six can be expected to canyoneer together.

Canyoneering occurs almost entirely in specific, well-documented places, following specific approaches and exits. Impacts from canyoneers are likely to be very specific in location and type, thus making it relatively simple for the land manager to manage the impacts. All popular locations are known, and are currently limited to nine routes. Exploration is not widespread, and may identify two or three additional "good routes" in the next couple of years; but is unlikely to cover more terrain than that.

Canyoneering generally takes place in terrain which is especially resistant to human impacts. Most canyoneering occurs in watercourses where the surface is renewed by flash floods on a regular basis, or on slickrock which is impact-resistant. There may be short social trails through vegetated terrain to get to a wash bottom or to a slickrock approach – social trails that can be managed to minimize physical impacts. In-canyon, rappels sometimes result in rope grooves and sling grooves that scar the Entrada sandstone. These are away from the routes travelled by casual Arches visitors, and usually only seen by canyoneers.

The Zion Canyoneering Coalition is an organization of canyoneers, and we have no comments on the climbing portion of the Technical Backcountry Management Plan.

Science-based Planning

The ZCC calls on the Arches Planning Team to develop a flexible management plan based on verifiable facts. The first part of the planning process then becomes figuring out what is actually going on, on the ground, such as by finding un-burdensome ways to measure actual use in the canyons, and objective ways of measuring physical impacts. Park statements indicate a need for this plan because "increased climbing and canyoneering use" is "straining the park's ability to effectively manage those activities in Arches." Does the Park have data to back up this claim?

We have seen National Park planning processes for canyoneering that have been based upon "feelings" and "personal observations" of Park personnel, and applied Park personnel norms rather than sport-participant norms to such items as target encounter rates and acceptable limits of change. We claim (ironically, without evidence) that the best management plan can only be developed with a strict devotion to actual verifiable facts, careful analysis of the data, and a reluctant application of burdens to the Park visitor.

The Planning Team should avoid surveys to justify burdens placed on Park visitors. Asking visitors what they want you to do is unlikely to produce good management plans, but it is easy to manipulate surveys to produce the results desired, and justify management actions that the prejudices of the Planning Team favor. The ZCC considers this a tactical error.

As an example: if asked, many recreational canyoneers would say there should not be commercial guiding on canyoneering routes, because it interferes with their access to the same routes. A move to quash commercial guiding based on this "opinion poll" would be misguided and counter to Park Goals. Commercial guiding clients are also visitors to the Park, but unlikely to be involved in and have a voice in the planning process. The planning team would do better to study the facts on the ground: are there actual conflicts between commercial and private canyoneers? Where and when? How can these conflicts be mitigated while imposing the least burden on both user groups?

Planning Issues Identified in the Scoping Document July 2010

The ZCC supports the stated goals of the CCMP, namely:

Protect and conserve the park's natural and cultural resources and values, and the integrity of wilderness character for present and future generations.

Ensure that recreational uses and activities in the park are consistent with its authorizing legislation or proclamation and do not cause unacceptable impacts on park resources and values.

In addition to the authorizing legislation, the areas in question are managed under NPS policy as Wilderness as defined by the Wilderness Act of 1964. We would like to bring the Planning Team's attention the defining characteristics of statutory Wilderness:

(2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation;

In many places, the Park Service has concentrated on minimizing social encounters in Wilderness to the exclusion of all other goals, focusing on a simple definition of "Solitude". A more nuanced understanding of "Solitude" indicates that, for Wilderness travelers, it mainly focuses on the feeling of being an animal in the wild lands, free from the social and governmental constraints that enclose our daily lives in society. In this reading, the three attributes "solitude", "primitive" and "unconfined" all point toward the same kind of Wilderness, a Wilderness that is substantially degraded by aggressive management actions and restraints on Visitor activites. We consider it consistent with the Wilderness Act that the Park manage visitor Wilderness activities with the least-burdensome actions that can achieve the desired result.

Unacceptable Impacts

A primary goal of this CCMP is to "ensure that recreational uses and activities in the park are consistent with its authorizing legislation or proclamation and do not cause unacceptable impacts on park resources and values."

Management policies that emerge from this plan will result from how Park planners define what constitutes an "unacceptable impact." This standard should be clearly outlined in the draft CCMP (with similar references in other NPS plans). The term "unacceptable impact" as a standard for land management raises many more questions than it answers:

Could an "appropriate use" also sometimes cause "unacceptable impacts"? Does Arches have specific examples of an "unacceptable impact"? What is the difference between an activity that causes "unacceptable impacts" and an activity that causes "impairment"? How significant are "unacceptable impacts" when compared to "impairment"? Can a significant impact be acceptable? Can an "unacceptable impact" not be significant?

Specifically, the ZCC is looking for a science-based analysis of what constitutes an unacceptable impact, rather than using the norms of Park staff without critical analysis.

"Unacceptable impacts" is context dependent. An extraordinary and popular canyoneering route will have a higher level of impact considered acceptable than an obscure and barely-used route. Impacts that are in plain site of casual Arches visitors must be taken more seriously than impacts deep in the backcountry, only seen by canyoneers.

Public Involvement

We hope that the Arches Planning Team is genuinely interested in working with the public to develop a plan that will protect the Park resources while degrading the visitor's Wilderness experience as little as possible. Meeting the statutory requirements for public participation (two comment periods, of which this is one) has proven ineffective in the past to produce a plan with public buy-in. In the interest of producing a plan that is in alignment with Park values and current standards of the democratic process, we encourage the Planning Team to step beyond the statutory obligations and involve the public more fully in the process.

The Zion Canyoneering Coalition is interested in participating in the Planning process to the fullest extent possible.

We thank Arches National Park for the opportunity to provide Scoping Comments. We look forward to working with the Planning Team in developing a workable, equitable Canyoneering Plan for Arches National Park.

Tom Jones, chairman Zion Canyoneering Coalition

bump FYI submit what ever you have now time is running out

--- In Yahoo Canyons Group, "TomJones" <ratagonia@...> wrote:
my apologies for the lateness of the stimulation. Arches has started developing a management plan and they want your scoping comments. They don't give us much to work with, but...
The link to comment on the plan is:
http://tinyurl.com/archescomments
> The scoping document can be found in the same vicinity.
Comments are due by August 10th, as in, Tomorrow. Please get on this if you would like a say in how canyons are managed in Arches.
My comments:
> August 9, 2010
Arches National Park > Planning Team – Climbing and Canyoneering Management Plan > 2282 S West Resource Blvd > Moab UT 84532
Zion Canyoneering Coalition Scoping Comments for Arches National Park Climbing and Canyoneering Management Plan
> Dear Arches Planning Team –
The Zion Canyoneering Coalition appreciates the opportunity to provide scoping comments for the planning process of a Climbing and Canyoneering Management Plan for Arches National Park. We support the goals and objectives of the Park, including management of most of the backcountry areas as Wilderness under the Wilderness Act of 1964; and of the stated Goals of the plan. We wish to support the Planning Team in understanding the management problems associated with Canyoneering and Climbing, and in moving to develop a management plan that best meets the Park and Plan objectives while minimizing unnecessary burdens placed upon the Park Visitor.
The Zion Canyoneering Coalition
The ZCC was formed in October 2002 as the voice for technical canyoneers when working with land managers when dealing with technical-canyoneering related issues. The canyoneering community is small and politically/socially diverse, and has had few issues to organize around. The ZCC worked with Zion National Park in decreasing canyoneer impacts; establishing hardened, unofficial trails; reviewing options for social trails of most concern; and in commenting on the ZNP Backcountry Management Plan. The ZCC has also worked with BLM, Utah State Park officials, and county Sherriff/SAR organizations as a representative of the canyoneering community.
INTRODUCTION
Canyoneering in Arches National Park
Arches National Park is a key resource for canyoneering activity in the Moab area. While many people explored the canyony fins of the Fiery Furnace and perhaps established rappels, Arches was explored and opened as a technical canyoneering venue with the arrival of Matt Moore in Moab in 1997, and the founding of Desert Highlights. Self-guided canyoneering started to pick up in Arches with the posting of information to the Internet starting around 2003. Canyoneering as a sport, and use in Arches has grown steadily since then, however, usage rates are still very low and the number of participants quite modest. Use is concentrated in nine canyons in the Park, as detailed on Shane Burrows's climb-utah.com website, the primary source of canyoneering information for recreational canyoneers.
Technical canyoneering requires very specific terrain for a fun, safe and enjoyable canyoneering experience. Arches has such terrain, at least in nine specific places. Other terrain in the Moab area does not offer very many places where the required attributes come together to form interesting canyons. Arches canyons are characterized by being short (usually half-day), technically straightforward, intriguing, friendly, somewhat physical and definitely fun. Exploring canyons in Arches provides an intimate relationship with the landscape not found by hiking along the paved paths. Canyon in Arches are on the "Easy" end of the technical canyoneering scale, thus canyoneers that enjoy canyons in Arches tend toward family and youth groups, and are largely beginners and intermediates, without a high level of training or skill. These attributes of the canyons also make them ideal for first-time canyoneers, and therefore quite good for guiding. Guided visitors enhance their appreciation of the Park by experiencing the terrain on an intimacy level unavailable to the non-technical, non-guided visitor.
Canyoneers use natural terrain features where available to anchor rappels. Matt Moore has been a pioneer in applying ghosting techniques (techniques that anchor rappels but leave no human artifacts behind) to the canyons of Arches, and in teaching these techniques to other Utah canyoneers. Bolts also have a history of being used in Arches where natural anchors or ghosting techniques do not produce a good result. The Entrada Sandstone (and in some places Navajo Sandstone) of Arches is particularly soft, and shows the passage of canyoneers rather quickly. Expert application of ghosting and natural anchor techniques can minimize the impacts of canyoneer passage, but not all canyoneers are experts in these techniques, and often avoidable impacts are created. Bolt anchors can be used in certain locations to minimize the impact on the resource.
The Fiery Furnace is an interesting maze of non-technical and technical passages, some of which is considered canyoneering. The FF has been managed via a permit and quota system for a considerable time period, and the ZCC feels that the management system here is working. This does not, however, mean that the same system should be extended to all off-paved-trail travel in the Park – rather, some elements of this system could be adapted to managing canyoneering activity in the rest of the Park, AND some or all of the details of the FF current plan should be carefully considered.
GENERAL COMMENTS
Canyoneering is NOT Climbing
While it is perhaps appropriate to develop the management plan for both of these technical, Wilderness-appropriate activities at the same time, I hope it is clear that from a planning perspective, the differences between the sports (patterns of use, social impacts, physical impacts) are perhaps more important than their similarities. Canyoneers like climbers are drawn from a wide range of Americans, though the overlap between the two groups is small. Canyoneering can be done in small groups of one or two, but also easily adapts to groups of considerably large size, even twenty or thirty. Experienced veterans and first-time canyoneers will often be in the same group, and enjoy the same canyon in the same way at the same time. Families with children as young as six can be expected to canyoneer together.
Canyoneering occurs almost entirely in specific, well-documented places, following specific approaches and exits. Impacts from canyoneers are likely to be very specific in location and type, thus making it relatively simple for the land manager to manage the impacts. All popular locations are known, and are currently limited to nine routes. Exploration is not widespread, and may identify two or three additional "good routes" in the next couple of years; but is unlikely to cover more terrain than that.
Canyoneering generally takes place in terrain which is especially resistant to human impacts. Most canyoneering occurs in watercourses where the surface is renewed by flash floods on a regular basis, or on slickrock which is impact-resistant. There may be short social trails through vegetated terrain to get to a wash bottom or to a slickrock approach – social trails that can be managed to minimize physical impacts. In-canyon, rappels sometimes result in rope grooves and sling grooves that scar the Entrada sandstone. These are away from the routes travelled by casual Arches visitors, and usually only seen by canyoneers.
The Zion Canyoneering Coalition is an organization of canyoneers, and we have no comments on the climbing portion of the Technical Backcountry Management Plan.
Science-based Planning
The ZCC calls on the Arches Planning Team to develop a flexible management plan based on verifiable facts. The first part of the planning process then becomes figuring out what is actually going on, on the ground, such as by finding un-burdensome ways to measure actual use in the canyons, and objective ways of measuring physical impacts. Park statements indicate a need for this plan because "increased climbing and canyoneering use" is "straining the park's ability to effectively manage those activities in Arches." Does the Park have data to back up this claim?
We have seen National Park planning processes for canyoneering that have been based upon "feelings" and "personal observations" of Park personnel, and applied Park personnel norms rather than sport-participant norms to such items as target encounter rates and acceptable limits of change. We claim (ironically, without evidence) that the best management plan can only be developed with a strict devotion to actual verifiable facts, careful analysis of the data, and a reluctant application of burdens to the Park visitor.
The Planning Team should avoid surveys to justify burdens placed on Park visitors. Asking visitors what they want you to do is unlikely to produce good management plans, but it is easy to manipulate surveys to produce the results desired, and justify management actions that the prejudices of the Planning Team favor. The ZCC considers this a tactical error.
As an example: if asked, many recreational canyoneers would say there should not be commercial guiding on canyoneering routes, because it interferes with their access to the same routes. A move to quash commercial guiding based on this "opinion poll" would be misguided and counter to Park Goals. Commercial guiding clients are also visitors to the Park, but unlikely to be involved in and have a voice in the planning process. The planning team would do better to study the facts on the ground: are there actual conflicts between commercial and private canyoneers? Where and when? How can these conflicts be mitigated while imposing the least burden on both user groups?
Planning Issues Identified in the Scoping Document July 2010
The ZCC supports the stated goals of the CCMP, namely:
Protect and conserve the park's natural and cultural resources and values, and the integrity of wilderness character for present and future generations.
Ensure that recreational uses and activities in the park are consistent with its authorizing legislation or proclamation and do not cause unacceptable impacts on park resources and values.
In addition to the authorizing legislation, the areas in question are managed under NPS policy as Wilderness as defined by the Wilderness Act of 1964. We would like to bring the Planning Team's attention the defining characteristics of statutory Wilderness:
(2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation;
In many places, the Park Service has concentrated on minimizing social encounters in Wilderness to the exclusion of all other goals, focusing on a simple definition of "Solitude". A more nuanced understanding of "Solitude" indicates that, for Wilderness travelers, it mainly focuses on the feeling of being an animal in the wild lands, free from the social and governmental constraints that enclose our daily lives in society. In this reading, the three attributes "solitude", "primitive" and "unconfined" all point toward the same kind of Wilderness, a Wilderness that is substantially degraded by aggressive management actions and restraints on Visitor activites. We consider it consistent with the Wilderness Act that the Park manage visitor Wilderness activities with the least-burdensome actions that can achieve the desired result.
Unacceptable Impacts
A primary goal of this CCMP is to "ensure that recreational uses and activities in the park are consistent with its authorizing legislation or proclamation and do not cause unacceptable impacts on park resources and values."
Management policies that emerge from this plan will result from how Park planners define what constitutes an "unacceptable impact." This standard should be clearly outlined in the draft CCMP (with similar references in other NPS plans). The term "unacceptable impact" as a standard for land management raises many more questions than it answers:
Could an "appropriate use" also sometimes cause "unacceptable impacts"? > Does Arches have specific examples of an "unacceptable impact"? > What is the difference between an activity that causes "unacceptable impacts" and an activity that causes "impairment"? > How significant are "unacceptable impacts" when compared to "impairment"? > Can a significant impact be acceptable? Can an "unacceptable impact" not be significant?
Specifically, the ZCC is looking for a science-based analysis of what constitutes an unacceptable impact, rather than using the norms of Park staff without critical analysis.
"Unacceptable impacts" is context dependent. An extraordinary and popular canyoneering route will have a higher level of impact considered acceptable than an obscure and barely-used route. Impacts that are in plain site of casual Arches visitors must be taken more seriously than impacts deep in the backcountry, only seen by canyoneers.
> Public Involvement
We hope that the Arches Planning Team is genuinely interested in working with the public to develop a plan that will protect the Park resources while degrading the visitor's Wilderness experience as little as possible. Meeting the statutory requirements for public participation (two comment periods, of which this is one) has proven ineffective in the past to produce a plan with public buy-in. In the interest of producing a plan that is in alignment with Park values and current standards of the democratic process, we encourage the Planning Team to step beyond the statutory obligations and involve the public more fully in the process.
The Zion Canyoneering Coalition is interested in participating in the Planning process to the fullest extent possible.
> We thank Arches National Park for the opportunity to provide Scoping Comments. We look forward to working with the Planning Team in developing a workable, equitable Canyoneering Plan for Arches National Park.
Tom Jones, chairman > Zion Canyoneering Coalition >