Death Valley National Park is accepting comments to their Wilderness and Backcountry Stewardship Plan until tomorrow (Oct 9). American Canyoneers has been examining the impacts of the plan, with help from local Canyoneers who know Death Valley well, and have formulated the following response. There are important changes that could affect your access to Death Valley. We ask that you consider the position below and provide comments to the National Park Service today using the online tool: http://parkplanning.nps.gov/document.cfm?documentID=47802 American Canyoneers Position: We are against day use permits as cited in Alternative C and D. As a result, we favor alternative A and B, or C and D amended with the removal of the day use permit for canyoneering. Here are our reasons: a- Most Death Valley visits for the purpose of technical canyoneering are multi-day visits because the Park is remote and far from the population centers where most canyoneers live. Specific canyons chosen for canyoneering descents are often spontaneous, especially on the second or third day of a trip. Physical fatigue, weather, lighting, group dynamics, skills, etc. often result in a change in the canyon selected for a descent. There is no way to get online to select a different permit if you're already in Death Valley because there is no cellular coverage in many areas of the Park. A party could drive for many hours, in the wrong direction, at significant cost of time and fuel to attempt to alter a permit in person. The convenience of an online permit system is more than offset by the inability to alter permits while inside in the Park given the 3.1 million acre size. b- Zion National Park is the only Park that issues canyoneering specific day use permits. Zion is 20 times smaller (148,000 acres) than Death Valley (3.1 million acres) and yet has nearly three times the visitation (2.8 million Vs 1 million). Zion is also one of the top canyoneering destinations in the World bringing high canyoneering traffic. Grand Canyon National Park, at 1.2 million acres and 4.5 million annual visitors, is a closer analogy to Death Valley. Even though Grand Canyon is one third the size and has nearly 5 times the visitation, Grand Canyon does not issue day use permits for any activity, including canyoneering. If people spend the night in the backcountry then a backcountry overnight use permit is required. Grand Canyon overnight use permits are based on large use areas covering 10's of thousands of acres in most cases. Canyoneers can generally camp at large in a use area and do any technical canyon of interest. The NPS at Grand Canyon makes no attempt to record which canyons are being done through their permit system because canyoneering occurs on durable flood plain surfaces that are violently altered through flash floods. Like Death Valley, Canyoneering in Grand Canyon is a fairly recent activity and usage is low. Grand Canyon is currently updating their Backcountry Management Plan and no plans exist to issue permits for day use activities. c- Death Valley contains many unexplored slot canyons. A permit system specific to any slot canyon will require constant IT system updates to allow permits to be issued to newly discovered canyons at great cost to the NPS. d- Reasons that often drive the creation of a permit system include the following: 1- Rules will be printed on the permit and can therefore be better enforced if canyoneers break rules 2- A day use permit for each canyon allows the NPS to ensure groups don't collide or get crowded 3- The NPS wants a record of canyon use to assess impact and guide further management actions These objectives can be met in other ways. American Canyoneers, the access organization representing technical canyoneers (www.americancanyoneers.org ), can post the Death Valley unique rules on its website and can facilitate the rules being posted on other canyoneering websites. The NPS can also post the rules on its own website. Grand Canyon created a "technical canyoneering bulletin" to make Canyoneers aware of local rules. The prospect of there ever being crowing in Death Valley due to canyoneering popularity is very low. It's very large and many canyon options exist. The NPS in Grand Canyon monitors canyoneering use through a checkbox on overnight permits. This provides information on popular use areas but not specific canyons. Grand Canyon has rangers that occasionally descend the more popular day use canyons to monitor impacts. These monitoring trips are often combined with high angle search and rescue training. Grand Canyon also relies on American Canyoneers to get the word out about issues and to self-police canyons. The community organizes trips to remove stuck ropes or perform canyon cleanup as required. e- While American Canyoneers does not support a day use permit system in Death Valley, if the NPS moves forward with such a system we strongly suggest the permits be issued based on large use areas so Canyoneers can have many canyoneering options while inside any particular use area. American Canyoneers believe that canyoneering guiding should be allowed in Death Valley National Park. Many Canyoneers get their first exposure to technical canyoneering on guided trips. Each canyoneering destination tends to have unique "local" challenges and guiding can effectively provide inexperienced Canyoneers with the skills necessary to descend Death Valley canyons. The number of canyoneering opportunities in the Park is so large that conflicts between self-guided trips and guided trips are unlikely. American Canyoneers supports the NPS efforts to put leave no trace ethics in place for Death Valley which ban new bolting activities and encourage canyoneers to replace and remove old webbing at anchors stations.