Grand Canyon River Access
and the Recreational Use Allocation

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In 1975, the head of the NPS’s Division of Visitor Services stated, on behalf of the Interior Secretary, that the NPS recognized that the river concessioners offered “the only means of access” for those “who do not wish to make a sizeable investment in equipment, have no desire to gain proficiency in boating skills or are not acquainted with a boat owner,” and therefore that, “for the majority of Americans, a white water trip is more accessible through a commercial outfitter than by any other means.” The NPS reiterated its position in a 1975 letter from NPS Director to a member of Congress:

 

[W]e believe that the commercial outfitters provide the only practical means of access . . . for the vast majority of Americans. The 50 to 50 ratio proposed by a few would be unfair to people . . . who could make a river trip only with an outfitter. No one has an accurate count of the number of private boaters in the country, but certainly it is negligible as compared to the balance of the populace.

  
And, in June 1994, the head of the NPS, Director Roger Kennedy, discussing the NPS’s administration of the allocation, explained:
 

The present format authorizes private river runners, who are a very small percentage of the interested public, to utilize a fairly large percentage (32 percent) of the total allocation. It does not seem appropriate to make a change because of the requirement to endure a wait on the Private River Runner list. A significant alteration to the allocation would still result in a substantial wait while limiting the number of non skilled visitors who could experience such an activity.

  
Thus, he continued, “[t]he opportunities must be evaluated in respect of the recreational desires of all publics in relation to the need for resource protection.” As the NPS Chief of Concessions has stated, then, the allocation decision is “really a question of what is best for the Park and the overall public.”

THE “WAIT LIST” IS A POOR INDICATOR OF DEMAND
The “wait list” for private boaters, highlighted by many who are critical of the current allocation as justification for increasing the non-commercial allocation at the expense of the commercial sector, is neither a sound reflection of private demand nor an indication of relative demand for self-outfitted trips versus professionally-outfitted trips. Moreover, arguments in favor of increasing the non-commercial allocation at the expense of the commercial allocation ignore the fact that demand has no doubt increased for both those interested in professionally outfitted trips under the auspices of a NPS concessioner and those who wish to acquire a permit and organize their own trip. As the NPS recognized during the CRMP revision process initiated in 1997, “the demand for access by all members of the public (those who desire self outfitted trips, and those who desire commercially outfitted river trips) has increased since the last Colorado River Management Plan revision.”

To the extent that relative demand is a factor considered by the NPS in allocating use, the wait list, as the NPS and other stakeholders have long recognized, is a poor indicator of actual demand for self outfitted river trips. One of the primary reasons for this is that only the trip leader, rather than the names of all trip participants, is placed on the waiting list. This encourages duplicate applications, where individuals interested in taking a trip together will all put their names on the waiting list, thereby enabling the participants to take multiple trips. In addition, the NPS has observed that a significant percentage of people on the waiting list put their names on the list (or are children whose names were placed on the list by their parents) not necessarily ever planning on taking the trip. All of these factors, according to the NPS, “artificially inflate the non-commercial waiting list and make it a poor indicator of actual demand.” Indeed, in December 1997, the NPS observed exactly how widespread this situation had become: a full twenty one percent of the names of the waiting list shared either a common address or phone number.

The problem with using the wait list as an indicator of demand for self guided trips also has been observed by stakeholders in the Park management process. Some, including members of the private boating community, have recognized that people “don’t really have to wait 8 [or ten or twenty] years to go on a non commercial trip, they only have to wait to be the permit holder” and that a number of people “often go together every 2 3 years by making reverse invitations to each other depending on who gets a permit.” Revealingly, according to a 1998 NPS study, “commercial boaters tend to ‘plan’ their trip in advance longer than private boaters (the majority for commercial boater planned between nine months and two years ahead for the trip while the majority of private boaters planned for one to six months ahead.”) Others have observed that a number of private boaters know how to use the system and go every year, one stating that one of the consequences of the existing wait list system is that boaters not on the wait list “frequently run the river annually.” A January 7, 2000 letter from a private boater to the River District Ranger exemplifies the problem with using the waiting list to infer the level of demand for self outfitted trips:
 

I am the holder of a permit to run a private river trip in the Grand Canyon in May of 2000. . . . Imagine my dismay when I learned that my trip leader was also finally issued a permit . . . . Not only are our permits for the same summer, they’re in the same month! As all of the boatmen of my acquaintance are the same as those he will invite on his trip, it becomes effectively impossible for me to organize my trip as I had planned.

  
Statistical analysis of the existing data further illustrates the point. An analysis of publicly-available non-commercial river trip participant lists shows that, between April 16, 1995 and September 6, 2000, more than one out of every ten boaters (11.5% or 1,893 out of 16,467) running the river on a self outfitted trip went down the river more than once in that five year period alone, some running the river as many as ten times.

The suggestion that the existence of the waiting list demonstrates that user-days should be taken from members of the public interested in professionally outfitted river trips and instead allocated to those interested in self outfitted trips also ignores the fact that demand for professionally outfitted trips also has increased substantially. An oft-repeated refrain from some in the private boater community is that shifting part of the allocation for professionally-outfitted trips to private boaters must be warranted because, while non-commercial do it-yourself rafters have to wait for years for a permit, someone interested in a professionally-outfitted trip can purchase one for the next season. The suggestion is that there must therefore be a surplus of professionally-outfitted trips.

The fact is, however, that the commercial allocation is as fully subscribed as practicable. Indeed, evidence shows that demand for professionally guided trips exceeds availability, and that concessioners have turned away members of the public interested in taking a professionally guided trip or established extensive waitlists (although very few people on those lists actually gain access due to low cancellation rates for professionally outfitted trips). As Park management has found, however:
 

[T]here is no way of determining how long a person has waited to arrange their schedule or to save enough money to go on a commercially outfitted trip. There may be many people with the desire to go on a commercial river trip, however no list of such people exists, thus they are not being counted. There is also no way of telling how many commercial passengers have been turned away by one or more river concessioner [sic]. The fact that commercial companies turn prospective customers away every year due to allocation limitations would seem to indicate excess demand in that sector too.

  
 
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