Subject: Public Comment on Proposed Grand Canyon Backcountry Permit Fee Increase

Dear Grand Canyon National Park,

The Coalition of American Canyoneers is a 501(c)(3) organization, with 2,000 members, focused on promoting and preserving access to canyoneering on public and private lands by building on a foundation of ACES: Access through Conservation, Education and Safety. Many of our members enjoy the sublime beauty of the limestone slot canyons inside Grand Canyon. These canyoneers are often especially drawn to the slot canyons in the remote parts of the National Park where solitude and wilderness characteristics still remain. Many of these canyoneering oriented trips require three to five days of duration to enter and exit the vast landscape.

I am writing to express my concerns regarding the proposed fee increase for overnight backcountry permits at Grand Canyon National Park.

Issues with the Proposed Increase:

  • Recent Increase and Frequent Hiker Program Removal: The recent fee increased from $8 to $15 in April 2024, coupled with the elimination of the frequent hiker program, has already significantly raised costs for frequent overnight backpackers. Another 60% increase within a year is excessive.
  • Lack of Transparency: A detailed breakdown of where the additional revenue will be directed is crucial. Are funds solely focused on Booz Allen Hamilton’s rec.gov initiative, or are they also dedicated to essential infrastructure improvements like outhouses, trail maintenance, campgrounds, and water sources? Without knowing the specific allocation, the public cannot effectively analyze the proposal.
  • Declining Overnight Backcountry Use: Statistics show a 20% decline in overnight user nights since pre-COVID levels, highlighting a potentially shrinking user base. This raises questions about the rationale for further cost increases. (Source: https://www.nps.gov/grca/planyourvisit/upload/2022_Backcountry_and_River_Use_Statistics.pdf)
  • Unequal Impact: Increased fees disproportionately impact remote backcountry users who rely less on developed infrastructure (72% of users are in corridor areas, according to park statistics). The new fee structure punishes those seeking longer, more remote experiences who utilize fewer resources.
  • Price Exclusion: These increases risk pricing out low-income individuals and families from backcountry experiences, limiting accessibility.
  • Comparison to Other Parks: The proposed fee structure is nearly 5 times higher than other major parks like Yellowstone and Yosemite, which charge $5 per night.
  • Day Users Pay Nothing: The Grand Canyon corridor area has become substantially burdened with high day use visitation. Day users frequent water faucets, outhouses, shade structures, Phantom Ranch flush toilets, bridges and even impact trail maintenance, yet they pay zero. The number of SAR events associated with day use activities is quite high because day users are often least educated about hiking etiquette and dangers of below the rim hiking. Not only is this inequitable, but it’s just plain wrong.

Suggested Alternatives:

  • Tiered Fee System: Implement a fee structure based on use areas. Primitive and Wild areas could have lower fees, potentially decreasing with trip duration after two days. Corridor areas could have higher fees to account for increased infrastructure utilization.
  • Multi-Night Discounts: Offer discounts for multi-night users exceeding a specific number of days.
  • Day Use Fee: Similar to Tuweep, consider introducing a day use fee in corridor areas to address safety concerns and provide resources for managing increased day users. The day use fee at Tuweep has seemingly been successful, and as a result, a day use fee program already exists within the rec.gov system. Use the Tuweep model across the entire Park.
  • Complete Backcountry Management Plan: Finalize the Backcountry Management Plan, which was addressing day use restrictions and other relevant issues, then implement nuanced remedies that are aligned with broad management of the Park.
  • Remote User Fee Considerations: Remote overnight hikers who minimally use developed infrastructure should not be burdened by disproportionate fees that subsidize other users. Remote hikers generally do not want infrastructure like developed water access, outhouses, and trails.

Safety Concerns:

Historically, Grand Canyon has had one of the highest incidents of SAR events and fatalities of any National Park. Day hikers, runners, and rim to rim hikers are a disproportionate part of the problem. They frequently have zero touch points with the NPS before walking below the rim, and the lure of the place brings people who often have no desert hiking experience. A permit system for day users, even if online like the Tuweep model, would be an important “touch-point” opportunity to promote safety education.

I urge you to consider these alternatives and ensure a transparent and equitable fee structure that promotes responsible backcountry use, accessibility, and safety for all visitors.

Thank you for your time and consideration.

Sincerely,

Tyler Goodfellow

President and board member

Coalition of American Canyoneers