Dave Taliaferro
Rob White
Managers, Arkansas Headwaters Recreation Area
PO Box 126
Salida, CO 81201
October 24, 2000




Dear Mr. Taliaferro:

I am writing on behalf of American Whitewater regarding the September 2000 draft Revision of the Arkansas River Management Plan.

American Whitewater represents the interests of non-commercial river runners (referred to as "private" boaters in the plan).

I encourage you to work closely with Ric Alesch, Jay Kenney, and the Colorado White Water Association (CWWA) to address both American Whitewater and the CWWA's concerns as expressed in our written comments.

1. Counting Boats Rather than People Underestimates Use:

Measuring capacities by counting boats rather than people understates the true ratio of commercial to non-commercial use on the river. The CWWA and American Whitewater pointed out this flaw in the 1998 document. During earlier negotiations to address planning the state and BLM agreed to start counting both boats and people, but unfortunately previous park management was not committed to this concept and it was never implemented. However, the problems and misperceptions that it causes are still with us today.

The basic problem is that most commercial use occurs in rafts with many passengers and most private use is in kayaks or canoes with only one or 2 passengers, so private boaters tend to average one person per boat.

On the surface allocating an equal number of boats to both commercial and private use seems fair; however, in reality the ratio is more like 6 or 7 to 1 in favor of commercial use.

Most capacity-controlled rivers in the United States count users not boats. In fact the Arkansas River is the only major allocated Western river that American Whitewater is aware of with such a system. Furthermore, equating a large commercial raft to a small 1-person kayak for purposes of evaluating impacts and perceptions of crowding is not appropriate. It is equivalent to the highway department treating a semi-truck the same as a car.

2. American Whitewater Opposes Doubling Commerical Use on the Numbers Section of the Arkansas River

We oppose doubling commercial use on the Numbers section of the Arkansas River -- from 30 boats per day to 60 boats per day. The Numbers is a world-class section of whitewater. Years ago Paddler Magazine listed it as one of the 10 best whitewater runs in the country. It is of critical importance to our members and all non-commercial users. It was the only section of whitewater on the river where private use had a priority over commercial use in the 1998 plan. The current draft revision proposes to reverse this priority, based on a user-day approach to recreation allocation. Commercial boats average about 7 times the users of non-commercial boats on the Numbers. So the calculation would work as such: 60 boats x 7 passengers per boat = 420 commercial users vs. 350 for private boaters, plus an estimated 12 additional safety boats under another new clause in the plan that would further increase commercial use.

Allowing greater commercial use on the Numbers will increase safety hazards for non-commercial boaters. This section of river is known for its long, technical rapids. Rafts can not maneuver like kayaks can, and when the two types of boats come in contact the kayaker usually loses.

3. Safety Boaters Need to Be Counted in the Commercial Use Ceiling

Allowing safety boats on commercial trips without counting them against the ceiling is inequitable to private users. In effect this increases commercial traffic on the river.

We do not oppose important safety needs; however, we request the plan either (a) allow a similar extra boat for each private party on all affected sections, or (b) counts every visitor including guides, safety boaters, and staff equally under the use ceiling. The bottom line is that the proposed policy has a net effect of increasing the commercial allocation relative to private use, thereby creating a double standard. This is not appropriate.

4. Support Increasing Private Boater Use on the Brown's Canyon Section

Safety is just as important for private boaters as it is for commercial users and we should be given the same allowances in capacity controls. Increasing the private allocation on Browns Canyon by 50 boats is supportable; however, this increase is a false gain since so many private boaters avoid this section now when it is overrun with commercial use on busy weekend days. We support this increase as a step toward equity, but we feel it is in no way equal to the impacts in increased commercial use seen in other parts of the plan.

5. Oppose Increasing Non-Commercial Use on the Royal Gorge Section

We oppose an increase in commercial use on Royal Gorge -- from 150 to 225 boats per day. An increase of 75 boats would allow another 575 people (75x7) in rafts, in addition to the change in policy on safety boats would add another estimated 45 safety boats to the commercial allocation, for a total estimated increase of 620 commercial users a day. This increase in commercial use will degrade the experience for other users and increase safety hazards for private boaters.

6. Question: Why Were No Commercial Use Decreases Considered?

We do wonder why only increases were considered in this plan revision. Brown's Canyon is already over capacity with raft traffic and options for reducing commercial use should have been considered.

There appears to be a lack of broad-based private boater input into this planning process (more on this below).

We also question the factual basis for assuming that we can increase use on the river without degrading the experience for others, reducing safety, or creating resource impacts. Are there any surveys or other studies showing that the physical, biological, and social capacity can handle these increases? We do not find proof in the document.

7. Close the Training Trips Loophole for Commercial Use

Chapter 2, P. 16 - Training trips are added in this revision to "events" authorized for exemption to capacity controls. Again, this is a loophole creating a way around capacity limits for commercial use and should be deleted, or it needs to be applied across the board to commercial and non-commercial users. Commercial guides cause impacts and create crowding too, not just their passengers. Non-commercial user groups need to have training trips for new boaters as well.

8. Do Not Charge Fees for Simply Floating on a River

Chapter 2, P. 18 - There is a new statement in bold italics allowing fees to be charged for river use. We predict this will lead to general fees, sooner probably than later. In his very first meeting after the new plan was published in 1998 the new park manager said he could live with everything else in the plan, but did not agree with the statement that no fees would be charged just to be on the river. We accept fees for using developed facilities, but we oppose fees for simply being on the river, which is a public resource and right-of-way just like any state highway in Colorado. Charging a river runner a fee for floating is akin to charging a pedestrian for crossing the street or a parking lot, or charging a bicyclist for riding on the highway. It simply doesn't make sense.

If the State feels there is inadequate funds from facility use fees then an increase in facility use fees should be considered. Finally, if such a general use fee is contemplated, it should apply to all users at the recreation area, such as fishermen, hikers, and bicyclists; not just river runners. Incidentally, we encourage our members to buy their annual parks pass at the AHRA so that the money will stay in the park. The state should also consider asking the Legislature for a change in the law that says the AHRA must be 100% self-supporting. Our understanding is that this is one of, if not the only state park unit that has this limitation. The AHRA is one of the most valuable natural resource assets in Colorado and it should be treated as such.

9. The Comment Period was Unjustifiably Short

We would like to go on record objecting to the incredibly short comment period. This was set at 30 days, but most of the non-commercial boaters did not receive a copy of the plan until half way through this process.

The comment period was extended a mere 5 days (to October 20) but this still really allowed only about 20 days total for public comment. As a primarily volunteer organization it is very difficult to get group input when only a few days are allowed. The public period should be 90 days to allow adequate time for comments, or at least a minimum of 60 days to allow us to meet with our boards of directors or get other input from our membership. There are about 8 months left before the next paddling season so we see no reason why this request can not be accommodated. Though some members of the public have had opportunities to comment earlier in the process, and this document has been extensively worked over by the Citizen's Advisory Committee, of which CWWA had a representative, this is the first time the public at large has had a chance to see the proposed charges. Those earlier efforts are not a substitute for broad-based public input. To work on something for so many months internally and then only allow the public and representative organizations like American Whitewater only 20 days to effectively review and comment is both a sham and a shame.

10. The Public Comment Process was Structured to Avoid Real Opportunities for Input From Primary User Groups

By denying requests to hold a public meeting in Denver, the planning team significantly reduced opportunities for public comment and input from the primary visitor base.

Even after several requests were submitted for a meeting in Denver, including Ric Alesch's earlier request on behalf of CWWA's 700 members, most of whom live in the greater Denver area, it is clear that the planners were unwilling to solicit useful and constructive public input. At no time in this plan revision process has the State and BLM had a public meeting in Denver, even though we requested a public meeting in Denver earlier in the planning process. During the 1998 plan developments there was at least one meeting in Denver, and, anecdotally, it was the most well attended meeting of all the public meetings on the plan.

Most of the non-commercial users on the Arkansas come from outside the Valley. Indeed the largest single user group is in the greater Denver area. Having meetings only in the Valley skews input toward private landowners and commercial outfitters living in the area. I think a meeting in Denver would show the extensive concern that the whitewater community has about public use on this river, especially increased commercial traffic in places like the Numbers and the Royal Gorge.

Thank you for the opportunity to comment on this plan. Please let us know how we can help you revise this document to make it more acceptable to the non-commercial boating public. Please direct questions to myself or Ric Alesch. Finally, please also let us know when the appeal period will begin.

Sincerely,
s/
Jason D. Robertson