Ben Hardings Issues and Answers
+++++++++++++++++++++++++++++++++++++++
> Issue: The current management system arbitrarily and
> unnecessarily creates classes of river runners.
>
> The current rationing system forces river runners to classify
> themselves according to their preference for commercial or
> private trips. This classification is arbitrary and unnatural.
> River runners, regardless of their preference for river travel,
> are all citizens with an equal birthright to our national parks.
> Classification introduces the possibility of bias, so a rationing
> system should not classify river runners unless and until it is
> absolutely necessary. Alternatives exist to the existing policy
> and should be adopted.
>
> Solution: Adopt a management method that treats all river runners
> as a single group.
>
> The fundamental action that NPS should take is to adopt a
> rationing system that treats all river runners the same to the
> maximum extent possible. Unlike the current system where a river
> runner first assigns themselves to one class of user, an
> equitable system would have river runners first apply to NPS for
> permission to run the river. Once permission to run the river
> has been granted, the river runner would then arrange to make
> their run according to their preference. Such systems are called
> "common-pool" or "freedom-of-choice" systems.
>
> Because river running in GC is rationed according to launches,
> under a common-pool system river runners who wish to run the
> river on their own would have to declare their intent to do so
> prior to obtaining a permit in order to reserve a launch date.
> River runners who wish to take advantage of commercial river
> services would make arrangements for their trips as they do now,
> subject to obtaining a permit from NPS. The issue of launch
> scheduling should be separated from the rationing system and
> should allow river runners enough flexibility to make private or
> commercial arrangements.
>
> Once the fundamental switch to a common-pool system has been
> made, options exist for the rationing system. Three common
> methods of rationing are: waiting list, lottery and reservation
> system. All three of these systems are in wide use in public and
> commercial situations. Although the details of implementing a
> system are beyond the scope of the format required for these
> comments, the following important points should be considered.
>
> Permits should be issued to trip leaders or group leaders who
> should be allowed to form their group. Limits on repeat trips
> can be dealt with separately and are addressed below.
>
> Lottery systems must have some system for granting "preference"
> to those not selected in a given year. Such a self-correcting
> system insures that no one waits excessively for a permit.
> Systems such as this are in use in hunting license systems in
> some states.
>
> Lottery systems and waiting lists should be set up so that river
> runners receive a permit well in advance of their earliest launch
> season and should provide for flexibility in launch scheduling.
>
> A reservation system should have some limit on the number of
> permits by a single individual. A reservation system can use a
> waiting list for each launch date to accommodate cancellations.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: The current system uses an arbitrary allocation of river
> access between commercial and private river runners and does not
> respond to actual demand.
>
> The current rationing of GC access between the commercial and
> private sectors is arbitrary and not based on actual measures of
> demand. Further, what evidence that does exist indicates clearly
> that the imbalance between supply and demand is far worse in the
> private sector than in the commercial sector.
>
> The available evidence indicates that the supply of access for
> private trips is far lower than demand for these trips. At the
> same time, evidence indicates that the supply of access for
> commercial trips is reasonably in balance with demand for those
> trips. The waiting list for private river trips is between 8 and
> 16 years long, depending on estimates of cancellations.
> Concessionaires do not schedule trips more than two years in
> advance, and many seats on commercial trips are filled in the
> year in which the trip is run. If there were demand for
> commercial trips exceeding two years of capacity, the
> concessionaires would offer schedules and take reservations.
> That they don't indicates that demand for commercial trips is
> less than two years capacity.
>
> Solution: Adopt a system that automatically responds to demand.
>
> The fundamental problem with the current management method is
> that it relies on a division of use between private and
> commercial sectors. River runners have a preference as to which
> means of running the Colorado River they will use. NPS should
> let the river runners decide. A system that does this will
> automatically be in balance with demand.
>
> The fundamental property of a system that automatically responds
> to demand is that prospective river runners apply to the NPS for
> a permit and NPS grants the permit directly to the river runner.
> Once a permit is granted to a river runner, he or she is then
> free to arrange to run the river themselves or procure the
> services of a concessionaire. This "common-pool" or "freedom of
> choice" system has been described above.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: The current system excludes large segments of the U.S.
> population
>
> The current system rations by price in the commercial sector and
> inconvenience in the private sector. These rationing methods
> eliminate large percentages of the U.S. population from having
> reasonable access to the Grand Canyon.
>
> Commercial trips through the entire canyon cost around $2800 per
> person. This excludes all but a small percentage of the U.S.
> population. The miner's canary in this system is the Boy Scout
> or Explorer troop or similar youth group. It is impossible for a
> Boy Scout Troop in any but the richest few zip codes in the U.S.
> to even contemplate a commercial trip in the Grand Canyon.
>
> Similarly, the current waiting list system for private trips,
> with its minimum 8-year wait, imposes an unreasonable obstacle
> on private river runners. Things change in eight years and many
> people who have the interest in running the canyon may find
> themselves unable to do so when they finally come to the front of
> the line. Our Boy Scouts serve as an example: Scouts who
> enter a troop at age 10, at the time a troop submits an
> application for a private river trip, will be graduating from
> high school, or college, or perhaps have scout-age children of
> their own, by the time their permit is drawn.
>
> Once a private applicant comes to the head of the line the
> current system is inflexible and presents additional obstacles.
> First, the aspiring river runner has little flexibility to
> schedule their trip. Private river runners are no different than
> commercial river runners--they have constraints on vacation time
> and other limitations such as school schedules. The current
> system allows them to defer their permit for one year. If they
> cannot accommodate to launch availability in the limited window
> allowed by NPS they lose their opportunity to run the river,
> regardless of the time they have waited on the list and the
> amount of fees they have paid.
>
> Because of the inflexibility of the existing system of private
> access rationing, almost half of the permits granted through the
> waiting list are canceled. Almost all of these canceled permits
> are used by people who are able to drop everything to run the
> river on short notice or at odd times of the year.
>
> Solution: Adopt a system that eliminates unnecessary rationing
> obstacles, provides a wider variety of river running services and
> opportunity and that lowers costs.
>
> In the commercial sector several steps can be taken to lower
> prices:
>
> Remove the price of access from commercial river trips. This
> can be done by converting to a common-pool or freedom of choice
> system.
>
> Increase competition by increasing the number of concessionaires
> and the variety of services offered. Current concessionaires
> offer relatively homogeneous services. NPS should license
> low-cost outfitting and guiding services to operate in the park,
> provided that they meet minimum safety and insurance
> requirements.
>
> In the private sector, elimination of the long waiting list and
> allowance for more scheduling flexibility would decrease
> obstacles to many. A fundamental change, to a common-pool system
> is required to shorten the waiting time. A well-designed system
> can add additional scheduling flexibility, as discussed
> elsewhere.
>
> It is important to note that the need for scheduling flexibility
> has been raised primarily with regard to commercial customers,
> but it is just as much a need in the private sector. By moving
> to a common-pool system and by treating commercial customers the
> same as private river runners there will be increased pressure on
> NPS to develop scheduling methods that meet the needs of all
> river runners.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: The current system discriminates against private river
> runners because it makes them wait much longer than commercial
> passengers before they can run the river.
>
> All evidence indicates that the private river runner must wait
> much longer for a trip than a corresponding commercial customer.
> As noted above, concessionaires generally do not schedule trips
> more than two years at a time, a practice that almost certainly
> reflects the demand from their customers. At the same time,
> private river runners face a minimum 8-year wait for a launch
> permit. This imbalance constitutes discrimination against those
> citizens who wish to travel through the canyon on a private trip.
>
> Some argue in defense of the current system that the waiting list
> for private trips is really just to lead a trip, that in fact
> many more people can go on private trips either by attaching
> themselves to another's permit or picking up a cancellation.
> This argument ignores the fact that many people are waiting for a
> permit, and paying real money to do so. There must be some
> important advantage to them to do so rather than just tag along
> or pick up a cancellation. What people on the list are waiting
> for is the opportunity to plan their own trip. Most people
> cannot take advantage of ad hoc opportunities. Who, for example,
> will want to take my family with two small boys. Conversely,
> which groups might I be comfortable with, in terms of safety and
> company.
>
> Solution: Adopt a system that treats commercial passengers and
> private river runners equitably.
>
> Adopt a common-pool system described elsewhere, along with a
> flexible and efficient launch scheduling system.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Existing river tour concessionaires are re-selling access
> rights.
>
> A significant portion of the cost of a Grand Canyon river trip is
> attributable to the purchase by the passenger from the
> concessionaire of the right to use the river. That this occurs
> can be demonstrated by an economic analysis of concessionaire
> operations but is more directly evident from the fact that
> charter trips, e.g. for kayak support, are offered.
>
> Solution: Separate access from outfitting, guiding and tour
> operations.
>
> Adopt a system that does not rely on grants of access rights to
> concessionaires. The common-pool system will do this.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: River access rights can be treated as assets by tour
> companies.
>
> Access rights can effectively change hands without being put up
> for bid. When business transfers do trigger a bid process for
> river access rights, the access rights are often granted to the
> purchaser.
>
> Solution: Separate access from outfitting, guiding and tour
> operations.
>
> Adopt a system that does not rely on grants of access rights to
> concessionaires. The common-pool system will do this.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Private river runners cannot schedule trips.
>
> Under the current system, private river runners are offered
> little flexibility in scheduling their launches. Because of the
> exceedingly long waiting period before a private permit is
> issued, personal situations can change. Children, not even
> conceived at the time of permit application, may be in school, or
> work or financial conditions may restrict the applicant in the
> use of the permit at the time it is available. Currently , NPS
> allows an applicant to defer a permit for one year. There seems
> no reason for such limited flexibility. One result of this is
> excessive cancellations.
>
> Solution: Adopt a system wherein all river runners reserve launch
> dates.
>
> Any system that replaces the current one should provide a launch
> scheduling system in addition to a rationing system. The launch
> scheduling system should allow as much flexibility as is
> practicable. Waiting list and lottery systems should allow for
> reservation of launch dates years in advance, once the applicant
> has cleared the end of the rationing system. Applicants could be
> allowed, once they have cleared the rationing system, to reserve
> a primary launch date as well as secondary dates behind other
> reservations.
>
> This type of flexibility is currently available for commercial
> passengers and should be extended to all river runners.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Lack of data on which to base management decisions.
>
> NPS has no formal contact with commercial passengers and collects
> no data regarding their trip arrangements or demographics.
> Further, NPS cannot conduct follow-up surveys on satisfaction and
> other issues. NPS has far more data about private river runners.
>
> Solution: Adopt a system that inherently gives NPS more data and
> better access to river runners, undertake additional data
> gathering and analysis and routinely publish all data and
> analyses.
>
> The common-pool or freedom of choice system would require river
> runners to obtain a launch permit from NPS. As part of this
> process, NPS would collect information about trip arrangements.
> For example, NPS would know as part of the normal course of the
> permitting process when each permit was originally requested, the
> name of the permit holder and all participants on the trip or in
> the commercial group and the mode of river travel used by the
> group.
>
> In addition to collection of this basic information, NPS should
> conduct surveys on river runners, tracking their expectations and
> attitudes from initial contact until after the trip, and
> collecting demographic information. Information such as this
> would allow for better management decisions. In order to allow
> the public to evaluate NPS management, all raw data should be
> made public, along with the results of all analyses.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Canyon use is at or over limits set by resource damage and
> crowding
>
> Solution: Do not increase overall use.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Current clustering of launches on weekends increases
> crowding and encounters.
>
> Because more trips launch on weekends, these trip cohorts
> experience greater crowding at attractions and have more frequent
> encounters on the river. In addition, these effects spill over
> to trips launched near the weekend that are traveling at a
> different speed.
>
> Solution: Evenly distribute all launches over the week.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Large trip sizes increases crowding at attractions.
> Solution: Reduce maximum trip size.
>
> Select a maximum trip size that allows for reasonable
> configuration of oar and motor trips. Apply the same maximum
> trip size to trips under commercial and private permits.
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Repeat trips by some river runners may interfere with
> access by others
>
> There are no limitations on repeat trips for commercial
> passengers. There are some limitations on the number of recent
> trips a private permit holder can have. There are no records of
> individual river use in the commercial sector. Anecdotal
> evidence indicates that substantial repeat use takes place on
> private permits.
>
> Repeat use may or may not displace other river runners. Because
> private trips are managed on the basis of launches, filling a
> permit with repeat river runners will not displace a launch. It
> is difficult to know if repeat river runners on private permits
> displace other potential trip participants. Many repeat trips
> under private permits are made as a result of cancellations.
>
> The situation is different in the commercial sector. Assuming
> that demand is present for additional non-repeat business, repeat
> trips under commercial permits are much more likely to displace
> other river runners. This is because commercial river trips,
> while managed on a launch basis, are almost always filled with
> all comers.
>
> Even though the impact of repeat trips are different, it is fair
> to apply the same rules to the different sectors.
>
> Management of repeat trips is possible with any rationing system
> and can be adjusted to meet management goals.
>
> Solution: Adopt non-repeat rules
>
> Adopt non-repeat rules as needed to meet management goals.
> Non-repeat rules should be independent of the rationing method
> used to limit use (i.e. a waiting list, lottery or reservation
> system).
>
> Repeat rules should be stated in terms of the number of trips
> allowed in a given time (e.g three trips in five years), rather
> than a fixed interval between trips (e.g. two years). This
> allows flexibility to deal with opportunities that may arise
> (e.g. family trips, time off from work, financial conditions).
>
> +++++++++++++++++++++++++++++++++++++++
> Issue: Commercial crew take away opportunities for other river
> runners to enjoy the river
>
> Commercial crew are necessary for commercial trips, but they take
> up space that could be occupied by other river runners. This
> issue is similar to the issue of repeat use. As such, and all
> other factors being equal, commercial river trips are not as
> efficient as private trips in providing access to the river to
> citizens. Depending on the type of trip, this overhead may range
> from 5% to 25% or more.
>
> Commercial river trips are necessary to serve that segment of the
> population who want or need help in running the river. However,
> the management system should provide for the use of commercial
> services only to the minimum extent required to meet the demand
> for these services. The management system should be neutral as
> to the type of trip used by the river runner. The current
> system, because of its arbitrary and incorrect allocation of use,
> artificially inflates the amount of commercial use and thus
> inflicts unnecessary overhead on river access.
>
> Solution: Recognize that commercial river use is inherently less
> efficient and do not encourage it above natural demand.
>
> The current system provides a larger fixed allocation of use for
> commercial use in spite of evidence that demand for private river
> trips far exceeds the smaller allocation available for those
> trips. Adopt a common-pool system that responds to actual demand
> for river use.
> --
> --------------------------------------------------
> -- Ben Harding blh@hydrosphere.com --
> -- Hydrosphere Resource Consultants --
> -- Hydrosphere Data Products --
> -- 1002 Walnut, Suite 200 --
> -- Boulder CO 80302 --
> -- --
> -- 303-443-7839 voice 303-442-0616 fax --
> -- --
> -- Publishing Natural Resources Data on CD ROM --
> -- Consultants in Natural Resources Planning --
> --------------------------------------------------
>
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