March 10, 2022
Mr. Edward Keable, Superintendent
Grand Canyon National Park
PO Box 129
Grand Canyon, AZ 86023
Dear Superintendent Keable:
I am writing on behalf of over 2,100 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 40,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former NPS directors, regional directors, superintendents, resource specialists, rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
The Coalition is concerned about the lack of a public comment opportunity prior to Grand Canyon National Park’s (GRCA) decision to increase the cost of overnight backcountry permits. It has been a long-standing National Park Service (NPS) practice for parks to offer a public comment opportunity when any significant user fee increases are being considered. Increased entrance and user fees can discourage lower income communities and people of color from visiting GRCA or other parks. As a result, it seems obvious to us that the public should have the opportunity to comment on proposed fee increases, especially at a large park like GRCA which has multiple user fees and some of the highest fee rates within the system.
The authority for the NPS to recover and retain costs associated with managing special park uses is found at 16 U.S.C. 3a. Charges established for a special park use under this authority are intended to recover costs associated with managing that activity and not to generate revenue beyond actual cost. According to NPS Director’s Order (DO) 53 Special Park Uses1https://www.nps.gov/subjects/policy/upload/DO_53_2-23-2010.pdf, “Superintendents should consult DO #75A Civic Engagement and Public Participation for guidance about notifying the public about permit fees or other special use park issues. Local decisions regarding special park uses may have Servicewide implications and set precedents that affect management of other parks.” See Section 2, Background, p. 2.
As described in DO-75A2https://www.nps.gov/policy/DOrders/75A.htm, Section IV Scope, “[t]he civic engagement and public involvement policies of this order… [a]pply to discretionary decision-making … at all levels and within all program areas of the National Park Service where: 1) the public has an identifiable interest or is likely to be interested, 2) there may be applicable knowledge or expertise likely to be available only through public consultation, or 3) there are complex or potentially controversial issues.” See Section IV Scope. In addition, “[t]he NPS role is to provide opportunities for the public to be involved in meaningful ways, to listen to their concerns, values, and preferences, and to consider these in shaping our decisions and policies.” See Section V Definitions.
On February 28th, 2022, GRCA announced it would increase the cost of overnight backcountry permits from $8 per person per night to $12 per person per night (in addition to the $10 per group permit), starting July 1st, 2022, a 50% increase in the nightly per person fee. Whereas there was no public comment period prior to the GRCA announcement, in recent years many parks have invited public comment about proposed increases in user fees before deciding to implement them. In some cases, public feedback has resulted in a park not increasing fees or in revising the proposed fee structure.
Under the new fee structure, GRCA will have one of the most expensive backcountry permits in the National Park System. For example, 5-day/4-night trip for two people at GRCA will cost $106 ($10 per permit + $48 per person). In contrast, the same 5-day/4-night backcountry trip for two people would cost a total of $20 ($10 per permit + $5 per person) at Yosemite National Park; $25 ($15 per permit + $5 per person) at Sequoia – Kings Canyon National Parks; $56 ($7 per night per person) at Glacier National Park; $35-45 (advance vs. day-before) at Grand Teton National Park; $32 ($4 per night per person, capped at no more than $20 per person) at Great Smoky Mountains National Park; $5 for the permit at Zion National Park; and $0 (i.e., free) at Shenandoah National Park.
The press release announcing the fee increase states that the fee increase is necessary to pay “actual costs for operating Grand Canyon’s permit offices and Backcountry Information Centers.” While recovery of costs associated with managing a special park use are authorized under 16 U.S.C. 3a, a public comment period for the announced fee increases would have allowed for a greater understanding of the impact of these increases on the general public and perhaps identified creative solutions to be offered and explored for increasing the efficiency and operations of the backcountry office.
In addition, while many other national parks have transitioned their permit systems from phone to fax to email to recreation.gov, GRCA is still using a fax-only system that requires extensive labor to process and follow-up with alternative itineraries. We encourage GRCA to modernize its system as doing so would not only improve customer service, it would also require less labor to administer the system, thus reducing costs. The current system also places the entire administrative cost burden on those who actually receive permits; since those who apply but do not receive a permit bear no cost, despite the administrative work needed to process their requests. Other parks have moved to a non-refundable permit application fee, which offsets the cost of administrative work and better disperses the cost burden.
In conclusion, we encourage you to put a temporary hold on the GRCA backcountry permit fee increase until after the park has held a public comment period on the proposed increase. This would provide an opportunity for the public to suggest and for the park to consider impacts of the proposed fee increases as well as alternative approaches that could effectively offset actual costs. If you have any questions about our concerns, please feel free to contact us.
Michael B. Murray, Chair
Coalition to Protect America’s National Parks
2 Massachusetts Ave NE, Unit 77436
Washington, DC 20013
cc: Charles Sams, Director, National Park System
Update – August 17, 2022
Please see the attached letter from Superintendent Ed Keable regarding the letter sent March 10th, 2022.