October 5, 2023
Grand Teton National Park
Post Office Drawer 170
Moose, WY 83012
Subject: Comments on Visitor Use Management at Grand Teton National Park
Dear Superintendent Jenkins:
I write to you on behalf of more than 2,500 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 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, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
We appreciate Grand Teton National Park’s efforts to address concerns around increasing numbers of visitors, people’s ability to have safe, valuable experiences in the park, and the ability of park managers and staff to protect park resources. You are to be commended for initiating a Visitor Use Management (VUM) planning process and associated public scoping on the heels of valuable studies of current visitor use patterns and resource concerns at the park. This should lead to a plan that identifies appropriate future conditions, indicators, thresholds, and park-wide or location-specific visitor capacities to enable the park to achieve and maintain desired resource conditions and visitor experiences that are consistent with the purposes for which the area was established. Once the plan is implemented, it will be important for the park to conduct periodic monitoring to track success and public acceptance as management actions are implemented in the future.
We also encourage the park to consider adaptive management strategies as new data is made available and lessons are learned as to approaches that work best in different situations. Over time, the park may wish to consider a combination of strategies, such as timed entry to certain areas, day-use reservations, seasonal reservation systems, peak time limits (such as on holidays and during core day hours), and other methods.
It is not clear to us from the story map or the PEPC listing whether this VUM process also applies to the John D. Rockefeller, Jr. Memorial Parkway (parkway), which you and your staff manage along with Grand Teton National Park. We encourage you to include the Rockefeller Parkway in this planning effort if you have not already intended to do so. Including the parkway would provide the opportunity to get ahead of issues that might arise if visitor use continues to increase there. The inclusion of the parkway, which has few developed trails and facilities would also add to the spectrum of visitor opportunities for solitude and quiet associated with low-density roadside camping on Grassy Lake Road and low levels of river use on the wild stretch of the upper Snake River within the parkway.
As at many other parks, congestion at parking and other areas and long waits are major issues, along with associated resource impacts, such as user-created trails, cross-cutting, and noise. For example, there is a notable conflict between the stated goals for a quiet, contemplative Laurance S. Rockefeller Preserve and the increasingly popular “jump-off rock,” which has grown into a popular swimming spot for sometimes loud parties of users along a well-used trail that accesses several other backcountry areas including Granite and Open Canyons. In another example, String Lake has become as busy as an urban beach and water sports area, and we recognize that some visitors may yet find it desirable. However, tolerating unlimited numbers of cars parking along roadways, even if safely off the pavement, can result in subtle resource damage to vegetation and wildlife habitats.
We appreciate that the park has already taken on complex planning issues, such as for the Moose-Wilson corridor, where you are now implementing improvements to the road and parking areas. We hope that, along with the recent influx of needed infrastructure funds, the park also obtains the capacity to implement traffic management experiments or regimes that were also analyzed in those previous planning discussions. Results of such efforts could greatly inform options for offering varied experiences there and in other often congested sites, such as by promoting the cooler shoulder seasons or by limiting user numbers at certain days or times for people who want more opportunities for quieter experiences. We respect that systems employing technological solutions or reservations to manage use at busy localities likely require increased staff, funds, and/or infrastructure, and our organization has consistently advocated that the NPS be allocated more such resources.
National parks have for many years developed effective ways to limit overnight lodging capacities and limit commercial uses. In Grand Teton National Park specifically, there are well-established use limits on guided climbing and rafting trips, which should be continued as these efforts have contributed to limiting resource impacts and spreading out people doing those activities, resulting in quality user experiences. In recent years, however, increases in private climbing and rafting trips that are neither limited nor guided—while they provide freedom to users to go when they please—have upped the congestion and user conflicts at parking lots and on trails to “the Grand” itself, as well as at river launch and stopping spots. The VUM process should address the management of day use and noncommercial use in the park and parkway.
Grand Teton National Park also is challenged by a growing culture of extreme and/or competitive recreation. In some users’ efforts to break records, like speed-climbing the peaks, people have caused trail-cutting erosion and even user conflicts, such as hikers running or yelling for others to get out of the way. There are backcountry skiers who resist closures of critical winter bighorn sheep habitats because they prioritize their access to any untouched slopes. The park’s VUM process should address all seasons of use and visitor safety issues as well as resource concerns.
Another important consideration is to maintain affordable visitor opportunities. As you well know, Grand Teton National Park does not lend itself to being easily visited without many Americans spending a fair amount of money just to get there. There is still no good option to take a bus from Jackson to the park, affecting even local residents of lower or average incomes. Guided climbing, rafting, and even wildlife-watching excursions, like lodging in and near the park, can add to the expense for visitors. Fees for front and backcountry camping continue to rise, and we understand that concessions laws and contracts influence these, along with the NPS’s desire and ability to recoup operating dollars through the Federal Lands Recreation Enhancement Act (FLREA). But we hope the park will consider the effects that more and higher fees for campsites, reservations, and even cancellation fees have on average citizens.
Also, the concept of visiting this and other parks on the spur of the moment is being lost. While we encourage the park to consider reservation systems or use allocation as may be appropriate, we also urge flexibility in such efforts, to incorporate ways in which visitors might take advantage of last-minute cancellations, early-entry hours, or other creative ways in which people can access the park without requiring them to always make plans months in advance.
A thoughtful Visitor Use Management model for Grand Teton National Park and the John D. Rockefeller, Jr. Memorial Parkway will be key to conserving the cultural and natural resources, ecosystem services, outstanding environmental quality, and visitor experiences highlighted in the parks’ 2017 Foundation Document, enabling laws, and National Park Service policy and law. We appreciate the opportunity to comment on this important planning endeavor.
Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks