December 1, 2023

Arches National Park
2282 SW Resource Blvd.
Moab, UT 84532

RE: Arches National Park Visitor Use, Access, and Experience Planning

Dear Arches National Park,

On behalf of the National Parks Conservation Association (NPCA) — and our nearly 1.6 million members and supporters nationwide — and the Coalition to Protect America’s National Parks, we write to express our gratitude to the team at Arches National Park and the National Park Service Regional Office for your commitment to addressing the complex challenges of managing visitor use, access and experience.

Founded in 1919, NPCA is the leading citizen voice for the national parks. Our mission is to protect and enhance America’s National Park System for present and future generations. We are a national nonprofit with headquarters in Washington, D.C. and regional and field offices across the country, including our Utah office in Salt Lake City. The Coalition to Protect America’s National Parks (Coalition) is comprised of more than 2,500 members, all of whom are retired, former, or current National Park Service employees or volunteers 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.

Our organizations remain committed to working with the Park Service and other stakeholders to protect predictable, high-quality visitor experiences at national parks. As organizations that advocate for the parks along with a diverse set of partners, we recognize the salient challenges national parks face from increasing visitation, declining funding, and staffing and housing shortages. We are invested in all that is at stake at Arches National Park, including the world-class natural and cultural resources and recreational opportunities inside and surrounding the park, as well as the quality of life for residents of and visitors to Grand County, especially the community of Moab.

That established, it is time for permanent action. The Park Service has been working to manage traffic congestion at Arches National Park for more than 15 years. Arches conducted the Traffic Congestion Management planning effort from 2015-2017, which was concluded without an implementation plan. This comment period is the third time in the past five years the Park Service has asked for public feedback on visitor access and experience at Arches. We humbly request that the Park Service be respectful of the public’s time and attention and launch a long-term visitor use plan with haste.

We appreciate the opportunity to comment on visitor use, access and experience at Arches National Park.

We will offer feedback on 1) issues, objectives and goals for evaluating visitor access management, 2) the strategies presented in the most recent newsletter, 3) considering other strategies, and 4) impressions, improvements and successes of the managed access pilots, as requested. But to be clear, we believe the Park Service has found a strategy that works for managers and visitors: timed-entry reservations.

Issues, Objectives and Goals for Evaluating Visitor Access Management

In its newsletter, Arches National Park states its objectives and goals for management strategies related to visitor access and experience are (in short):

  • Reduce congestion at popular park sites
  • Provide predictable access to key destinations
  • Provide adequate trip planning and traffic congestion information to visitors.

We concur with these goals and affirm the Park Service is currently achieving them under the pilot timed- entry system.

Our priority goals, in alignment with the Park Service’s stated objectives and goals, are:

    • Visitor experience: maintain high-quality visitor experiences, as established and monitored using scientific principles, such as people-per-viewscape
    • Visitor access: prevent temporary capacity closures, ensure reasonable parking availability
    • Transportation: minimize entrance lane queues, prevent illegal driving and parking activities (e.g., parking on shoulders, damaging fragile roadside vegetation)
    • Communication: invest in creative and iterative efforts to reach visitors and prospective visitors with information about timed-entry
    • Operational feasibility: visitor service conditions are managed at levels and using systems that create safe and smooth working conditions for Park Service staff

Strategies Presented in The Most Recent Newsletter

The findings of several studies and visitor surveys conducted in Arches National Park have shown timed- entry reservations are both effective in addressing the park’s objectives and goals for visitor use management and popular among visitors. For instance, in its study Pilot Timed Entry System at Arches National Park in 2022, the Park Service found visitor access to the park entrance and to parking improved during the pilot timed-entry system, as did visitor experience quality (as measured by people per viewscape) in all locations measured (Windows, Delicate Arch, Devils Garden). Additionally, 84% of visitors surveyed by Utah State University in 2022 indicated they would like there to be a reservation system on future trips. The data show timed-entry reservations are effective and desirable, and we believe they should remain in place at Arches National Park.

We support exploring the strategy build for demand: entrance station as an appropriate compliment to a timed-entry reservation system. Expanding and redesigning the entrance lanes and main (Moab) entrance station infrastructure at Arches could present a way to shorten processing time for certain user groups (such as commercial use authorization holders who come in and out of the park often and do not need to nor wish to spend time interacting with Park Service staff upon arrival). Notwithstanding, redesigning the main entrance station is not a sufficient strategy on its own for achieving the park’s goals related to congestion, so it should only be pursued in tandem with timed-entry reservations

The newsletter lists several strategies that have already been thoroughly considered and studied over the years. For instance, Arches National Park’s 2016 Transportation Study determined a shuttle system would

not be feasible nor effective due to the length of the park road, distance between destinations, cost to acquire and operate the shuttle buses, and trail crowding effect. In the 2017 Traffic Congestion Management Plan, the Park Service assessed and concluded a second entrance would add to existing overcrowding at popular destinations inside the park and would not meet desired future conditions at more remote areas of the park. Examining recurring strategies — such as a mandatory or voluntary shuttle system and build for demand: secondary roads — anew with no fundamental change in conditions on the ground is unnecessary and inefficient.

A daily reservation system has not yet been publicly studied at Arches National Park, but it is unlikely to address the park’s congestion and destination access challenges, which are time-bound phenomena based in predictable (but unshakable) human behavior. (Additionally, a daily reservation system would likely accommodate fewer total vehicles per day compared to timed-entry reservations.) Similarly, site-specific reservations have not yet been publicly studied, but we believe they are not desirable due to the increased complexity for visitors and the burden-to-benefit ratio of administrative oversight and communication incumbent upon the Park Service. We believe these strategies should be dropped from consideration.

As we stated in 2021, we do not support the strategy build for demand: existing hotspots. Park maintenance budgets are already strained, and Arches National Park is not a landscape of sufficient size and topography to absorb the impact of additional parking lots and other major infrastructure. Significant additional infrastructure would be highly visible, could result in undesirable impacts to natural and cultural resources, and would not likely solve the goal of providing predictable access to key destinations. Moreover, we believe the Park Service has already expanded facilities adequately.

Considering Other Strategies

We believe no new strategies need to be considered and many of the strategies currently listed should be dismissed, as noted previously.

Impressions, Improvements and Successes of Managed Access Pilots

Adaptive management is a key approach to visitor use management under the Interagency Visitor Use Management Council Framework, and it is an approach Arches National Park has employed well in its managed access pilots. For instance, during the 2022 timed-entry pilot, long queue formation at the park entrance stations was a documented problem. Park staff at Arches made incremental adjustments to their systems and practices to address the problem, and it was largely ameliorated by the end of the 2023 pilot. (There is still some room for improvement, especially to accommodate vehicles operated by commercial use authorization holders whose specific needs are different than the general public. As stated above, redesign of the main entrance station is a possible strategy for addressing those needs.) We have full confidence the Park Service will continue to manage a timed-entry reservation system adaptively to address ongoing and future issues using research and monitoring.

One issue we encourage Arches National Park to monitor for is visitor use that occurs outside the timed- entry reservation periods, both time of day (before and after the reservation requirement) and day of the year (in the days and months outside the reservation requirement “season”). We are confident the Park Service is actively monitoring this already as we saw the 2023 timed-entry pilot expand into the month of October (after concluding in September in 2022), and we are encouraged by this adaptive management. We encourage the Park Service to consider adjusting the season and timing of timed-entry reservation requirements as visitation patterns and visitor coping strategies evolve.

Intentional community outreach to user groups and communities already underrepresented in park visitation should be a priority strategy developed iteratively and creatively alongside timed-entry reservations. We encourage the Park Service to assess timed-entry data, user surveys and staff observation to identify groups among whom successful timed-entry reservation adoption is low and develop communication and outreach strategies intended for those communities. Park staff at Arches could co- learn about this kind of intentional community outreach with staff at other parks working hard to effectively reach new user groups.

Many visitors to Arches plan to visit multiple national parks on a single trip. We encourage Arches National Park to contribute to systems that streamline and coordinate reservations at other parks while maintaining its functionality for achieving its own objectives and goals. This coordination could smooth the experience of planning multi-park trips, especially international ones. We acknowledge that elements of this kind of desired multi-park coordination is most achievable in a permanent system and not a reasonable request for a pilot. Importantly, government contractors with the reservation platform will need to cooperate with the Park Service in good faith toward these efforts to better serve visitors.

To conclude, two seasons of timed-entry pilots have been useful tests of a viable strategy to meet the park’s purpose and need for visitor use management. The pilots were instructive; year-over-year, the staff at Arches National Park managed adaptively to problem solve gaps in efficiency of operating the system and refined the system to maximize use within daily target visitation levels (within the realm of the possible using We expect timed-entry reservations will continue to be adaptable and responsive to changing visitation patterns.

We strongly believe continuing timed-entry reservations in a pilot phase beyond year three (2024) is unnecessary for Arches National Park as the Park Service has the data and public input to move forward with a draft environmental assessment for public review. While pilots are helpful learning tools, perpetuating programs in a pilot form fosters continued uncertainty — visitors do not know definitively what to plan for, businesses cannot develop long term business plans nor customer communication strategies, and park staff are unable to work on more sophisticated refinements of the system if they are not certain another year will be authorized. The pilot phase for timed-entry reservations at Arches National Park has been hugely effective, and it now needs to lead into and shape a long-term plan for visitor use, access and experience.

Thank you for your ongoing commitment to visitor experience, resource protection and staff well-being at Arches National Park and for the opportunity to comment. We will continue to advocate for augmented resources for the Park Service across regions to do excellent visitor use management. We look forward to continued engagement and partnership in a long-term visitor use, access and experience planning process.


Cassidy Jones
Senior Visitation Program Manager
National Parks Conservation Association

Erika Pollard
Campaign Director, Southwest
National Parks Conservation Association

Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks