December 13, 2023

Gary Ingram, Superintendent
Rocky Mountain National Park
1000 US Highway 36
Estes Park, Colorado 80517

RE: Rocky Mountain National Park Long-Range Day Use Visitor Access Strategy and Environmental Assessment

Dear Superintendent Ingram:

On behalf of the National Parks Conservation Association (NPCA) and our nearly 1.6 million members and supporters nationwide, including over 36,500 throughout Colorado, and the Coalition to Protect America’s National Parks, we write to express our gratitude to you and the planning team at Rocky Mountain National Park (ROMO) for your leadership on visitor access management and to comment on the park’s long-range day use visitor access strategy and environmental assessment (EA).

Founded in 1919, NPCA is the leading citizen voice for the national parks. We are a national nonprofit with headquarters in Washington, D.C., and we staff 27 regional and field offices across the country, including in Denver, Colorado. Our mission is to protect and enhance America’s National Park System for present and future generations. One of our major priorities is advocating for visitor use management that both protects the park resource and visitor enjoyment as stipulated in the Organic Act of 1916.

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 NPS 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.

The land that is now ROMO was primarily inhabited by the Ute and Arapaho Tribes, with presence of several other Nations, including the Eastern Shoshone, Apache, Comanche, and Cheyenne. ROMO is committed to acknowledging this painful history and maintaining its respectful, active relationships with Tribal Nations, and we urge that work to continue. Thank you specifically for providing members of Indigenous Tribes who wish to enter the park for spiritual or traditional practices an exemption from the long-range day use access plan.

NPCA and the Coalition strongly believe a permanent day use visitor access management plan as outlined in Alternative B: Timed Entry Reservations for Rest of Park and the Bear Lake Road Corridor (BLRC) (NPS Preferred Alternative) is the vital next step for long-term health of ROMO, its visitors, and its treasured staff.

Within the NPS Preferred Alternative and as explained further below, we urge you to consider the following:

  • Require timed entry year-round in the BLRC on weekend days.
  • Clarify the plan’s application to commercial use authorization (CUA) holders.
  • Continue studying the potential future need for a Longs Peak Trailhead educational permit requirement and how best to manage this requirement.
  • Continue studying impacts that occur outside the timed-entry reservation periods and times of year when reservations are not required to identify necessary adjustments.
  • Invest in transit as a necessary management tool.
  • Invest in targeted community engagement to reduce visitation barriers for underrepresented individuals.
  • Consider climate change as a key factor in a future year-round reservation system.

We urge the Park Service to complete a final plan that implements the NPS Preferred Alternative for ROMO as early as possible in 2024.

Thank you for today’s opportunity to comment more specifically as follows:

I. All national park managers must be supported to implement innovative visitor management solutions that respond to the unique needs of park landscapes.

Our organizations recognize that there is no one-size-fits-all solution to visitor use management. As the landscape, destinations, and visitation patterns are unique for each national park, managers need a full suite of tools and potential solutions to their visitor management challenges based on park size, sensitivity of natural and cultural resources, staffing, infrastructure, and other factors.

While the solutions for each park will be different, some of our most popular parks, like ROMO, must actively manage visitor access through reservation systems to protect the park resource and the visitor experience most comprehensively.

Ignoring this reality through a No Action Alternative not only disregards ROMO’s many years of pilots, research, adaptive planning, and public engagement on this issue, but it also wrongfully assumes this problem will solve itself.

The National Park Service 2022 Visitation Report shows visitation to America’s national parks continues to rebound toward pre-pandemic levels (in 2019 alone, 327.5 million visits were made throughout the park system, nearly equaling the entire population of the United States). National parks received 312 million recreation visits in 2022, up 15 million (5%) from 2021. Even despite the Park Service’s efforts to bolster visitation at lesser-known parks and at times of the year when parks historically see fewer visitors, numbers at popular parks like ROMO continue to soar. As you know all too well, ROMO remains one of the busiest parks in the National Park System with nearly a 45% increase in visitation since 2012. Visitation increased from fewer than three million visits in 2010 to a peak 4.6 million in 2019, placing it at number three for most visited parks in the nation.

ROMO is a unique landscape encompassing more than 265,000 acres, comfortably more than double the size of Denver, and its visitation management planning process is designed to meet its specific needs. For example, the park is nearly 95% designated wilderness, which puts an additional legal responsibly on staff to manage the landscape compatibly with the Wilderness Act of 1964. Due to the purposeful lack of developed infrastructure in the park, visitors generally dominate the same readily accessible areas, like the BLRC and areas right off Trail Ridge Road. Another unique aspect of the landscape is the alpine tundra that comprises approximately one-third of the total park area. Because alpine tundra is a fundamental resource and very fragile, park managers must give it increased attention for protection in this ecosystem (EA, 3-31-32).

ROMO’s visitor use pattern is also distinctive, and often local. As reflected in the EA’s analysis of socioeconomic studies and surveys conducted by the park over the years, the overwhelming majority of ROMO visitors are repeat day users (as there are no lodges within the park boundary) who prefer to visit areas that are readily accessible by private vehicles. Most visitors live in the Front Range, which is one of the fastest-growing areas in the nation. In fact, Colorado’s population grew by nearly 16% between 2010 and 2022, from 5 million in 2010 to approximately 5.8 million in 2022 (US Census Bureau 2023). Citing a Biodynamics and RRC Associates 2023 study, the EA illustrates the enduring enthusiasm visitors have toward accessing the park and overall readiness to embrace a reservation system as a means toward achieving that access: “[o]verall, visitation to Rocky Mountain National Park has been consistently increasing . . . visitation was not disproportionately impacted by the pilot timed entry systems implemented in 2020-2022.” (EA 3-8).

Visitor surveys, which informed the EA, show that most people visit the park to view wildlife or natural scenery and to “hear sounds of nature/quiet” (Cullinane, Flyr, and Koontz 2022, EA, 1-2 ). Rapid growth in day use visitation has harmed these values, while degrading natural and cultural resources, increasing safety concerns, and straining park staff’s ability to perform daily operations.

Discounting a permanent long-range day use strategy that responds to ROMO’s unique and urgent needs, the No Action Alternative puts the future of this treasured park in jeopardy. NPCA and the Coalition will not support proposals that impair the long-term planning process for this landscape and other parks currently struggling with overcrowding. For ROMO, and for other popular parks facing acute visitation challenges, a long-term reservation system will allow the park resource and the visitor experience to thrive.

II. ROMO is now firmly positioned to lead the nation’s first permanent parkwide visitor access strategy through the NPS Preferred Alternative.

Building upon its history of visitor use management over the past three decades and its distinction as the first national park to not only implement a pilot timed entry permit system (TEPS) in 2020, but also to reassess and execute three subsequent seasons of this innovative solution in 2021-2023, ROMO is now firmly positioned to lead the nation’s first permanent parkwide reservation system through the NPS Preferred Alternative (Alternative B: Timed Entry Reservations for Rest of Park and the Bear Lake Road Corridor (BLRC)).

We applaud the adaptive nature of the proposed plan under all proposed action alternatives, allowing park managers to implement, monitor, and adapt accordingly as indicators and thresholds change. Adaptive management is a key approach to visitor use management under the Interagency Visitor Use Management Council Framework, and it is an approach ROMO has employed well in its pilot TEPS. The superintendent must have discretion to authorize temporary, site-specific closures to mitigate critical resource impacts without requiring a lengthy public comment process (EA, 2-2, C-3). For example, the ptarmigan species, a permanent park resident that breeds in alpine habitat at or above tree line along Trail Ridge Road, is in decline likely due to excessive trampling of vegetation, widespread illegal parking, and visitor-created trails. While recovering the ptarmigan’s fragile habitat could take decades, the park’s ability to temporarily close impacted areas is an additional strength to the long-term plan that will help protect the species.

These comments primarily focus on the NPS Preferred Alternative because it is far more favored by our organizations than the other two alternatives for several reasons, including the fact that it has been tested by previous pilot systems. Our opinion on the other alternatives includes the following: Alternative C (timed entry reservations for the BLRC and daily reservations for the rest of the park) may provide a higher quality experience for reservations to the rest of the park by allowing fewer visitors overall—940 reservations would be allowed each day for the park to adhere to its desired conditions and thresholds (versus the 1,875 reservations allotted daily for the rest of the park in Alt. A) (See EA, 2-5, Appendix C). However, without timed entry for the rest of the park, park staff will lose a tool key toward adaptively managing peak visitation times during the day and alleviating congestion at both the entry gate and at highly visited destinations outside the BLRC.

It is possible that Alternative C, in part, could lead to less stress on park resources. For example, disturbances to highly sensitive wilderness wildlife identified by the park, including bighorn sheep, raptors, and migratory bird species (EA, 3-57) would presumably be reduced from less human-caused noise and visitor presence on and off-trail during the reservation period. However, by accommodating fewer visitors, Alternative C risks pushing more people to enter the park before and after the reservation period toward dawn and dusk, impacting night-active species.

While it is possible Alternative D (timed entry reservations for the BLRC and temporary entrance closures for rest of the park) may allow for more spontaneous arrivals when the gate is open, temporary entrance closures will create an extremely unpredictable, reactive system. This structure does not include a mechanism to disperse crowding since up to 85% of visitors travel through the East entrances, creating a vastly unequal burden for staff at those entrances and major uncertainty for visitors as to when gates will reopen. This situation will create chaos all day during popular seasons and compromise the park’s ability to respond to emergencies because of bottlenecks at entrance stations. When temporary entrance gate closures are in effect, visitors may try to concentrate in immediate areas to be ready when the park reopens, increasing emissions as cars idle and decreasing the quality of visitor-park staff interactions.

The greatest strength of the NPS Preferred Alternative lies in the fact that it mirrors the last two TEPS and was informed by the past four TEPS pilot seasons and two public comment periods, all processes where the park staff analyzed and refined the system through scientific analysis, visitor survey data, and nationwide public engagement. During each of the TEPS pilots, staff collected extensive traffic, trail, and baseline data on social trails, bare ground areas, and human waste along highly visited trail corridors. During this next year, we anticipate ROMO will continue to learn even more about the specific trends and data from this past season, as well as lessons learned from other parks embarking on adaptive visitor access management plans.

We believe that a timed-entry reservation system, focused on spreading visitors out across time of day and season and across the park in appropriate destinations, is the best long-term solution for managing levels of visitation at ROMO during peak times year-round to protect the visitor experience and park resources. To that effect, the NPS Preferred Alternative is the best option for “ . . . maintain[ing] the greatest amount of access while meeting desired conditions.” (EA-2).

Such a system gives visitors more certainty, reduces crowding (especially at high-demand areas like the BLRC) and enhances the visitor experience, including but not limited to providing more reliable access to parking and facilities, increased interaction with park rangers, less obstructed views, and easier access to keystone experiences or other points of interest.

The visitor experience improved when ROMO required timed entry reservations through the TEPS, as confirmed throughout the EA, the public comment processes, and by park staff. During last month’s public engagement session, ROMO’s planning team shared that before the TEPS pilots were implemented, park staff had to resort to restricting access in certain areas such as the BLRC. Turning people around every day, typically in summer months, as early as 9am, staff continually experienced demoralizing staff-visitor confrontations. With anger and frustration, visitors would circle the Bear Lake parking lot over and over each day. A 2021 survey comparing visitor experiences before and after the TEPS found that 76% believed their park experience under the reservation system “. . . was about the same, somewhat better, or much better than previously experienced, with nearly half reporting that their experience was somewhat better or much better.” (Creany and Monz, 2023; EA 3-8). The EA notes that this type of positive finding was reiterated in the public comment periods held in 2021 and earlier in 2023 where visitors expressed a sense of reassurance under the TEPS (EA 3-5, 3-6). It is worth noting that, during the TEPS, the local gateway economy was strong, and in fact appears to have thrived. In 2021, Estes Park businesses reported a 20% increase in visitor spending (from nearly $420 million in 2020 to $504 million in 2021) and Grand County experienced a 92% increase in sales tax revenue from 2018 to 2022 (; EA, 3-19).

Also incorporated in the EA is an examination of what visitors value and expect from their experience at ROMO, findings which further support the NPS Preferred Alternative. These include a 2022 survey that found “ . . . viewing wildlife or natural scenery as the most important reasons to visit the park” (Culliane, Flyr and Koontz 2022; EA 3-2). Indeed, “access to wild places” is recognized by park management as one of the park’s key fundamental resources (EA, 3-2). Also, for most visitors, the BLRC is a unsubstitutable, sought after destination for these values and experiences. For this reason, NPCA and the Coalition strongly agree with the park’s proposal to require a timed entry reservation for the BLRC within each alternative (Alternatives B, C, and D would each allot 2,940 reservations to the BLRC daily).

Like the past few TEPS, the NPS Preferred Alternative encourages visitor use patterns to be less concentrated in time and space which leads to positive downstream impacts: rangers able to interact with visitors more frequently, routine maintenance of facilities and roadways with less congestion. “[D]ata collection indicates that in July 2017, more than 300 vehicles were accessing the corridor each hour from 8am to 4pm on average. In 2021, the average number per hour never exceeded 250, indicating a reduction in approximately 400 cars per day during the summer month.” (EA 3-12). By focusing on a two-reservation system, the NPS Preferred Alternative addresses crowd dispersal holistically instead of the more reactive stance the park employed from 2016-2019, where park staff managed vehicle access within highly congested areas on a first come, first serve basis. Park staff had to repeatedly block vehicle access to the BLRC after parking spaces quickly filled, which ultimately either pushed crowds elsewhere in the park or required cars to turn around, idle, and return to see if parking spaces were available (a scenario which happened every day in July of 2019). An adaptive, data driven, and intentional plan gives visitors more certainty, reduces crowding during peak times, and enhances the visitor experience.

For some visitors, it is possible the experience may still be influenced by the inability to secure a reservation for the visitor’s exact desired entrance time. However, it is unrealistic to assume any of the proposed alternatives could guarantee this level of certainty to every visitor. It is also possible that the expectation of getting the exact preferred timeslot was more prevalent in the earlier days of TEPs when people were still adjusting to the new system. These expectations may have changed, especially as reservation systems became acute issues for other popular parks like Arches, where a recent study found that the majority of visitors who weren’t able to enter the park on their desired date or time did not feel impacted the quality of their experience (Arches National Park 2022 Pilot Timed-Entry Visitor Experience Survey Technical Report). Furthermore, reservations are now the norm for several surrounding landscapes in Colorado, including but not limited to Brainard Lake, Mt Blue Sky Recreation Area, Hanging Lake, Pikes Peak, Eldorado Canyon, Maroon Bells, St. Mary’s Glacier, and Quandary Peak. Lastly, in 2021, observing that certain batches of timed-entry permits were quickly selling out every day, sometimes by the same visitors, to break this pattern the park quickly pivoted to holding back a certain percentage of permits to offer day before reservations, a technique also employed during the 2022 and 2023 pilots and reflected in the NPS Preferred Alternative.

We are encouraged by the Park Service’s ongoing commitment to engage both new and reoccurring visitors on the need for a reservation system, so that expectations can continue to match experiences. We urge this commitment to continue into the final plan and its implementation.

Within the NPS Preferred Alternative, we urge ROMO to consider the following:

 Require timed entry year-round in the BLRC on weekend days.

We understand that currently there are many days outside of the summer/fall season where park visitation to the BLRC does not reach its visitor capacity of 2,200 people at one time. Factors like hazardous weather and the absence of a shuttle system during October to May generally limit visitor transportation to key trailheads in the BLRC overall. However, we urge you to consider timed entry on the weekends throughout the year for the BLRC. While demand to access the park certainly lessens on winter weekdays, Trail Ridge Road’s winter closure as well as closures in the Wild Basin area result in fewer locations for dispersal, concentrating impacts to this one area. Further, it is not unusual for parking lots at Bear Lake to be completely full by late morning on many winter weekends and holiday vacation weeks like spring break. Currently, when parking lots fill on these busy days, the protocol is for park staff to temporarily restrict access at the kiosk set up near the junction with Beaver Meadows Road (EA, D-18). Timed entry on the weekends would provide BLRC staff and visitors more certainty, more positive interactions, and a better overall experience.

  • Clarify the plan’s application to commercial use authorization (CUA) holders.

    We applaud the inclusion of CUAs within each proposed alternative, a requirement that we urged you to consider in our comments earlier this year. Given its permanent nature, we strongly agree the long-range day use access plan must also apply to CUAs, without exception. An exemption for commercial tour operators not only gives people who can afford to pay for these services an unfair advantage over those who cannot, it also sends the wrong message to other national parks currently suffering the impacts of unchecked commercial tour operators, including congestion, noise, and air pollution.

    While CUAs are not currently in as high demand at ROMO compared to some other popular parks, the EA describes a pattern of rapid, substantial change in recent years that is concerning and needs to be further examined: “. . .park staff recorded a notable shift in the number of visitors participating in guided activities from 2017 to 2020 (excluding 2020). In 2017, nearly 35,000 visitors participated in a guided activity; in 2022, this number increased by approximately 34% to more than 53,000. The substantial increase was noted from 2019 to 2021, when interactive, interpretive vehicle tours became more popular among visitors. The percentage of visitors participating in guided activities compared to the annual number of visitors was 0.79% in 2017. This percentage increased to 1.22% in 2022.” (EA, 3-25).

    Under the proposed plan, CUA holders are not required to get reservations unless the total CUA clients remain below 2% of average annual visitation. The EA explains that the park continues to require CUA operators to report their annual visitor use numbers and that if a 2% threshold is exceeded for two consecutive years, then the park will require CUAs to get reservations. However, the EA does not provide the current number of CUA holders in the park or explain how this number is counted, and how many more the plan could potentially allow. To better understand impacts to the resource and visitor experience, we urge the park to clarify how many more CUA holders this structure will potentially allow and the process of how the park will determine future management of CUA holder access.

  • Continue studying the potential future need for a Longs Peak Trailhead educational permit requirement and how best to manage this requirement.

    In our January 2023 comments regarding the need for a long-range plan, NPCA urged ROMO to require visitors to obtain an educational permit to hike or climb the Longs Peak Trailhead. We argued that, because the 14,259-foot-high Longs Peak summit is technical, narrow, and dangerous for the unprepared hiker, and since twenty percent of ROMO’s search-and-rescue operation is concentrated in the Longs Peak region of the park, requiring visitors to get an educational permit prior to the summit would help alleviate the strain on both visitors and staff. It is our understanding that Alternative C would require this permit, but after further discussion with park staff over the past year, we now have a more informed understanding that a permit is unlikely to be a need at this time.

    However, due to its ongoing popularity and the need for visitors to be adequately prepared to access hazardous terrain, our organizations urge the park to continue studying the potential need for an educational permit requirement or similar manner of proactively managing the number of visitors accessing the trailhead in the future. The National Park Service uses permits and reservations as a visitor safety measure at sites and destinations within parks (e.g., Half Dome cables at Yosemite, Angels Landing above Scout’s Landing at Zion) where overcrowding poses significant safety concerns. We encourage the park to continue to monitor Longs Peak and consider similar management tactics that would enhance visitor safety on the trail.

  • Continue studying impacts that occur outside the timed-entry reservation periods and times of year when reservations are not required to identify necessary adjustments.

    We encourage ROMO to actively monitor 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 season). It is our understanding that, during each of the past pilot TEPS, the park generally experienced a surge in visitors before and after the times of day when reservations were no longer required. We appreciate that, depending on changing visitor use patterns or potentially if this pattern increases, the park may expand the number of days, weeks, and/or the window of duration when reservations are required. While uncertain as to whether these surges will increase, the EA anticipates the general pattern to continue and has nevertheless concluded the NPS Preferred Alternative would still provide cumulatively beneficial impacts to the park and visitor experience (EA, 3-55).

    With more people entering the park before and after the reservation hours, there may be more impacts to fundamental resources that may need to be analyzed, such as natural quiet and the health of wildlife most active at dusk and dawn. For example, the EA notes that the NPS Preferred Alternative will have “. . . likely less impact on natural sounds due to the broader distribution throughout the day . . . but [that] human sounds could [also] potentially occur for longer duration during the day, possibly neutralizing beneficial impacts on the natural acoustic environment . . .” (EA, 3-60). We encourage the Park Service to consider adjusting the season and timing of timed-entry reservation requirements as studies, visitation patterns, and visitor coping strategies evolve.

  • Invest in transit as a necessary management tool.

    Most people arrive to ROMO in private vehicles. Investing in mass transit is a necessary tactic for mitigating the deleterious effects overcrowding has on the visitor experience and resource integrity. However, mass transit options should be considered as one tool in coordination with others for managing visitor use, and we applaud ROMO for adopting this approach. Removing private vehicles from park roadways alleviates vehicular traffic, but it does not necessarily account for human congestion. We are pleased the long-term plan (all proposed alternatives) would continue to maintain a shuttle system as a necessary investment to minimize crowding and congestion and reduce carbon output and that all visitors using the Hiker Shuttle are required to obtain a timed entry shuttle permit as a means of ensuring the park isn’t alleviating vehicle congestion at the expense of increasing human congestion. Shuttle services will continue to be a visitor need: in September 2023 shuttle ridership increased 33.90% over September 2022, and year-to-
    date totals for 2023 have increased 27.88% over 2022. We encourage ROMO to continue utilizing shuttle buses along two routes – the BLRC and the Moraine Park Route. We urge the park to consider a mandatory shuttle for BLRC reservations at peak hours when the parking lots still typically fill to capacity.

    The various socioeconomic studies conducted by the NPS demonstrate that travel, and associated cost, is one of the major barriers to equitable access (EA, 3-21). We encourage ROMO to continue its partnership with the Colorado Department of Transportation on ways to improve the Bustang regional bus service. Currently, visitors can access the park from Denver and other select locations in the Front Range for approximately $15 round trip, but this service is only offered on weekend days and holidays.

    As another transportation investment in addition to the shuttle system, we urge the park to include active management of e-bikes on existing park roads as part of the long-term plan, including consideration of creating certain opportunities where main areas of the park are only open to bikers and hikers. Currently, e-bikes are only allowed in areas where vehicles are allowed, a commendable measure to preserve wilderness characteristics and avoid detrimental impacts to the fragile alpine ecosystem. While e- bikes are an excellent way to experience national parks, reduce emissions and take vehicles off the road, absent management or adequate trail/road/charging/bike rack infrastructure, large numbers of e-bikes and scooters can cause pedestrian conflicts, clutter trailheads and conflict with shuttles/vehicles on narrow roads. We appreciate that the EA notes that bikes and e-bikes might be subject to the long-range day use visitor access strategy in the future should use levels increase.

  • Invest in targeted community engagement to reduce visitation barriers for underrepresented individuals.

    We applaud ROMO for its active local partnerships, including Visit Estes Park, NoCOPlaces2050, the Colorado Tourism Office (including its new Destination Stewardship program launched to promote balancing economic growth with environmental and cultural preservation), Estes Valley Library, and the gateway chambers of commerce in Estes and Grand Lake. Working with the local business community and the Colorado Department of Transportation to help educate visitors about the long-term planning process and provide information is mutually beneficial for the park and its neighbors. ROMO already has a transparent and strong relationship with its gateway communities, admirably ensuring their support prior to implementing each of its pilot TEPS. We are confident that the park will continue its process of transparency and innovative collaboration, a commitment reflected throughout the EA and critical toward navigating an interdependent dynamic between parks, communities, affiliated Tribes, and adjacent public lands.

    We encourage the park to continue these efforts while also expanding trip-planning public education into areas more consistently outside of the park, including intentional community engagement to make sure that individuals already underrepresented in park visitation aren’t further excluded. 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 ROMO could co-learn about this kind of intentional community outreach with staff at other parks working hard to effectively reach new user groups.

    As part of the community outreach process and beyond, we urge ROMO to examine factors affecting people’s ability to plan their visits and options for mitigating any barriers. More research is needed to understand specifically how perceptions of visitor use management systems influence a disproportionately underrepresented individual’s intention to visit, and to determine best practices and resources needed for making communication about visitor use management available in a multitude of languages and cultural communication contexts.

    While it is unclear as to whether the pilot TEPS or the long-term planning process directly impacts visitor demographics—and the EA notes that “[t]he park works with nonprofit youth groups, schools and affinity groups to bring underrepresented groups into the park . . .” (EA, 3-24)—consistent outreach is needed to determine how to improve these efforts and minimize barriers.

    We applaud ROMO for proactively working with Rocky Mountain Conservancy to reduce potential technological barriers by providing high-speed internet access at visitor centers located outside the park entrance stations and providing iPads at the visitor centers that allow visitors to spontaneously acquire a reservation permit when available. This is a model solution that should be replicated in other parks looking to implement reservation systems.

Consider climate change as a key factor in a future year-round reservation system.

Because of our climate change crisis, parks face more frequent and intense natural disasters and threats to infrastructure, cultural resources, and changes in wildlife patterns that will also hinder visitor experience. ROMO is still reeling from the impacts of the 2020 fire season and is estimated to have one of the most significant increases in wildfires of all U.S. parks. Though there is inherent uncertainty in predicting climate events, we urge the park to incorporate a response plan for the visitor use patterns anticipated to change in the coming years due to climate change, as noted by the EA: “Recent climate change research suggests that Rocky Mountain National Park may see up to a 34% increase in visitation during the peak season and up to a 72% increase in shoulder season visitation based on air temperature and potential visitation growth. . . “ (EA, 3-25, 3-36). Given these sobering estimates, we appreciate the adaptive nature of the long-term plan and urge ROMO to also consider planning for a possible shift toward a year-round reservation system.

III. Chronic underfunding of ROMO compounds the impacts of increased visitation, underscoring the crucial need to adopt a long-range day use access plan by 2024.

NPCA and the Coalition recognize that, even with an expert visitor management planning team, impressively dedicated volunteers, and several years of thoughtful pilot TEPS processes, increased visitation at ROMO still stresses an already underfunded budget. A long-range plan is an urgent investment needed as early as possible in 2024 to address, and, ideally, lessen, the future financial impacts of increased visitation. The EA highlighted a particularly heartbreaking cultural resources challenge: “ . . . approximately 14% of ROMO has been surveyed for archeological resources (37,025 out of 265, 795 acres) and most of this is over two decades old at this point and completed by para-archeologists . . . many trail corridors and wilderness campsites have never been inventoried . . . Tribal members also ask how the park will protect cultural sites from visitor impacts . . .” (EA, F-2).

Another impact that is too often overlooked is the toll that overcrowding takes on the morale of NPS staff. It is well documented that, due to under-investment by Congress, in recent years growth in visitation has occurred at a similar rate to declines in park staffing nationwide. This has left parks like ROMO with less personnel to oversee growing numbers of visitors. For instance, between 2011 and 2019 park visitation increased nationally by 17% while over the same time the Park Service lost 16% of its staff capacity, or approximately 3,500 positions.

As a result, NPS staff and other employees working in the park are forced to take on collateral duties outside of their job descriptions and expertise. This often results in high levels of staff burn out, turnover, and impact to park employee’s mental health. This situation is only worsened by the parallel crises facing ROMO and the surrounding community in regard to the high cost of living and the scarcity of affordable housing.

We will continue our longstanding commitment to advocate for enhanced federal funding, including but not limited to an emphasis on park staffing, housing, cultural resources, and the soon-to-expire Public Lands Legacy Restoration Fund, so that ROMO can do this critical work while implementing its long-range plan.


For more than a century, ROMO has remained a vital part of our natural and cultural heritage set aside for current and future generations to explore, honor, and enjoy. The future health of this remarkable landscape depends on today’s investment in a long-range day use visitor access plan through the NPS Preferred Alternative.
We urge you to move quickly to complete this planning process as soon as possible in 2024, both to protect park resources in the near term and to also provide additional certainty to future park visitors in the years to come.

We commend the park’s civic engagement process throughout the years as it studied and refined its pilot timed entry permit system process, including its ongoing collaboration with gateway communities and neighboring land managers at the county, state, and federal level, and we look forward to continuing our work as an engaged partner.

With gratitude,




Tracy Coppola
Colorado Senior Program Manager
National Parks Conservation Association
Denver, Colorado

Michael Murray signature



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