November 23, 2024
Delivered via the Planning, Environment & Public Comment Portal
Lena Pace, Superintendent
2282 SW Resource Blvd.
Moab, UT 84532
RE: Visitor Access and Experience Plan and Environmental Assessment
Dear Superintendent Pace,
On behalf of the National Parks Conservation Association (NPCA) and the Coalition to Protect America’s National Parks (Coalition), we write to express our gratitude to the team at the Southeast Utah Group and the National Park Service Regional Office for your commitment to understanding and addressing visitor use challenges. We appreciate the research, public engagement and analysis Arches National Park (the park) has conducted over decades to inform the Visitor Access and Experience Plan.
Since 1919, the National Parks Conservation Association has been the leading voice of the American people in protecting and enhancing our National Park System for present and future generations, with more than 1.6 million members and supporters nationwide. 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 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 are committed to working with the Park Service and other stakeholders to protect meaningful, 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 preserving all that is at stake at Arches National Park, 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 and San Juan Counties and Moab City.
We appreciate the opportunity to share our thoughts during this environmental assessment of the Arches National Park Draft Visitor Access and Experience Plan. We will offer feedback on 1) background and need for a plan, 2) alternatives, 3) alternatives considered but dismissed, and 4) affected environment and environmental issues. Within the Preferred Alternative, we urge the park to consider the following:
- Revisiting the vehicle use levels at indicator lots for days during the reservation system to ensure exceeding the design capacity 20% of the time meets desired conditions and for days outside the reservation system to ensure monitoring feasibility
- Clarifying whether the Salt Valley Road and Willow Springs Road visitor capacities include full concessioner and commercial use authorization permit holder use and account for bicycles, and ensuring traffic counters can be calibrated for bicycles.
Background and Need for a Plan
We humbly acknowledge Arches National Park is the ancestral and current homelands of the Hopi Tribe, Las Vegas Tribe of Paiute Indians of the Las Vegas Indian Colony, Moapa Band of Paiute Indians of the Moapa River Reservation, Navajo Nation, Rosebud Sioux Tribe of the Rosebud Indian Reservation, Southern Ute Indian Tribe of the Southern Ute Reservation, Ute Indian Tribe of Uintah and Ouray Reservation, Ute Mountain Tribe, White Mesa Ute, and Zuni Tribe of the Zuni Reservation. We value their knowledge of and connection to this place in the present day and since time immemorial. We believe and advocate for their ongoing access to the park and the important role they play in guiding management of the park.
Arches National Park is a wondrous place that inspires awe and interest in many — so many, in fact, that annual visitation has increased at a staggering rate in the past 15 years (74% annual visitation increase from 2011 to 2021). Outpacing infrastructure and staff capacity, this rapid growth in visitors — the majority of whom arrive in private vehicles — has resulted in many challenges: hours-long traffic queues, traffic backups onto the state highway, lack of available parking, congested roadways and trails, crowded viewpoints, etc. Despite many strategies employed to address crowding and congestion, the effects persisted and ballooned, the visitor experience was rapidly diminishing and Park Service staff were overburdened. A plan was needed to provide predictable, safe and efficient access to the park.
From 2012 to 2021, the Park Service conducted a number of studies, projects and planning processes to address these challenges, including: alternative transportation planning, parkwide road maintenance and modification, traffic congestion management and pilot timed entry. The learnings from these efforts, along with the guidance of the 1995 Visitor Experience and Resource Protection Plan, inform the Visitor Access and Experience Plan. The plan incorporates feedback from Tribal Nations, commercial use authorization permit holders (CUAs), local, state and federal officials and the public. It is crucial the Park Service now take action to solidify a long-term plan to manage visitor use in a way that protects high- quality visitor experiences, resource integrity and operational sustainability.
Alternatives
a. Actions Common to All Alternatives
Our organizations appreciate the park’s intention to continue to monitor conditions and implement data- driven management actions to protect visitor experience and access as well as natural and cultural resources.
The park has made exemplary strides in visitor information and orientation; the materials produced and outreach conducted in recent years has been exemplary for the agency. Even still, we encourage the park to continue improving and innovating to reach audiences who are likely to be missed by park communications and less likely to navigate technology successfully, such as older people and non-English speakers. Additionally, intentional engagement of communities historically marginalized in park access (e.g., people of color, young people, people earning low incomes) is an essential and ongoing effort to provide truly equitable access to parks. The park can explore partnerships with institutions that serve specific communities underrepresented in parks to provide relevant and meaningful programming and communicate information in ways tailored to the audience. Such efforts to be proactively welcoming to new communities are also important aspects of visitor information and orientation.
Among additional management actions to take regardless of the chosen alternative, minor facility upgrades are reasonable and responsible. Given both the budgetary climate at the Park Service and the possibility that facility changes can improve visitor access (especially for CUAs, an important stakeholder group) we view upgrades, such as a partial third entrance lane/booth as a prudent future development.
We also strongly support the park’s commitment to maintaining Tribal Nation access. We encourage the park to continue to improve and innovate ways to be welcoming to and inclusive of Indigenous persons coming to the park for a variety of purposes, ceremony and enjoyment included.
b. Alternative A: No Action, Return to Pre-Pilot Management
The no action alternative returning the park to year-round visitor access on a first-come, first-served basis is unacceptable and unequivocally harmful to visitor use, access and experience at the park. The likely return of temporary entrance and area-specific closures as a tactic for managing anticipated traffic congestion would result in unpredictability for visitors and other area institutions, such as local businesses. Assigning staff to step away from their primary, mission-critical duties to manage traffic and parking would be demoralizing for staff and wasteful of the park’s resources.
c. Actions Common to Alternatives B & C
Eliminating all foreseeable future use of entrance and area-specific closures is a positive outcome for visitor access, use and experience at the park. Maintaining predictable visitor access through seasonal reservations is imperative for protecting high-quality visitor experiences and efficient visitor use. Additionally, the reliable access that reservations afford visitors has positive effects on the nearby community and businesses.
We generally believe the implementation of a nominal reservation fee as part of a seasonal reservation system is acceptable and not burdensome for visitors — with the exception of system-wide fee-free days. We urge the park to redouble efforts to clearly communicate the fee requirement and purpose on these days.
Combining Backcountry and Primitive Zones into one zone and creating new Sensitive Resource Protection Zones are sensible actions. Maintaining current visitor uses in the new Sensitive Resource Protection Zones, while situating the park to monitor and take management action as needed to protect park values, is prudent. Identifying cultural sites and ethnographic resources in these new zones to be monitored for impacts of visitation is crucial as recreation within and proximate to the park grows and changes with emerging technologies, such as e-bikes. We appreciate and support the ability of the park to place use restrictions in Sensitive Resource Zones in the future.
Overall, the park’s proposal to adopt monitoring indicators, thresholds and related triggers represents good science and will guide sound data-driven management. However, we have three concerns:
- We recommend and advocate for adequate staffing dedicated to the monitoring plan on a consistent basis as required by the monitoring schedule.
- The threshold for the indicator ‘Vehicle use at indicator lots for days during the reservation season’ seems rather lenient and may not maintain desirable conditions consistently. We request clarification for arriving at the following threshold: ‘Days during the reservation season: vehicles per day do not exceed the design capacity of the lot more than 20% of the time’.
- The threshold for the indicator ‘Vehicle use at indicator lots for days outside the reservation season’ seems difficult to monitor and track. We request clarification for the following threshold and explanation of a reasonable monitoring strategy: ‘Days outside the reservation season: Vehicles per day do not exceed the design capacity of the lot more than three days per week for three consecutive years’.
Identification of visitor capacities is both critical and required by law to protect resources and provide high-quality visitor experiences. We value the park’s consistent consideration of desired conditions (most effectively achieved when visitation is dispersed over time) to determine the capacities in Table 2-3 (pg. 2-8) and agree with the proposed visitor capacities in general, especially at the key sites. We support the inclusion of the two roads as analysis areas for visitor capacity, but we have a few concerns about them.
Given the spectrum and amount of recreational use and planned development in the area (within and proximate to the park), we anticipate change in the use of Salt Valley and Willow Springs Roads. Identifying capacities for these roads is a good first step, and we encourage the park to ensure it can monitor and maintain these capacities to uphold desired conditions throughout the park. To support this, we ask for the following clarifications:
- Do the carrying capacities for Salt Valley Road (12 vehicles per hour) and Willow Springs Road (8 vehicles per hour) include all vehicles traveling as part of a concessioner or CUA party?
- Can traffic counters on the Salt Valley Road and Willow Springs Road detect bicycles? If not, can they be calibrated to do so to enable the park to monitor and account for the number of visitors entering by bicycle (especially at Willow Springs Road)?
We believe the use of a seasonal reservation system to maintain the flow of visitors consistent with identified desired conditions and visitor capacities is an efficient and effective way to manage visitor access, use and experience in the park. The ability to adapt the system for changes in visitation patterns along the lines of seasonality, time of day and duration/distribution are important for continued system success in meeting desired conditions. Additionally, we appreciate the park’s commitment to maintaining Tribal access to the park without reservations, even while it reserves the ability to adjust the reservation requirement for currently excepted groups — such as CUA, special use, campground, or backcountry permit holders — in the future. We believe the park must preserve the future option to include bicycles in the reservation requirement to maintain roadway safety and avoid trailhead/trail congestion.
Availability and timing of reservations at the park during the timed entry pilots has been appropriate for meeting management objectives for visitor access, use and experience. To ensure that continues to be true into the future, we have one recommendation:
- The park must consistently analyze reservations and make adaptive adjustments in order for any reservation system to achieve long-term effectiveness. We recommend and advocate for adequate staffing dedicated to managing the reservation system.
We commend the park for being open to new technology to enhance visitor access and the functionality of related infrastructure and systems. We advocate for online reservation platforms to be improved for accessibility, clarity, transparency, fairness and user performance.
CUAs are an important part of the park and play an integral role in the success of the Visitor Access and Experience Plan. We agree with the park’s perspective on the role of CUAs and possible future inclusion in the reservation requirement.
d. Alternative B: Timed Entry Reservations
We support Alternative B: Timed Entry Reservations as the approach with a proven record of success and broad support over three years of piloting and believe it best meets the purpose and need for this plan. By distributing use over time, peak periods of crowding and congestion are reduced and largely eliminated, improving access at the park entrance, visitor use of key sites and the overall visitor experience of being in the park. Additionally, timed entry allows for a greater number of daily vehicle entries than the other alternatives while maintaining desired conditions. The combined effect of maximizing visitor access, maintaining high-quality visitor experiences, and managing visitor use to protect resources is a trifecta of positive outcomes.
We appreciate the park’s preparedness to adjust timed entry reservations into different times of year and times of day as visitation patterns change and believe this adaptability will set the park up for success implementing this plan over time. We are confident the park staff are equipped with the knowledge and experience to adjust reservations according to skillful monitoring of capacities, desired conditions and data from the reservation system. The park staff have displayed their ability to do this adroitly over the past three years of pilot timed entry. That established, continued staff capacity is critical for timed entry reservations to succeed. We recommend and strongly advocate for appropriate dedicated staffing to execute Alternative B.
e. Alternative C: Daily Reservations
Similar to Alternative B, Alternative C: Daily Reservations revolves around robust management guidelines and objectives, including desired conditions and visitor capacities. Though maximizing visitor flexibility, as daily reservations would do, is appealing for some types of park visitors, daily reservations would allow fewer daily vehicle entries than other alternatives. We believe the upshot of increased visitor flexibility is outweighed by the increased overall access allowed by timed entry reservations.
Moreover, a daily reservation system is unlikely to meet the purpose and need for this plan. Peak arrival will continue to be a visitation pattern the park cannot influence with daily reservations. Even if the park reduces reservations to attempt to preserve desired conditions at peak times, we anticipate a return to entrance station queues and lack of parking at key sites for a number of hours each morning for many months of the year. Daily reservations are not as operationally efficient as timed entry reservations for engineering visitation patterns at the park.
Alternatives Considered but Dismissed
The park spent more than a decade researching, implementing and piloting abundant strategies to alleviate crowding and congestion. We are confident the list of alternatives considered but dismissed has been properly assessed and determined. As a management strategy, the timed entry reservation system has proven to work best — it is fiscally feasible and promptly addresses crowding and congestion.
Affected Environment and Environmental Issues
a. Visitor Access, Use and Experience
We agree that Alternative B addresses all of the identified issues (long wait times and queues, full parking lots, crowding at key sites, overburdened facilities and staff) most effectively while allowing maximum visitor use within the identified capacities. By implementing this action, the park would also adopt management direction to preserve high-quality experiences, resource integrity and operational sustainability.
b. Socioeconomics
The timed entry pilots and analyses conducted in Grand and San Juan Counties and Moab City comparing socioeconomic factors before and during pilot years show timed entry is not economically detrimental and improves quality of life for residents. Additionally, improvements to overall economic health are possible due to potential growth in visitation outside the reservation system requirements (i.e., seasonality). We find these analyses to be accurate and reflective of what we have heard from the communities.
Equitable access is a persistent concern for parks across the nation. The park’s assessment of the literature about barriers to national park visitation illustrates a great many factors affecting a person’s likelihood to visit a park. The assessment also argues timed entry reservation requirements and the associated nominal fees are a minor barrier in a sea of more substantial ones. We appreciate this analysis and also acknowledge the park (and other entities, such as organizations like ours) can and should continue to work to reduce barriers to park visitation. The park is already innovating reservation system design features and other practices to enhance equity (e.g., making 40% of reservations available the day before, experimenting with not requiring reservations during a summer stretch of time when tickets have not sold out in the past, partnering with the community on messaging and outreach), which we commend and encourage the park to continue and expand.
Thank you for your ongoing commitment to exemplary resource protection, visitor experience and staff well-being at Arches National Park and for the opportunity to comment. We very much look forward to continued engagement and partnership on the successful implementation of the Visitor Access and Experience Plan.
Respectfully,
|
Cassidy Jones |
Erika Pollard |
| Susan L. Fritzke Executive Council Member Coalition to Protect America’s National Parks |