What does the Bill Say and Do?

After an amendment released on October 7, 2015, the Yellowstone and Grand Teton Paddling Act currently requires the National Park Service to use the full NPS suite of administrative tools to write regulations to manage paddling on a specific 429-mile set of rivers and streams in the Parks. The Parks have three years to write this management plan at which time the old regulations banning paddling in the Parks will be stricken from the public record. Rumors that the bill mandates paddling without a study are not true. The bill directs the Secretary to “promulgate regulations to allow the use of hand-propelled vessels on waters in YNP and GTNP…These regulations shall be promulgated in accordance with laws, regulations, and policies generally applicable to units of the NPS and sections 551 and 559 of Title 5, US Code (Administrative Procedure Act).” The bill and amendment are displayed at the bottom of this WyoFile article: http://www.wyofile.com/greens-bill-open-yellowstone-paddling-regardless-study/

What is APA’s goal with the bill?

To establish a framework that allows the NPS to manage paddling in such a fashion that people are able to enjoy the Parks using self-propelled boats on carefully selected reaches of moving water while leaving the natural resources of the Parks in an unimpaired condition.

Why is river paddling an appropriate activity for Yellowstone National Park?

Packrafting and other forms of river paddling are appropriate in the Parks because they satisfy half of the NPS mission to provide opportunities for primitive recreation. If managed sustainably, paddle sports are extremely low impact, thus by default allowing the Parks to satisfy the other half of the NPS mission, which is to leave the Parks unimpaired for future generations. Paddle sports are a perfect match for Yellowstone and Grand Teton! Misunderstandings about packrafting and other forms of river running are common, much in the same way that mountaineering is portrayed in social media with an emphasis on risk-taking, adrenaline, and physical challenge. Packrafting trips, like those that could be had in Yellowstone, combine wilderness backpacking with river travel where self-reliance and solitude are fundamental to the experience. The activity of packrafting is not an “end in and of itself”; it is a means to an end, requiring an intimate understanding of the landscape including both land and water. Wilderness packrafting in Yellowstone would foster an appreciation of Park values, resources, and history in a contemplative and self-determined manner. In Mountains Without Handrails, a superb resource about recreation in National Parks, Joseph Sax advocates for “contemplative and self-determined” recreation. This is packrafting at its core and exactly what’s at stake.

Why can’t we leave just one place alone and keep it untouched?

It is a noble and worthy endeavor to preserve areas from the impacts of mankind. However, Yellowstone missed that opportunity over 100 years ago. Backpackers, anglers, swimmers, photographers, and horse-packing groups already use the Yellowstone backcountry river corridors and have been using them for decades. Backpackers walk the trails, pull drinking water from the streams, and use campsites. Anglers tromp along banks, walk the river beds, use campsites, and pull fish from the rivers. Horses wade in the streams, defecate everywhere, and graze the grassy banks. We believe that restoring the traditional primitive activity of paddling to these corridors and balancing this use with other traditional uses will not increase the overall human impact.

With so many other rivers to paddle outside of Yellowstone and Grand Teton national parks why don’t packrafters just go there?

Of course paddlers can paddle somewhere else. In fact, we can paddle virtually everywhere else, and that is what makes the 65-year-old paddling bans in Yellowstone and Grand Teton so frustrating for Americans who prefer to experience our National Parks by floating quietly through them. Paddling rivers through Yellowstone would be an incredible and very low impact way to experience the Park, just as it is across our public lands. This is similar to asking why hikers need to be allowed in Yellowstone when there are literally thousands of miles of trails outside of Yellowstone.

For curiosity’s sake, we wanted to find out just how many miles of navigable rivers there really are in the Greater Yellowstone area. So we conducted an inventory and roughly traced the river courses. We excluded rivers that are currently closed to paddling so that we could get a feel for what other paddling options are available in the region. In total, we counted 3,175 miles of navigable rivers in the Greater Yellowstone region that are open to paddling.

At first glance, there appears to be an abundance of rivers. Why can’t paddlers be content with these 3,000+ miles of river? Well, a closer look reveals that only 12% of these rivers, or 394 miles, are suitable for the average paddler looking for the type of wilderness paddling experience that could be found in Yellowstone and Grand Teton if it was allowed there. Only the rivers in blue on the map match the caliber of the rivers in Yellowstone—free flowing, few or no roads or bridges, no diversion dams, and reasonable navigability (class IV or less with some portages).

The rivers in red run the gamut of issues, but not one of them is regularly navigable by an average paddler looking for a wilderness experience. These rivers either run along roads, through towns, cattle ranches, residential areas, under bridges, and over dams. Some of these rivers run only for a very brief period in the spring, and most of them have extreme whitewater available to only a few highly skilled and bold paddlers. Many of these streams are choked with wood, boulders, and even barbed wire, and thus are too dangerous for the appetite of most paddlers. These less desirable rivers make up the balance…2,781 miles or 88%. The argument that there are plenty of rivers to paddle outside the Parks is completely unfounded! Please see our rough inventory for more detail.

The high plateau terrain and ample summer flows in YNP create a unique geo-hydrology that is not present on surrounding waters that score the more rugged adjacent National Forest lands. Yellowstone and Grand Teton National Parks have an exceptionally high concentration of world-class rivers in a wilderness setting that are far from highways. This seclusion is what many paddlers seek. Also, please consider the following double-standard that GYC seems to endorse: There are countless opportunities outside these Parks for hiking, fishing, backpacking, mountaineering, and backcountry skiing, yet YNP and GTNP do not have regulations effectively banning these other traditional activities. Why then should a closure apply to paddling?

How does opening paddling benefit the Parks?

How does anything we do in the Parks benefit the Parks? How does allowing any backcountry activity “benefit” the Parks? Opening the Parks to regulated paddling would serve half of the Park Service mission by providing opportunities for primitive recreation. Also, the analysis required with the Yellowstone and Grand Teton Paddling Act, along with resultant regulated paddling opportunities, would allow the Park Service to be a better steward of its amazing river resources.

The Snake River Headwaters CRMP states that paddling access is allowed on 86% of the newly designated Wild and Scenic Rivers. Is that not enough?

With regard to newly designated Wild and Scenic Rivers in the Snake River headwaters, which often are cited out of context by paddling opponents, 351 miles of the total 410 Wild and Scenic miles (86%) are open to paddling, but relatively few of these river miles are within the national parks. Only 46 river miles (11%) of the new Wild and Scenic rivers fall within YNP, and of these, only 3.4 miles are open to paddling. GTNP contains 53 miles of designated rivers, of which 40.4 miles (10%) are navigable and open to paddling. Only between 3.8 and 10 miles of these GTNP rivers provide an opportunity for wilderness paddling. The rest of the designated Wild & Scenic River miles in GTNP fit into the “red” category in the previous FAQ item…they parallel roads and are accessed by boat ramps.

Are All Miles of Rivers Protected By the 2009 Act Navigable?

An estimated 67 miles of designated rivers (16% of the 410 total miles from the 2009 Act) are not navigable. An additional 121 miles (30% of the 2009 Act’s miles) either parallel a road or are accessible by road. An additional 45 miles (11% of the 2009 Act’s miles) are currently closed to paddling.  Therefore, 57% of the newly designated river miles are not available for wilderness packrafting trips. Of the remaining 176 miles of river (43%), only between 7.2 and 13.4 miles are available for remote wilderness packraft trips on NPS lands. All other protected river miles traverse lands managed by the US Forest Service.

Why aren’t packrafters content running the “red” rivers in the map above?

The wilderness paddling experience is a valid and valuable one. The geography and hydrology of YNP and GTNP are remarkably well-suited to this form of primitive travel. YNP and GTNP backcountry paddling probably won’t be an activity for everyone, but neither is backcountry fishing, hiking, photography, or geyser gazing. YNP and GTNP include many appropriate wilderness settings for different kinds of no- and low-impact recreation, including packrafting on some waters that are now off-limits. Furthermore, the fact that river paddling is allowed and even encouraged on many of the rivers and streams that flow into Yellowstone and Grand Teton is also why the current ban is illogical and problematic. Several important watercourses flow into the Parks from the Teton, North Absaroka, and Absaroka-Beartooth wildernesses. These rivers and streams provide natural “water trails” for wilderness travelers. Having to exit the waterways at arbitrary management boundaries between Wilderness and National Park makes as much sense to a paddler as it does to spawning cutthroat trout. Similar to thru-hikers navigating the Continental Divide Trail, these water trails that cross jurisdictional boundaries need to be managed in a consistent manner.

What Are Key Geohydrological Features of Some of The Moving Waters in YNP & GTNP?

Rivers and streams outside the Parks are dependent on snowmelt, and hence are runnable only for a couple months in the spring and early summer. Meanwhile, many of YNP’s rivers are runnable throughout the summer and into the fall because of the abundant groundwater resource. Most of the rivers and streams outside of YNP run fast, steep, and technical. They descend from high angular mountains and are beyond the skill level of most paddlers. In contrast, YNP’s rivers run off a broad plateau. YNP’s navigable waters have a much wider range of difficulty, with concentrated opportunities for beginner and intermediate paddlers, especially families, as well as some reaches of genuinely difficult and dangerous whitewater. Packrafters in particular are drawn to wilderness rivers with remote access. YNP’s rivers present packrafters with the beautiful challenge of having to hike overland to reach them. Only a handful of rivers in the adjacent National Forests have this degree of remoteness with consistently runnable volume. Most of the adjacent National Forest high wilderness streams are too technical for the average packrafter.

There are plenty of opportunities for wilderness paddling on Yellowstone’s backcountry lakes. Why not just paddle on the lakes?

Comparing lake and river paddling is like comparing hiking to mountaineering or snowshoeing to backcountry skiing; they are entirely two different experiences. As discussed previously, the activity of paddling wilderness rivers is not an end in and of itself; it is a means to an end. And that end is one of the most eloquent, least impactful, and contemplative means to experience a wild landscape. If paddling can occur on all but five of Yellowstone’s 168 lakes without degrading park resources, surely paddling can also occur on stretches of Park rivers without adverse effects.

What about Invasive Aquatic Invasive Species?

While the risk of introducing aquatic invasive species (AIS) by paddling is an important consideration that needs to be examined during the three-year study, it’s worth noting the current AIS epidemics have occurred during the 65-year period that river paddling has been is banned. Currently, there are no regulations governing paddling rivers or streams flowing from adjoining lands managed by the US Forest Service and into the parks. So if small paddle craft were a real threat of introducing aquatic invasives into the Parks, it should have already happened from paddlers using these streams outside the Parks. Better management and education about these “water trails” that cross management jurisdictions would significantly reduce the risk of the inadvertent introduction of aquatic invasive species and is exactly the outcome we seek from the three-year funded study and rule making required by the Yellowstone and Grand Teton Paddling Act.

A permitted river system could pay for itself and improve the AIS program for all users. The current AIS program puts too much emphasis on low-risk small boats that are easily cleaned, drained, and dried, and not enough real teeth to prevent the launch of potentially infected larger power boats. Look at the history of the spread of quaggas and zebras, the most noxious offenders, in the U.S. – Great Lakes – Lake Mead – Lake Powell and outward. These are not kayakers or rafters that are spreading these mussels. If Yellowstone and Grand Teton really want to get serious about the spread of AIS they would require a high-risk inspection on any boat with a bilge that has been in an infected state before they launch on Park waters – they are not currently doing this.

What will paddlers do if they encounter wildlife?

During wildlife encounters, paddlers would do the same thing that any other backcountry user would do…remain calm, keep moving without engaging, and give a wide berth. The beauty of paddling is that the human imprint is so ephemeral. It would be interesting to see during the analysis which forms of recreation in the river corridor have the greatest impact on wildlife. Much fear has been expressed about the effects of paddling on wildlife, but no conclusive studies have ever been made showing that paddling has a lasting impact on wildlife. Paddlers are asking that the Parks do this analysis, and create a management plan for the river corridors that balances the impacts between the traditional primitive uses, such as hiking, angling, camping, and horseback riding.

Does H.R.974 tie the hands of Park managers?

No. It enables Park officials to manage river resources by replacing two statutes within the Code of Federal Regulations (CFRs) instituted in 1950 and 1962 with new regulations to be developed by the Parks [see sections 7.13(d)(4)(ii) and 7.22(e)(3) of Title 36]. Unlike with CFRs, Park managers would be able to modify their Superintendent Compendium and River Management Plans as conditions warrant. This is the standard operating procedure in all other National Parks. Note, these YNP-and-GTNP-specific CFRs were enacted 65 years ago to mitigate overfishing, but could not foresee at that time that many visitors would seek to experience the Parks by paddling rivers without fishing.

Does H.R.974 legislate access onto public lands for a special interest?

Small interest groups should not be able to legislate their special uses onto public lands without exceptional grievance. However, paddling rivers in Yellowstone and Grand Teton National Parks is an extraordinary situation where a ban of a traditional primitive use was instituted 65 years ago and has been maintained with no scientific justification or precedent in the National Park system. Moreover, after the passage of the Craig Thomas Snake River Headwaters Legacy Act, the NPS unilaterally dismissed an obligation to evaluate additional river paddling opportunities on the newly designated Wild and Scenic rivers. Our nation’s democracy has a system of “checks and balances” which allows the various branches of government to watch over each other. H.R. 974 provides a Legislative Branch remedy to a continuing Executive Branch oversight.

Is H.R.974 “the Camel’s Nose Under the Tent?

We do not see this legislation as setting a dangerous precedent or opening the door to other recreational uses. Paddling rivers in small boats has history and tradition in YNP and GTNP with legal grounds for legitimacy and grievance. Other new uses such as ATVs, jetskis, paragliding, etc do not have a historic legal basis for access. Also, paddling rivers in small boats is a well-established and accepted recreational use in every National Park and Monument with river resources (as well as Wilderness Areas, National Forests, and BLM units). If other land management units can manage river paddling in a sustainable manner, so can Yellowstone and Grand Teton. These Parks are off-mission largely because of the two antiquated CFRs.

What will a NEPA process look like after the bill passes?

Some opponents of the bill have expressed a concern that the NEPA process will allow anyone with an idea about boating in the Parks to weigh-in. For example, rafters that want the Parks to build boat ramps, or inner tubers that want to float the Firehole River could send comments urging the Parks to cater to their interests. This is true. Anyone with an interest in paddling in Yellowstone and Grand Teton can weigh-in. However, this does not mean that the Parks have to grant their requests. The Parks’ analysis will weigh public input with Park values and resource protection.

From a River Adventurer’s Perspective, Is There Anything Notable About Paddling Resources in Yellowstone National Park?

Paddling is to Yellowstone as mountaineering is to Grand Teton. Yellowstone has world-class river resources with the gamut of flows, topography, and paddling grades. While the Grand and Black canyons of the Yellowstone would offer exceptional class IV and V paddling, the upper Yellowstone  is a meandering class I/II river through a broad valley full of wildlife, forests, and meadows. As for flow, Yellowstone’s rivers are unique along the continental divide. While the crests of Wyoming’s Wind Rivers, Colorado Rockies, and Montana’s Northern Rockies lose much of their snowpack in the summer and their streams wither to a trickle, Yellowstone’s rivers flow year-round, mingling rain and meltwater running off impervious volcanic beds with geothermal water from ducts deep within Earth’s crust. Not only do Yellowstone’s rivers have perpetual flow, they course through a vast subalpine wilderness of rocky canyons, thick forests, and stunning meadows unmatched anywhere in the Lower 48. GTNP has many small streams that cascade from the high peaks. Most of GTNP’s navigable streams course through the Park on their way from the Yellowstone plateau and surrounding mountain ranges into the Snake River.

What is the Geographic Scale of the Currently Banned Yellowstone-Teton Paddling Resource?

YNP’s broad uplift sheds water into seven major river systems: Snake, Falls/Henry’s Fork, Madison, Gallatin, Yellowstone, Clarks Fork, and Shoshone. GTNP features at least two additional major river systems that flow through that Park from the east: Buffalo Fork and Gros Ventre. Flowing into these nine rivers are hundreds of tributary streams.

How Many Miles of Moving Waters Flow in YNP & GTNP?

The NPS estimates that there are approximately 7,500 miles of rivers and streams in both Parks. The NPS estimates that there are about 2,373 miles of perennial streams in YNP. The NPS has not provided any estimates of total river mileage in GTNP.

Is There a More Refined Inventory of Moving Waters in YNP & GTNP?

To help the NPS establish a baseline for a paddling analysis, the American Packrafting Association has created an inventory of runnable rivers and streams in YNP and GTNP. Of those 2,373 miles of perennial streams in YNP, APA counted 62 navigable river stretches totaling 594 miles. The APA is asking the NPS to analyze paddling on 39 of these streams for a total of 403 miles. This is less than 6% of the mapped blue lines, and ~17% of the perennial streams. Nine of those 39 stretches run free at least 10 miles through the Park; six stretches run for over 20 miles.

In GTNP, APA counted 19 navigable river stretches totaling 135 miles. APA is asking the NPS to analyze paddling on 13 of these streams for a total of 77 miles.

What Moving Waters Are Now Open to Paddling in YNP?

The 3.4-mile stretch (0.5% of YNP navigable rivers) in YNP, between Shoshone & Lewis Lakes, is currently open to paddling. That’s it.

What Moving Waters Are Now Open to Paddling in GTNP and the JDR Jr. Parkway?

In Grand Teton and J.D. Rockefeller, Jr. Memorial Parkway, there are 27 runnable river stretches totaling 133 miles. Only 40.4 river miles (30% of GTNP navigable rivers) are currently open to paddling. While spectacular, these open stretches through GTNP have no challenging whitewater that many paddlers seek and they do not provide paddlers a secluded wilderness experience. They have developed boat launches, they run parallel to major highways, and they host unlimited private use and high levels of commercial use. None of the open rivers in GTNP are suitable for wilderness packraft trips.

Is Packrafting and Other Light Craft Paddling for Experts Only?

As with all outdoor pursuits, skill requirements for safe and low-impact packrafting vary. For packrafters and paddlers of other small watercrafts such as canoes, hard-shell kayaks, and inflatable kayaks, YNP and GTNP contain a vast resource of untapped river-running potential for beginners, intermediates, and experts. The rivers of YNP and GTNP offer everything from scenic family-friendly canoeing, to multi-day Class 2-4 packrafting trips, to world-class whitewater opportunities for all ability levels. The Yellowstone-Teton Paddling Act and the NPS’s sophisticated implementation of a paddling access program – drawing on NPS experience in every other national park with river resources, all of which have managed paddling programs – will help a new generation of Americans of broad ability levels and interests get out of their cars and connect with a very special landscape and suite of rivers.

Is It Possible to Float on Rivers and Concurrently Practice Leave No Trace Disciplines?

Yes. Excellent access to a concentrated array of magnificent rivers, paired with the existing interpretive and ranger capabilities of YNP, present a supreme opportunity for Americans to intimately and kinesthetically experience wild nature with no lasting impacts. River floating, backpacking, bank-fishing, wade-fishing, hiking, and backcountry photography all demand respectful discipline from practitioners.

Where Did the Current Bans Come From?

In 1950, the Yellowstone Annual Report noted under the title “Management and Protection of Fish Resources”:

  1. Heavy fishing pressure exerted on park waters during the post‐war period made it necessary to add two new provisions to the Park regulations. The first of these provides that fish may be taken from the Madison and Firehole Rivers only with artificial flies or single baited hooks and prohibits the use of other lures. The second prohibits the use of boats on Park streams. These new regulations, which became effective on the opening of the fishing season on May 30, 1950, and the limit of take of five fish per person per day, which became effective a year earlier, have met with general approval of anglers and others who are interested in the protection of sport fishing in park waters.

Where Are These Rules To Be Found?

The 1950 YNP ban was entered into the Code of Federal Regulations at (Section 7.13(d)(4)(ii) of title 36). Grand Teton Park followed suit in 1962, registering Section 7.22(e)(3) of title 36. Please take a look for yourself.

https://www.law.cornell.edu/cfr/text/36/7.13 (Scroll to (d)(4)(ii)). (Yellowstone)

https://www.law.cornell.edu/cfr/text/36/7.22 (Scroll down to (e)(3)). (Grand Teton)

Are The Underlying Reasons for The Bans Still Valid?

The fisheries-based reasoning behind the original 1950 paddling ban in YNP and 1962 ban in GTNP has been invalid for decades. River boating was banned in YNP to relieve fishing pressure and perceived conflicts with bank fishermen on popular angling rivers, such as the Madison, Firehole, and Yellowstone rivers. No empirical studies have verified that the paddling ban has reduced fishing pressure. Fisheries impacts from paddlers who paddle the area’s rivers without fishing have not been documented.

Are Anglers More Entitled to Enjoy National Parks Than Recreational Paddlers?

While conflicts between paddlers and anglers (many recreational users participate in both activities) have not been shown to exist, some might be perceived or anticipated. Integrating traditional, low- and no-impact recreational uses is part of the NPS’s duty of managing these parks. Getting along with fellow citizens, whose entitlements to enjoy different kinds of no- and low-impact forms of recreation are equal, is part of the citizens’ task of equitably sharing these national parks. Mitigation measures for actual or perceived conflicts may warrant development and implementation. Throughout YNP and GTNP, and across national parks throughout the United States, well-crafted fishing regulations adequately protect the fisheries by stating where, when, and what type of fishing is permitted.

Is Riparian Corridor Impact Mitigation Only A Paddler’s Burden?

A YNP report in 1986 entitled “Boating on Yellowstone’s Rivers; An Analysis and Assessment” provided an appraisal of paddling with regard to nine resource and management concerns on 18 river stretches in YNP. The report put the burden of the nine concerns squarely on the shoulders of paddlers, when the impacts cited could apply just as readily to other visitors to the river corridors, such as anglers, hikers, sight-seers, birders, and swimmers. Critical readers of the report have found it to be heavily subjective rather than scientific and afflicted by a flawed statistical analysis. Please read it for yourself and see if those criticisms seem valid to you.

What Sort of Paddling Impact Analysis Has GTNP Done?

GTNP crafted unsubstantiated rulings in 1962 and 1971. In 1997, GTNP did a comprehensive analysis and rule making for boating on the Snake River (see Snake River Management Plan), but GTNP never has studied the impacts paddling might have on streams within its boundaries other than the Snake River.

Are There Responsible River Paddling Stewardship and Service Organizations Involved in This Effort?

The American paddling community has proven itself as river stewards through countless individual efforts and with aid from local paddling clubs. National organizations such as American Whitewater, American Rivers, the American Canoe Association, and the American Packrafting Association continue to support service and stewardship programs. Through the Snake River Fund, anglers, commercial guides, whitewater adventure companies, scenic float tour operators, and paddlers of every stripe in the Jackson Hole area have organized themselves for the 17 years between 1998 and the present date to achieve river conservation, river cleanups, and responsible management.

Do the Local YNP and GTNP Paddling Proponents Have Any Record of High-Level Success?

In 2003, a consortium of paddlers and organizations convened with the common interest to protect the headwater streams of the Snake River as Wild and Scenic. The Campaign for the Snake River Headwaters (CFSH) kicked off in the spring of 2005 with broad-based support from community members, business owners and employees, landowners, outfitters, and other stakeholders. People agreed that Wild and Scenic designation would preserve the rivers’ “outstandingly remarkable values,” protect the local economic vitality, and secure opportunities for recreation. The late U.S. Senator Craig Thomas strongly supported the initiative. Senator Thomas passed away before gaining a foothold for the bill in Congress. Senator John Barrasso took office in his place and took up the cause. The Craig Thomas Snake Headwaters Legacy Act was signed into law in August 2009, designating 410 miles of river as Wild and Scenic.

Were Any of The 410 Miles of Waterways Protected by the 2009 Act Already Within YNP and GTNP?

Of the 410 miles of river protected by the 2008 Craig Thomas Snake River Headwaters Legacy Act (passed in 2009), 99 miles of river fall within YNP and GTNP. The Bridger-Teton National Forest, an agency of the U.S. Department of Agriculture, administers the other 311 miles of river.  Regardless of the identity of the host federal department or agency, all of the miles designated as Wild & Scenic must be managed in compliance with the Wild and Scenic Rivers Act of 1966.

What Specific Analysis and Management Duties Fell Upon the NPS Following Passage of the 2009 Act?

The basic follow-up burden for federal host agencies is called a Comprehensive River Management Plan and Environmental Assessment (CRMP/EA). With regard to assessing recreation opportunities on those 99 miles of river in the Parks, the Department of the Interior’s guidelines for Wild and Scenic rivers state:

  1. Studies will be made during preparation of the management plan and periodically thereafter to determine the quantity and mixture of recreation and other public use which can be permitted without adverse impact on the resource values of the river area. Management of the river area can then be planned accordingly.

More specifically, the 2009 Act states:

  1. The designation of the rivers and streams of the headwaters of the Snake River System under the Wild and Scenic Rivers Act will signify to the citizens of the United States the importance of maintaining the outstanding and remarkable qualities of the Snake River System while preserving public access to those rivers and streams and continuing to allow historic uses of the rivers and streams. The purposes of this section are to protect for current and future generations of citizens of the United States the outstandingly remarkable scenic, natural, wildlife, fishery, recreational, scientific, historic, and ecological values of the rivers and streams of the headwaters of the Snake River System.

What Implementation Work Was Done Pursuant to the 2009 Act and the 1966 Wild & Scenic Rivers Act?

When the Comprehensive River Management Plan and Environmental Assessment (CRMP/EA) was released in spring of 2013, the NPS dismissed the requirement of a detailed analysis of paddling. In a sub-section entitled “Conflicts with Existing Regulations” (page 58), the NPS contended that existing CFRs banning paddling outweigh provisions of the Wild and Scenic Act. However, U.S. Code for the administration of Wild and Scenic Rivers {Chapter 28, 16 U.S.C. 1281(c)} gives precedence to “the more restrictive provisions” when there is a conflict between other “Acts” and the Wild and Scenic Rivers Act. Existing paddling bans are the result of previous administrative rule making, and are not cited in any “Act.” No “Act of Congress” supports a blanket ban on boating. Therefore, the Wild and Scenic Rivers Act, which requires a full analysis of recreational uses, probably has precedence in this case. If there are reasons for banning paddling in the Snake Headwaters in the Parks, then those reasons should have flowed from an analysis of recreational user capacity in the CRMP/EA. The NPS has done no such analysis.

Might Any Provision of the 1966 Wild & Scenic Rivers Act Preclude River Paddling?

Packrafting and other forms of paddling have been found to be consistent with Wild and Scenic values on nearly all other designated rivers across the country. With proper analysis and management, packrafting would likely be determined to be consistent with the outstandingly remarkable values of these Wild and Scenic Rivers in YNP and GTNP. In a subsection entitled “Existing Restrictions Contribute To The Protection Of Values For Which Rivers Were Designated” (page 59), the NPS cited Section 10(a) of the Wild and Scenic law, which states:

  1. Each component will be managed to protect and enhance the values for which the river was designated, while providing for public recreation and resource uses which do not adversely impact or degrade those values.

The NPS did not engage this analytic frame. Had the agency done so, it would have needed to show that the paddling bans were directly responsible for preserving the outstandingly remarkable values present in the Snake River headwaters. By dismissing a thorough evaluation of packrafting, the NPS may be in violation of this provision of the statute because the law requires the study of recreational uses.

Why Not Sue The NPS Over The Flawed Implementation of the CRMP/EA As Required by the Passage of the Craig Thomas Legacy Act in 2009?

Paddling advocates continue to have recourse in the federal courts to compel agency compliance with these provisions of the canon of Wild & Scenic Rivers law. Making a federal case out of something is slow, expensive, grinding work. With regard to clearing the regulatory hurdles that ban paddling, only a new rule making by the NPS, or an act of Congress can do it. A legislative solution that compels compliance with existing federal statutes is a better, faster, less laborious avenue of redress, though it is not without its own costs and perils.

What Is The Paddlers’ Vision for Recreational Use of Moving Waters in YNP and GTNP?

Packrafters and other paddlers are conservationists and hold the river environments of these Parks with the highest esteem and stewardship. By the very nature of our craft, we travel light, fast, and with little or no impact.

Firstly, we are not advocating for unlimited use of the “water trails” by packrafters. APA will advocate for balanced managed use of the river corridors by traditional uses. The analysis would take all traditional uses of the river corridors into account and re-allot numbers of each activity to create a sustainable low-impact setting. This is the analysis and rulemaking that should have occurred with the Snake River Headwaters CRMP in 2013 to be in compliance with Wild and Scenic law, which does not discriminate among traditional uses as these Parks have done. We envision that packrafters would be allotted one or two launches per day or less on each stretch, while the numbers of horse packers, anglers, and/or backpackers would be reduced to accommodate paddling. The Parks would determine the ratio of uses in each corridor depending on a variety of factors. We don’t believe that packrafters have anymore impact on wildlife and aesthetics than backpackers, anglers, horsepackers, birders, swimmers, photographers, etc…all of which are currently allowed. This is especially true if you consider the relative duration of impact of each of these uses on any given scene along a river corridor. With only one or two paddling parties or less per day going by, the impact-moments are virtually negligible. That is the beauty of packrafting…it is silent and ephemeral.

Secondly, we are not advocating for paddling access to all Park streams at all times. We have heard the opposing views about keeping some Park streams free from watercraft, particularly those rivers with iconic landscape viewsheds. We have always appreciated the need to limit the impacts of recreation during periods that are critical for wildlife. Hence, either during bill markup (while it is being considered in House subcommittee) or during the upcoming scoping process (after the bill passes), we intend to ask the Parks to consider paddling on only 480 miles of rivers in both Parks, and trust the Parks to determine when paddling is appropriate on those stretches. Please note that, according to the Parks, there are 7,500 miles of blue lines in both Parks, and 2,373 miles of perennial streams in Yellowstone. If paddling is allowed, it will only be allowed on a small percentage of Park streams.

Thirdly, we envision river running limited to small paddle craft and small non-commercial parties. We envision rivers as “water trails” that easily conform to existing backcountry regulations, including camping in designated sites. No new facilities, parking lots, boat ramps, or bathrooms will be required. Through an open public study and rule-making process, we intend to help the NPS craft responsible and functional access rules and regulations. On our own initiative, and with our own friends and members, we will educate the public about the unique safety and ecological considerations of paddling in YNP and GTNP.

What About Inner Tubes?

Although many find this activity distasteful and dangerous, it is not for any of us to pass judgement on how others enjoy the outdoors, as long as their actions do not negatively impact the environment or others’ peaceful enjoyment of nature (inner tubers are notorious for leaving litter, drunken behavior, and unsafe practices). After the bill passes, it will be up to the Parks to determine what types of crafts are permissible and to set regulations about minimum required equipment. In banning paddling, the NPS left a void in the very fabric of Yellowstone and Grand Teton national parks. Imagine if Grand Teton or Yosemite banned mountaineering and rock climbing. Visitors would be flummoxed by the stultification of the very urge that draws them there. Indeed, Yellowstone managers are partially responsible for creating a dangerous situation where the absence of stewardship for the river resource leads young ignorant adventurers down rapids without appropriate equipment. Every year hapless youngsters launch inner tubes into the great rivers with no protective clothing or means of control. Being a true steward of Yellowstone’s great river resources means regulating paddling, providing interpretation, and allowing natural social forces such as mentorship, scholarship, and journalism govern outcomes on personal safety and judgement.

UPDATE: The October 7, 2015 amendment to the bill now eliminates the possibility that inner tubes could be used in the Parks by specifying “hand-propelled vessels designed for river travel.”

What Are the Purposes of National Parks in America and What is the Mission of the NPS?

The NPS exists “to provide for the enjoyment of” these parks “by such means as will leave them unimpaired…” The non-impairment standard is essential to the well-being of national parks; backcountry paddling, like backcountry fishing, hiking, backing, and horse-packing, must meet this standard. Meeting that standard will require paddlers’ diligence and care; it requires diligence and care from every person who ventures into the wild places in these national parks.

  1. The fundamental purpose of national parks, monuments, and reservations…is to conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.

  2. The National Park Service preserves unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations. The Park Service cooperates with partners to extend the benefits of natural and cultural resource conservation and outdoor recreation throughout this country and the world.

Are Park-wide Paddling Bans the Norm or an Anomaly Across National Parks in the United States?

Strategies for managing recreation on water trails work well throughout the National Park system. Of all the 401 national parks and monuments, only YNP and GTNP have blanket paddling bans in the CFR. 94% of runnable streams in these two Parks are closed to paddling. All other parks and monuments with significant navigable rivers and streams allow paddling with a permit (Grand Canyon, Canyonlands, Dinosaur, Denali, Glacier, Glacier Bay, Zion, Grand Staircase-Escalante, Black Canyon of the Gunnison, Wrangell-St. Elias, Rainier, North Cascades, Olympic, etc). In the last few years Yosemite National Park, which has had very restrictive paddling policies, selected an alternative that allows paddling in its plan for the Tuolumne and Merced rivers. Paddling is allowed in designated Wilderness Areas, one of the strictest land use designations on public lands. Likewise, National Forests, National Seashores, and Wild and Scenic Rivers welcome paddling as a traditional use and manage it, when necessary, with permits. In some parks, river rangers and backcountry rangers have adopted packrafts as useful management tools.

Who Are Some of the Yellowstone-Grand Teton Paddling Advocates?

Packrafters seek low-impact wilderness experiences. A group of avid packrafters from across America founded the American Packrafting Association (APA) in the fall of 2012 to educate the growing number of enthusiasts about safe packrafting practices and minimizing our impacts on other users and river ecosystems. Our hope is that through increased education, we can create partnerships with public land managers to increase opportunities for packrafters on public lands where appropriate. Our top priorities are human safety and protection of the river environment, most relevantly: wildlife, geothermal features, cultural sites, and riparian ecosystems. Access to wild rivers is a privilege that our members trust will follow. With this respectful approach, we are productively working with Grand Canyon, Canyonlands, Dinosaur, and Yosemite national parks to broker sustainable access for packrafters. With your help, we hope to begin a similar partnership with Yellowstone (YNP) and Grand Teton (GTNP) national parks.

APA is partnering with a Congresswoman with a lifetime score LCV environmental score of only 6%. Not exactly a conservationist’s ally.

While not everyone agrees with all of Representative Lummis’s views on the environment, she has been quite responsive and helpful to us on this issue. She and her staff have been very reasonable and professional throughout the process. She has no other motive in this other than to assist a low-impact traditional user group to regain access to their national parks. Ideas that this legislation represents a “slippery slope” or “the camel’s nose under tent” are baseless and irrational.

Although APA has members in over 30 countries, we are registered as an unincorporated non-profit organization in Wilson, Wyoming. Our Congressional representative is Cynthia Lummis. When Rep. Lummis heard about the NPS dismissing an analysis of paddling in the 2013 Snake River CRMP, she took it upon herself to introduce the legislation. We decided to support it. The paddling bill has been a great place to find common ground with many different people and organizations.

What Are Packrafts?

Packrafts are small inflatable rafts that usually weigh less than 10 pounds with paddle and the whole kit. Some packrafts weigh as little as 1.5 pounds! Deflated, they roll up to the size of a sleeping bag for easy carriage in a backpack or travel bag. Inflated, packrafts are suitable for both the mellowest family trips and the most technical whitewater. Packrafts may be used on road-accessed river runs just like any other non-motorized river craft, but what makes them unique is their portability. An individual paddler can easily carry his or her packraft over mountains to reach remote rivers, allowing rewarding itineraries that combine paddling with backpacking, backcountry skiing, canyoneering, or mountaineering. Much like backcountry skis allow remarkable low-impact winter adventures, no other tool allows such creative and intimate travels through landscapes as the packraft, with resource impacts that are no greater than backpacking or angling. Packrafters require no boat launches, access roads, parking areas, or developed facilities of any kind; just a good pair of hiking shoes and the will to reach remote rivers. With their large tracts of roadless backcountry, YNP and GTNP hold some of the finest packrafting venues in the contiguous United States.

When Did Packrafting Begin?

While packrafting has been a mainstream activity only since 2000, the sport’s modern pioneers have been at it since the 1950s. The concept of packrafting is as old as primitive man’s urge to utilize waterways for transport. Some have recently referred to paddling as a “new use” with regard to the waters of YNP and GTNP, but this is not the case at all. Native Americans and Euro-American trappers used small portable paddle craft for utility on these streams long before these areas became Parks. Recreational packrafting began in 1876 when Lieutenant Gustavus Doane, on unapproved military leave, dragged and paddled a log raft from Yellowstone Lake over the divide and down the Heart and Snake rivers. Other adventurers, such as Olaus and Mardy Murie, paddled canoes on Yellowstone’s rivers throughout the early 1900s.

Who Makes Packrafts and Who Can Use Them?

Although a number of American manufacturers had been producing packrafts since the early 1980s, the packrafting revolution began in 2000 when Alpacka Raft LLC began manufacturing lightweight durable boats and successfully marketing them in Alaska, Europe, and the Rockies. Development of high-tech lightweight packrafts comes at a time when Americans are actively seeking opportunities for deeper kinesthetic connections with wild rivers and landscapes. Today, at least nine different companies in the U.S. manufacture and market packrafts. Materials, design, and construction have proven durable and functional in the biggest and most technical whitewater, as well as in arctic waters and rocky/woody creeks. Great for beginner paddlers, most agree that packrafts are far more stable, maneuverable, and protective in whitewater than inflatable kayaks; and more stable, comfortable, and spacious for cargo than hard-shell kayaks. Modern packrafts are available with spray skirts, self-bailing floors, thigh straps, cargo bays, and high-tech hull shapes for navigating technical whitewater.

What Does Packrafting Look Like?

This is the “pack” half of packrafting.

This is the “raft” half of packrafting.

What Do National Park Paddling Proponents Hope You Will Do?

Please take an objective look at the facts, make an informed decision about whether to support this legislation. Please develop and share your perspective with your family and friends. We hope you will see that carefully managed river paddling access to select rivers and streams in YNP and GTNP could be really good for Americans, paddlers, and the Parks, while protecting the resources we all treasure in an unimpaired condition. At a time when many Americans are starved for time  in  nature,  packrafting  is  an  activity  that  would  allow  Park  visitors  a respectful, sustainable,  intimate  and  active wilderness experience.

Contact Us

American Packrafting Association

PO Box 13
Wilson, WY 83014