Open Letter to Sequoia and Kings Canyon National Park Administration

TSX was recently invited to provide input on proposed changes to management of the area around Mt. Whitney in Sequoia and Kings Canyon National Park. As part of the Park’s recently completed Wilderness Stewardship Plan, commercial activity within the newly defined Mount Whitney Management Area is likely to become severely restricted beginning in 2018. Below is an informative letter we sent after attending a workshop on the topic that was hosted by the Park Service. For background, the slide deck from the workshop can be downloaded here (SEKI Alternative Presentation 5-12-16).

I’m writing to share additional background and thoughts as we discussed. I appreciate your willingness to take these into account when planning the phase-in of new backpacking commercial use restrictions in 2018.

I started TSX in late 2010. Unlike other backpacking outfitters that do multiple routes, and types of trips, TSX provides only one experience, and we do it extremely well. Each summer we take motivated individuals from age 11 to 70 years plus, band them together as a team, and trek over 75 miles across the Sierra to the summit of Mt. Whitney. We call this the Trans-Sierra Xtreme Challenge.

The route we take is a “non-traditional” route. We start out of Sugarloaf, hike through Big Wet Meadow, over Colby Pass, and into the Kern-Kaweah River drainage, before climbing again towards the Whitney group, It’s a route I first discovered when I was 14. I was introduced to this trail through a 5th grade teacher, Mike Murphy of Clovis, CA, who has been leading kids and community members across this exact same route to Mt. Whitney every year since 1983 – that’s 33 years and counting. The experience has been a source of inspiration for me and many others in my family and community over the last 30 plus years. Mike and I started TSX to open this unique experience up to touch more people. While physically, mentally, and emotionally challenging, the trail experience positively impacts just about everyone it touches. It changes lives.

Our program is unique based on how we operate, how we’ve grown, and who we serve. We are a local, independent organization, not affiliated with national brands, national clubs, or outfitting organizations. Since our modest inaugural treks with the public in 2011, we’ve grown organically, leading five transSierra treks in 2015. Our tight, singular focus, and passion for this route, enables us to offer experiences at a price points that are significantly lower than comparable backpacking treks.

List prices of comparable outings as of 6/21/16

REI Adventures – $2,599 (7 day Cottonwood/Whitney/Cottonwood)
https://www.rei.com/adventures/trips/namer/mount-whitney-hike.html

SYMG – $2,550 (9 day Trans-Sierra route)
http://www.symg.com/trips/backpacking/trans_sierra.php

TSX – $1,399 (8 day Trans-Sierra route)
https://tsxchallenge.com/trans-sierra-xtreme-challenge/

Our singular focus and compelling price point means that we help people of all ages, shapes, backgrounds and sizes, reach goals they might never have dreamed possible, like trekking across the Sierra to the highest point in the contiguous U.S., Mt. Whitney. In 2015 more than 25% of participants were ages 12-33, and 50% of participants were under 45 years of age. For roughly half of our 2015 participants, this was their first-ever overnight backpacking experience.

When I first hiked this route with Mike in 1994, it too, was my first ever overnight backpacking experience. We slept on Mt. Whitney’s summit, and exited Whitney Portal.

As a Commercial Use Authorization (CUA) permit holder, we’ve modified the experience to minimize impact around Mt. Whitney. First, all of our commercial groups exit via trail to Rock Creek / Horseshoe Meadows (this adds almost 20 miles and 2 days to the original experience). Second, our teams basecamp at Crabtree the day that we summit Mt. Whitney, making full use of the pit-toilet located on site, concentrating use at Crabtree’s facilities while minimizing impact to other areas of wilderness. Third, we pack-out all human waste generated between Crabtree and Mt. Whitney’s summit using WAG bags, and dispose of it after exiting the trail via Cottonwood pass. We do this as a best practice, with no formal requirement to do so. Last, we are 100% backpacking oriented, and never use stock support for gear or re-supply, resulting in minimal trail impact compared to stock supported groups.

The planned changes to commercial use under the Wilderness Stewardship Plan (WSP), and the pending quota restrictions for the Mount Whitney Management Area (MWMA) in particular, could have a significant impact on our ability to operate. Based on your presentation from May 12, 2016, it’s noted that Commercial Service Day (CSD) allocations for Non-Stock travel in the MWMA will be capped at 930 days under the WSP. In 2015, we had 44 clients enter the MWMA, for the CSD equivalent of 4 days: on day 1 approaching the MWMA from Junction Meadow to Crabtree; day 2 hiking from Crabtree to Mt. Whitney and back; day 3 hiking from Crabtree to camp between Rock Creek and Chicken Spring Lake; and day 4 hiking past Chicken Spring Lake to Horseshoe Meadow and out. Based on my understanding of how CSDs will be counted, those 44 clients would require an allocation of 176 days, or 19% of the annual MWMA quota.

Since the Trans-Sierra Xtreme Challenge is the only activity we conduct within the park, capping or reducing our ability to secure CSDs in the MWMA could significantly hamper our ability to operate, or grow this experience.

Before I share some ideas on methods to consider for allocating CSDs in the MWMA, there are two other potential solutions to consider which would result in better outcomes for the goals stated in the WSP.

Solution 1: Reduce the number of days requested by commercial operators
Consider this, our impact in the Mount Whitney Zone / Mount Whitney Management Area is doubled due to Forest Service restrictions designed to reduce the impact in these areas. If a trans-Sierra trek like ours were permitted to exit via Whitney Portal, the total time spent by TSX participants in the in these areas would be cut in half. Instead of base-camping at Crabtree and exiting Horseshoe Meadow, we would approach the Mount Whitney Management Area/Zone on day 1, then summit Mt. Whitney and exit Whitney Portal on day 2. The 176 commercial service days logged in 2015 could be slashed to 88.

Solution 2: Combine commercial and non-commercial quota pools, allocate based on public demand
Allowing commercial operators to compete for MWMA quota with the general public, under certain conditions, eliminates an arbitrary commercial services quota, and makes the balancing of commercial and non-commercial allocation a function of public demand. Some people prefer to experience the wilderness with the added knowledge and confidence that a professional outfitter provides. Others prefer to access it on their own. However, fixing the number of MWMA CSDs at 930 will ultimately exclude less-experienced people from accessing this portion of the backcountry. Combining the designated commercial and public pools of quota, and equalizing the application process will shift the allocation decision to the public. The total quota size and wilderness impact doesn’t change.

These solutions might require more long-term planning and coordination to achieve, but considering them and beginning that process now could result in better outcomes for the wilderness, and the public.

Analysis of CSD Allocation Methods
For the analysis of allocation alternatives presented in May, an important, missing criterion is what is best for the public? The general feeling from reviewing the slide deck options, and from the discussion in the room during your presentation in May, was that the park service is looking for a solution that is best, or fair, for the operators. Adding a “what’s best for the public” criteria to your analysis might impact the way the alternatives are viewed.

Commercial Service Day Allocation methods that limit competition, market entry, or make determinations based on administrative/historical use formulas, are inefficient and not best for the public. We’d favor a responsive allocation system that puts public demand at the center of the CSD allocation process.

Here is an alternative allocation method to consider:

1. 1. Keep the application process for CUAs open as it is today, so that new operators can come into the market, and underperforming ones can leave, without retaining value through historical CSD allotments.
   2. Have existing CUAs submit their quota requests, with trip itinerary, on March 1 of each year, when backcountry permits are also made available.
   3. Each request must also include a verifiable client list (sample attached).
   4. Allocate CSDs in bundled groups (maximum client-guide ratio X the number of service days required for itinerary).

I.e. If we had 3 verified clients for our route with 4 nights in the MWMA, and were allowed a client-guide ratio of 6-1, we would be allocated 6 X 4 = 24 MWMA CSDs. If we had 7 verified clients, and were allowed a maximum client-guide ratio of 6-1, we would be allocated 12 x 4 = 48 MWMA CSDs.

This would give operators security knowing that they can run a trek for existing clients, and with added confidence that they can sell additional spots to make it profitable.

1. Distribute CSDs among requesting operators in this manner until all CSDs are accounted for.
2. Hold any remaining CSDs until April.
3. CUAs submit new quota request April 1, along with updated client list and itineraries.
4. Repeat process through May.
5. When the Park’s regular back country quota system begins in late-May, all remaining CSDs – and CSDs pre-allocated by grouping but without an updated verifiable client list to support their use – become 1st come 1st serve on an as needed basis. Updated client lists will continue to be required to secure any remaining CSDs.

Why this is good for the public

• Forcing client lists, and requiring updates ensures that CSDs don’t go unused.
• New operators with new trips, ideas, service and business models can come in and compete.
• Historically biased or unresponsive formulas aren’t used.
• Allocation is fluid and based on public demand; will mirror market.
• All economic segments of public, and experience levels, can continue to be served.

Why this is fair to operators

• Success not tied to computer savvy, but actual demand for service offered.
• Allocation reflects operator’s interest and capacity.
• Grouping of CSDs to guide-client ratio allows operators to plan profitable outings.
• Timing allows operators to reasonably book and fill up trips.

Why this is good for the Park Service

• New system is driven by “what’s best for public”, encouraging competition and efficient, responsive allocation of scarce resources.
• Timing of allocation process coincides with timing of active permitting processes in park.
• Park service not in position to pick winner or losers of commercial operators.
• Active permitting process generally limited to 3-4 months of the year.

The alternative proposed has parallels to what currently takes place on a year round, monthly basis, in the Grand Canyon, for ALL backcountry permits, both public and commercial. I’d be glad to discuss this alternative, and the nuances of implementing this alternative vs. other considered options at your convenience.

Thanks again for your time and consideration, and your willingness to take our thoughts and background into account as you plan your next phase of implementation of the Wilderness Stewardship Plan for backcountry commercial use.

Sincerely,
Christopher Casado