US Congress Law
Rescue Cost Recovery: Request for Comment


March 9, 2001
 
 
Denali National Park and Preserve
Attn: Mike Gauthier
PO Box 588
Talkeetna AK  99676
Re: Denali Rescue Cost Recovery Study
 
Dear Mike:
 
On behalf of The American Alpine Club, I would like to respond formally to your request for comment regarding the rescue cost recovery study mandated by PL-106-486.  This law, introduced by Sen. Frank Murkowski (R-AK) and passed by Congress late last year, requires the Department of Interior to investigate three topics:
 
1. The suitability and feasibility of recovering the costs of high altitude rescues on Mount McKinley,
2. The suitability and feasibility of requiring climbers to provide proof of medical insurance prior to the issuance of a climbing permit, and
3. Review the amount of fees charged for a climbing permit and make such recommendations for changing the fee structure as the Secretary deems appropriate.
 
This study will be an important opportunity for the National Park Service to explain the multiple layers of complexity surrounding a visible, emotional issue that appears at first blush to be remarkablysimple.  The issues surrounding equity, legal liability, and financial responsibility must be explored so that policy makers appreciate what actions are likely to help and harm the situation.  We understand that the second topic has been expanded by Denali National Park and Preserve to include assessing the suitability and feasibility of requiring climbers to provide proof of rescue insurance prior to the issuance of a climbing permit.  We address this issue in section 2a of our response.
 
The AAC, founded in 1902, is the oldest national organization representing the interests and concerns of American mountaineers and rock climbers.  While our mission statement is long and varied, the major points include:
·         conservation and preservation of mountain and polar regions of the world,
·         exploration and scientific study of mountain and polar regions of the world,
·         promoting and disseminating knowledge about the mountains through our meetings, libraries and publications, and
·         representing the interests and concerns of the American climbing community.
 
The AAC’s current membership numbers almost 6,200 individual members throughout the US and abroad, including more than 100 in Alaska.  We also represent more than 52 climbing-related businesses that have joined our corporate membership program, as well as several thousand individuals who are members of our affiliate mountaineering clubs.   According to a membership survey conducted last year, 33 percent of AAC members who live outside of the state have climbed in Alaska, while another 32 percent plan to do so within the next couple of years.  (One would assume Denali National Park and Preserve was the primary destination for most members due to its internationally renowned reputation among climbers.)  Our members are frequent visitors to wilderness areas and National Parks, averaging 74 days climbing per year.  Consequently, a significant portion of our members would be affected by any rescue cost recovery proposals Denali National Park and Preserve may seek to implement, particularly because they will serve as a model for other National Parks nationwide.
 
A.  Determine the suitability and feasibility of recovering the costs of high altitude rescues on Mount McKinley.
 
The AAC remains staunchly opposed to charging climbers for rescues, a position that has not changed substantially from the early 1990s when recouping rescue costs on Mt. McKinley first arose as a major issue.  Charging for mountain rescues, whether after the fact or beforehand in the form of a rescue fee or rescue bond, is bad public policy for several reasons. 
 
From a practical level, charging for rescues often delays the initial request for help, which increases the risks for rescuers and subjects alike.  By the time a lost or injured climber calls for a rescue, he or she may be in worse condition physically or in a less accessible location, and the weather may have deteriorated significantly.  All of these factors can increase the complexity and cost of performing rescue services.  Because of these concerns, the Mountain Rescue Association, an organization representing 80 volunteer rescue teams from throughout the United States, Canada, and the United Kingdom, is on record opposing charging for rescues because “no one should ever be made to feel they must delay in notifying the proper authorities of a search or rescue incident out of fear of possible charges.” 
 
Charging one highly visible and readily identifiable user group – in this case mountaineers – for rescue services that are provided free of charge to all other National Park visitors is blatantly discriminatory.  According to 2000 NPS data, 35.3 percent of all National Park search and rescue missions were for “other” causes, which generally are not recreation related and cannot easily be categorized.  Hikers, boaters, and swimmers accounted for 24.4 percent, 10.3 percent, and 9.8 percent of rescues respectively, while climbers represented only 3.6 percent of all rescues.  (Nine percent of rescues were for “mutual aid” in which NPS officials responded to outside organizations on adjacent lands, such as a state park or Forest Service property.)  There also is no direct correlation between the type of visitor activity and the cost of a rescue.  Searches for lost hikers and downed aircraft can be exponentially more expensive than locating and transporting an injured climber from a known location on a mountain.  As the Anchorage Daily News succinctly put it in an August 1998 story preceding Sen. Murkowski’s rescue cost recovery hearing,
 
Though most of the search and rescue money in Alaska is spent on looking for missing planes, lost hikers and hunters, and disabled boats, that’s not what stirs the debate.  It’s the rescues – often highly publicized rescues – of climbers on Mount McKinley. 
 
Climbers should not be singled out to pay for services that are free to other Park visitors simply because they are highly visible, they are few in number, or their recreational pursuit is perceived as dangerous by some.
 
Search and rescue is one of many public safety functions performed by land managers nationwide, as is attending to fires, motor vehicle accidents, and responding to criminal acts.  All park visitors may at some point get lost or hurt while in our National Parks, whether it be a climber involved in a mountaineering accident or a sedentary tourist who succumbs to a heart attack while strolling on a paved nature trail.  Similarly, all visitors may at some point be the victim of a crime or be involved in an automobile accident.  The NPS has not selectively identified and charged other visitors they believe to be “at risk” for other public safety functions (e.g. smokers who may be more likely to start a wildfire, convicted criminals who may be more likely to engage in criminal activity, etc.)  In 1999, the total cost per visitor of performing all search and rescue activities was a mere 1.2 cents – a small fraction of the total cost of $6.90 per visitor for all NPS functions.  If actions must be taken to pay for search and rescue costs, the AAC recommends that the National Park Service establish a national search and rescue fund.  A small surcharge on all Park visitors would be the most equitable and defensible solution given that climbers account for a small proportion of all search and rescue operations system wide and the potential need for search and rescue services exists for all Park visitors.
 
While charging for rescues may solve an immediate budgetary problem, it may create a bigger fiscal headache by reducing or removing the discretionary shield that protects the National Park Service from liability regarding if, when, and how the agency performs rescue services.  In 1991 the AAC helped the NPS prevail in the Johnson vs. Department of the Interior case before the U.S. Court of Appeals for the Tenth Circuit [949 F.2d 332; 1991 U.S. App. LEXIS 26805] that established rescues as a discretionary function.  The ruling stated that
 
…the rangers’ decision if, when or how to rescue inherently involves the balancing of safety objectives against such practical considerations as staffing, funding and minimizing government intrusion.  As such, these decisions are grounded in social and economic policy, and thus are shielded from liability under the FTCA discretionary function exception.
 
The Park Service still retains the ability to recover costs from individuals if they believe the climbers’ actions constituted creating a hazard.  However, charging for all rescues may limit the agency’s flexibility and may open the agency to multi-million dollar lawsuits.  Beyond removing the discretionary shield regarding when a rescue is launched, charging for rescues also may force rescue agencies to provide a certain standard of care.  One large legal settlement would wipe out many years of revenue brought in from charging climbers for rescues on Mount McKinley and other peaks in the Alaska Range. 
 
Charging for rescues is inconsistent with the National Search and Rescue Plan, a document that establishes policies and responsibilities for all U.S. government agencies providing rescue services to fulfill domestic and international obligations, which then-Secretary Bruce Babbitt signed on May 3, 1999 on behalf of the Department of the Interior.  Section 40 specifies that “[t]his Plan covers civil SAR operations such as: …Land (including SAR operations associated with environments such as wilderness areas, swift water, caves, mountains, etc.).”  Section 48 requires that “[t]he Participants agree that SAR services that they provide to persons in danger or distress will be without subsequent cost-recovery from the person(s) assisted.”  Based on these provisions of the National Search and Rescue Plan, charging climbers in Denali National Park and Preserve for mountaineering rescues would violate national policies the Department of the Interior pledged to uphold.
 
Rather than look only to recoup existing rescue costs, the National Park Service must evaluate more fully what costs legitimately should and should not be assigned to mountaineering rescues.  Frequently, when costs are cited for a given mountaineering rescue in the Alaska Range, they include the cost of military personnel and helicopter flight hours, which can be substantial.  For example, in 1992, the year with the highest rescue costs, all search and rescue expenses totaled $431,245.  Of this total, the military incurred $225,345, while the NPS incurred $206,000.  Military rescue units must train constantly for various rescue scenarios – including mountain environments – so that they are prepared when called on to rescue downed military aircraft, damaged ships, etc.  These training costs are billed to their training budget regardless of whether time is spent on training exercises or real-life rescues.  It would be totally inappropriate to ask mountaineers to pay for military training exercises that otherwise would be accounted for in military training budgets.
 
According to an AAC analysis of NPS data, the largest single factor in escalating search and rescue costs in Denali National Park between 1980 and 2000 was the introduction of the Lama helicopter, a specialized high-altitude rescue tool.  In the 12 years prior to introduction of the Lama helicopter, rescue costs for Denali National Park averaged $56,807 per year, the most expensive season cost $114,770, and only one of the 12 years saw rescue costs above $100,000.  In the nine years from 1992 to 2000 with the Lama helicopter in use, average annual rescue costs doubled to $112,045, the most expensive year cost $206,000, and five of nine years had rescue costs above $100,000.
 
 
The Lama definitely has allowed some rescues to be conducted that otherwise would not have been possible, and some people who survived may have died without it.  However, elimination of the Lama helicopter contract would be the most significant action the NPS could take to contain the costs associated with mountain rescues in the Alaska Range.
 
The NPS also should seriously consider scaling back the rescue service infrastructure provided to climbers in the Alaska Range.  Trained volunteer rescue groups perform most search and rescue activities on public lands nationwide.  The Park Service should explore how volunteer rescue groups could be utilized in Denali National Park and Preserve to reduce rescue costs.  Beyond saving money, reducing the rescue infrastructure in the Park also sends a powerful message to climbers, particularly foreign mountaineers, that rescue services are no longer near at hand.  The Denali rangers point out in their educational materials that:
 
Rescue of injured or ill climbers, if possible at all, may be exceedingly slow and uncertain if weather conditions are not ideal.  You should be prepared and equipped to perform self-rescue.  Each party must rely on its own resources and cannot count on the aid of other climbers or rescue personnel.
 
Nevertheless, the highly visible ranger presence on Mount McKinley at the 14,000-foot camp and through the contracted Lama helicopter may give many climbers a misleading sense of security that the NPS will launch a rescue if anything goes wrong. 
 
NPS data show that foreign climbers, while comprising only 38 percent of the climbers on McKinley and Foraker, were responsible for roughly 62 percent of all rescue costs on these two mountains.  There exists a belief among many foreign climbers that rescues can and will be launched when needed by hurt or tired climbers.  An accident report sent by Denali rangers to the AAC for inclusion in the 2001 edition of Accidents in North American Mountaineering illustrates the problem.
 
The D2K party was adamant that Lev Sarkisov be flown off from the 17,200-foot high camp without delay, regardless of the weather conditions.  They learned very quickly that the Park Service doesn't provide a European-style helicopter rescue service and that Denali's weather dictates everything. 
 
Reducing the rescue infrastructure on Mount McKinley will send a strong and clear message that the National Park Service intends to return the mountain to a more natural condition typical of American wilderness, and that this change will require greater self-reliance by all climbers.  Telling mountaineers when they arrive in Talkeetna that you no longer have a high-altitude helicopter capable of making extreme rescues and that you no longer have a permanent ranger presence high on the mountain will remove a psychological crutch that causes some climbers to push on when they should turn back. 
 
B.  Determine the suitability and feasibility of requiring climbers to provide proof of medical insurance prior to the issuance of a climbing permit.
 
This aspect of the rescue study came from the belief by Sen. Murkowski that injured climbers were causing financial problems for local medical care providers by not paying bills following treatment.  When he introduced the bill authorizing the study, Sen. Murkowski said,
 
I want the Secretary to evaluate requiring climbers to show proof of medical insurance so that hospitals in Alaska and elsewhere are not left holding the bag as they sometimes are under present circumstances.  It is a good neighbor policy that should be put into effect at the earliest opportunity.
 
The AAC acknowledges that lack of health insurance is a widespread, serious, and longstanding problem facing many Americans.  Nevertheless, the AAC questions whether there is any information available showing climbers to be less insured than the population as a whole.  We also assert that having health insurance coverage has no bearing upon whether a person should be allowed to climb in Denali National Park and Preserve – or visit any National Park, for that matter – and a requirement that climbers demonstrate proof of health insurance coverage before being issued a mountaineering permit would be discriminatory. 
 
According to the US Census Bureau, an estimated 42.6 million Americans – fully 15.5 percent of the national population – did not have health insurance in 1999, the last year for which figures are available.  Yet, this overall uninsured rate glosses over many disparities regarding coverage.  For example, health insurance coverage varies tremendously based upon age, whether one is employed or unemployed, works full-time or part-time, or has a high-income level or a low-income level.  While 24.1 percent of Americans with household incomes of less than $25,000 do not have health insurance, only 8.3 percent of Americans with household incomes of $75,000 or more do not have health insurance.  Similarly, while 22.4 percent of part-time employees aged 18-64 were uninsured, only 16.4 percent of full-time employees were uninsured – though an astounding 47.5 percent of poor full-time workers lacked health insurance coverage.   
 
To give a sense of what these numbers may mean to mountain climbers, our recent membership survey (conducted by a professional survey firm using scientifically valid statistical techniques) showed that AAC members would be more likely than the average person to have health insurance coverage.  Forty-one percent of Club members responding to the survey had incomes in excess of $75,000, which places them in a category with roughly half the number of uninsured individuals as the national average.  An additional 20 percent of members had incomes between $50,000 and $75,000.  Two out of three members surveyed did not have a child under age 18 living at home, so this income would be less diluted than for the average American household.  Further, since climbers from most other nations attempting to climb in Denali National Park and Preserve – particularly those from Europe – have some form of national health insurance coverage, it appears that McKinley climbers are far more likely to have some form of health insurance than the average person entering the National Park System.  Absent any compelling information from the Park or Anchorage-area hospitals, this is an issue based more upon groundless speculation than fact.
 
The AAC questions whether it is relevant for the NPS to ask any Park visitor about health insurance coverage of any type.  The National Park Service’s Organic Act established National Parks
 
…to conserve the scenery and the natural and historic objects and the wild life 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.
 
There is no mention of limiting access due to lack of health insurance, ability to pay, or any other factor.  Given that the National Park Service incurs little to no expense for direct health care of injured Park visitors, we believe there is no legitimate reason for the NPS to force anyone to divulge whether they have health insurance coverage.  The working poor of this country are the most likely segment of our society to lack health insurance, yet they pay taxes that support our public lands.  They already face significant obstacles in paying entrance fees to enjoy their National Parks (the Denali mountaineering fees is the most expensive individual fee in the country) without forcing them to show proof of medical insurance, which most simply cannot afford. 
 
The Department of the Interior already has gone on record as being opposed to requiring that climbers show proof of medical insurance before being issued a climbing permit.  On May 13, 1999, when S. 698 was being heard before the Senate Subcommittee on National Parks, Historic Preservation, and Recreation, Department of the Interior Deputy Assistant Secretary Stephen C. Saunders testified against this aspect of the bill saying it would not be in the public interest.  He remarked:
 
With regard to considering the question of whether to require climbers to have medical insurance, we do not believe a study is warranted.  We believe the issue of payment for medical treatment at a hospital or other medical facility should remain beyond the authority of the National Park Service or Department of the Interior.  This is an issue between the private citizen, his family and his doctors.  The National Park Service is responsible for the care of patients during a rescue and for their transportation to an appropriate medical facility, but should not be involved in assessing the adequacy of medical insurance for care that can extend for years beyond a person’s initial injury.
 
While we are encouraged at the Department’s previously stated opposition to this requirement, we hope you will reject it forcefully in your study.  This is a fundamental question of fairness regarding access to public lands and discrimination of one highly visible user group.  Unless you require all Park visitors to show proof of medical insurance (and force all motorists entering the Park to show proof of automobile insurance), we believe this is a blatantly discriminatory and unlawful requirement. 
 
2a.  Determine the suitability and feasibility of requiring climbers to provide proof of rescue insurance coverage prior to the issuance of a climbing permit.
 
Though not required by the Congressional legislation, the NPS is looking more broadly at the issue of requiring climbers to provide proof of rescue and evacuation insurance before being issued a mountaineering permit.  While the AAC believes strongly that climbers must be self-reliant and be responsible for their own actions, we have serious concerns that a mandatory rescue insurance requirement will not be an effective solution to the current situation.  Requiring proof of rescue insurance coverage (and billing policies after rescues have been completed) involves many of the same legal and practical pitfalls as charging subjects for rescues.
 
The AAC provides worldwide rescue and evacuation insurance as a standard membership benefit for its members on peaks up to 6000 meters in height.  We believe this is a prudent and responsible benefit to provide to our members so that they can begin to recoup expenses associated with any mountain rescue services they may need.  Members who attempt peaks with elevations greater than 6000 meters may purchase additional insurance from our carrier on a weekly basis.  The rates for this supplemental coverage increase with the height of the peak.  For example, peaks above 6000 meters but below 7000 meters (which would include Mount McKinley) require an additional fee of $25 per week, while peaks between 7000 meters and 8000 meters require a $50 per week fee, and peaks above 8000 meters require a $75 per week fee. 
 
Our rescue policy and policies offered by major European alpine clubs have limits on the amount of money that will be paid out per insured climber and per rescue.  The AAC’s policy covers rescue costs up to $5,000 per member, but caps overall payments at $10,000 per accident/rescue regardless of the number of AAC members involved.  It is our understanding that the major European insurance policies do the same, though the dollar value limits are different.  This means that Denali National Park would be able to recoup some, but not all, of their rescue costs if they required climbers to have rescue insurance. 
 
Utilizing NPS rescue cost data and making some assumptions regarding rescue insurance coverage, we determined that between 1997 and 2000 the Park could have recouped approximately $80,700 of an estimated $135,858 incurred rescuing American climbers on Mount McKinley and Foraker if the NPS had required all American climbers to have AAC rescue insurance coverage using our current policy terms.  It is unknown how much of the estimated $224,680 incurred by foreign climbers the Park could have recouped, since we do not know what claim limitations their policies provide.  Rescue insurance would have paid for most, if not all, of the NPS expenses associated with most rescues, since they were less than our accident claim limits.  However, rescue insurance undoubtedly would not have covered most or all of the most expensive rescues – those that cost more than $25,000 and garnered significant media attention – because of the claim limits.   
 
Another factor that must be addressed when considering the requirement of carrying rescue insurance is the impact claims will have on current rescue insurance policies.  Former South District Ranger J.D. Swed, quoted in a Boulder Daily Camera news story, highlighted a major problem.
 
When someone pays for a service in advance, they expect to get it.  If someone pays for an insurance policy and they get to the 14,000-foot mark and decide they need to come down, who is to say they don’t have to be taken down.
 
The experience in Europe shows conclusively that when people have rescue insurance they can and will call for rescues in situations the NPS today would not view as worthy of launching a rescue.  The AAC is the primary American group currently providing rescue insurance coverage to its members.  Several years ago an organization called the World Climbing Association provided rescue, medical, and gear replacement insurance to climbers, but the organization ceased operation after a few years.  (As we understand, this stemmed from an inability to write the number of policies stipulated by its underwriter.)  If climbers can call for a rescue whenever they feel like it, the increased utilization of rescue services could have a disastrous impact on the number and cost of mountaineering rescues, as well as on our claims experience, drying up the market for rescue insurance underwriters.
 
While the AAC continues to work with the Park Service to investigate options associated with rescue insurance, we want to make clear that the Club is opposed to singling out climbers to provide rescue insurance coverage when other Park visitors are not asked to be financially responsible for their rescues.  If rescue insurance proves to be a viable concept, it should be applied broadly among allvisitors.  Alternately, a two-cent surcharge on all NPS visitors for a national search and rescue fund would cover search and rescue activities system wide and would not discriminate against any specific user group.  Such a fund would rectify the current situation in which individual Park units must pay for rescue costs under $500 and regional NPS offices must pay for rescues above $500, both of which require diverting money from existing projects since there is no dedicated rescue fund.
 
C.  Review the amount of fees charged for a climbing permit and make such recommendations for changing the fee structure as the Secretary deems appropriate.
 
The AAC and the broader climbing community were upset with many of the management actions taken in 1994, but especially the imposition of a $150 per person mountaineering fee for climbers attempting Mount McKinley and Foraker.  We viewed the fee as totally out of line with similar recreation use fees charged throughout the National Park System for other activities.  The only other comparable management fee at that time was a $75 per group fee for rafting the Colorado River through the Grand Canyon.
 
There also was significant opposition to the blanket 60-day advance registration requirement.  While advance registration has allowed the Park to educate and inform novice climbers to the unique hazards and conditions faced in the Alaska Range, we believe there should be some system whereby climbers with demonstrated experience in the Alaska Range can be exempted from this advance registration requirement.  We do not know what impact such a program would have on the workload or cost of the mountaineering program.
 
Though the Denali mountaineering ranger staff have been analyzing the mountaineering program budget, we were not able to see detailed figures before drafting this response.  Thus, we are not able to make recommendations based on valid budget figures from the NPS, but must quote figures cited in news reports and other sources that might not be fully accurate.  Our goal is to continue working with the NPS during the study period to sort out those expenses that legitimately tie in with oversight of the mountaineering program.  We also hope to determine what portion of overall management costs should be charged to specific visitor groups rather than be paid for from general agency appropriations.
 
The charge from Congress was to evaluate whether the current fee structure for a mountaineering permit to climb McKinley and Foraker was sufficient, and to propose modifications if the fee needed to be adjusted.  The AAC believes that before the adequacy of the fee can be evaluated, the Park first must review the type and level of component services offered by the mountaineering program to determine which legitimately should be included as services offered only to climbers.  The Park should give serious thought to what programs and levels of service can be eliminated or modified to save costs. 
 
As was discussed in the rescue cost recovery section, a major source of cost savings for the mountaineering program could be realized by eliminating the contract with the Lama helicopter.  We have not seen current figures from the Park regarding its total cost and the portion that may be charged to the mountaineering program for non-rescue functions.  However, two years ago when the Anchorage Daily News covered Sen. Murkowski’s rescue cost recovery field hearing, the paper reported that the three-month lease contract for the Lama helicopter cost the agency $260,000.  Reportedly the cost has risen since then to $300,000.  We are aware the helicopter is used for administrative purposes, such as setting up and taking down the 14,000-foot administrative camp (and presumably also the 7,000-foot camp), as well as for mountaineering rescues.  The AAC believes elimination of the Lama helicopter can result in substantial cost savings for both administrative and rescue services. 
 
We also question whether it is necessary to continue to maintain the 14,000-foot administrative camp on the West Buttress route.  Prior to the establishment of Dr. Peter Hackett’s medical research camp in 1982, there was no facility high on the mountain.  Its presence – first as a medical facility, now as an administrative camp – has been cited as a reason for the survival of some climbers, but also as an explanation why some climbers avoid being self-reliant.  As Jon Waterman wrote in “Surviving Denali,”
 
One can only guess how many climbers might have died from HAPE if the medical camp had not been set up (for independent research, not to rescue climbers) at 14,300 feet in 1982.  Now too many climbers rely upon the oxygen and expertise of the doctors.  This not only reduces Denali’s difficulty, but reflects poorly upon the esthetics of those who come each year to climb North America’s highest peak.
 
We do not know the costs associated with setting up, occupying, and removing the high camp, but it likely is significant.  Additionally, it would be helpful to know what percentage of the costs associated with the establishment, operations, and removal of the 7,000-foot camp are charged to the mountaineering program given that it facilitates access for fee-paying climbers headed to McKinley and Foraker, as well as the operation of flight services that may not involve fee-paying clients (i.e. climbers who are headed to peaks that do not require payment of a mountaineering fee and to sightseers who may simply land on the Kahiltna Glacier).  These are services that may be needed, but that should be reviewed to determine whether all persons utilizing them are charged for a portion of their cost so that one group does not shoulder a disproportionate burden.
 
The Park also should look at other, non-mountaineering related programs to determine how much it costs to provide these services and what percentage of these costs are passed on to the visitors who use them.  For example, what portion of the cost of managing snowmobile, hiking, backpacking, camping, flight seeing, and other recreational uses of the Park is charged to specific visitors?  Do people on a scenic flight who fly into the Park, land on a glacier, and return to the airstrip even pay a standard entrance fee?  What portion of the total cost of running the visitor center, developed campsites, the trailer dump station, and the shuttle bus between Park Headquarters and Wonder Lake is charged to people who use these developed facilities and services? 
 
One also must question what is a fair split between general appropriation support versus user fee support of specific management programs, particularly those that allow visitors to explore the remote and more primitive parts of Denali National Park and Preserve.  It unquestionably is easier and cheaper to manage for “turnstile” visitors who drive into the Park, pay their entrance fee, tour the visitor center, and then leave than it is to manage dispersed backcountry users.  However, the National Park Service mission and goals are much broader than simply cycling through the cheapest and easiest visitors to serve.  Just as urban residents subsidize the more expensive phone service of rural residents so that all members of our society can have access to this vital technology, it seems reasonable that some cost sharing between easy-to-serve and hard-to-serve visitors should be encouraged to ensure that the full spectrum of recreational opportunities are available within the Park.
 
The AAC recognizes that climbers must pay for some aspects of the management of mountaineering in Denali National Park and Preserve.  In order to make climbing as affordable as possible, we would like to see unnecessary or excessive services reduced or eliminated and the fees charged be reasonable.  We look forward to helping you sort out these expenses once accurate figures are known.
 
Conclusion.
 
Climbers want to be responsible, largely self-reliant visitors to the National Park System who do not create a financial burden on the system as a whole.  The issue of how the National Park Service pays for and executes search and rescue services is a thorny one that cannot be addressed with simplistic responses.  The AAC believes there are significant legal and discrimination issues surrounding charging mountaineers for rescue services, requiring medical and/or rescue insurance before being granted a climbing permit, and determining how much visitors should pay directly for management services through user fees. 
 
The Club appreciates the opportunity to comment on this Congressionally mandated study, and we hope these comments prove of assistance at this phase in the study’s development.  We look forward to working with you as the study progresses.  Please be sure to send copies of all relevant documents to the two Club staff members, Executive Director Charley Shimanski and Deputy Director Lloyd Athearn, who are working on this important issue.  They both can be reached at the Club’s headquarters.  The mailing address is 710 Tenth Street, Suite 100, Golden, Colorado 80401. 
 
Thank you again for this opportunity to comment on this important issue.
 
Regards,
 
 
 
 
C. James Frush
President