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 AACs 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. Murkowskis 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, thats
not what stirs the debate. Its 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 agencys
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 Services 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 persons
initial injury.
While we are encouraged at the Departments 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 AACs 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 dont
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. Murkowskis 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 Hacketts 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 Denalis difficulty, but reflects poorly upon the
esthetics of those who come each year to climb North Americas
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 studys 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 Clubs 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
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