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This letter from Mike Lewis of the American Alpine Club was sent to the TPWD in early April.

Try as we might, we cannot find anything in this proposal that is unreasonable or harmful. Ergo, it will be stored in file 13 by the TPWD.

April 10, 2000

Mr. Walter D. Dabney
Director, State Parks Division
Texas Parks and Wildlife Department
4200 Smith School Road
Austin Texas 78744

Dear Mr. Dabney,

On March 23, 2000, you met with a group of individuals at Hueco Tanks State Historical Park representing the El Paso Climbers Club and the Access Fund. We regret that an individual representing the American Alpine Club was not able to attend on short notice. It is our understanding from conversations with individuals present at the meeting that you have requested specific proposals from climbing organizations regarding revisions to the current Public Use Plan for Hueco Tanks. It is our desire to continue to work cooperatively with your organization and to present a specific logical and rational approach for management of recreation at Hueco Tanks. We believe there is significant room for improvement in the current management strategy.

The AAC has been involved with the issue of a Public Use Plan since it’s inception with Mr. Bill Palmer, then acting State Parks Division Director, in early 1997. In a 15-point letter, the AAC assisted local climbers to provide the initial basis for the formation of the original Draft Public Use Plan. Most of our initial ideas were incorporated into the original Draft PUP, however some additional concepts were added or modified from their original context. The Volunteer Guide Program arose from such a modification (of the original Volunteer Ranger Proposal) and was perceived to represent a method that allowed TPWD to control the activities of park visitors, thus beginning the initial (of many) reductions in personal freedoms. The initial PUP that was "finaled", after meetings held in El Paso with Rep. Norma Chavez attending, looked nothing like the original Draft PUP and severely restricted access to the majority of the park. Despite significant negative comment from the climbing community, TPWD implemented the PUP, largely disregarding these comments.

On March 29, 1999 Jeff Drucker with the El Paso Climbers Club (EPCC) and I met with Mr. Robert Cook in his office at TPWD headquarters to discuss the Public Use Plan at Hueco Tanks. Our concerns regarding the current PUP were that the local park staff at Hueco Tanks are interpreting the plan and enforcing provisions of the plan in a manner much stricter than written in the actual document. This is evident when one examines the local rules and how they are enforced compared to what is specifically written in the PUP. Specific comments and recommended improvements were provided to Mr. Cook in a letter dated April 5, 1999. Additionally, previous correspondence dated January 20, 2000 was provided to your organization in response to the Draft Public Use Plan Review, published in December, 1999. Most of the relevant issues pertaining to park management and rock climbing were addressed in these transmittals and we request that you please refer to them for additional background on our proposed strategy.

In our opinion, the current PUP and proposed draft modifications to the PUP presently being considered place too much emphasis on institutional controls as a method to manage the park. The current approach places park management in the same context as an open-air museum that must be guarded around the clock and is open to specific guided tours of limited length that fall within the strict criteria of two or three park employees. This approach, which severely restricts personal freedoms, is not practical to implement.

For many years, from 1969 to 1998, the park was open to visitors with virtually no controls or management plans. This approach obviously led to some abuses and resulted in vandalism of rock art and resource degradation. The primary reasons for environmental degradation can be attributed to the lack of a well-defined trail system, absence of backcountry toilet facilities, and poor drainage control. Resource degradation of archeological sites stemmed from the fact that TPWD had not inventoried these sites and park visitors were allowed to frequent them without any guidance regarding site sensitivity. In areas known to be primary rock art locations (such as the Bucket Roof, Blood and Gore area, Nuclear Arms area), rock climbers observed site closures for many years with very few documented incidents of non-compliance that we are aware of. Incidents of vandalism that occurred on North Mountain have not been attributed to rock climbers, and this is an area still generally open to the public.

In our opinion, the long overdue need to manage the park correctly and the observed resource degradation forced TPWD to over-react in their approach to control access. The environmental degradation issues at this park are certainly no worse (and actually better) than those I have personally observed at a number of other parks in the system. The construction of a comprehensive trail system, installation of backcountry toilet facilities, and correction of some drainage problems would likely resolve many of these issues. The main issues driving TPWD's need to control park access is related to preserving archeology and indigenous rock art. We feel that these goals can be accomplished in a manner that involves using volunteer coordinated projects and scientific information gained in recently completed survey efforts or future surveys. Our vision of a logical and rational management approach that includes park volunteers and improves recreational access are presented in the following headings:

Area Specific Designations

The current PUP provides for wholesale closure of the majority of the park, allowing only guided tours to be conducted with many limitations. We believe that the current restrictions have allowed TPWD to conduct resource studies and gain significant knowledge that was not previously documented. The information gained from these surveys, and from additional (future) survey efforts can be utilized to group the areas of the park into four major categories:


  • Closed Areas- These areas would be designated closed to public access due to their extreme sensitivity and need for preservation or need for further scientific study. These would include the most scientifically valuable areas which require preservation or have a specific cultural sensitivity. Access and activities in these areas can be allowed by specific permit.


  • Restricted Areas- These areas would be limited only to guided tours because of their sensitivity and characteristics that will not allow appropriate hardening or improvement for general public access. Such sites may include accessible rock art images that are located within close proximity to known rock climbing sites. Activities may be restricted in these areas as needed for preservation.


  • Improved Areas- Areas where some minor improvements or site hardening may allow general public access. These areas could be protected by adding soil cover, appropriate signage, limited fencing, or other techniques to allow public access and still provide protection and preservation. All activities generally will be allowed, subject to site specific, posted limitations.


  • Open Areas- The remaining areas of the park where general access and activities are allowed. These areas are less sensitive by archeological and rock art standards and shall be linked by the improved trail system that directs travel to rock outcroppings where people walk over hard rock surfaces.

It is important to note that rock climbing groups have supported site specific designations since the inception of the original Draft PUP. We feel that the proposed area designations should be acceptable by all parties and allow for varying degrees of access and activities based upon the particular sensitivity of the sites. Proposed park improvements and the Volunteer Ranger program (discussed in later headings) are integrally linked in the success of this management strategy. Guided tours would be required only in specific Restricted Areas and could be provided optionally in Open Areas and Improved Areas. It is anticipated that a much larger portion of the park would be open to general public access, if properly managed.

We propose that a test area such as the Dragon's Den be utilized to determine the feasibility of this approach. The Dragon's Den would be particularly useful as a test area for many reasons: 1) it is located in close proximity to the parking lot and may be accessed easily by both park visitors and rangers; 2) there are few significant rock art or archeological sites; 3) the area contains many popular rock climbing boulders; 4) there does not appear to be significant cultural sensitivity associated with the area; and 5) it is a reasonable site for the implementation of volunteer conservation efforts. The initial efforts should focus on determining the possible areas within the Dragon's Den that require improvement or hardening prior to allowing general access. Volunteer and park guided efforts should be implemented to generate the needed improvements (trail, drainage, signs, etc.) and to create the portion of the overall trail system providing access to this area. The use of volunteer coordinated efforts would generate the "ownership" and emotional attachment among local user groups needed to create the long-term accountability for park preservation. Particular sensitivity by TPWD in this area would go a long way toward re-building a good relationship between park users and local park staff.

Park Improvements

Critical to the success of the park management strategy is the park improvement plan currently being conceived by TPWD. These improvements include the design and construction of a comprehensive trail system throughout the park. If properly designed, the trails will provide direct access to the rock formations frequented by rock climbers and other visitors. Direct access to Open Areas and Improved Areas should be the priority focus of the constructed trail system. These areas will be the most frequented in the park. Access to Restricted Areas and Closed Areas may be constructed at a later date, if at all. The trail system has the obvious benefit of greatly reducing foot traffic across archeological deposits and the added benefit of reducing environmental effects produced by unauthorized foot trails in the desert. The trail system should direct foot traffic, as much as possible, over hard rock surfaces. Since Restricted Areas should be accessed by guided tour only, a less extensive trail network is required for these areas. At select crossroads on the trail system or popular areas frequented by park users, backcountry self-composting toilet facilities should be provided. The presence of self-composting toilets will reduce problems with human waste in the park and the temptation for persons to stray from the developed trails to take care of personal business. Additional improvements such as drainage control are required in many

areas to preserve archeological sites and improve general environmental conditions in the park. Drainage control may be an essential part of the improvements needed to allow public access.

Volunteer Ranger Program

Because park accessibility will be increased under this management strategy, additional staff will be required to patrol backcountry areas of the park and ensure compliance. It is not anticipated that additional TPWD staff will be added, rather a program of trained volunteers, with different focus and responsibilities than guides, will be established to assist TPWD. The Volunteer Rangers (VRs) should be trained to act as the "eyes and ears" of the park staff. Their focus will be to patrol the backcountry, observe individuals and groups at Open Areas and Improved Areas and report to park staff regarding unacceptable behaviors or violations of the park rules. The VRs may be able to prevent resource degradation problems before they occur. They will be used to verify that unauthorized individuals or parties are not entering Restricted Areas or Closed Areas, including the examination of guided tours in Restricted Areas and special use permits in Closed Areas. The VRs should be equipped with a radio system that puts them in direct contact with park headquarters and the park staff. Their presence in the remote areas of the park will undoubtedly discourage incidents of vandalism and other detrimental actions. Persons judged to be responsible would be enrolled in the program and trained by park staff. A proposed incentive for VRs, other than unrestricted access to the park and free campground location, is to obtain supplemental funding and stipends for VRs through climbing-related organizations, including the AAC and AF. Examples of individuals who may be suited for the VR program include graduate students at the local university, wintering climbers, summer interns from land management programs, etc.

Volunteer Guide Program

The new park management strategy should de-emphasize this program for rock climbing because it is clearly NOT working. The VG program should be made optional, except in Restricted Areas. Volunteer Guides (VGs) are not currently allowed to participate in the activity for which they are guiding and tours are limited to two hours in length. This is a HUGE disincentive for rock climbers to become involved with the program. It is not realistically enforceable with hiking, rock art observation, or birding, but is totally focused on repressing the number of rock climbing VGs (due to lack of incentive to lead a tour) and thereby reduces the number of climbing tours to the current low levels. The lack of certified commercial guides and VGs has been an ongoing problem for climbers wishing to reserve tours in the current restricted areas.

Volunteer or commercial guides could use a web-based reservation system in the future to book time for tours and also allow participants to sign up for tours in advance from anywhere in the world. Park staff can monitor booking of time slots and the location/destination of the tours.

Climbing Fixed Anchors

As yet, the Memorandum of Understanding with the El Paso Climbers Club (EPCC) for the inspection, monitoring, and replacement of fixed anchors has not been reinstated. The former MOU has been expired for a number of years and, to my knowledge, no significant maintenance or replacement of fixed protection has occurred to the bolted routes in the park. This poses a potential safety concern and should be addressed immediately. At Enchanted Rock, a comprehensive effort has been underway for the past 3 years to inspect, provide maintenance, and replace inferior fixed protection. This is a service to TPWD and to the climbing community that could potentially avert life threatening or fatal tragedies. The rock climbing community has paid for all these improvements and provided the volunteer labor to implement

them. We suggest that TPWD contact the EPCC and the Central Texas Climbing Committee (CTCC) regarding plans to implement an inspection and replacement program for fixed climbing anchors at the park.

The AAC thanks you for the opportunity to provide this conceptual proposal for an alternative management strategy at Hueco Tanks SHP. We do not believe that the philosophy of creating an "open air museum" at Hueco Tanks is consistent with TPWD’s goals or mission. We believe that recreation and preservation at Hueco Tanks can both be achieved with the appropriate insight and courage to implement a creative management strategy.


Michael J. Lewis Jr.
Conservation Committee Chair,
American Alpine Club