BLM’S Tangle Lakes Archeological District


December 2006

To: Bruce Rogers

Dear Bruce and Cory:

The following are the comments of the Alaska Quiet Rights Coalition (AQRC) on the Proposed Action for future OHV management in BLM’s Tangle Lakes Archeological District (TLAD).

AQRC is a statewide non-profit organization with approximately 600 members/supporters which works to protect the rights of Alaskans to quiet places for the benefit of users of our public lands, home and cabin owners, communities, businesses, wildlife, visitors and future generations. We believe natural quiet and natural sounds are intrinsic resources of our public lands which deserve as much protection as other resources like fish and wildlife, scenic beauty, clean air and water,
etc. We advocate that public land managers provide a fair and balanced allocation of Alaska’s public lands for both non-motorized and motorized uses.

Natural quiet, natural sounds, and the opportunity to hear and enjoy them, are fundamental natural resources/values that, not all that long ago, Alaskans took for granted. Now, because of nearly ubiquitous recreational motorized vehicles, both individual and commercial, on the lands and waters and in the air, natural quiet and natural sounds have disappeared, in all seasons, from many of our public lands. It is essential, from the standpoint of both humans and wildlife, that we protect those resources in the few locations where they still exist and, just as important, restore them to a significant portion of the lands from which they have vanished.

Consequently, we cannot support additional motorized OHV use in the TLAD. The TLAD, to our knowledge, is one of the very few, if not the only, area in BLM’s Glennallen District where any restrictions at all are placed on OHV use. Yet, unlike some lands under other federal, or state, management in Alaska, OHV use is not totally prohibited, which would create a truly quiet area, but is instead restricted in the non-snow season to several designated trails. While we might accept the existing designated trails and present level of use in the TLAD, the Glennallen District’s overall OHV management should focus on prohibiting, or otherwise restricting, OHV use on at least some other lands under their stewardship, thereby providing additional high quality non-motorized opportunities, rather than increasing it in one of the only locations where an attempt has been made to protect cultural resources. And of course not only cultural resources benefit from those OHV restrictions. At the same time that cultural resources are protected, an opportunity for a non-motorized hunt is provided; a quiet refuge for wildlife and for other non-motorized recreationists is created; and natural quiet, natural sounds, fish and wildlife, soils and vegetation, and scenic beauty are given at least some higher level of protection than they would normally receive.

More specifically, we oppose designating and opening spur trails (this effectively rewards illegal use, and two miles of spur trails is hardly insignificant); connecting the Osar Lake and South Landmark Gap trail systems; and considering any new motorized routes. The goal of TLAD management should be to protect a wide range of resources and values by limiting OHV use, not by meeting desires or “demand” for additional motorized use. Additional use should be steered to other lands, both state and federal, of which there are many thousands of adjacent or nearby acres, that are perhaps less valuable for cultural and other purposes, and that have not been specially designated. The Glennallen District should strengthen, not weaken, its management of OHV use on the lands for which it holds stewardship responsibilities. It should also move more quickly towards a better balanced, fairer allocation of high quality recreational opportunities between motorized ones, which now hugely predominate, and non-motorized ones, which are few and far between at best.

At the present time, although the TLAD management scheme is certainly not perfect from the standpoint of non-motorized hunters, other quiet/primitive recreationists, wildlife, natural quiet and natural sounds, there are gaps between the designated motorized trails where a sometimes fairly high level of relief from motorized use can be found. Developing spur trails, linking trails, and creating new routes, would eliminate those relatively quiet gaps.

We also have questions about the maintenance proposals. Are all of the designated trails in locations that BLM considers appropriate? We presume that many/most/all (?) of the trails are social trails. If BLM were starting from scratch to develop a trails plan for the area, would it have developed and designated each of these trails? If any of the trails, or segments of the trails, are in inappropriate locations, maintenance, especially expensive Geoblock, might be throwing good money after bad. If any of these trails, or segments of them, are in inappropriate locations, closing them, or closing segments of them, would be preferable to spending a considerable amount of money to try to maintain them.

Furthermore, as we understand it, existing levels of use have created unacceptable damage, which is one of the major reasons, if not the major reason, BLM is undertaking this plan. We suspect that hardening or other maintenance which makes motorized trail use easier and more comfortable will increase overall use, as well as get more folks into the more remote country where they’ll be tempted to explore even further by creating additional spur/social/illegal trails. We don’t think either of these results should be encouraged.

All this is not to say that BLM is undeserving of credit. It is to be commended for attempting, within the confines of a difficult political situation, to better manage OHV use in both its East Alaska Resource Management Plan (although the proof there will be in the implementation planning pudding) and in this TLAD plan. We just think that some of the proposals in this present plan would be steps backward rather than forward.

But others are very positive. We think the expansion and improvement of the non-motorized hiking trail associated with Tangle Lakes Campground is a very good idea. The location will make it readily accessible to thousands of Alaskans and Outside visitors who camp at that campground without having to make a separate trip to a trailhead, and when they might be looking for things to do after establishing their camp.

Furthermore, although we generally heartily support the designation or development of additional non-motorized hiking trails, we fully concur with BLM’s decision not to propose such a trail at Whistle Ridge, where it might interfere with the rare non-motorized hunting opportunity provided there.

We also support not marketing the TLAD as a destination point (it’s already quite well known, and no one’s trying to keep it a secret); the expansion of educational efforts at trailheads; the development of a law enforcement plan which would increase law enforcement staff presence during the 4th of July weekend and the caribou and moose hunting seasons; OHV weight restrictions, some of which are aimed at helping to protect the Gulkana Wild and Scenic River corridor; and prohibiting motorized off-trail travel for game retrieval unless it is outside of the seasonal date restrictions (this is a current management practice, and surely it’s not unreasonable to ask hunters to do some walking to retrieve their game away from the motorized trail that gave them access to the general area).

We also appreciate the recognition of natural quiet in the Standards and Monitoring section. This is a positive symbolic step, and hopefully of some practical value as well. The photo points and other monitoring suggestions are excellent.

Impact zones of only 1/2 mile on either side of motorized trails are not realistic, however. In that open country, visual impacts can be noticeable for significantly longer distances, and noise impacts can travel for a mile or more. Presumably it is clear from our comments above that we do not support even under the 1/2 mile definition increasing the impact zone above the existing 25,000 acres (14% of overall acreage), which would in any case appear to be an underestimate. The proposed action would increase the impact zone a very substantial 68%.

In closing, we’d emphasize what should be an obvious point: this is an archeological district, not a motorized recreation area. Nearly all of the hundreds of thousands of other BLM managed public lands in the region are open to effectively unrestricted motorized recreational use (not that we think that this is appropriate or responsible management). These special TLAD lands deserve special, unwavering protections, rather than so-called “protections” that are subject to periodic weakening when OHV ownership increases.

Thank you for the chance to offer these comments and for your sincere desire to better manage in this important cultural area what can be a very destructive use if not responsibly controlled.


Cliff Eames
Board Member
Alaska Quiet Rights Coalition