Chugach National Forest: Chugach Powder Guides Ten Year Permit

December 1, 2007

glacier_district_special_uses@fs.fed.us
Teresa Paquet-Special Uses
Glacier Ranger District
P.O. Box 129
Girdwood AK 99587

Dear Teresa Paquet:

The purpose of this letter is to supply the Alaska Quiet Rights Coalition (AQRC) scoping comments relative to the proposed ten year special use authorization requested by Chugach Powder Guides. As you are aware, AQRC has been an active participant in the Churgach National Forest Plan, the five year permit for CPG, the Kenai Winter Access Plan and other permit authorizations. AQRC is a statewide nonprofit organization with approximately 600 members/supporters who believe natural quiet and natural sounds are natural resources to be protected by public land managers. AQRC advocates that nonmotorized recreation deserves a share of our public lands equal to those granted to motorized recreationists and that cabin owners and wildlife deserve protection from motorized recreation.

We understand that the request is for the issuance of a new ten year permit for the period of Jan. 1, 2008 to December 31, 2017; not merely the extension of the existing five year permit for five years beyond the current expiration date of April 20, 2009. Our review of the 2005, 2006 and 2007 reports and evaluation indicates that CPG is apparently meeting the requirements of its permit, generally, in a satisfactory way though some late reporting and incursions into “no fly areas” have been noted annually.

The major issue raised by the Forest Service evaluations is the failure of the Forest Service to have yet completed the wildlife studies identified in the September 2004 Record of Decision (ROD) as being necessary to validate and or modify the proposed mitigation measures. The ROD recognized that concerns over the effects of helicopter skiing on wildlife constituted a “significant issue” and, in fact, ,states at page 7 that “…the implementation of this decision will incorporate the findings and analysis of four ongoing studies, including mountain goat habitat modeling, brown bean den modeling, wolverine distribution and movement patterns…”.
It does not appear from the reviews and evaluations performed by the Forest Service that CPG has supplied any significant wildlife observations which would fill the gap in knowledge concerning those three wildlife species.

The Forest Service acknowledges in the ROD that its wildlife knowledge base needs to be improved. AQRC does not believe the Forest Service should grant a ten year permit to CPG until all the information is in hand and the impacts of heli-skiing on this wildlife is analyzed and appropriate modifications made to the existing mitigation measures. While the Forest Service may wish to accommodate the financial interests of this permittee, we believe it has an equal, if not greater, responsibility to the wildlife on its lands which are affected by the activities it authorizes. Until the Forest Service knows the impacts created by this activity and has crafted mitigation measures which protect the affected wildlife to the maximum extent possible, it is irresponsible for the Forest Service to award this ten year permit. Moreover, that decision would ignore the promise made in the ROD that the results of the studies would “inform” the measures taken.

Thank you for this opportunity to comment.

Sincerely yours,

Susan Olsen, for the Alaska Quiet Rights Coalition