September 19, 2011
Monica Alvarez, Project Manager
Chugach State Park Planning
550 West 7th Avenue, Suite 1050
Anchorage, AK 99501-3579
Dear Ms. Alvarez:
The purpose of this letter is to offer the comments of the Alaska Quiet Rights Coalition (AQRC) on the Public Review Draft of the Chugach State Park Management Plan (Plan). Many of our members and supporters are frequent users of Chugach State Park and value its sense of wildness, presence of wildlife and the fact that it is largely non-motorized. As you may recall, AQRC has submitted comments on each phase of this planning effort:Â May 28, 2008 on scoping; May 28, 2008 on draft goals and objectives; October 13, 2009 on the draft Trail Management Plan and April 30, 2010 on the draft Access Plan. We have recently review the issue response summary released for the Trail Management Plan. Unfortunately, we find that many of our earlier critical comments need to be repeated in the review of this Plan.
As a statewide, nonprofit organization, AQRC is dedicated to protecting the rights of Alaskans to quiet places for the benefit of public land users, home and cabin owners, communities, businesses, wildlife, visitors and future generations. We believe natural quiet and natural sounds are resources of Chugach State Park which are to be treasured and preserved like other resources of our public lands such as clean water, scenic beauty and clean water. We find that in most cases multi-use trails do not work for the non-motorized user and we advocate for separate trails and areas to be reserved for the non-motorized recreationist. We seek to work with public land managers to insure that they provide a fair and balanced allocation of recreational opportunities for the non-motorized as well as the motorized recreationists.
As an overall matter we appreciate the fact that this proposed Plan does not revise in any significant manner the original designation of areas open or closed to snowmachines or ORVs. We also appreciate the discussion concerning the experience the non-motorized user of the park expects. Too often land use plans ignore or fail to recognize the importance of the non-motorized userâ€™s experience and, consequently, continue to promote unworkable multiuse trails or areas.
However, we are very critical concerning four fundamental aspects of this Plan: (a) we do not think that the Park Goals and Objectives adequately reflect the statutory purposes for which the park was formed, they are internally inconsistent and fail, we believe, to adequatelyÂ acknowledge that protection of the resourceÂ is a paramount responsibility (it is implicit that a â€œspecial purpose siteâ€ under the state Constitution be managed and maintained for future generations); (b) the Plan totally lacks any data and analysis of that data so that it is not possible to determine whether this trail, this proposed facility or this policy will meet the need expressed; (c) priorities are not identified in any meaningful way and (d) Chapter 5 Guidelines appear to weaken the protections to be afforded Wilderness.
A) Goals and Objectives:
Recreation Goal: providing â€œ …opportunities and …facilities to keep pace with the needs and diversity of Alaskans and visitorsâ€ implies that any kind and any amount of activity is apparently acceptable without acknowledging that the parkâ€™s natural resouces are impacted by human use and that adverse impacts must be managed, controlled or prohibited by policies and management practice.Â There is no mention of enforcement in this Plan or of putting in place systems to measure impacts, carrying capacity or limits of acceptable change. As stated, the goal contradicts the second line in the Chapterâ€™s introduction â€œ…to provide for a spectrum…while protecting park resources.â€ We find the first Objective-to provide for an equitable distribution of facilities and opportunities for â€œall capabilitiesâ€- to be overlay broad since it is not possible to provide an equitable distribution for â€œall capabilitiesâ€. In regard to the second Objective we question whether it is the role of a state park to promote â€œcommunity healthâ€; is this not more appropriate for a municipal facility?
Resource Goal: â€œProtect park resources to allow for diverse visitor experiences…â€ We believe that park resources need to be protected for their own sake, so that theÂ future user of the park can experience it in much the same way as the current user; so that the area set aside for a park still exists to offer a park experience. The second Objective reflects one of the statutory mandates for creating the park; it needs to stand by itself and does not fit under the goal as stated forâ€to… protect and provide a satisfactory water supplyâ€ is not part of a visitorâ€™s experience or understanding. The third Objectiveâ€…encourage opportunities for wildlife viewing…â€ fails to meet the mandate of the enabling legislation which requires park managers â€œ…to provide areas for the public display of local wildlife…â€ In recalling the recent wolverine debacle we would also argue that this statutory language is equal to any statutory language which directs ADF & G and urge DPOR to insist that wildlife in CSP be managed for park purposes. The fourth Objective appears to be the only reference to the wilderness aspect of this park as stated in the enabling legislation. We object to the wording on the grounds that substituting the word â€œMinimizeâ€ for â€œprotectâ€ significantly understates the statutory mandate â€… to protect the existing wilderness characteristics…â€
Access Goal: We find the goal â€œ:..for the benefit of all Alaskans and visitorsâ€ to be overly broad which the second Objective appears to acknowledge with its reference to â€œbalanceâ€. It well may be that certain access points will need to be shut down when over-capacity. However, in the absence of any discussion or analysis of visitation figures, or what would constitute being out of balance- such as an amount of resource damage or adverse visitor experience or other measures-we fail to see how this objective can be met.
B) Lack of data and analysis: We find it ironic that The Management and Staffing Efficiencies section indicates on page 74 that â€œAccurate assessment of park visitation patterns and recreational use…is necessary to accurately project future demand, and match commensurate facilities and services…â€ Our first question is why this data was not gathered during the planning period ? How can this plan guide management decisions for twenty years when DPOR lacks the basic data to inform managers as to how people, in what numbers, use the park today and the visitor trends for future years. Secondly, on what basis were the Trails Management and Access Plans constructed if the planning staff did not have access to accurate visitation data or surveys of how people recreated or wanted to
recreate ? How could the planning staff propose that a certain new trail be constructed or that it would meet a need or that improving a certain access point would help disburse need from overcrowded access points ? Â Similarly, we question why this plan does not include the â€œstaffing analysisâ€ suggested on page 72. DOPR staff knows full well, as indicated in the wording used in the Staffing Needs, Management Objectives and Justification columns on page 73, that the positions listed will be difficult to establish. If easy, the park would already have an adequate number of rangers, etc. Using â€œseveralâ€ to identify needed ranger staffing demonstrates why this information should have been gathered during the planning period.
C) Lack of specific priorities: Chapter 7: Implementation loosely identifies priorities:Â access (with the Glen Alps Trailhead listed as a â€œmajor implementation priorityâ€); maintenace of the existing trail network and â€œproviding additional recreational opportunitiesâ€.No cost estimates are included. Virtually the only hard figure cited in the entire Plan is that DPORâ€™s deferred maintenance for park facilities amounts to $60,000,000 with CSP having the largest amount, of approximately $7,000,000.Â Why is deferred maintenance not identified as a priority in this Plan, ahead of construction of new trails or facilities ? We recommend that this be adopted. While this Chapter makes the case that specific phased project steps are more appropriately dealt with in the site planning phase than in a broad management plan, we note that the discussion of future site planning does not indicate when, or if, the public will be involved. For example, the redesign of the Upper Huffman Trailhead did not include an opportunity forÂ public to comment; it is critical that the proposed road project up to Glen Alps have a robust public comment period.
D) Specific comments on Chapter 5 Guidelines
Table 5.1: Resource Management:
Timber Sales: We object to allowing â€œTimber Salesâ€ in the Wilderness area as such would involve motorized means to get the timber out in order for commercial interests to be involved.
Table 5.2 Public Uses:
Snowmobiles: We object to the broad, and vague, authorization which would allow snowmobiles in the Wilderness if use was in support of â€œother permitted activitiesâ€. For example, doesnâ€™t mean that snowmachiners engaged in trapping or hunting could go into the Wilderness on their machines ?
Bicycles: change 11 AAC 20.040 to 20.050;Â we object to bicycles being allowed into the wilderness area, regardless of whether or not resource impacts would occur, because it would be introducing a mechanical device into an area where man is expected to be on foot. Since there are few, if any, hardened paths and roads in the wilderness area, any use of bicycles in wet weather will cause resource damage which DOPR would be unaware of since the rangers lack the capacity to patrol the Wilderness area.
Motorized Equipment: change wording under Wilderness to â€œCompatible if managed by DPORâ€.
Dog Sledding: we do not agree that dog sledding is compatible in the Recreation Development area because of safety issues and conflicts resulting from a dog sled team moving on the same trails and in the same area as the many human recreationists.
Table 5.3: Other Uses:
Outdoor and/or Military Training, Drills or Exercises: we believe such activities are not compatible in Wilderness at any time when the legislative directive is to â€œprotect the existing wilderness characteristicsâ€.
Organized Events: We do not believe that organized events belong in the Wilderness area and moreover, in the absence of a state statutory or regulatory definition of â€œwildernessâ€, we question how DPOR can judge whether a proposed event is â€œconsistent with the values of the area.â€
Table 5.4 Facilities:
Improved Campsites: We do not believe the improved campsite facilities belong in the Wilderness area for they would undercut the values of the Wlderness area, such as primitive recreational opportunities, as set forth in the Purpose & Characteristics section of Chapter 5;
Public Use Cabins, Yurts, and Shelters: for the same reason as cited above, we object to allowing such facilities to be build in the Wilderness area;
Trails: We object to considering trails of any nature to be allowed in the Wilderness area since one of the chief values of the Wilderness area is the notion that one is alone and must rely on oneâ€™s own abilities in the face of physical and mental challenges. Having a trail to follow takes away the need to rely on oneâ€™s own abilities.
We also wish to urge park planners to use caution in planning the location for an RV campground in Bird Valley (ID 103, Chapter 6: Turnagain Arm Planning Unit) to insure that the location would not encourage or permit motorized uses in the Wilderness area.
Table 5.5: Commercial Uses:
Resource Extraction by State Parks: We fail to see how resource extraction could be conducted without the introduction of motorized transportation in the Wilderness area and therefore object to this provision.
E) Our final comments express AQRCâ€™s opposition to the construction of the proposed road from the Upper Huffman Trailhead to the Glen Alps Trailhead as outlined in Chapter 6: Hillside Planning Unit. The concept plan shows construction of a 2 1/2 mile road with six satellite parking lots which would accommodate approximately 260 parking spaces. The road would be plowed in the winter and, once completed, would be the only vehicular access to the Glen Alps Trailhead. What is proposed is a far cry from the original proposal in the 1980 Master Plan. That called for a 1/2 mile road to be constructed from the Upper Huffman Trailhead out to the existing road (which was the Gas Line maintenance road). The current proposal makes no use of the existing Gas Line trail, but instead would lay bare a 2 1/2 mile by 100 foot (minimal) swath, bring major construction activity into CSP and scatter the wildlife.
The noise, dust, erosion, disruption and visual impactÂ (for one, two or three ? construction seasons) created by this industrial-type activity in a wilderness-type setting would drive out the current users as well as the wildlife. The effect of the noise and sight of the traffic on the completed road-think how far noise travels in winter-will continue to adversely affect the local trail user and, in essence, destroy this section of the local and the formal trails in CSP. Using these trails would be like recreating in an urban setting, next to a highway.
We understand that the underlying purpose for this proposal is to â€œfixâ€ the parking problem at Glen Alps when in summer the parking lot fills up and later visitors have nowhere to park. However, all this proposal really does is to move the parking problem from one side of the Glen Alps Trailhead to the other side. It will not necessarily disburse use. Wonâ€™t the same number ofÂ people still want to climb Flattop, view the city from the observation platform or be in an â€œalpineâ€ area ?Â The underlying premise seems to be that folks, once they have parked in one of the six lots, will simply get out of their cars and either walk up to the Glen Alps Trailhead or choose to explore one of the adjacent Hillside trails without having to go through the Glen Alps Trailhead. How will this meet the need of the somewhat infirm visitor who just wants the unobstructed view from the overlook ? Or maybe the hope is that many folks will just be satisfied with the view from the Upper Huffman Trailhead or use those trails so fewer cars would try to go further
As previously discussed, this Plan contains no statistics, surveys or analysis. Accordingly, DPOR has no way to know, or even guess, whether this proposal will â€œfixâ€ the current parking problem. In view of all the adverse affects this construction would cause to the park, current users of the area, wildlife and the total uncertainty that this proposal will even come close to solving this particular parking issue, AQRC is unequivocally opposed to this proposal.
We believe there are far-less disruptive alternatives that DPOR should consider before authorizing this major construction project within a state park: a (different, cheaper) shuttle service during the summer or work with the heir of the Indian allotment to acquire lands adjacent to the park for additional parking.
Thank you for this opportunity to comment.
Susan Olsen, President
Alaska Quiet Rights Coalition
P.O. Box 202592
Anchorage, AK 99520