Comment Letter: Denali Winter and Shoulder Season Plan

November 28, 2018

From: Alaska Quiet Rights Coalition

P.O. Box 202592

Anchorage, AK 99520

Superintendent, Denali National Park
ATTN: Winter planning
PO Box 9
Denali Park AK 99755

Ref: DNP&P Winter and Shoulder Season Plan

Dear DNP&P Planning Team;

Thank you for the chance to comment on the DNP&P Winter and Shoulder Season Plan.

The Alaska Quiet Rights Coalition (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.

AQRC recognizes and appreciates the fact that NPS is one of the few agencies that is monitoring the soundscape and makes the natural soundscape an important resource to protect.

Alaska’s natural beauty, wildness, wildlife, expanses of undisturbed open space, and peace and quiet are among its most cherished values, and Alaskans, our visitors, and future generations have the right to experience the natural sights, sounds and quiet beauty of our state.  In the vast majority of cases, the obtrusive noise, summer landscape degradation and winter snowscape defacement, exhaust, and dangers of motorized recreation are incompatible with those special natural experiences. 

Unfortunately, though, natural quiet and the opportunity to hear and enjoy natural sounds are increasingly hard to find in our state—a fact which would surprise the great majority of non-residents for whom Alaska is a potent symbol of the natural and the wild, not of noisy mechanization.  Although there are many places in Alaska that look the same as they did 100 or more years ago, very few sound as they did only 10 or 20 years earlier.  

Consequently, not only do we need to protect those quiet areas that still remain, but we need to restore many previously quiet lands to their former, more natural, more pristine condition.  Most of us, until quite recently, took the restorative quiet of the outdoors for granted.  We assumed that the backcountry would always provide a quiet refuge from the noise, busyness and artificiality of our towns and cities.  That assumption, to our great chagrin, has proven to be false.  We now know that natural quiet and natural sounds require our—the public, and the public’s stewards, the land managers—constant vigilance if they’re to survive even into the middle of our present century. 

Natural quiet and natural sounds should be recognized by all public land managers as critical resources in and of themselves that deserve no less consideration than clean air and water or fish and wildlife and their habitat.  Soundscape plans should be prepared.  The analysis of proposed agency actions should include a determination of the possible effects on natural quiet and natural sounds and on the humans and wildlife that enjoy or depend on them.  Alternatives should be considered.  

Ironically, accessible natural quiet can be easier to find in the lower 48, in the many designated Wildernesses where motorized recreation is prohibited, than in supposedly wild Alaska, where many federal land managers erroneously believe that ANILCA requires them to allow obtrusive recreational activities, for example, snowmachining, even in designated Wilderness.  Recreational snowmachining, inaccurately characterized as “traditional,” is allowed in spite of its numerous adverse impacts and the conflicts it so often creates with truly traditional, low impact means of access like walking, snowshoeing and cross country skiing.  We can and should do better.

DNP&P has done an admirable job of protecting the core wilderness zone from motorized recreation in the winter months by not allowing recreational snowmachining.  I know this from personal experience.  I skied from park headquarters to the Muldrow Glacier in 1974 and continued to do long ski trips in DNP&P, north of the Alaska Range, until 2006.  Each winter trip offered the same wilderness qualities of snow untracked by motorized use and a soundscape unaltered by motorized noise.  In 1974 this was the norm for much of Alaska, but that has changed.  I also began doing winter ski trips along the south side of the Alaska Range in the mid 1970’s and experienced wilderness.  In 1980 the places I visited were included in DNP&P.  The management policies in the 1980 additions to DNP&P are far different and the winter wilderness character has been degraded .   No longer can one expect there to be quiet or pristine snow in additions to the park. Motorized recreational snowmachine use has totally changed the character of the area.  Snowmachines were to be allowed for traditional activities like transportation to ones cabin, trapping, obtaining firewood, etc.  Free–for-all recreational snowmachine riding like is taking place in additions to the park are not a traditional activity.  It is very disappointing that this winter planning process will not address the area between Cantwell and the Kahiltna Glacier.  It is particularly disturbing that despite the fact that this area has been part of DNP&P for 38 years that there is “no current visitor use data”.  This is something that should be addressed immediately.  NPS needs to know what activities are taking place, how many people are participating in activities in this region of the park and how the activities are affecting the soundscape, non motorized recreation and wintering and spring wildlife.  At what point will there be a winter planning process for the Yentna River region of DNP&P?

In the Stampede Trail corridor and additions north of the “old park” wilderness area snowmachine use should be restricted to established trail routes.  There are several advantages to having snowmachines using trails and not free riding everywhere, especially when snowmachines travel at moderate speeds.  Snowmachine trails provide excellent opportunities for dog mushing, skijoring and skiing.  Trails can be safe for multiple uses when snowmachines do not travel at high speeds.  Slow to moderate speeds without quick acceleration of snowmachines are also far quieter and therefore do not disturb wildlife or other users as much.  When snowmachines stay on trails wildlife has places to go to get away from motorized activity and other park recreational users can also choose to leave the trail and explore regions where they will not encounter snowmachine tracks or noise.

AQRC’s focus has been on motorized recreation, not subsistence.  And ANILCA, rightfully so, has more liberal policies for the use of motorized vehicles for necessary subsistence than for non-essential recreation.  Subsistence use of motorized vehicles should, nevertheless, be subject, where appropriate, to reasonable regulations (as provided for in ANILCA).

Wilderness is a resource that is being eliminated or is threatened around the world.  DNP&P should do all it can to protect and preserver the wilderness it manages for wildlife habitat and generations of people to come that will want to experience wilderness.  As this winter planning process moves forward make decisions based on how best to maintain the winter wilderness of DNP&P.


Brian Okonek, president

Alaska Quiet Rights Coalition