April 4, 2014
Superintendent Don Striker
Denali National Park & Preserve
P.O. Box 9
Denali Park, AK 99755-0009
Dear Superintendent Striker:
The Alaska Quiet Rights Coalition (AQRC) is a state-wide nonprofit organization which, like the National Park Service, believes natural sounds and natural quiet are resources of our public lands which deserve protection. We appreciate NPS’s efforts to establish and maintain soundscapes in its parks to protect these resources. AQRC further believes that for recreationists to experience and enjoy these resources it is necessary for land managers to separate motorized and non-motorized users and set aside trails and areas, of sufficient size, for the exclusive use of quiet recreationists. We advocate for our positions through offering written and oral comments on land use plans and issues. In this regard, AQRC commented a number of times on the various planning stages of the park’s Backcountry Management Plan (BMP).
In those comments, among other concerns, AQRC urged NPS to take the opportunity in the BMP to define the extent and/or type of snowmachine use allowed “for traditional activities”. We do not believe that the Congress intended to include recreational snowmachining-which inevitably includes things like high speed riding and the tracking up of entire hillsides, lakes and meadows-as a “traditional activity” and certainly not the type of “traditional activity” contemplated by Section 1110(a) of ANILCA. We felt then, as we do now, that defining the scope of acceptable activity is critical in view of the enormous increase in snowmachine traffic on the lands adjacent to Denali NP & P and the total lack of any state management of snowmachining activity on either public domain lands or specially designated lands like those set apart in Denali State Park. Instead, DNP &P took the position in the Final BMP and in the 2/21/06 Record of Decision that it was not necessary to attempt to define that term for the park additions and preserve because the preferred alternative set “specific standards for resources and social conditions” for each management area. And, action would be taken “if the conditions are not achieved or conditions are deteriorating in part of in whole because of snowmachine use…” Clearly, as the BMP implementation discussion indicated, this requires a monitoring plan.
It is, however, our understanding that a monitoring plan was not developed and that little, if any monitoring, of snowmachine use has taken place despite substantial increases in the amount of traffic since the BMP was adopted. Moreover, in the absence of any definition of “use for traditional activities” NPS by default apparently deems all snowmachine activity to be “use for traditional activities” thus ignoring the qualification set forth in the law. In turn we are certain that NPS’s inaction has now made it virtually impossible to attempt to regulate snowmachining in the additions and preserve when and if necessary.
Please advise if monitoring of snowmachine use has been undertaken. We are particularly interested in knowing whether the impacts of this activity on the soundscape and wildlife have exceeded the standards set forth in the BMP for the applicable management areas and, if so, what actions are contemplated.
Thank you for your consideration of these concerns.
Susan Olsen, Director
Alaska Quiet Rights Coalition