September 29, 2016
Dear Mr. Joyner,
The following are the comments of the Alaska Quiet Rights Coalition on DNR’s proposed regulatory package for the Knik River Public Use Area. We have attached the comments we submitted in September of 2015 so that we won’t need to repeat the background material we provided earlier that supports our recommendations.
Founded in 1996, AQRC’s mission is to maintain and restore natural sounds and natural quiet in Alaska through advocacy and education for the benefit of people and wildlife; protecting wildlife, of course, requires protecting it not only from disturbing mechanical noise but also from the more obvious habitat damage done by poorly regulated ATVs, snowmachines, airboats, etc. More particularly, we’re dedicated to protecting the rights of Alaskans to quiet places for the benefit of public land users, home and cabin owners, communities, businesses, visitors, future generations, and wildlife. We believe that natural sounds and natural quiet should receive the same consideration given to other ecological values, such as clean air and water, fish, wildlife, soils, vegetation, scenic beauty, and wilderness character. 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 just 10 or 20 years ago.
In addition to protecting ecological values like the ones listed above, one of AQRC’s specific goals is a fair and equitable overall balance on the public lands between those managed for motorized recreation, and those managed for quiet, truly traditional forms of recreation like hiking, canoeing, kayaking, snowshoeing, and cross country skiing.
We were happy to see in the Dear Alaskans letter that DNR recognizes that “certain activities currently being conducted within the KRPUA are creating negative impacts on public lands and waters, and in many cases creating a negative or unsafe environment for other users of the area.” We’re also pleased that in light of this DNR’s intent is “to reduce adverse impacts and to provide a higher level of protection for the area’s natural resources.”
It would be unfair to say that the proposed regulations don’t go at least a ways towards reaching this goal. A major focus is the shooting range, and certainly fees are entirely appropriate, and stricter management is clearly needed. The Rippy Trail will be better off with the proposed maximum weight limit for motorized vehicles (although we recommend that this trail be closed to motorized vehicles altogether), as will the Jim Lake Overlook Trail, where motorized vehicles would be prohibited. Finally, some protection for fish and wildlife habitat and populations (especially waterfowl) should be expected to result from the seasonal prohibition of motors on Manmade Lake and the seasonal horsepower limitation on Jim Lake. We appreciate and support these proposals.
Unfortunately, a great deal more is needed, as we said in our earlier comments, if DNR is going to be a truly responsible steward of these exceptionally rich lands and waters. These proposals don’t go nearly far enough. In spite of the proposed protections, DNR’s focus for the area seems to continue to be accommodating motorized recreation, an activity which brings with it the very significant impacts and conflicts that a number of individuals and groups have previously brought to the agency’s attention.
We still feel very strongly that the following recommendations should be adopted if DNR is truly serious about protecting the Jim-Swan wetlands area (again, please see our earlier comments):
1. All motorized uses in and adjacent to the Jim-Swan wetlands should be prohibited from early April to late October to protect highly important populations of Trumpeter Swans and other waterfowl.
2. ORVs should be allowed on only a limited number of designated trails, and only at times when impacts on both fish, wildlife and habitat will not be significant. Furthermore, although creating new trails is already illegal, it remains a serious and recurring problem. For example, ORVs continue to leave the Rippy Trail, degrading important habitats. The only truly practical solution to this problem, which we strongly recommend, is to prohibit ORV use altogether on this trail.
3. The six inch rule should be repealed. Condoning damage of this magnitude should be unthinkable, and an embarrassment to DNR.
4. ORVs used in the KRPUA should be registered, and should have a large, legible decal prominently displayed.
5. Additional enforcement capacity should be provided for the PUA.
6. Shooting range hours should be reduced. The range should be closed for at least two full consecutive days each week to allow people to enjoy an overnight outing free of at least this significant source of noise.
7. Non-motorized recreational opportunities should be enhanced. One of our board members noted, and we all agreed, that the noisy, degraded KRPUA was far less enjoyable than, for example, the quiet, less impacted Reflections Lake Trail and surroundings. DNR should try to make at least some sizeable portion of the KRPUA as pleasant an experience as Reflections Lake, thereby accommodating the many residents and visitors who are seeking peace and quiet, not noise and degradation, in a natural area.
Thank you for the chance to offer these comments. The Jim-Swan wetlands area deserves a very high level of protection. This level of protection is currently lacking and, unfortunately, will still be lacking even if DNR’s proposed regulations, though they offer some improvement, are enacted. Significantly stronger regulations are needed, as outlined above.
Alaska Quiet Rights Coalition