Revised Draft Backcountry Management Plan for Denali National Park and Preserve

July 13, 2005
Paul Anderson, Superintendent
Denali National Park and Preserve
P.O. Box 9
Denali Park, AK 99755

Dear Mr. Anderson:

The purpose of this letter from the Alaska Quiet Rights Coalition  (AQRC) is to submit comments on the Revised Draft Backcountry Management Plan for Denali National Park and Preserve (Plan).

The Alaska Quiet Rights Coalition is a statewide, nonprofit organization which, like the National Park Service, regards the natural soundscape as a natural resource to be protected, like other resources, by the managers of public lands.  Our advocacy for natural quiet in the backcountry is not just to eliminate sounds of motors, but to create opportunity for the quiet recreationist to experience the intangible values, such as peace, solitude and self sufficiency, that a natural soundscape affords. On lands managed by agencies with a multiuse mandate, AQRC calls for for a fair balance of recreational opportunities for the motorized and nonmotorized recreationist, both summer and winter.   We advocate for both road-accessible and backcountry opportunities for the quiet recreationist.  AQRC is also concerned with the rights of cabin owners to have peace and quiet and for wildlife to be free from the noise of recreational machines in the backcountry.

AQRC applauds the efforts made in this Plan to articulate, in a straightforward manner, the unique wilderness and resource values of this Park and NPS’s legal obligations under the Organic and Wilderness Acts and ANILCA to honor, protect and preserve such values. These values are both tangible, such as natural sounds, and intangible, such as wilderness values like solitude. The governing laws set a very high management standard: to manage parks so that the scenery, natural and historic objects and wildlife are left unimpaired for the enjoyment of future generations (Organic Act); or if Wilderness, the Act speaks of land which has outstanding opportunities for solitude or a primitive and unconfined type of recreation. The specific mandate of Section 203(a) of ANILCA requires management  “to provide continued opportunities, including reasonable access, for wilderness recreational activities”.   (For the record, we note that though state government apparently fails to believe that NPS has the authority or obligation to protect intangible values, the Constitution of the State of Alaska recognizes that intangible values do in fact exist and are to be preserved and protected, as established by Section VIII which authorizes the legislature to acquire “areas of natural beauty”.   AQRC also appreciates the emphasis this Plan places on the discussion and analysis of the natural soundscape as one of the Park resources to be protected.

We fully support a number of the premises and constraints adopted in the Plan.  For example, we believe that this Plan successfully makes the case that the land contained in the Park and Preserve, for historical and legal reasons, is different from, and is to be managed differently than, the surrounding public lands where such values are not necessarily protected.  We further note that about 3.7 million acres of the park additions and preserve have been deemed suitable, and of that amount, 2.25 million acres have been proposed to be recommended, for formal wilderness designation. Under NPS policy such lands are required to be managed in a manner which will not diminish their wilderness character or jeopardize their eligibility for formal designation. AQRC also finds very useful for our analysis, the framework for examining recreational opportunities in a wilderness park, set forth at pages 384-5, which categorizes recreational activities based on the degree to which the activities are “wilderness dependent”.  The Plan concludes that under this framework “Recreational activities that depend on wilderness conditions, such as experiencing solitude and isolation, observing natural ecological processes, or  challenging oneself with wilderness travel” are most consistent with Denali’s statutory guidance. It further concludes that snowmachine racing and highmarking fall into a different category, which is for activities which occur outdoors but do not need wilderness conditions.

The issue to be discussed in these comments is whether AQRC, after review of the Plan, finds that, the Preferred, or any other, alternative, provides a management framework which in the future will restore and maintain Denali National Park and Preserve as a wilderness park.   AQRC does not believe that the Preferred Alternative provides management which satisfies both the legal and policy requirements of a wilderness park. In our opinion, the Preferred Alternative inappropriately attempts to accommodate activities which compromise the very wilderness values for which the Park was created and is required to be managed. For example, 11% of the lands are to be classified as Management Area A whose purpose is to “provide a diversity of opportunities for wilderness recreational activities that are relatively accessible to day users and to those who have limited wilderness travel skills or equipment”.   Is this the type of activity envisioned when Section 203(a) of ANILCA added the four million acres or appropriate in possible Wilderness or is this the type of activity which should be limited to the Front country areas?  In Management Area A, natural sounds can be “requently disturbed” by motorized noise up to 25% of any hour and there may be up to 25 motorized noise intrusions per day that exceed natural ambient sound. The Preferred Alternative would permit snowmachining for “traditional activities”, but the failure to define the term means snowmachining could occur anyplace at any time throughout the 4 million acres in the park additions and preserve. Indeed, 64% of the park additions and preserve would be open to snowmachining (p.274).  Which since the Old Park is closed, means that 64% of the park additions and preserve would be open to snowmachining.  Moreover, in the event that Congress designated additional wilderness, the Preferred states that NPS would seek an exception (to the prohibition of any motors in Wilderness) to continue to permit recreational snowmachining in the designated Corridors.

AQRC supports the People for Parks Alternative which we believe provides the most protection of the wilderness and resource values of the Park.  We strongly support extending the existing definition for traditional activities currently in use for the Old Park to the 1980 Park Additions and Preserve. Section 1110(a) of ANILCA requires no more than to allow snowmachining for “traditional activities” and that activity is then further subject to reasonable regulations.  As set forth in the analytic framework to determine wilderness dependent recreational activities, recreational snowmachining does not fall into the third category which the Plan indicates are the type of activities most consistent with Denali’s statutory guidance.  We contend that recreational snowmachining is, in fact, in conflict with wilderness values. The purpose of the “snowmachine corridors” set forth in alternatives 3, 4 and 5, is not to control or necessarily channel snowmachine traffic, but to inform snowmachiners and others using the corridors, or adjacent lands, of what to expect in terms of possible noise and presence of other parties. We see no way to preserve the wilderness values and resources of the Park, particularly its natural soundscape, except to prohibit recreational snowmachining in all areas of the Park. That traffic can be accommodated on the surrounding public lands which were not established with the same requirements to preserve wilderness values.

We strongly support the formation of an “Aircraft Overflights Working Group” and strongly recommend that group include representation of people, such as cabin owners, who are directly impacted by the noise of air tourism, though located outside of the Park boundaries. It has never been apparent to AQRC why those who built a cabin in the backcountry for the very purpose of experiencing living in the backcountry, have to sacrifice their experience for that of the momentary experience, which is all facilitated by a public agency, of the flightseeing tourist. It well may be that voluntary measures will not work to preserve the Park values adversely affected by relentless overflights and in that case we recommend NPS seek legislation which would permit some limitations of overflights in order to protect the unique wilderness values of Denali.  In turn, any limitations would help restore the opportunities for experiencing natural sounds by cabin owners now directly impacted by overhead flightseeing routes.

Whichever alternative is adopted, AQRC is very concerned about the ability of NPS to actually manage this Plan.  A Plan based on desired future conditions requires clear, quantifiable standards and conditions, a monitoring plan with specific timelines and an extensive monitoring and enforcement capability. Unless this can be guaranteed, this Plan should not be approved.  The Final needs to address this concern explicitly and what NPS will do in the absence of adequate additional funding and staffing. There is no way to tell from the budget on page 520 whether the figures are adequate to support the additional monitoring staff and resources required since a cost analysis is not set forth.  As a small, but essential, step, we suggest that the language in whatever alternative is selected be strengthened wherever possible by changing “shall” from “may” or “could”, etc.,  in order to both inform the public as well as NPS staff as to the standard.   We recommend, and strongly urge, that NPS set up a citizen’s monitoring advisory committee to help develop a specific annual monitoring plan and priorities, provide oversight to the monitoring efforts and results and help gain public support for NPS’s management efforts in Denali.

AQRC appreciates the emphasis this Plan places on the value of natural sound as an inherent natural resource of a national park- “they (natural sounds) are inherent components of the scenery and the natural and historic objects and wild life protected by the Organic Act”.  The Plan further points out that due to the wilderness character of the Denali backcountry areas, human generated sounds which intrude on the natural soundscape, such as planes or snowmachines, are to be characterized as noise under NPS policy. We believe, however, that the standard set for “minimally acceptable resource conditions” for natural sound disturbance permits too much disturbance, reaches the level of impairment and fails to meet NPS’s soundscape policy.  For example, in Management Area A, the desired future condition is the standard of  “High” which permits motorized noises to be audible up to 25% of any hour and up to 25 motorized noise intrusions (over natural ambient sounds) per day.  The Plan does not consider this level of noise to be excessive;  we disagree. We do not believe this amount of noise should be allowed in a wilderness park and recommend a standard of lower impacts throughout most of the management areas.  While the Plan makes clear that most of the noise is caused by planes and thus out of NPS’s jurisdiction to manage, NPS does have the option of prohibiting recreational snowmachining and limiting flightseeing landing (as advocated in the People’s Alternative) in order to protect and restore the natural soundscape to the backcountry of this wilderness park. AQRC further takes issue with the Plan’s conclusion on page 282 that “Natural sound disturbances do not represent permanent changes in park resources; however if plan actions allow indefinitely recurring seasonal disturbances the affects would be considered long term”.  This statement appears to address the sounds of a natural soundscape that are momentarily “masked” by the sounds of a machine, such as a plane, but why could not that noisy interval qualify as a permanent change?  At what point does a long term impact become permanent? Does permanent mean forever or simply lasting beyond the life of the plan?  Must an impact be permanent before it is considered to be an impairment?  Is it not an impairment of the natural soundscape if for most of the life of the plan the natural sounds in X place no longer include certain animal or bird sounds due to displacement by recreational motors? The conclusion appears to say that if the soundscape at some point during the life of the plan can be restored, there can be no impairment. Under that “moving” standard, you could permit unlimited motorized recreational traffic in the Park additions and Preserve for years without finding impairment of the resource or having to take action since in the last year of the plan, you could prohibit snowmachining and restore the natural soundscape.  We believe the Plan needs clearer standards throughout.

In summary, Denali National Park and Preserve is a backcountry wilderness park, mandated to be managed differently from surrounding state and federal public lands and obligated by law and NPS policy to protect the Park’s tangible natural resources as well as its intangible values.  To manage this park NPS must adopt strict and clear standards and indicators to accurately measure the impact of activities on the resources to be protected and then have the capacity and commitment to monitor the standards in such a way that NPS can and will have the political will to, through adaptive management, change direction in order to protect impacted Park resources.  As written, however, this Plan erodes the very values it purports to protect by attempting to accommodate activities, such as recreational snowmachining, which have no place in a wilderness park.

Thank you for this opportunity to comment.

Sincerely yours,
Trisha Herminghaus, President
Alaska Quiet Rights Coalition
PO Box 202582
Anchorage, AK 99520