November 11, 2005
Robert Lloyd, Planning Team Leader
Bureau of Land Management
Anchorage Field Office
6881 Abbott Loop Road
Anchorage, AK 99507-2599
Dear Mr. Lloyd:
The purpose of this letter is to offer the comments of the Alaska Quiet Rights Coalition (AQRC) on the Ring of Fire Draft Resource Management Plan and Environmental Impact Statement (Plan). AQRC is a nonprofit, 501(c)(3) organization with more than 600 members and supporters from throughout the state. We believe that natural sounds are a natural resource to be protected, like other resources, by public land managers. We seek Â a fair and balanced allocation of Alaskaâ€™s public lands for both the non-motorized and motorized user. AQRC also seeks to protect Â wildlife and remote cabin owners from the sounds and other impacts of unwanted motorized recreation.
We appreciate the difficulties of attempting to do land use planning in an area the size of Â the Ring of Fire and for lands Â consisting Â of small, discrete and unconnected parcels Â spread throughout the area. AQRCâ€™s focus in reviewing this Plan is on OHVs and Â opportunities for non-motorized recreation. Accordingly, AQRC supports the creation of the Haines Block and Knik River SRMAs and the Neacola ACEC on the grounds that special management units offer the potential for the type of recreational opportunities we seek. We strongly support Â the creation of the ACEC, since it , unlike the two SRMAs, is unencumbered BLM land and therefore, if designated, would guarantee continued Â opportunity for primitive recreation. While both Alternative C, the conservation alternative, and Alternative D, the preferred alternative, designate all lands as â€œlimitedâ€ to OHVs and create the three special management units, we support Alternative C,for providing greater non-motorized recreational opportunities since it at least allows for the possibility of Wild and Scenic River designation.
However, we find no reference to providing opportunities for Â non-motorized activity in the entire Plan. (In fact, we found only one mention of the term, on page 4-112.) In particular, we are very disappointed that the Knik River SRMA contains no reference to, Â or plans for, non-motorized recreation despite the Â fact that the area is currently used Â by both motorized and non-motorized recreationists. Â We are certain that BLM is aware that people who have historically used this area for non-motorized recreation now feel pushed out by the unregulated motorized activity, Â vandalism, Â shooting, etc. AQRC believes BLM has the responsibility to provide recreational Â opportunities for all users of its lands. In view of Â the current â€œmessâ€ and the total lack of Â management, which characterizes this area, we recognize that BLM will encounter great difficulties once it attempts any management or Â enforcement. AQRC is aware that future implementation planning must be undertaken to sort out what the â€œlimitedâ€ designation means to OHV activity. However, Â â€œtamingâ€ OHV activity alone, such as a requirement Â to remain on designated trails or roads, will not automatically create opportunities for non-motorized recreationists. For example, in AQRCâ€™s experience, It is rare that designating trails to be mulituse provides the type of recreational opportunity the non-motorized user Â seeks. We request, therefore, that the Preferred Alternative in the Final Plan affirmatively state that one goal of the Knik River SRMA is to provide opportunities for non-motorized users. It well may be that a corridor along the river could be created and designated open to all type of Â motorized activity without harming the resource, but we would expect many of the upland areas would be damaged by such activity and should be managed for non-motorized activity.
Further, AQRC is concerned that should pending state legislation to create a Knik River Public Use Area be enacted, BLM will conform its management to it. We consider the legislation as written to be extreme, creating a â€œsacrifice zoneâ€ for motorized activities. Â We do not believe BLMâ€™s responsibility to manage its public lands, in a fair and balanced manner, should be determined by such extreme schemes. But if, in fact, Â BLM intends to create, and manage, the Knik River SRMA strictly for motorized activity, AQRC objects, strongly, to both Alternatives C and D.
Finally,AQRC Â believes tying the designation of â€œlimitedâ€ to the stateâ€™s policy set forth in â€œGenerally Allowed Usesâ€ in the proposed special management areas is misguided. The policy contains a huge loophole by allowing the phrase â€œwhenever possibleâ€ to modify the requirement that OHVs must remain on existing roads and trails. This loophole precludes any and all enforcement since it is the user who interprets when it is possible, or not, to stay on the road or trail. Â We are not aware of a single instant where general state lands have Â been protected by user observance of this policy and we doubt the state can provide any examples. The purpose of creating special management units such as SRMAs and ACECs is to provide the opportunity to impose different management practices than those generally applied to BLM lands. (The stateâ€™s Â policy itself indicates that it is to be applied only for general state Â lands which lack any special management designations.) AQRC believes adoption of the stateâ€™s policy unnecessarily ties BLMâ€™s enforcement actions during the period of time between the ROD, approving the Plan, and the completion of the implementation planning in the special management areas. This could be a long period of time since the Plan states that Â the priority for implementation planning will be the unencumbered lands in the ACEC. During this time, for example, what enforcement action can BLM take on its 80,000 acres in the Knik River SRMA under the stateâ€™s policy ? AQRC recommends that BLM designates its lands within the proposed special management units as â€œlimitedâ€ without reference to the stateâ€™s policy. In that way, BLM would have much more flexibility in managing OHV activity in the interim. For example, it could post its lands and require OHVs to stay on roads and trails, without exception.
We Â note that the Plan does make special provisions for snowmachining (e.g., see page 3-165). In accordance Â with the â€œConditions for Generally Allowed Usesâ€, which modifies the more general statement of policy contained in â€œTravel Across State Landâ€, Â snowmachines under this Plan must stay on trails and roads whenever possible. AQRC doubts Â the snowmachine community agrees with this stance or that this is BLMâ€™s intent.
Thank you for Â this opportunity to comment.
Trisha Herminghaus, President
Alaska Quiet Rights Coalitio