March 14, 2013
Bureau of Land Management
Alaska State Office
222 West Seventh Ave., # 13
Anchorage, AK 99513
Re: Ring of Fire, Draft Resource Management Plan Amendment, Haines Block
The following are the comments of the Alaska Quiet Rights Coalition (AQRC) on the above document. In addition, we support the detailed comments submitted by Lynn Canal Conservation, which we are briefly supplementing in this letter.
Founded in 1996, AQRCâ€™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. More particularly, weâ€™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, and scenic beauty. 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.
One of our specific goals is a fair and equitable overall balance on the public lands of those managed for motorized recreation, and those managed for quiet, truly traditional recreation like hiking, canoeing, cross country skiing and snowshoeing.
At the present time on BLM lands in Alaska, there is a very sizeable imbalance between lands managed for motorized, and lands managed for non-motorized, recreation. Lands managed for quiet sports are only a small fraction of the lands managed for motorized sports. Because of the inevitable conflicts between the two types of recreation, the result is the displacement of quiet users from vast areas of BLM lands, in spite of misleading terms like â€œsharedâ€ or â€œmulti-useâ€ lands. Consequently, quiet recreationists seeking a high quality–as opposed to a highly frustrating–experience are unfairly restricted to the very small portion of BLM lands that are managed for non-motorized sports. And since the situation is even worse on the state public domain, BLM should provide opportunities for quiet recreation that are effectively unavailable on general state land. This argument for quiet alternatives gains additional strength when the large number of helicopter landings on Forest Service land is also considered; thereâ€™s certainly no shortage of opportunities for helicopter recreation in the region, on BLM, Forest Service, and state lands.
As suggested in the Draft Amendment (DA), helicopter noise can be very intrusive to humans, more so than most other mechanical noises, and can significantly adversely affect wildlife such as goats, eagles, and wolverines. AQRC believes that forms of recreation that significantly conflict with other users and with wildlife should be permitted, not generously, but only sparingly, by public land managers.
Consequently, we are very disappointed in the alternatives provided in the DA. There is no true conservation alternative. Such an alternative would, at the very least:
1. maintain indefinitely the Monitoring and Control Area, not just for its scientific value, but also as a refuge for both goats and humans from the surrounding motorized use; 2. include the nominated Area of Critical Environmental Concern; 3. reduce the number of permitted landings below the existing allowance of 2,400, which is far more than appears to be needed; and 4. provide more protective mitigation for mountain goats, including the 2 kilometer buffer recommended by the Northern Wild Sheep and Goat Council.
Furthermore, AQRC believes that BLM has substantially underestimated the intrusive effect of helicopter noise on both communities and other public lands users. For example, the Haines Borough, in a 1996 advisory vote, came out not supporting summer heli-tourism. Additionally, BLM seems to assume (see the Skagway Acoustical Environment discussion) that if there are other noise sources, thereâ€™s no reason not to add another oneâ€”even if, as is often the case, many if not most of the other noises are, or to a large degree are, essential, unlike commercial helicopter flightseeing or heli-skiing, which are of course non-essential recreation. AQRC hears arguments like this frequently from snowmachine advocates when a recommendation is made to manage a particular area of the public lands for quiet recreation: â€œSince jet planes fly overhead, there are already noise impacts in the area, and snowmachine use should therefore be allowed.â€ But for a sizeable number of Alaskans, as well as visitors, the fewer noise sources the better, and as many sources as possible should be eliminated.
BLM also includes as examples of already existing noise the occasional use of airplanes for transporting private individuals into a remote area. But these flights are in fact quite infrequent and are not anywhere near as disturbing as a more or less regular schedule of a large number of flightseeing or heli-skiing trips.
Finally, itâ€™s not uncommon for agencies to suggest, as BLM does here, that since the number of other recreational trips to the backcountry is small, helicopter flights will affect only a small number of other users, and should therefore be permitted. But recreating in an area where other contacts are rare, and where opportunities for solitude are great, is exactly what those recreationists are seeking, and deserve to be able to find. BLM, if itâ€™s a true multiple use agency, should be providing not just commercial motorized recreation opportunities, but those other, more natural types of recreational opportunities as well.
We urge BLM to adopt a true conservation alternative (see above). Thank you for the chance to offer these comments in support of natural sounds, natural quiet, and truly traditional forms of recreation.
Member, Board of Directors
Alaska Quiet Rights Coalition