South Denali Draft Implementation/ EIS

November 7, 2005

South Denali Planning
P.O. Box 588
Talkeetna, Alaska 99676

To whom it may concern:

The purpose of this letter is to provide comments from the Alaska Quiet Rights Coalition (AQRC) on the Draft South Denali Implementation Plan and EIS (DEIS) and the Draft Amendment to the Denali State Park Master Plan (Amendment). 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 by Alaska’s public land managers and we seek to secure a fair and balanced allocation of the recreational opportunities available to non-motorized and motorized recreationists. AQRC also seeks to protect wildlife and remote cabin owners from the sounds and other impacts of unwanted motorized recreation.

We have three major criticisms of these documents: there is no discussion, or establishment, of carrying capacity; the cumulative effects analysis fails to address indirect impacts and, further, fails to adequately address impacts of ongoing operations. Moreover, in light of the statement made in the Amendment at page 25 that “Very little natural resource or recreational research has been conducted within Denali State Park”, we question the cumulative effects analysis which generally concludes that construction and operational impacts will be moderate.

It is clear from the language, concept plans and size of the facilities proposed that the purpose of building a visitor’s center is to accommodate the demands of industrial tourism for a destination to which they can bring their clients. The Preferred Alternative locates the visitor’s center just off the Parks Highway. We find this to be a welcome evolution in this multiyear planning effort and is a clear acknowledgment of the true purpose of the center. The estimated visitation figures projected on page 256, which range from 218,000 to 275,000 for the first year the center will be open to 241,000 to 368,000, by 2015, are truly amazing and alarming. Translating those figures into the number of daily bus trips between the transportation center and the visitor’s center and return, we calculate that at the low end, there would be 2422 visitors a day or 60 bus trips up and 60 bus trips back while at the high end the figures would mean 4088 visitors a day with 102 bus trips up and 102 bus trips down, the 3.5 mile road. (We used a 90 day season and 40 passengers per bus for these calculations.) While the footprint of the facility might be considered modest, the resultant level of activity will create a tremendous impact to an area of the state park which now is essentially wild. Without a prior determination of carrying capacity, state park managers have no way to counteract the ever- increasing demands of industrial tourism. That being the case, we recommend that the Final Plan and EIS contain a scheme for regulating future usage of the Park, such as a permit system for accessing various trails or annual quotas limiting the number of visitors each tour company can bring in any one year.

The DEIS deals with the issue of impacts during the construction phase, but pays scant lip service to the impacts caused by ongoing operations. For example, no estimate is given of the number of people who would travel to the visitor’s center in order to hike or backpack up the new trail to the Curry Ridge trail. Not only is that tundra environment exceedingly fragile, but the wilderness experience expected by the hiker/backpacker is easily destroyed by encountering, seeing or hearing other people. Backpacking on Curry and Kusugi Ridges is a premier backpacking destination because it is above tree line and can easily be accessed from the Parks Highway. There is no discussion as to how this recreational experience will be preserved, for either the person accessing the area via the visitorâ’s center or those using the other trailheads.

The DEIS fails to discuss indirect impacts. As an example, there is no mention of the indirect impacts which cabin owners in the area will experience in winter from the increased parking included in the Petersville Road improvements (to occur regardless of which action alternative is selected). It appears from our calculations that additional parking spaces for at least 70 cars and 200 RV/snowmachine/ ATV trailers will be provided. Furthermore, once the transportation center is constructed, 300 additional car spaces and 160 RV/snowmachine trailer parking spaces could be made available for winter recreation. Even though the DEIS shows that there are large number of recreational cabins within each of the subareas, and the documents discuss how the improvements will meet the needs expressed by the local communities, it says nothing about the “indirect” impact, increased snowmachine traffic, which the improvements will bring to residents outside the community centers. The impacts of snowmachine noise and traffic on cabin owners at current levels of usage is already substantial and seriously degrades their experience. The DEIS states nothing about the “indirect” impact which will result from more visitors to the Curry and Kusugi Ridges, to the soils, vegetation and wildlife, much less the recreational experiences of the hiker or backpacker. The DEIS references, but does not analyze, the indirect impacts 300 Boy Scouts could have, on a daily basis, on the trails and recreational experiences of those accessing Denali State Park via the visitor’s center, its trails or other trailheads.

AQRC is also concerned that winter nonmotorized recreational opportunities be made available on the trails to and around the visitor’s center, the road from the transportation center and the trail to Curry Ridge. The DEIS appears to state that all trails will be multiuse, though the suggestion is made at page 41 of the Amendment that the summer hiking trails near the visitor center could be maintained for Nordic skiing. Multiuse trails rarely provide the type of quiet recreational experience the nonmotorized recreationist is seeking. AQRC would strongly recommend that this development not become the means by which Curry Ridge becomes the new snowmachining mecca. We would recommend that all trails built in conjunction with this development and both Curry and Kusugi Ridge be closed to snowmachines on several grounds. First, the state general lands surrounding Denali State Park, as well as the rest of Denali State Park, are completely open to snowmachining providing adequate snow cover is available. Secondly, winter nonmotorized trails are virtually nonexistent in the area. Moreover, we understand that snow conditions on the ridges are frequently inappropriate for snowmachining due to drifts and windswept, bare tundra vulnerable to ecological damage. State Parks does not have the staff to manage motorized recreation in such high-risk areas. Also, it is worth keeping in mind that at some point in the future, the tourism industry may well see business opportunity in marketing Alaska as a winter tourism destination. You can be certain that the image presented will be of quiet, nonmotorized activities, such as skiing, dog mushing and snowshoeing through a trackless, quiet snowscape of spectacular beauty. The industry will demand that public land managers provide nonmotorized trails and areas, out of sight and sound of snowmachines. At the very least, in order to provide a fair and balanced allocation between non-motorized and motorized recreationists, limit snowmachines to a corridor to reach Curry Ridge and reserve all the surrounding new trails for nonmotorized recreation. However, these plans, regulations and enforcement capability must be in place prior to construction.

The proposed Visitor Center and transportation center will act as a magnet and have a huge impact on the immediate area as well as the rest of Denali State Park. As discussed above, the estimated visitation is enormous and will forever change the area, though the footprint may be small. Because of these impacts it is imperative that a number of “triggers” be part of the Final Plan and EIS and ROD and be conditions under which construction proceeds. First, the MatSu Borough must have in place a zoning plan which is enforceable which covers borough, state and private lands within the area to prevent a second “glitter gulch”. Secondly, Denali State Park must have approved regulations in place which allows snowmachine closure on certain trails and areas, a permit system for accessing Curry Ridge when demand necessitates and similar powers to protect the resources of the Park. Thirdly, there must be a commitment to provide funding for sufficient staffing to permit enforcement of winter and summer activities in the Park. (We note that the plan indicates that Denali State Park is now down to one ranger-shame on us!) Fourth, Denali State Park must have authority from the legislature to close the road between the transportation center to the visitor center to private cars during the tourist season(s). Fifth, the necessity to develop a framework for determining carrying capacity, must be acknowledged by Denali State Park managers and a process set in place.

The lands within the boundaries of Denali State Park were set aside to be managed differently from general state lands due to the natural resources of the area. While the location of the proposed facilities falls within the Recreation Development zone and would appear to be within the type of activity permitted under that zoning, it is our opinion that the activities resulting from the development will far exceed the level of impact anticipated in the Natural Area and Wilderness zones and will severely impact the resources of the Park located outside the center’s footprint. This Park could easily be sacrificed to the demands of industrial tourism unless carrying capacity determinations are carefully developed and strong management is in place to protect the Park.

Thank you for the opportunity to comment.

Sincerely yours,

Trisha Herminghaus, President
Alaska Quiet Rights Coalition