Ben Ellis, Director, Division of Parks and Outdoor Recreation
John Moosey, Manager, Matanuska-Susitna Borough
Don Striker, Superintendent, Denali National Park and Preserve

Dear Director Ellis, Mat-Su Borough Manager Mosley and Superintendent Striker:

The Alaska Quiet Rights Coalition (AQRC) Board of Directors believes that Phase 1 construction of the proposed South Denali Visitor Center Complex (SDVCC) in Denali State Park (DSP) should not take place until there is funding to also complete Phase 2.

AQRC is very concerned that necessary guidelines are not in place to control development and protect park resources, assuring a quality visitor experience at the proposed SDVCC in DSP. There have been many plans over the last 40 years to develop a major tourist destination in DSP. No steps have been taken to protect the park itself, as well as the region, from the hundreds of thousands of projected visitors and the many businesses that will crop up in the area to serve them. Development of the SDVCC depends on cooperative arrangements between the Matanuska-Susitna Borough (MSB), Denali National Park and Preserve (DNP&P) and the Division of Parks and Outdoor Recreation (DPOR). Each has a significant role to play.

During the summer of 2013, Phase I of the construction of SDVCC in DSP is slated to begin. It is probable that the MSB assembly will approve a land donation enabling the state to receive land that will be used for an access road exiting the Parks Highway at Milepost 135.4. The road, approximately one mile in length, will lead to an area where a maintenance/ranger office, 35 site RV campground, 22 site day-use parking lot and interpretive trail will be built. Electrical power will be extended along the Parks Highway to Milepost 135. Completion of Phase I will have major implications to the visitor use patterns in DSP both summer and winter. When additional funding is secured, Phase 2 will extend the road to the site where the proposed SDVCC and trails will be constructed. Additional facilities (30 bus parking lot, 100 additional car parking sites, 15 site walk-in campground and a visitor contact area ) will also be added to the development built in Phase I. Completion of the entire SDVCC is estimated to cost $40 million. Currently, there is no funding for Phase 2. SDVCC is expected to be a major attraction for tourism and to provide a “world class” experience. Unfortunately, the necessary steps to maintain the region as a “world class” experience have not yet been taken.

Adequate staffing and funding for both the short and long term operation and maintenance of the SDVCC and resource protection of DSP in general is lacking. DSP’s summer resource management and day-to-day maintenance and operations are currently minimally funded by general state funds. Phase 1 of the SDVCC has received funding for construction only. There is no guarantee of funding Phase 2. The 2011 Feasibility Study is premised on the assertion that the entire SDVCC (Phase 1 and 2) will be up and running. The major attraction and money maker will be the visitor center built in Phase 2. The absence of that revenue and the lack of park staff management will make management of the Phase I summer visitor stream very difficult. Is it anticipated that DNP&P will participate with staffing and/or funding for Phase 1 ?

Additionally, we assume that upon completion of Phase I construction, the parking lot and ranger station will also be open in winter. If so, the parking lot and road will need to be plowed to accommodate the ranger station and provide parking for winter visitors. Where will the funding to operate and maintain these facilities come from ? Will a fee be charged for vehicle parking ? Will it be sufficient to pay for proper management of activities and to protect the park ? We were informed that staff working to develop a trails plan for DSP has been diverted to other projects. It is AQRC’s opinion that without a trails plan in place that designates non-motorized winter use areas for recreational opportunities, snow machines will overrun the area, displace any quiet recreation from the area and create a pattern of motorized use, including up to and around the site of the proposed visitor center. This may preclude any future ability or desire to designate areas closed to snow machines. Motorized recreational use around the visitor center will degrade the “world class” experience. Many people visiting this nations natural wonders like Denali are also seeking the natural sounds and quiet of the region.

AQRC asks that Phase 1 construction be held off until there is funding in place for Phase 2. This will assure that when the project is complete there will be an adequate revenue stream to properly manage impacts created by the new facility. Over the years, in multiple public meetings and comment periods, the public has voiced concern regarding the proposed SDVCC. Since the facility is expected to draw hundreds of thousands of visitors yearly, it is imperative, before construction begins, that management guidelines and regulations are in place that will protect the region and assure a quality visitor experience. Many critical issues have not been addressed. To assure that the overall region is managed properly the DSP Special Land Use District (SPUD) must be strengthened and the DSP Trails Plan must be completed.

Sincerely,
Brian Okonek
President, Alaska Quiet Rights Coalition

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
Planning Area

Dear BLM:

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, 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. 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, 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 “shared” or “multi-use” 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; there’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, there’s no reason not to add another one—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: “Since jet planes fly overhead, there are already noise impacts in the area, and snowmachine use should therefore be allowed.” 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, it’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 it’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.

Sincerely,

Cliff Eames
Member, Board of Directors
Alaska Quiet Rights Coalition

To whom it may concern:

The purpose of this letter is to offer the comments of the Alaska Quiet Rights Coalition (AQRC) on the Eastern Interior Draft RMP/EIS and its Supplement dated Jan. 2013.
AQRC is a state-wide non-profit organization whose mission is to maintain and restore natural sounds and natural quiet on our public lands through advocacy and education for the benefit of people and wildlife. We advocate for a fair and balanced allocation of areas and trails on our public lands for the use and enjoyment of the non-motorized recreationist.

First, we set forth some general observations about the overall plan. AQRC appreciates BLM’s efforts to place all of its lands in the Eastern Interior under travel management plans which requires lands to be designated as “open”, “closed” or “limited” to OHV use. We applaud BLM for recognizing, and attempting to mitigate, resource damage caused by recreational OHV use such as trail braiding, user-created trails, damage to vegetation, erosion and spread of non-native plants as well as adversely affecting wildlife. We support the issuance of free permits to allow the access guaranteed by ANILCA to “closed areas” as a feasible way to distinguish legitimate subsistence users and those engaging in “traditional activities” from recreational snowmachiners. However, AQRC would urge BLM to adopt transparent procedures to ensue that activities considered “traditional” were in fact occurring in each area at the time of ANILCA passage before issuing those permits. We note that as part of this planning effort the Field Office conducted a wilderness characteristics inventory which determined that 99 % of the BLM lands in the planning area have wilderness characteristics. While each of the alternatives propose protecting differing amounts of the wilderness characteristics present, we would urge BLM to go forward, in a separate planning effort, and recommend formal Wilderness designations to Congress.

AQRC supports Alternative B for the Fortymile and Steese Subunits as providing most protection for, and expansion of, recreational opportunities. We also support the Alternative B ACEC designations in both subunits for their protection of caribou and sheep habitat and strict prohibition against most summer OHV use. In regard to the Upper Black River Subunit, we certainly support this area being brought into the planning process for the first time and support the designation of the Salmon Fork ACEC and its closure to summer OHV use. Since this subunit is very remote and the text indicates that current OHV use is limited, limiting the weight of summer OHV use in the remaining 75% of the subunit outside the ACEC may provide sufficient resource protection.

We are most concerned about the White Mountains Subunit and the decision that hardrock mineral leasing could be allowed, as extensively examined in the Supplement. We realize that Alternative D, opening 160,000 acres, is not BLM’s Preferred Alternative, C, which along with Alternative B, does not lift the mineral leasing closure. However, the fact that this possibility was explored in depth indicates that there is interest in this possibility. The potential adverse impacts from mining spelled out in the Supplement are multifold: on wildlife, particularly in the current White Mt. caribou caving and post-caving areas, on the summer recreational experience in the Backcountry and Semi-Primitive management areas, the increased OHV traffic and consequence damage created by new trail creation, rutting of existing trails and trespass off trails. While the new interpretation of ANILCA may allow the lifting of the mining prohibition, we argue that the public recreation values of this area trump the mining potential. We note that the discussion about Leasable Minerals in Table 2. 22. Comparison of Impacts: Common to All Subunits would appear to indicate that there is a lack of such minerals on the BLM managed lands in these subunits whether under Alternative B, C or D. While the possibilities of mining taking place may, therefore, be slim, the consequence of opening these wild, remote lands which lack infrastructure is to invite the industrialization of these prime recreational areas and is simply incompatible with the outstanding recreational values of this subunit and the Congressional language establishing this National Recreation Area. Mining may create some benefits but too often may cause substantial damage, particularly to the wildlife and wilderness characteristics of the land.

AQRC supports Alternative B for the White Mountains Subunit. Clearly this subunit offers many accessible opportunities for recreation, both motorized and non-motorized. AQRC is under the impression that the multi-use trail system works well in winter and without the usual user conflicts between the quiet and the motorized recreationist in the rest of the state. LImiting ORV travel in summer to designated trails or by permit only will hopefully limit conflict with hikers and backpackers and will help reduce substantially the damage currently caused by by cross-country ORV use. We also supports Alternative B on the grounds that it does not permit UTV use. It is our conviction, based on incidents occurring on other public lands, that unless there is continual monitoring by BLM rangers, UTV users will “trespass” into closed areas and trails with resulting resource damage. We also support the designation of the ACEC of 589,000 acres to protect wildlife values, particularly caribou and Dall sheep habitat, with summer OHV use limited to designated trails. While we do not object to continuing the access to, and riding by OHVs, trucks and motorhomes in/on the disturbed gravel area of the Nome Creek tailings area, we do wonder how this is monitored to ensure travel does not venture off the disturbed areas.

Thank you for this opportunity to comment.

Sincerely yours,

Susan Olsen, Board Member
Alaska Quiet Rights Coalition
PO Box 202592
Anchorage, AK 99520

Re: Opposition to HJR 7 and SJR 3 (that Urges Congress to Open Arctic National Wildlife Refuge for Oil & Gas)

Dear Alaskan Legislator:

Over 50 years ago, Alaskans played a major hand in establishing the Arctic National Wildlife Refuge (“Refuge” or “Arctic Refuge”) to preserve the wilderness and wildlife values of this corner of Alaska on an ecosystem scale. Today, it remains the only area of Alaska’s North Slope protected by law from oil and gas exploration and development. The Refuge’s value as an intact ecosystem is increasingly important in the face of a rapidly changing climate.

Our organizations, representing thousands of Alaskans, support protection for the Arctic Refuge from oil and gas leasing, exploration, and development. This is in the best interest of Alaska and the nation for a number of reasons:

1) Oil and gas development and wilderness are not compatible. There is no safe way to explore and develop the biological heart of the Arctic National Wildlife Refuge, its Coastal Plain. Despite the oil industry’s numerous assurances, the National Research Council found long-term, major impacts from oil and gas operations on Alaska’s North Slope to tundra vegetation, migratory birds, caribou, bowhead whales, subsistence, and other cumulative effects. Despite technological advances in the oil industry, there are still large numbers of oil spills every year on Alaska’s North Slope, roughly one a day on average. Directional drilling does not solve this problem. It would result in spills and pollution just like conventional drilling and the impacts of noisy development and pollution would inevitably extend into key wildlife and subsistence areas, including the nearly 100 miles of sensitive coastlines.

2) Protecting the Arctic Wildlife Refuge is important ecologically and culturally. The Arctic Refuge’s narrow Coastal Plain is the center of wildlife activity for birds, fish, polar bears, marine mammals, caribou, and other wildlife. It deserves our nation’s strongest protection. Oil development here would adversely affect the health of the Porcupine Caribou Herd, which the Gwich’in people rely on for their subsistence, cultural, and spiritual needs. The calving and nursery grounds on the Coastal Plain of the Refuge – where up to 40,000 calves are born each summer – are referred to as “the sacred place where life begins.” For the Gwich’in, it is a human rights issue that they be allowed to continue their way of life, so protecting the Coastal Plain upholds the UN Declaration on the Rights of Indigenous Peoples. The Coastal Plain supports the subsistence way of life for the Inupiat and other Alaska Native people.

3) Tourism is vital to Alaska’s economy and plays an important role in the health of Alaskan businesses. People visit Alaska because of its spectacular natural beauty and extraordinary wilderness opportunities. Eco-tourism is a sustainable economy dependent on intact ecosystems with high wilderness values such as the Arctic Wildlife Refuge. The Arctic Refuge represents wilderness at its wildest. Oil development would have long-term negative consequences on the recreation and tourism industries that rely on these wild lands.

4) We must pursue alternative ways to meet our energy needs in Alaska and America – drilling in the Refuge is not part of that equation. Nationally, increasing the fuel efficiency of our automobiles, developing renewable energy sources, and adopting energy efficiency and conservation technologies are safer, cleaner, and quicker alternatives to meeting our energy needs than opening the Arctic Refuge to oil and gas leasing and development. In fact, such measures are the only way to truly reduce our dependency on foreign oil. As Alaskans, we do not need to wait for federal action or speculative revenues to continue to support Alaska’s strong program of funding renewable energy, energy efficiency, and weatherization programs or to promote measures for Alaskans’ energy self-sufficiency.
Not all Alaskans support opening the Coastal Plain of the Arctic Refuge to oil and gas. We oppose HJR 7 and SJR 3 and support continued protection of the Arctic Refuge.

To that end, we urge President Obama and Congress to defeat any efforts to allow any oil and gas leasing, exploration, or development in the Coastal Plain of the Arctic Refuge. Adopting a Wilderness designation for the Arctic Refuge Coastal Plain will protect this magnificent place for future generations of Alaskans and all Americans; it is that goal toward which we should all aim.

Sincerely,

Pamela A. Miller, Arctic Program Director
Northern Alaska Environmental Center

Dear Anchorage Parks and Recreation Commission;

Thank you for this opportunity to comment on the Alaska State Snowcross Lions Club proposal to open the Jodphur Motocross Track at Kincaid Park to winter snowmachine racing and freestyle practice and events. Alaska Quiet Rights Coalition (AQRC) is opposed to allowing the Jodphur Motocross Track to be used in the winter for snowmachine or other motorized practice and events .
The Alaska Quiet Rights Coalition (AQRC) is dedicated to protecting the rights of Alaskans to quiet places for the benefit of public land users, home and cabin owners, communities, businesses, wildlife, visitors, and future generations. The mission of AQRC is to maintain and restore natural sounds and natural quiet in Alaska through advocacy and education for the benefit of people and wildlife.

Kincaid Park has a cross-country ski trail system that is world class. The rolling terrain and lush forest the finely groomed trails traverse make skiing there a marvelous experience for expert racers and families alike. A snowmachine snocross track and freestyle practice and event area does not mix well with the winter activities that Kincaid Park has become well known for.

1) The Municipality of Anchorage and Kincaid Park have been closed to snowmobiling for years due to safety issues and noise disturbance. Past problems with snowmachine activity have proven that both are legitimate concerns.
2) While aircraft arriving and departing from the Ted Stevens International Airport reminds one that they are skiing in the largest city in the state instead of the wilds of Alaska this does not justify creating a whole other level of noise disturbance to Kincaid Park or the neighboring subdivision.
3) Opening the Jodphur Motocross Track to snowmachine racing will create a level of noise that will have a huge negative effect on the cross-country skiing experience on the trails at Kincaid Park as well as the quality of life in the Sand Lake neighborhood. Noise will not stop at the borders of the Motocross Track. Winters cold air and lack of leaves on the trees allow sounds to carry much further from their source than in the summer. The noise from the race track will be heard far, far away.
4) Stock mufflers do not substantially reduce the noise of snowmachines that are operated at full throttle and repeatedly reved up. The type of high pitched noise created by snowmachine engines is very intrusive. There is no good way to substantially reduce the noise of the snowmachines when they are throttled to accelerate quickly. Th muffler systems of todays snowmachines may make them quieter than the past when at an idle or operated at a slow steady speed, but when accelerated to full throttle the snowmachines are dangerously loud.
5) Placing a motorized race track between a neighborhood and motor free, muscle powered park area does not represent prudent planning. It will only serve to create more conflict. No doubt there will be times when rogue snowmachine riders will tear up the groomed ski trails with their paddle track machines and endanger skiers.

On a technical note, we wish to draw your attention to the following:
A) Anchorage Municipal Code 9.42.020.A.5 prohibits snowmachine operations within 500 feet of an established skiing area or other recreational area where the operation would conflict with recreational use. Does this proposal fall outside this prohibition ?
B) The existing Pt. Campbell/Kincaid Park Master Plan (1983 Anchorage Winter Recreation Development Program) does not mention or authorize snowmachining as an acceptable use. In fact, it contains a number of references and recommendations prohibiting motorized uses. For example, p. 2.11 states “Permanent recreation uses that create significant noise impacts, such as all-terrain vehicles, are inappropriate on the site” or on page 3.6 “…it is recommended that motorized recreation vehicle use not be considered as a program element…due to severe conflicts with existing park use…trails, highly susceptible to damage…noise impact is considerable…” Without amending the Master Plan, we do not believe there is authority to permit snowmachining in any form in Kincaid Park.
C) The current 1997 Areawide Trails Plan contains a suggestion by the local snowmachine club that the O’Malley golf course or the 70 acre tract on the Minnesota-O’Malley curve be made available for a family (snowmachine) riding area. We make the obvious point that a snowcross race track is hardly the same as “a family riding area”. We further assert that, due to noise disturbance to residential areas, neither of these two locations can be considered as a substitute location should the use of the motorcross area be denied.

The Jodphur Motocross Track should remain closed to winter motorized use.

Sincerely,

Brian Okonek, AQRC president