July 28, 2016
Wrangell-St. Elias National Park & Preserve
ATTN: Bruce Rodgers
PO Box 439
Copper Center, AK 99573
Sent via email to bruce_rogers@nps.gov
Re: Additional Comments on Proposed Action for Wrangell-St. Elias National Park and Preserve Backcountry and Wilderness Stewardship Plan
Dear Mr. Rogers:
Following are additional comments on the Proposed Action (PA) for the Wrangell-St. Elias National Park and Preserve Backcountry and Wilderness Stewardship Plan submitted by the Alaska Quiet Rights Coalition (AQRC). AQRC is also submitting two other sets of comments, in conjunction with other organizations, concerning the PA and recreational motorized vehicle use in Wilderness and national parks, in general, and a legal interpretation of Section 1110 (a) of ANILCA which we believe prohibits recreational snowmachining as a “traditional activity”. These comments focus on various of the Proposed Actions not otherwise addressed in our other submittals.
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 (protecting wildlife requires protecting it not only from disturbing mechanical noise but also from the more obvious habitat damage done by poorly regulated ATVs, snowmachines, jet skis, airboats, etc.). 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, soils, vegetation, scenic beauty, and wilderness character. 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.
In addition to protecting ecological values like the ones listed above, one of AQRC’s specific goals is a fair and equitable overall balance on the public lands between those managed for motorized recreation, and those managed for quiet, truly traditional forms of recreation like hiking, canoeing, kayaking, snowshoeing, and cross country skiing.
Aircraft. We’re comfortable with how the Proposed Action handles most aircraft use, but we do have a few comments.
Why is there no standard for private pilot use (p. 10)? Will there never come a time when the number of private flights in the park significantly detracts from WRST’s wilderness character and the visitor experience? We think such a time could come, and that a standard should be identified (see, e.g., the standard for administrative use of helicopters in Wilderness). We would make the same comment—standards should be identified—for administrative activities like fixed-wing overflights and “motorized administrative use” (includes snowmachines, ORVs, and small motors) (p. 10).
Helicopters should be strictly regulated in all of WRST, but especially in designated Wilderness, where they should not be allowed. Helicopters are exceptionally annoying. A strong, non-recreational need for their very limited use should be required even outside of Wilderness. The Proposed Action sets the limit for administrative use of helicopters in Wilderness, and in one backcountry zone, at the present baseline. This might be reasonable for truly important purposes in the backcountry, but not in Wilderness. And this standard should be applied to all backcountry zones.
Flightseeing should be very strictly controlled. Our preference would be that it not occur at all over WRST. The NPS may not be able to regulate overflights, but it can regulate landings, and none should be allowed in designated Wilderness. To the extent that there are flightseeing operators who operate, or want to operate, over the Park, the Service should attempt to work out voluntary agreements with the operators to designate flight paths or zones that minimize on the ground impacts. Consideration should be given to avoiding those areas where wildlife will be adversely affected. Consideration should also be given to avoiding those areas where humans will be most adversely affected–and this should include not only those areas where the largest number of visitors will be affected (which is the usual strategy), but also those areas where smaller numbers of visitors are trying to have a wilderness experience—including in backcountry areas that are not designated Wilderness—which would seem to be important in a backcountry and Wilderness stewardship plan. The goal should be to protect the natural soundscape, especially within the wilderness areas.
The Proposed Action does not appear to address flightseeing; we hope it will do so in the draft EA and Plan. We’re not sure how big a problem flightseeing is in WRST at the present time. But we certainly worry about the future. A recent brief piece in the travel section of the national news magazine The Week was undoubtedly worrisome. Titled “An Alaskan flying safari,” the article began by saying “To truly experience the majesty of Alaska’s Wrangell-St. Elias National Park—America’s largest protected reserve—you have to get up in the air….” (p. 32, July 1/July 8 issue).
We know how huge a problem flightseeing is in some units of the National Park System; we should try to get ahead of the curve in WRST by addressing the issue now—and by recommending that the Congress repeal the Alaska exemption from the federal statutes addressing flightseeing in National Parks.
Fish and Wildlife. AQRC’s initial focus was on the human, social aspects of the management of motorized recreational vehicles. Increasingly, however, we have advocated for the management of these vehicles (including land, water and air vehicles) for the benefit of fish and wildlife as well. The scientific literature regarding the adverse impacts of not only vehicle noise but other effects of vehicle use (such as snow compaction) is increasing and should be consulted.
Cumulative effects. This is a critical factor to take into account in developing this or any other plan. Seemingly small individual effects can all too easily combine into very significant cumulative effects. And recognizing how technologies can change (snowmachines are an excellent example), how new technologies can emerge (e.g., jet skis and hovercraft), and how use can increase exponentially in a relatively short period of time (e.g., snowmachining, jet
skiing), the Park Service needs to take the long view and to the greatest extent possible anticipate problems and put mechanisms in place that will allow it to deal with inevitable changes.
WRST has done this in the Proposed Action with regard to changes in the level of most individual activities, but it’s not clear if the effects of the sum of all of those individual activities has been considered. This needs to be done in the draft EA and Plan.
Subsistence. ANILCA includes special, more liberal provisions governing the use of motorized vehicles for legitimate subsistence use by qualified users. We support these provisions. But we also appreciate the Park Service’s willingness to implement reasonable regulations to manage this motorized use when appropriate. The Proposed Action does a good job of addressing this issue both fairly and responsibly.
In conclusion, we would stress that in this park the Proposed Action should recognize and emphasize the historic value of WRST’s wildness and Wilderness. In many parts of the lower 48, and in parts of Alaska as well, we’ve become more and more distanced from the experience of those who came before us and had no choice but to deal directly with the hardships a relatively undeveloped natural landscape presented. Travel without motors, and with very few roads, was one of the most significant challenges. Encouraging visitors to WRST to travel by foot, ski, and non-motorized watercraft—by providing a quiet, natural environment and consequently the opportunity for a high quality visitor experience—would help them and all of us appreciate more viscerally the history of our nation. At the same time, doing so encourages independence, self-sufficiency, and outdoor competence—the skills to overcome both physical and mental challenges—in the backcountry and Wilderness.
Thank you for this opportunity to comment.
Sincerely yours,
Brian Okonek, President
Alaska Quiet Rights Coalition
PO Box 202592
Anchorage, AK 99520