June 5, 2010
U.S. Fish and Wildlife Service
Arctic NWR â€“ Sharon Seim
101 12th Ave., Rm 236
Fairbanks, AK 99701-6237
Re:Â Scoping on Arctic NWR CCP Revision
Dear Ms. Seim and Mr. Voss:
The following are the scoping comments of the Alaska Quiet Rights Coalition (AQRC) on the Arctic National Wildlife Refugeâ€™s revision of its Comprehensive Conservation Plan.
We thank you very much for the opportunity to participate in this planning process for a highly valuable, almost entirely pristine area that is owned by all Americans and is considered by many to be our countryâ€™s premier wilderness and wildlife area.
Weâ€™d like to begin by telling you about AQRC.Â It might be that not all of this background information is strictly relevant to this planning process, but it will help you better understand us and our particular interest.
The Alaska Quiet Rights Coalition 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.
Alaskaâ€™s natural beauty, wildness, wildlife, expanses of undisturbed open space, and peace and quiet are among its most cherished values, and Alaskans, our visitors, and future generations have the right to experience the natural sights, sounds and quiet beauty of our state.Â In the vast majority of cases, the obtrusive noise, summer landscape degradation and winter snowscape defacement, exhaust, and dangers of motorized recreation are incompatible with those special natural experiences.
Unfortunately, though, natural quiet and the opportunity to hear and enjoy natural sounds are increasingly hard to find in our stateâ€”a fact which would surprise the great majority of non-residents for whom Alaska in general, and the Arctic Refuge in particular, are potent symbols of the natural and the wild, not of noisy mechanization.Â 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 only 10 or 20 years earlier.
Consequently, we urgently need to protect those quiet areas that still remain.Â Most of us, until quite recently, took the restorative quiet of the outdoors for granted.Â We assumed that the backcountry would always provide a quiet refuge from the noise, busyness and artificiality of our towns and cities.Â That assumption, to our great chagrin, has proven to be false.Â We now know that natural quiet and natural sounds require ourâ€”the public, and the publicâ€™s stewards, the land managersâ€”constant vigilance if theyâ€™re to survive even into the middle of our present century.
Ironically, natural quiet can be easier to find in the lower 48, in the many designated Wildernesses where motorized recreation is prohibited, than in supposedly wild Alaska, where many federal land managers erroneously believe that ANILCA requires them to allow obtrusive recreational activities, for example, snowmachining, even in designated Wilderness.Â Recreational snowmachining, inaccurately characterized as â€œtraditional,â€ is allowed in spite of its numerous adverse impacts and the conflicts it so often creates with truly traditional, low impact means of access like walking, snowshoeing and cross country skiing.Â We can and should do better.Â (See below for more on this issue.)
AQRC believes in a fair and balanced allocation of the stateâ€™s public lands for both non-motorized and motorized recreation.Â At the present time, there is a gross imbalance on the public lands that both unwisely and inequitably favors motorized recreation over muscle-powered recreation.Â In the interests of both good stewardship and fundamental fairness, this imbalance needs to be rectified.Â A reasonable proportion (weâ€™ve suggested 50%) of public lands and facilities of all jurisdictions throughout the state should be set aside for quiet recreationâ€”thereby also helping to protect clean air and water, fish and wildlife, scenic beauty, and the wilderness character for which Alaska is famous worldwide.Â (See below for more on this issue.)
Natural quiet and natural sounds should be recognized by all public land managers as critical resources in and of themselves that deserve no less consideration than clean air and water or fish and wildlife and their habitat.Â Soundscape plans should be prepared.Â The analysis of proposed agency actions should include a determination of the possible effects on natural quiet and natural sounds and on the humans and wildlife that enjoy or depend on them.Â (See below for more on this issue.)
AQRCâ€™s focus has been on motorized recreation, not subsistence.Â And ANILCA, rightfully so, has more liberal policies for the use of motorized vehicles for necessary subsistence than for non-essential recreation.Â Subsistence use of motorized vehicles should, nevertheless, be subject, where appropriate, to reasonable regulations (as provided for in ANILCA).Â (See below for more on this issue.)
Our more particular comments follow:
1.Â Vision.Â We are very pleased with the Planning Updateâ€™s vision for the refuge, expressed not just in the draft vision statement itself, but also in the refuge managerâ€™s letter, the draft goals for stewardship, and of course the refugeâ€™s purposes.Â Important themes, some of them mentioned several times, are wilderness/wildness, wildlife, naturalness, pristine and untamed landscapes, heritage, stewardship, solitude, respect, and restraint.Â None of these values are consistent with recreational motorized vehicle use in this wild, remote refuge.
2.Â Natural Quiet and Natural Sounds.Â These important but too often neglected resources deserve strong protection in the refuge.Â If not protected here, where will they be?Â The CCP should treat them as completely legitimate and independent resources, and the impact of refuge activities and decisions on them should be fully evaluated, just as is done for other important resources and values such as wildlife, clean air and water, scenic beauty, wilderness, etc.Â In addition, the revision should either include a soundscape plan at this point, or should mandate that a step-down soundscape plan be undertaken subsequently.
3.Â Wilderness.Â Wilderness is an important issue for our members, since we assume that the use of noisy and otherwise destructive and conflict creating motorized vehicles, other than for legitimate access (see below) and well regulated subsistence use, will not be permitted in refuge Wilderness.Â We firmly believe that the Congress in passing ANILCA did not intend that its â€œtraditional activitiesâ€ provision would create a loophole that would make designated Wilderness in Alaska far less wild than in the lower 48.Â The refuge should remain an example of our wild heritage.Â Visitors to our state should be able to find peace and quiet in this special place, not the noise and busyness that many of them are trying to escape–and that they assume they will be able to escape when they travel to â€œwildâ€ Alaska.
Airplane (not helicopter) drop offs for access to wilderness recreation (as opposed to airplane use for flightseeing or other recreation), and of course access to inholdings, are traditional and appropriate, although such use needs to be carefully regulated.Â Other non-subsistence motorized use is inconsistent with Wilderness and with refuge purposes and values and should not be allowed.
And of course we consequently support recommending to the Congress very substantial additional Wilderness acreage for the refuge.
4.Â Balanced Land Management Statewide. Nor need such motorized recreational use be allowed elsewhere in the refuge.Â The Arctic Refuge should be a counterweight, an alternative, to the vast majority of state-owned lands and BLM lands, and to the many other areas on the federal lands, where such recreational use is allowed, and in all too many cases, virtually unregulated.Â The gross imbalance referred to earlier can and should be at least partially righted by managing for non-motorized use on the refuge.
5.Â Wildlife.Â AQRCâ€™s focus is on the social impacts of motorized, primarily recreational, vehicles, since these issues seem to be so difficult for land managers to resolve responsibly.Â But an important part of the natural experience that non-motorized recreationists and visitors are seeking is seeing healthy populations of wildlife in a natural, undisturbed setting.Â Maintaining healthy wildlife populations, unaltered habitat, and biodiversity should of course be a major refuge goal and is one that we heartily support.Â Similarly, although our organizational emphasis is not on the preservation of scenic beauty, doing so is critical to a non-motorized userâ€™s enjoyment of his or her outdoor experience.
6.Â Subsistence.Â The promises made in ANILCA to subsistence users should be honored.Â This includes the use of motorized vehicles for subsistence when such use is not allowed for other purposes.Â But ANILCA clearly allows the subsistence use of motorized vehicles to be reasonably regulated, and whether there is a need for such regulation should be carefully, but fairly, evaluated in the revision.
Thank you again for the chance to comment on this important planning process.Â We feel confident that refuge staff recognize that they have a very special stewardship responsibility in managing this exceptional place and will manage it responsibly for both present and future generations of Americans.
Member, Board of Directors
Alaska Quiet Rights Coalition