Bureau of Land Management
Anchorage Field Office
Ring of Fire Resource Management Plan Amendment/SEIS
4700 BLM Road
Anchorage, AK 99507
June 18, 2009 – Scoping Comments
The undersigned organizations support retaining the current Mountain Goat Monitoring and Control Area in the BLM Haines Block, and protecting it by creating an Area of Critical Environmental Concern (ACEC) to be managed as a Research Natural Area (RNA).
The Federal Land Policy Management Act prioritizes creating ACECâ€™s for those areas meeting Importance and Relevance criteria. Â The Mountain Goat Monitoring and Control Area contains an important mountain goat resource that is sensitive to human disturbance. Â This resource has special worth and is more than locally significant because naturally occurring mountain goat populations on BLM managed lands nationwide have become scarce. Further, the Monitoring and Control Area requires special management in order to protect it from expanding helicopter-supported recreation.
If the Mountain Goat Monitoring and Control Area were instead placed inside a Special Recreation Management Area (SRMA), it would be managed â€œto meet the strategically-targeted primary recreation market demandâ€ for helicopter-supported recreation (DEIS page 3-174), putting these important goat populations at risk. Â BLM has already determined that a SRMA would allow â€œcontinued adverse effects [to mountain goats] of a currently unspecified magnitude from [helicopter-supported] recreational activities.â€ (PRMP/FEIS Attachment C page 20). Â There is an obvious inherent conflict between meeting the demand for new helicopter landing areas and protecting an area from the mandated activity. Considering the importance, significance, sensitivity, and vulnerability of the resource, the management focus needs to be on protecting goats, not providing recreation opportunities. Â This would be in keeping with the BLM management directive that â€œspecial management attentionâ€¦protect[s] the importance and relevance values of an area from the potential effects of actions permitted by the RMP.â€ Â (BLM Manual 1613.1.12).
â€œACEC designations highlight areas where special management attention is needed to protect, and prevent irreparable damage to important. . . wildlife resources .â€¦The ACEC designation indicates to the public that the BLM recognizes that an area has significant values and has established special management measures to protect those values. Â In addition, designation also serves as a reminder that significant value(s) or resources(s) exist which must be accommodated when future management actions and land use proposals are considered near or within an ACEC.â€ Â (BLM Manual 1613.02).
An ACEC can be managed as an RNA, where â€œresearch and monitoring are encouragedâ€ and serve as a â€œbaselineâ€ for long-term change. Â (PRMP/FEIS page 3-186). Â Research and monitoring are necessary because Haines/Skagway goat populations are currently threatened by acknowledged adverse impacts of â€œunspecified magnitudeâ€ from the increasing use of helicopters inside and over goat habitat. Specific scientific concerns about impacts to mountain goats include: displacement from prime habitat, acute or chronic reduction in foraging efficiency resulting in nutritional deficiency, reproductive failure, and increased vulnerability to predation. (1995 BLM and USDA EA for Helicopter Landing Tours in the Skagway and Haines Area pages 3-12 and 3-13).
In 2001, heli-ski permits were issued in some non-impacted areas previously identified as control areas, necessitating the creation of a formal Mountain Goat Monitoring and Control Area. Â (BLM Anchorage: Monitoring Mountain Goat Habitat Fidelity and Population Stability in Occupied Habitats With and Without Helicopter-supported Commercial Recreation in the Haines/Skagway Area of Alaska, page 5). Â BLM stopped monitoring goat populations in 2006, and then proposed placing the area inside a SRMA. Â Without protective management, helicopter landings will continue to expand into the Monitoring and Control Area until there are no non-impacted goat populations left.
BLM has already determined that the Haines Block goat resource is important. (PRMP/FEIS Attachment C page 166). Â Further, the area has a â€œparticularly diverse and unique set of flora and fauna due to its proximity to both interior Canadian ecosystems and coastal temperate rainforest ecosystemsâ€ (PRMP/FEIS page 3-57), and has â€œremarkable natural attributes and opportunities for research and education.â€ Â (PRMP/FEIS Attachment C page 166).
Given all the above, eliminating or placing the Mountain Goat Monitoring and Control Area inside a SRMA would cause irreparable harm to a vulnerable and valuable resource that has become scarce on BLM lands nationwide. Â The current planning process is the appropriate vehicle for creating an ACEC to be managed as a RNA, and we fully support this option.
Thank you for the opportunity to comment.
Nicole Whittington-Evans John Toppenberg
Associate Regional Director, Alaska Director
The Wilderness Society Alaska Wildlife Alliance
Pam Brodie Cindy Shogan
Chapter Chair Executive Director
Sierra Club Alaska Chapter Alaska Wilderness League
Karla Dutton Toby Smith
Alaska Director Executive Director
Defenders of Wildlife Alaska Center for the Environment
Susan Olsen Lindsey Ketchel
President Executive Director
Alaska Quiet Rights Coalition Southeast Alaska Conservation Council