January 17, 2014
Ms. Shelly Jackson
BLM Central Yukon Field Office
1150 University Avenue
Fairbanks, AK 99709
Dear Ms. Jacobson,
The following are the scoping comments of the Alaska Quiet Rights Coalition (AQRC) on the BLM’s Central Yukon Resource Management Plan.
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, soils, vegetation, 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.
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.
At the present time on BLM lands in Alaska, there is a very substantial 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 noisier and more damaging motorized sports (it would seem that forms of recreation that create far fewer conflicts far less damage would be favored, but that is certainly not the case at this time). Because of the inevitable conflict 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 state public domain lands, BLM should be providing opportunities for quiet recreation that are effectively unavailable on general state land.
The Central Yukon Plan should therefore identify and close to motorized recreational use (e.g., ATVs, snowmachines, airboats, jet skis, helicopters, fixed-wing planes) a substantial portion of the BLM lands within the planning area. Two types of closures should be made: those that protect lands and waters that are important for ecological values like fish and wildlife and their habitat, clean air and water, natural sounds, natural quiet, soils, and vegetation; and those that are important for social/conservation reasons like scenic beauty, wilderness character, and quiet recreation (note of course that closures for social/conservation reasons protect ecological values at the same time).
These closures are becoming increasingly necessary with the “increased use of off-highway vehicles” in the area (Newsletter 1, page 2). Only two issues are identified in the Newsletter (we recognize that there are more) as “current” issues that the revised RMP is needed to address; this increased off-highway vehicle use is one of them (Id.).
In addition, it should go without saying that the existing closure along the Dalton Highway should be continued to protect both subsistence resources and a wide range of ecological and other social/conservation values.
Finally, an important component of a revised RMP should be a soundscape plan that describes the current situation, provides for ongoing monitoring, and takes steps to protect the natural sounds and quiet that presently exist and to restore natural sounds and natural quiet to appropriate portions of the planning area where those resources have been lost.
Thank you for the opportunity to comment on this important planning area and for your serious consideration of these important issues.
Member, Board of Directors
Alaska Quiet Rights Coalition