December 11, 2013
Forest Plan Revision Team Leader
Chugach National Forest
161 East 1st Ave., Door #8
Anchorage, AK 99501
Dear Mr. Rees:
I attended the Nov. 20, 2013 public meeting held in Anchorage to discuss the assessment issues your team has identified to date. The purpose of this letter is to offer additional comments, both as an individual who recreates in CNF and as a board member of the Alaska Quiet Rights Coalition (AQRC), which participated extensively in the previous forest planning efforts and has commented on this effort as well.
In the group I was in there was an extensive discussion of the experience expected by quiet recreationists and the adverse impacts motorized recreation has on that experience when occurring in the same location. It was made clear, from the non-motorized recreationists, that the two uses are not compatible and that the Forest Service must separate these uses in its designation of areas and trails. It was further suggested that areas designated for non-motorized use be within one day’s trip from the road as well, of course, as designations for separate backcounty areas for muscle-powered recreationists. The motorized recreationists in the group stated their concern was access and the belief that they were increasingly being denied access. We believe that any analysis of CNF lands designated open, versus closed, to snowmachines demonstrates that this is not a valid claim; the amount of area open to snowmachining is magnitudes greater than what is closed or restricted to their use. Furthermore, the great majority of the areas that are most popular with both types of recreationist are managed for snowmachining. Finally, we would argue that access is likewise an issue for the non-motorized recreationist…to their fair share of trails and areas where they can recreate in undisturbed snow, without sight, sound or odor of motorized recreational vehicles.
Unfortunately, time did not allow much of any discussion about the current Wilderness Study Areas and how, or whether, to recommend formal congressional designation of wilderness for these areas. As we have indicated in previous comments, the Alaska Quiet Rights Coalition firmly supports a recommendation for formal Wilderness designations. One participant in our group pointed out that wilderness, once lost, cannot be regained so it is imperative to request formal designation now for the Chugach National Forest. Further, in response to a request that the wilderness study area designation be lifted in one area to accommodate a motorized trail, the point was made that the purpose of a wilderness designation is to preserve a large intact natural system. Accordingly, you cannot “de-designate” a piece here or an area there. AQRC believes that as usage of the forest continues to grow and new types of recreation are introduced and considered for accommodation, designated wilderness areas becomes increasingly valuable, scarce, and essential to maintain. Therefore, we strongly urge the FS through this planning effort to recommend congressional approval of Wilderness in the Chugach National Forest.
But, that said, we reiterate our position that any formal Wilderness designation is virtually meaningless unless, and until, the Forest Service re-examines and revises its interpretation of Section 1110(a) of ANILCA. (These comments are based on the material contained in the “What Can I Do In Wilderness ?” material produced by USDA Forest Service, Alaska Region, November, 2005 which we assume is still in effect.) The statutory language states that the Secretary shall permit the use of snowmachines as a method of transportation for traditional activities. However, we would argue that the FS has confused and conflated “method of transportation” with “ traditional activity”. The language on p. 6 of the above-referenced material states” …’traditional activities’ includes, but is not limited to, recreation activities that generally occur(ed) is the area at the time of designation”. We contend that recreational snowmachining did not occur, or if it did, at the time of designation it was too limited in scope to be pronounced a “traditional activity”. We request that the FS release the historical data justifing their interpretation that the amount of recreational snowmachining occurring in Chugach National Forest in and before 1980 constituted a traditional activity. It is our contention that without a reinterpretation of the meaning of Section 1110(a) of ANILCA, a recommendation for formal wilderness designation will not accomplish the purpose of the Wilderness Act.
Time ran out before we had an opportunity to inquire about how, and when, the planners intend to develop a travel management plan for snow vehicles and how this requirement will affect the CNF assessment process as well as the public input. We believe it is very important that the public be advised of this requirement and how it will be implemented as soon as possible in view of the existing conflicts among users groups.
Thank you for this opportunity to add additional comments to the public record of the planning process for the revised management plan for the Chugach National Forest.
Susan Olsen, member
Board of Directors
Alaska Quiet Rights Coalition