Chugach National Forest: Wilderness Considerations

April 14, 2013
P.O. Box 202592, Anchorage, AK 99520

Dear Chugach National Forest Plan Revision Team,

The following are brief additional comments, addressing the very important issue of Wilderness, from the Alaska Quiet Rights Coalition (AQRC) on the assessment phase of the Chugach National Forest plan revision process.

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, clean water, fish, wildlife, 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.

Frankly, it’s an embarrassment that there is not one acre of designated Wilderness on a National Forest as wild and vast as the Chugach [5.5 million acres]. We urge the Forest Service to recommend very substantial acreage on the Forest as Wilderness. The existing Wilderness Study Area [in Prince William Sound] is of course an obvious–and a prime–candidate for such a recommendation. In addition, however, areas should be recommended for Wilderness on the Kenai Peninsula as well. There’s no reason why residents who aren’t boaters, and the many visitors who enjoy hiking or skiing, shouldn’t be able to do what people in lower 48 Wilderness areas do all the time–drive to a trailhead and hike or ski into beautiful, largely pristine, soul-satisfying country.

Wilderness benefits, among other things, fish and wildlife and their habitat, clean air and water, scenic beauty, individual Alaskan recreationists, subsistence and sport hunters, subsistence, sport and commercial fishermen, visitors, and tourism operators–and it should help maintain or restore the natural soundscape: that is, natural quiet and the opportunity to hear and enjoy natural sounds.

Unfortunately–unlike the situation in lower 48 Wilderness–in designated Wilderness managed by the Forest Service in Alaska, neither the many people who treasure natural sounds and natural quiet, nor the birds and other wildlife that can be harmed by noisy motorized vehicles, are protected from the impacts of recreational snowmachines [in Alaska we generally call snowmobiles snowmachines]. These impacts include noise, which can be obtrusive and disturbing as a result of its loudness, its irritating variation in pitch, or its inappropriateness in an otherwise natural or wild setting–as well as additional impacts like air and water pollution, tracked up snowscapes, and the loss of the intangible, including spiritual, values that come with experiencing natural or wild land.

This ironic and disturbing situation results from the Forest Service’s flawed interpretation of Section 1110(a) of ANILCA [the Alaska National Interest Lands Conservation Act] [and the other federal land managing agencies virtually always interpret 1110(a) the same way]. Paraphrasing the pertinent language of this section, it allows the use of snowmachines for “traditional activities.” First of all, it’s questionable whether, at the relatively low level of recreational snowmachining occurring in 1980, that use can reasonably be characterized as “traditional,” especially considering the fact that Congress seemed to intend to carve out a very narrow exception to the general prohibition of snowmachines in Wilderness; this prohibition is a fundamental characteristic of the Wilderness Act. But even more telling is whether Congress would have intended, when it prohibited recreational snowmachining in the tamer Wilderness areas of the lower 48, to allow it in “wild” Alaska–a state which is a potent symbol of the wild and, from a historical perspective, of how people used to live and how our country used to be–an important historical benchmark.

We believe, as we said, that Congress intended to carve out a very narrow exception in Section 1110(a), and that the “traditional activities” for which snowmachines could be used (subject to reasonable regulations, and to prohibition after notice and hearing if such use would be detrimental to the resource values of the unit or area) were consumptive, subsistence-like activities, not snowmachining AS recreation. That is, the snowmachine would be used as transportation for hunting or fishing, not purely for recreation.

We suggest that the Forest Service re-examine the many time-tested values of the wild and of wildlands, including of course designated Wilderness, and seriously assess whether its policies truly protect the very important ecological and human (physical, mental, emotional, and spiritual) benefits of wilderness. It would seem to be the very antithesis of “wild” to use a machine recreationally to highmark and to track up (not infrequently with circles or figure 8’s) the beautiful snowscapes of entire meadows, lakes, and hillsides–often as far as the eye can see. Similarly, is it consistent with the commonly understood meanings of “wild” and “wilderness” to use a technology recreationally that destroys the peace and quiet of the backcountry, masks the ancient sounds of nature, and pollutes the air and water?

Additionally, there are millions of acres of public lands in Alaska (state and federal) that will never be designated Wilderness, a great many of which, if not most–in fact, nearly all at the present time–will always be available for recreational snowmachining. Wilderness should provide an older, more natural alternative to the use of newer and powerful mechanical technologies like snowmachines.

The Forest Service should take a very hard look at its Wilderness policy, especially in light of both vastly more recreational snowmachiners and far more powerful technology than was the case in 1980 [when ANILCA was enacted]–and should prohibit recreational snowmachining in designated Wilderness and in Wilderness Study Areas. It should do this because the Congress never intended to make the wild Alaska backcountry tamer, nosier, busier, more mechanized, and more artificial, than that in the lower 48. Alaska Wilderness should, if anything, be wilder. We sincerely hope we don’t have to resign ourselves to an Alaska that is wild only in our memories.

Access to Wilderness would not be denied. Recreationists would still employ truly traditional means of backcountry access–hiking, snowshoeing, skiing–but their modern, certainly not wild, technology would remain outside Wilderness boundaries, just as our cars do.

Logic and sound public policy support making some motorized vehicle exceptions in Alaska Wilderness (subject to reasonable regulations) for travel between villages and for subsistence–but not for non-essential, and harmful, purely recreational purposes.


Cliff Eames
Board Member
Alaska Quiet Rights Coalition