Chugach National Forest:Preliminary Need to Change, Wild & Scenic Rivers and Wilderness

June 10, 2015

Terri Marceron

Forest Supervisor Chugach National Forest

161 East 1st Avenue, Door 8

Anchorage, AK 99501

Dear Supervisor Marceron: The purpose of this letter is to express the comments of the Alaska Quiet Rights Coalition on the Preliminary Need to Change the Forest Plan, Wild & Scenic River Evaluation and Wilderness Area Inventory and Evaluation documents posted as part of the CNF plan revision process. We also reviewed other posted documents such as the Monitoring Reports, Monitoring Guide and Assessment report and wish to offer comments on these documents as well.

The Alaska Quiet Rights Coalition (AQRC) is a statewide, non-profit, volunteer organization which works with public land managers and comments on land use plans and permits to insure that natural quiet and natural sounds are recognized, and protected, as resources of our public lands. We advocate for quiet, non-motorized recreational opportunities and believe that separate trails and areas must be set aside for the use of the non-motorized recreationist if he/she is to have the recreational experience desired. As you are aware, AQRC was deeply involved in the 2002 Forest Plan and subsequent Kenai Access Plan planning efforts, particularly as they pertained to winter recreational opportunities. We are keenly interested in this current plan revision process and have a particular interest in following how CNF intends to implement the recent amendments to the Travel Management Rule as they pertain to over-snow vehicle travel.

We are delighted that the goals enunciated in the 2002 Forest Plan for recreational access will remain the same in the Revised Plan: maintain a quality experience for the motorized and the non-motorized users and recognize that it is important to provide the opportunity for quiet recreation. We support the decision to keep the strategic management directions for Travel Management in the Forest Plan and develop separate site-specific plans for winter and summer travel management plans which designate the specific roads, trails and areas for motorized and non-motorized travel and recreation. It is our understanding from the Anchorage meeting that you intend to develop the required separate summer and winter Travel Management plans by “importing” all the existing plans and decisions and will not be changing, or opening for public discussion, the road, trail or area designations. We do note, however, that the Assessment report acknowledges some existing conflicts between users and that infrastructure and terrain concentrations in CNF lead to difficulties in meeting the demands of the motorized and non-motorized recreationists. Please advise if our understanding is incorrect or if it is determined that it will be necessary to open the various designations to mitigate conflicts.

The Monitoring Guide, establishing the protocols for monitoring is dated September 2011. The posted Monitoring and Evaluation reports for 2006-2010 show that no monitoring was undertaken in regard to recreational purposes during those years. While monitoring was done in FY 2011, the Evaluation Report is not yet posted. It also appears than that the Assessment Report, dated November 2014 does not incorporate any monitoring data accrued since FY 2011 though reference is made to anecdotal information gathered. We wonder therefore if the situation as described in the Assessment is in fact accurate. It well may be that the pattern cited, of diminishing violations by motorized users, is currently correct, but without monitoring to back that up, it does raise questions. We also note that the Monitoring Guide indicates that the protocol adopted for the recreational component was a pilot to be re-evaluated after two years of implementation. If the protocol has in fact been re-evaluated, please advise of the changes.

AQRC fully supports the CNF staff eligibility and suitability determinations which concluded that segments of nine rivers within CNF qualify for Congressional designation under the National Wild and Scenic River System. We recognize that even without official designation, these segments are being managed to protect their scenic, recreational or wild values but believe greater, permanent protection is vital to insure these values are preserved for the benefit of future quiet recreationists. We also support the inclusion of the Copper River segment at Childs Glacier, if deemed suitable, in the recommendation to Congress. While we understand that small boundary adjustments have been made in the original boundaries of the Wilderness Study Areas, AQRC fully supports a recommendation to Congress to officially designate these areas as Wilderness. From reviewing the wilderness evaluation inventory on the website it would appear that CNF has successfully managed these wilderness study areas in a manner which has preserved the wilderness characteristics. Furthermore, the inventory which includes 99% of the entire forest, clearly indicates that a number of additional areas appear to qualify as wilderness and could be recommended for Congressional designation, such as Tashnuna River. We look forward to the recommendation for wilderness you make as part of this Forest Plan revision process.

AQRC was disappointed that no wilderness recommendation was made in connection with the 2002 Forest Plan, or subsequently. We have long believed that it was absurd that the second largest national forest in the country had no designated wilderness despite being, essentially, a wilderness forest. In connection with any wilderness designation recommendations, we request that the Forest Service re-examine its interpretation of 1110(a) of ANILCA, which allows a special motorized access exception to the Wilderness Act, by precisely defining what “the use of snowmachines … for traditional activities” means. As you are aware, the regulatory interpretation adopted by Denali NP & P of this phrase defined “traditional activity” as meaning the activity having occurred contemporaneously with the date of adoption of ANILCA and further determined that the activity was associated with consumptive uses. It would appear to us that the Forest Service position, pursuant to section 2326.1, R-10 Supplement 2300-99-2 to FSM 2300-Recreation, Wilderness and Related Resource Management, effective 1/27/99, is that “traditional activities” have been defined to include “recreation”, no timeline is required to establish what is “traditional” and use of a snowmachine for recreation has been transformed into allowing snowmachining as recreation. Please advise if there is other guidance on this issue.

AQRC has been informed that recreational snowmachining is now wide-spread throughout the WSA. We note that the Assessment Report indicates the FS is now assessing the extent of such use in the WSA as well as reviewing its ANILCA access policies. We are concerned that failing to “limit” the liberal FS interpretation of this provision will lead to recreational snowmachining being considered a routine, everyday activity in whatever areas are designated Wilderness despite what was intended to be a narrow exception to accommodate Alaskan circumstances. We do not believe Congress intended “traditional activity” to include recreational snowmachining.

Thank you for this opportunity to comment.

Sincerely yours, Brian Okonek, President, Alaska Quiet Rights Coalition

P.O. Box 202592 Anchorage, AK 99520