October 3,2015
Monica Alvarez
Chugach State Park Planning
550 West 7th Ave. Suite 1050
Anchorage, AK 99501
Dear Ms. Alvarez:
The purpose of this letter is to offer the comments of the Alaska Quiet Rights Coalition (AQRC) on the Issue Response Summaries and List of Recommended Revisions for the Chugach State Park Management and Trail Management Plans. We understand that the Public Review Drafts, accompanied by the List of Recommended Revisions will constitute final plans and be presented to the Commissioner for adoption. We further understand that the draft Access Plan is now considered a technical document which provides guidance but is not subject to approval.
As you know, AQRC is a non-profit, statewide organization which is dedicated to protecting the rights of Alaskans to quiet places for public land users, cabin and home owners, small businesses, wildlife and visitors. We work with public land managers to protect the landsʼ resources of natural quiet and natural sounds and to achieve a fair balance of the recreational opportunities available to the non-motorized and the motorized recreational user.
AQRC has followed these planning efforts closely: commenting on May 28, 2008 on the draft Management Plan Goals and Objectives and providing scoping comments; commenting on October 13, 2009 on the draft Trail Management Plan; participating in a group letter dated August 19, 2011 that objected to the lack of timely coordination and review of the draft Access and Trail Management Plans relative to the overall Management Plan; and, comments on the draft Management Plan on September 5, 2011. We consider this to have been a long, drawn-out, and confusing planning process.
We find the Recommended Revisions for the draft Management Plan to be quite minor, primarily fixing some errors and adding clarifications. While we appreciate that some of our specific comments concerning activities compatible with wilderness values led to revisions, our primary concerns have not been addressed. Our various communications have all stressed that the primary experience folks want in CSP is the ability to recreate in a natural, somewhat wild environment, whether in the Recreational Development, Natural or Wilderness Zones of the park. Instead, we believe the proposed Management Plan is very unbalanced in that the magnitude of proposed facilities and recreational activities plan will adversely change the nature of the park experience and affect park resources. We understand that most of this increased activity will take place in the Recreational Development zone, or front country, but in the seeming absence of any data to back up a sense of the carrying capacity, we fear the park has no ability to judge when to limit development or impose limits. Some of us now consider parts of Kincaid Park to be an urban park, with urban surroundings and activities; we do not want Chugach State Park to fall into the same trap wherein it is believed that all uses must be accommodated.
We find the proposed Trail Management Plan to be highly ambitious, even phased over a twenty-year time period. As originally voiced in our Oct. 13, 2009 comments on the Draft Trail Plan we remain troubled by the lack of data, analysis or discussion to support the various decisions made to build a new trail here, open this one to bicycles, classify this one as class X. The Issue Response Summary repeatedly justifies decisions in regard to specific trail designations on the grounds that the “plan seeks to strike a balance between expanding recreational opportunities and preserving existing experiences”. In our opinion, we believe the plan has very successfully fulfilled the “expansion” portion, especially for bicycle users, but in so doing, fails to “preserve existing experiences” for the principal park user, the walker or hiker. The assumption seems to be that you can add a different user group, using a different mode and speed of travel, without affecting the experience of the other, i.e., you can add bicycle travel to a heretofore walking trail without affecting the hikerʼs or skierʼs experience.
The trail standards for sustainability set forth in the Plan clearly will help in preserving some park resources. However, we find little attention is given to the need to also preserve the parkʼs other resources, such as wildlife, scenic and wild qualities, when accommodating recreational needs. In our opinion, It does not serve park values or the public which flocks to CSP because of its wild, natural values to allow (or cause) the recreational zone to become a sacrifice zone in order to accommodate all users without regard to carrying capacity.
To assure the success of the plan, we recommend that until improvements have brought trails up to the standard designated, new uses should not be introduced. New trails should not be constructed until maintenance of existing trails is completed. Further, we suggest that without a vigorous public education effort on trail etiquette, increased signage and on-the-ground enforcement capability, user conflict will grow. For example, a number of the trails proposed to be opened to bicycle use “end” at trails which are not proposed to be opened to that use. We believe the odds are very high that the bicyclist will not turn around but continue on. Also, since many additional trails or segments are opened up in this plan, folks will simply assume X trail is now open, regardless of actual designation.
Thank you for this opportunity to comment on these final plans.
Sincerely yours,
Brian Okonek, President
Alaska Quiet Rights Coalition PO Box 202592
Anchorage, AK 99520