October 13, 2009
Monica Alvarez, Project Manager
Division of Parks and Outdoor Recreation
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 on the Public Review Draft of the Chugach State Park Trail Management Plan.
The Alaska Quiet Rights Coalition (AQRC) is a statewide nonprofit organization which is dedicated to protecting the rights of Alaskans to quiet places for the benefit of public land users, home and cabin owners, communities, businesses, wildlife, visitors and future generations. AQRC advocates for a fair balance between non-motorized and motorized recreational opportunities on our public lands and believes natural quiet and natural sounds are resources to be protected by land managers. AQRC members and supporters Â recreate year-round in Chugach State Park.
First, we wish to congratulate the Division of Parks and Outdoor Recreation for adopting a comprehensive system of trail classification. It provides a clear, systematic approach to future trail development and renovation and informs the public. Â You also are to be congratulated for having completed the documentation of the the trails through the GPS system
We do, however, take general issue with this plan in two ways. First, we believe it is a mistake to separate the revision of the Chugach State Park Management Plan into three components( trails, access and management) which are released at different times. By developing the plans for trails and access points before the overall management plan, you limit the management plan to policies which simply implement the two previous plans instead of raising and deciding the overall park policies, such as carrying capacity, whether and where new trails are needed or where growth should be encouraged or discouraged. . The trail plan should flow from the overall perimeters of the management plan and not vice versus. How can you decide what trails are needed until you have articulated, and adopted, Â recreation goals and objectives in the management plan?
Our second criticism, flowing from the first, is that the trail plan presented is essentially just a trail classification plan. It lacks substance. The existing trails are simply categorized, some new trails are proposed and all without any discussion of whether the existing trails serve the needs of the user groups or whether there is a need for a new trail in this location with these characteristics. For example, what is the rationale and where is it discussed, for building new nordic ski trails when there are multiple such trails in the MOA or for opening particular trails to mountain bikes ? This kind of discussion and analysis needs to be part of this plan, in the absence of the overall direction and policy a management plan would provide.
We also have a number of specific comments and recommendations as follows below.
a)Since we realize that renovating an existing trail or building a new a trail to its designed use and class depend on future funding, AQRC recommends that renovation of existing trails should take precedence over building or acquiring new trails.
b) We Â recommend that where bicycles are allowed on Â multi use snow trails along with hikers and cross-country skiers, that they be required to use â€œfatâ€ tires so as to not wreak the trailâ€™s snow surface.
c) We question whether all trails open to bicycles in summer are suitable for winter use due to possible conflict among users caused by incompatible rates of travel and abilities to maneuver on snow. The current regulations which open trails to bicycles do not specify terra or snow use only. Accordingly, this means that all trails once opened allow bicycle use year- round regardless of whether, as a snow trail, that managed use has been listed. We recommend that the Division structure the regulations so that terra or snow use can be specified for certain trails.
d) We Â question whether it is a safe practice to allow skijoring as a managed use on a trail designed for nordic skiing. We raise a similar safety question in regards to managing use for both skiing and snowmobiles on the same trail.
e) We strongly oppose building a trail for summer use of ATVs on the south side of Eklutna Lake. That trail would mean that in summer, the entire lake would be surrounded by a connected ATV trail which will encourage increased ATV traffic. Â The noise could displace anyone recreating on the Â lake as well as others, such as hikers, bikers, horse riders or campers. Moreover, pollution from gas and fumes from ATVs could threaten Eklutna Lake as a water source for the Municipality of Anchorage. We also question whether the winter closure could be enforced.
f) It appears to us that the proposed trail plan would permit bicycles (segments 517,518, and 519 a and b) Â into the wilderness area of the park. If our interpretation is correct, the issue of whether bicycles are to be allowed in wilderness is a policy change that needs to be addressed. AQRC supports the original decision in the 1986 trail plan which Â prohibit motorized and mechanized vehicles from the wilderness area of Chugach State Park.
Thank you for this opportunity to comment.
Susan Olsen, President, Alaska Quiet Rights Coalition