CNF Spencer Glacier Recreation Permit: EA Scoping Comments

January 20, 2014
Glacier Ranger District
PO Box 129
Girdwood, AK 99587-0129

Attn: Teresa Paquet

Dear Ms. Paquet:

The purpose of this letter is to provide the scoping comments of the Alaska Quiet Rights Coalition (AQRC) on the proposed EA concerning the number and type of commercial recreation services at Spencer Glacier Whistle Stop.

As advocates for natural sounds and natural quiet on public lands, AQRC is pleased that this area is designated for non-motorized recreation and are very supportive of the further development of the additional whistle stops. We have no concern about the types of non-motorized activities shown in the table, but find the proposed number of parties, for some activities, and the maximum group sizes, for all activities, to be excessive. We understand that the number of parties and group sizes are maximums and are those set forth in the current forest management plan.

There are a number of reasons for our belief that both sets of numbers are excessive. First, the vast majority of guided commercial recreational activities listed would take place within the four hour or so window created by the train schedule. Secondly, that means that not only would different activities occur in the same place at the same time, but that the groups within a single activity would be operating at the same time. For example, the voyager canoe participants (potentially 300 persons in, say, 20 canoes) would be on Spencer Lake along with, say, 30 rafts holding 300 people going across the lake to the Placer River, for at least part of the same time. Likewise the 7 parties of 30 each, participating in guided hiking to Spencer Glacier, would all be on the same trail at the same time accompanied by the 3 glacier climbing parties of up to 30 in each party for at least part of the time. For similar reasons we think the possibility of up to 3 parties of 30 each camping outside of the developed recreation area, on the very same night, is at the very least an environmental disaster…think sanitation, damage to vegetation, etc. The result of issuing permits with these magnitudes would be that everyone participating in these non-motorized activities would see, hear and experience every other participant, including many of those visiting, but not participating in any guided recreational activity.

Our final, and overall point, is that allowing such high numbers we believe destroys the purpose of the whistle stop project and its Forest Plan goals. Our recollection is that originally this project was approved in order to provide, particularly for tourists, “a touch of wilderness” by allowing them to access a backcountry area otherwise inaccessible. We suggest that at least part of the “vision” for the project–backcountry access–is compromised by such numbers for one could hardly consider that being in the midst of such activity constitutes a “backcountry” experience. We also believe that the possible level of activity does not support the forest-wide goal of “maintain(ing) quality settings for non-motorized recreational opportunities” as cited in the material sent. While we are not aware of what is permitted under the classification of a “Developed Recreation Complex”, which designates much of this whistle stop area, we firmly believe that the more developed and crowded an area becomes the less it is possible to experienced it as wild, backcountry or unique. We are aware that a season’s average visitation of 5,000 visitors means a rough average of 50 people a day which is in no way close to the maximums shown in the table. However, now is the time to set realistic limits in order to protect the long-term success and purpose of the whistle stop at Spencer Glacier as well as the other proposed stops.

In short, AQRC urges CNF to sharply reduce the number of parties and number within a group in order to protect and preserve the Spencer Glacier as a backcountry experience for tourists and a stepping-off point for Alaskans who truly want a real backcountry experience.

Thank you for this opportunity to offer scoping comments.

Sincerely yours,

Susan Olsen, member of the board of directors
Alaska Quiet Right Coalition