November 15, 2018
From: Alaska Quiet Rights Coalition
P.O. Box 202592
Anchorage, AK 99520
To: Kachemak Bay State Planning
Dear Monica Alvarez;
Thank you for the chance to comment on the draft Kachemak Bay State Park and Kachemak Bay State Wilderness Park Management Plan.
The Alaska Quiet Rights Coalition (AQRC) 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.
Alaska’s natural beauty, wildness, wildlife, expanses of undisturbed open space, and peace and quiet are among its most cherished values, and Alaskans, our visitors, and future generations have the right to experience the natural sights, sounds and quiet beauty of our state. In the vast majority of cases, the obtrusive noise, summer landscape degradation and winter snowscape defacement, exhaust, and dangers of motorized recreation are incompatible with those special natural experiences.
Unfortunately, though, natural quiet and the opportunity to hear and enjoy natural sounds are increasingly hard to find in our state—a fact which would surprise the great majority of non-residents for whom Alaska is a potent symbol of the natural and the wild, not of noisy mechanization. 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 only 10 or 20 years earlier.
Consequently, not only do we need to protect those quiet areas that still remain, but we need to restore many previously quiet lands to their former, more natural, more pristine condition. Most of us, until quite recently, took the restorative quiet of the outdoors for granted. We assumed that the backcountry would always provide a quiet refuge from the noise, busyness and artificiality of our towns and cities. That assumption, to our great chagrin, has proven to be false. We now know that natural quiet and natural sounds require our—the public, and the public’s stewards, the land managers—constant vigilance if they’re to survive even into the middle of our present century.
AQRC believes in a fair and balanced allocation of the state’s public lands for both non-motorized and motorized recreation. At the present time, there is a gross imbalance on the public lands that both unwisely and inequitably favors motorized recreation over muscle-powered recreation. In the interests of both good stewardship and fundamental fairness, this imbalance needs to be rectified. A reasonable proportion (we’ve suggested 50%) of public lands and facilities of all jurisdictions throughout the state should be set aside for quiet recreation—thereby also helping to protect clean air and water, fish and wildlife, scenic beauty, and the wilderness character for which Alaska is famous worldwide.
Natural quiet and natural sounds should be recognized by all public land managers as critical resources in and of themselves that deserve no less consideration than clean air and water or fish and wildlife and their habitat. Soundscape plans should be prepared. The analysis of proposed agency actions should include a determination of the possible effects on natural quiet and natural sounds and on the humans and wildlife that enjoy or depend on them. Alternatives should be considered.
Several general principles should apply to all public land decisions regarding the use of recreational motorized vehicles, both private and commercial, and whether used on the land, water, or air (some of these principles will not apply to all types of vehicles).
1. An analysis should be done of the possible effects on natural quiet and natural sounds and on the humans and wildlife that enjoy or depend on them.
2. Several alternatives should be considered, including ones that eliminate and that minimize impacts and conflicts.
3. Actions that would result in increased in motorized activity should be balanced with measures to increase opportunities for high quality non-motorized recreation.
4. Public lands should be closed (to motorized recreational vehicles) until specifically opened, rather than wide open until closed (the latter policy is the case on most public lands at the present time).
5. Where areas are opened to motorized recreation, non-snow travel should be on designated, posted trails only. Cross country travel should be prohibited. Even in open snowmachine areas, travel only on designated trails will sometimes be appropriate.
6. Motorized recreational vehicle use should be allowed only where it will not cause significant environmental or social harm.
7. Where motorized recreation is allowed, adequate funding for monitoring and enforcement must be provided.
8. Motorized recreation should not be allowed on lands designated, managed or proposed as Wilderness.
AQRC believes that the draft Kachemak Bay State Park and Kachemak Bay State Wilderness Park Management Plan does not protect the natural soundscape for those seeking a place to recreate free of motorized noise and the impacts that noise has on wildlife as well as it should.
Before I comment on how AQRC believes the plan can be improved we want to commend the plan as is stated in Chapter 4, page 52 that the permitting of PWC’s was “eliminated” from consideration. PWC’s are able to be change speed and direction quickly, are able to be operated in shallow water, are noisy and are numerous. Their recreational use would adversely affect wildlife and other park users.
Chapter 4, page 49 acknowledges that there is interest for additional heli skiing landing areas and that drone use is increasing. Helicopter operations have been shown to have detrimental affect on wintering wildlife including mountain goats and certainly take away from a winter backcountry experience for those seeking quiet places to recreate. Drones, while wonderful tools for research and rescue, are annoying and invasive. There needs to be places on public lands where people can choose to go to get away from helicopter and drone recreational use. Helicopter skiing and recreational drone use should not be permitted anywhere in the park.
Chapter 5, page 60 states that aircraft “will remain restricted to areas identified in current regulation.” That helicopters “may continue to be authorized at Grewingk Glacier for scenic flight tours” and for heli skiing in the Sadie-Tutka Management Unit. If helicopter scenic flights landings are to be continued to be authorized at Grewingk Glacier the total number of landings per day should be capped to allow for periods of time when helicopters can not be heard by those engaging in activities on the ground and waters in the area. The sound of helicopters conducting flight seeing trips should not be allowed to dominate the soundscape. An altitude for helicopter approach and departures and a flight path from the glacier that best minimizes the noise of the engine(s) and rotor blades for those on the ground should be determined and recommended. Helicopter assisted skiing should not be allowed in the park. Any additional helicopter landing zones in the Grewingk Glacier area that may be considered as the glacier ice recedes needs to be carefully considered. Helicopter activity can disturb wildlife including moose, bear and waterfowl as well as other park users that are paddling boats, hiking, camping and wildlife viewing. It is important that any recreational helicopter use (dropping off sight seers, scenic flights, etc.) do not adversely impact other park users. To make sure that helicopter flights are not adversely affecting wildlife the Alaska Department of Fish and Game should conduct studies to determine where prime bear denning and feeding areas are, what terrain mountain goats use at different time of year, where prime moose habitat is and places waterfowl and shorebirds are using during migration and where sea birds are nesting so that proper management decisions can be made to regulate helicopter use.
Chapter 5, page 61 the plan states that Upper Hazel Lake may be opened to motor boats and that float planes may be able to land there as well. It is important that where motorized use is permitted that there are regulations in place that will protect wildlife and non motorized users of the lake. This could include a limit on outboard motor horsepower and type to reduce noise, speed of boats and wake size. There should be times of day when motorized use is not allowed on the lake to give non motorized users quiet time on the lake.
Chapter 5, page 64 states that snowmobiles may be allowed within specifically designated areas in Natural Zones. Page 84 states that snowmobiles will be allowed in Natural and Recreational Zones only for park management. Recreational snowmachining has had a tremendous negative impact on non motorized winter recreation and on wintering wildlife in many parts of Alaska. It is really important for the park to prohibit recreational snowmachining to provide a place for people and wildlife to get away from motorized noise.
Page 73 states that drones may be authorized in Natural Zones. Recreational use of drones is expanding at a rapid pace. Many people find it objectionable to hear the buzz of drones or to have their privacy invaded by drone use. Drone operations can intentionally or inadvertently disturb wildlife. Scientist that have reviewed studies about disturbances of wildlife by Unmanned Aircraft Systems (UAS) recommended “that UAS flights be avoided unless they constitute the least invasive option for necessary wildlife studies, and discouraged if they are performed just for leisure purposes such as flying or filming.” Recreational drone use should not be allowed in any of the park’s zones.
Page 75 states that airboats and hovercraft can only be used on salt water. Both airboats and hovercraft are very loud and can be heard from a great distance. Both can disturb wildlife and damage their habitat. Neither should be allowed to operate within the park.
Page 77 states that chainsaws will be allowed in Wilderness Zones and that generators will not be allowed in Wilderness Zones. Chainsaw noise would definitely take away from the wild character of a Wilderness Zone. While chainsaw use may be necessary at times for park management AQRC does not believe that recreational chainsaw (using a chainsaw to cut wood for a camp fire for example) use should be permitted.
Alaska is a special place well known for its’ vast wildlands and spectacular scenery. People live here, recreate here and travel from afar to experience untrammeled natural beauty and a chance to view wildlife. Kachemak Bay State Park and Kachemak Bay State Wilderness Park is a gem among many in Alaska. Noise created by motorized forms of recreation is increasing every year. Alaska State Parks should be a place where people can choose to recreate away from motorized recreational noise.
Brian Okonek, president
Alaska Quiet Rights Coalition