Comments on LAS 29362

December 17, 2013
Candice Snow
Dept. of Natural Resources
550 West 7th Ave., Suite 900c
Anchorage, AK 99501

Dear Candice Snow:

The purpose of this letter is to offer the comments of the Alaska Quiet Rights Coalition (AQRC) on LAS 29362. AQRC is a state-wide, non-profit organization which seeks to preserve natural sounds and natural quiet on our public lands for the benefit of wildlife, non-motorized users and cabin owners. We believe these are natural resources which deserve protections similar to those accorded clear air and clean water. We do not believe that multiuse trails and areas allow the non-motorized recreationist the recreational experience he/she seeks and urge public land managers to allocate, in a fair and balanced manner, separate areas and trails for both user groups.

It is our understanding that this permit request, LAS 29362, by Cruz Construction is for the purpose of “brushing” a 20 foot-wide, 43.9 mile, “trail” from the Denali Highway to a private parcel on the Susitna River in order to allow 8 different types of heavy-duty trucks to bring in construction supplies to the private parcel. The request is for year-round travel starting Jan. 1, 2014 and ending April 30, 2017. The proposed route is all on state land. We further understand that Cruz Construction does not have a contract which requires Cruz to obtain this permit, rather it is being sought in anticipation, or hope, of a possible contract.

AQRC is concerned that granting this permit will result in a de facto road that is built without proper supervision or construction methods and which is outside of DNR’s authority to grant. We are concerned about the damage to the tundra, wetlands and streams should these heavy vehicles be allowed to travel cross-country. We are concerned that this road will act to destroy the existing wildness, over a very large area, and adversely affect the unique driving experience for which the Denali highway is known and valued. The road will invite snowmachine and ATVs on the “trail” and into the area, year round, with adverse effects on wildlife and hunting opportunities. And, since DML & W lacks citation authority to enforce any stipulations which are mandated we fear that by the time someone goes to monitor how Cruz has “brushed” the road, the environmental harm will have occurred.

AQRC believes that the ramifications of granting this permit are so many and so extensive, from the adverse environmental damage created by such heavy truck traffic (the volume/frequency is not stated) to opening up the Denali Highway and surrounding area to development, that this should be subject to a full public planning process; not processed or approved simply as a land use permit.

Should DNR permit this activity, AQRC urges, at the very least, that the stipulations limit all brushing and travel to the winter, under appropriate snow cover and depth of frost measurements. The applicant must be held responsible for any fuel spills and all clean-up measures and costs. Above all, we urge DNR to make this permit effective only when and if the applicant can prove to DNR that it is under contract to provide this hauling service and will be able to fulfill its contractual responsibilities when restricted to winter work and travel only.

Thank you for this opportunity to comment.

Sincerely yours,

Susan Olsen, member of the board
Alaska Quiet Rights Coalition