Delta Wild and Scenic River Draft EA


It’s the great, big, broad land ‘way up yonder,

It’s the forests where silence has lease;

It’s the beauty that thrills me with wonder,

It’s the stillness that fills me with peace.

-Robert Service

May 6, 2010

Bureau of Land Management

Glennallen Field Office

Delta River Planning Process

ATTN:  Heath Emmons

P.O. Box 147

Glennallen, AK 99588

Re:   Delta Wild and Scenic River Planning

Dear Heath Emmons:

The following are the comments of the Alaska Quiet Rights Coalition (“AQRC”) on the Draft Environmental Assessment for the Delta Wild and Scenic River Planning Process.  Thank you very much for the opportunity to participate in this important process.

A.  About AQRC, and General Comments on the Natural Soundscape in Alaska

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 artificial, noisy mechanization.

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.  Nor is AQRC’s goal a purely negative one (that is, the elimination, in at least some significant portion of the outdoors, of artificial noise).  Our hope is to re-create the opportunity to both enjoy natural quiet for its own sake, and to be able to hear and enjoy, without noisy distractions, the beauty of natural sounds like chickadee songs, raven calls, leaves rustling in the wind, and even the quiet, just audible descent of falling snow.

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.

Ironically, accessible natural quiet can be easier to find in the lower 48, in the many designated Wildernesses where motorized recreation is prohibited, than in supposedly wild Alaska, where many federal land managers erroneously believe that ANILCA requires them to allow obtrusive recreational activities, such as snowmachining, even in designated Wilderness.  Recreational snowmachining, inaccurately characterized as “traditional,” is allowed in spite of a number of adverse impacts and the conflicts it often creates with truly traditional, low impact means of access like walking, snowshoeing and cross country skiing.

AQRC believes in a fair and balanced allocation of the state’s public lands for both non-motorized and motorized recreation—there is plenty of room for both.  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—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.

AQRC’s focus in these comments, consequently, will be on minimizing noise impacts, primarily from motorized recreational vehicles, but also from other artificial noise sources.  Our emphasis is on the social impacts of artificial noise, since land managers rarely do an adequate job of eliminating or minimizing these impacts.  But as we said above, minimizing those impacts provides other benefits as well—extremely important benefits, and ones which are far from merely incidental—such as helping to protect clean air and water, fish and wildlife, scenic beauty, and wilderness character.  And, finally, the vast majority of AQRC’s members and supporters, and others with a similar interest in natural quiet and natural sounds, are seeking not only a quiet experience, but one that is natural in other ways as well, and that provides the chance to enjoy primitive, muscle-powered forms of recreation in a high quality environment.


1.  Natural quiet and natural sounds.  BLM deserves a considerable amount of credit for starting to look seriously at this previously overlooked resource.  The DEA identifies this resource as an issue, looks at it as part of the affected environment, briefly assesses the impacts to it under the various alternatives, and references it in many of the charts that describe the preferred alternative.  The agency also proposes a number of actions that will reduce the impacts to natural quiet and natural sounds.  This is a very encouraging start, and AQRC is certainly appreciative.  But particularly for this especially important, congressionally designated unit, we believe the agency could have, and should have, done better, as we discuss below.

2.  Soundscape plan.  A comprehensive soundscape plan would probably require more resources than BLM has available for such a task in this area at this time.  Even so, at least a scaled-back soundscape plan should be undertaken in order to obtain baseline data and to start planning for maintaining and restoring natural quiet and natural sounds in the area.

3.  Motorized use.  We very much appreciate the proposed prohibition on both powerboat use and aircraft landings in Zones 1 and 4 during June and July—but in a special place like this Wild and Scenic River, appropriate, responsible management requires several important additional restrictions on motorized activities.

a.  Jet skis, airboats, and hovercraft.  These types of watercraft are EXTREMELY noisy and irritating, and they can, and of course too often do, because of their particular technical capabilities, seriously harm, both mechanically and because of pollution, lake- and river-side vegetation/habitat and the fish and wildlife that depend on that habitat.  Their use should not be allowed anywhere in the corridor.

We are very disappointed at BLM’s failure to take the commonsense approach of proposing to ban these harmful and unnecessary craft now.  The idea that the agency should wait until these craft become a serious problem in the corridor before banning them is incredibly short-sighted.  We have heard this argument from land managing agencies many times before, way too many times, and it is never a good policy.  At the present time, the constituency for allowing these watercraft in the corridor is relatively small; after their use there has become established, almost by definition the constituency has become sizeable enough to make banning the craft extremely difficult, if not impossible, politically.

b.  Other powerboats.  Powerboats are permitted almost everywhere in Alaska’s waters.  There should be some places where quiet water recreation can be enjoyed, and where wildlife can be free of noisy disturbances.  A relatively small, congressionally dedicated area like this Wild and Scenic River is just such a place.

Recreational powerboats should be allowed only on Round Tangle (campground users will recognize that there will be somewhat more noise here than in other areas), with a 15 horsepower limit (BLM’s present recommended limit).  This 15 hp limit should be maintained for subsistence use as well on the lakes, should exceptions be made there for big game subsistence hunting (although it is entirely possible to have a successful subsistence hunt, including transporting the game, on the lakes by non-motorized canoe).  Zone 4, and the entire Wild section of the river (surely “wild” should mean something), should be non-motorized for all purposes.  Powerboats could be allowed for subsistence purposes only in Zone 5, with motors no more powerful than is necessary for safety.

Finally, the small Tangle River reach between the wayside and where it empties into Round Tangle should be closed to all powerboat use now—not after a problem develops.  BLM recognizes that areas that now seem impracticable for motorized use could become routinely useable with “improvements” in technology.  It is foolhardy to wait until that happens to try to close this beautiful little fly fishing spot to an inappropriate and  unnecessary use.

c.  Aircraft landings.  Aircraft landings and takeoffs are very noisy.  They should be banned throughout the corridor unless it can be demonstrated that airplanes are used for transportation to the area (as opposed to within the area); if that’s the case, Round Tangle only could be made available for landings, and only at approximately current levels of use.

d.  Aircraft overflights.  BLM has proposed almost nothing to manage aircraft flights over the corridor.  Overflights, especially commercial ones for purposes like flightseeing or resource extraction, can create serious adverse impacts for both passive and active recreationists on the lands or waters below, and for some wildlife.  BLM should do everything possible to prevent this situation from developing and adversely affecting the experience along the Wild and Scenic River.  For overflights with no landings on federal lands, and therefore presumably no permit requirement, BLM should seek assistance from the FAA, and if that fails, should seek voluntary compliance with guidelines designating a zone of airspace above and adjacent to the river corridor within which flying should not occur except for reasons of safety when weather conditions are adverse.  Where a permit is required for landing, a condition of that permit should be that flying is prohibited within the designated zone except for safety reasons.

e.  ATVs.  Ideally, there would be no ATV use in this very special corridor.  There are millions of acres of state and federal public domain land where their use is allowed with virtually no effective restrictions.  We applaud BLM’s proposal to close to motorized use, and attempt to rehabilitate, all of the motorized social trails in the corridor.  And, although it’s unfortunate that there are two designated subsistence and mining ATV trails there (Top of the World and Rainey Creek), we do not oppose their use, for these purposes only, by permit.  Recreational motorized use on these trails should not be allowed.

f.  Snowmachines.  Snowmachines can be substantial polluters.  Their use in the corridor should be strongly discouraged.

4.  Non-motorized recreation.  AQRC advocates not only for the elimination or minimization of motorized recreational use and artificial noises on the public lands (with the many benefits thereby provided), but also for the specific provision of high quality muscle-powered recreation opportunities.  Consequently, we generally support the designation of both trails and larger areas, screened if at all possible from the impacts of motorized use, for non-motorized use only.  We therefore heartily support BLM’s proposals for the designation/creation of non-motorized trails in the corridor—with one exception.  After talking with local residents who use the area, we suggest not designating the Rock Creek Trail in order to maintain a sustainable berry resource for those residents.

5.  Property acquisition.  It would be a shame to see further development on the Tangle Lakes Lodge property.  BLM has indicated its willingness to consider purchasing that property to prevent inappropriate additional development.  It should act now, while the property is for sale, in order to prevent the substantial scenic and noise impacts that would result from additional development there.

6.  Other.  We very much support the proposed general prohibition on fireworks, recreational shooting, and chainsaws in the corridor.  We think it very inappropriate and unnecessary, however, to allow chainsaw use in the campground.  Just because a certain level of noise is inevitable in the campground (or to a lesser degree, elsewhere in the corridor) doesn’t mean that additional noise doesn’t exacerbate the problem.  It’s quite simple—less noise is better than more noise.  Chainsawing doesn’t have to occur in the campground, and it shouldn’t be allowed.  Similarly, generator use is very irritating, and should be banned in the campground from 5 pm to 9 am so that people can enjoy some peace and quiet after a busy, active day as well as get a decent, undisturbed sleep.

Thank you again for the chance to comment on this draft EA, and for the many good proposed decisions.  We very much hope, however, that BLM will see fit to significantly strengthen the final document and make its management scheme for this special corridor a truly, not just partly, responsible one that both the agency and the public can be proud of.


Susan Olsen

President, Alaska Quiet Rights Coalition

P.O. Box 202592

Anchorage, AK 99520