Dec. 12, 2009
Alaska Quiet Rights Coalition
P.O. Box 202592
Anchorage, AKÂ 99520
Denali State Park Trail Management Plan
550 West 7th Ave, Suite 1380
Anchorage, AKÂ 9905-3561
Dear Claire Holland LeClair, Project Leader :
Thank you for the opportunity to comment on the Denali State Park Trail Management Plan.Â Â The Alaska Quiet Rights Coalition (AQRC) is very pleased that Alaska State Parks is working on a trail plan for this increasingly popular park unit.
The Alaska Quiet Rights Coalition) 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.
Alaskaâ€™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.Â 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 and with quiet homes and neighborhoods.
Unfortunately, though, natural quiet and the opportunity to hear and enjoy natural sounds are increasingly hard to find in our stateâ€”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.Â 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.Â Most of us, until quite recently, took the restorative quiet of the outdoors for granted.Â We assumed that the backcountry would always provide a quiet refuge from the noise, busyness and artificiality of our towns and cities.Â That assumption, to our great chagrin, has proven to be false.Â We now know that natural quiet and natural sounds require ourâ€”the public, and the publicâ€™s stewards, the land managersâ€”constant vigilance if theyâ€™re to survive even into the middle of our present century.
Denali State Park offers wonderful opportunities for hiking on Kesugi and Curry Ridges from where magnificent views of the Alaska Range can be enjoyed.Â Before planning the upgrade of exiting trails or the routing of new trails, State Parks needs to determine what the carrying capacity of the trails will be, how to preserve and protect the soundscape and carry out wildlife studies to map critical habitat that trails need to avoid.Â (The proposed Visitor Center will attract thousands of people to hike on Curry Ridge and it is possible that hundreds of Boy Scouts from a camp being built at Blair Lake will take “adventure hikes” in the park each week.)
It is important to preserve Kesugi Ridge and Curry Ridge as outstanding backpacking wilderness experiences. Reluctantly we accept trail hardening, toilets and designated camp sites if necessary.Â We question whether Class 1 tread classification of up to 12 inches is appropriate for hiking on the tundra as all that is needed is a path that is well drained and sufficient to define the trail corridor. Existing trails, and any future new trails, need more regular maintenance than they now receive.Â Grass and brush need to be regularly trimmed, bridges repaired and downfall cut out.Â Existing trails that are either too steep to control erosion or lead people into prime bear feeding habitat (along salmon streams) need to be rerouted.
New trails: Due to the tundra surrounding the site of the Visitor’s Center, the trails must be very carefully designed so that the tundra is not beaten down and people stay on the trails.Â All trails around the VC must be hardened, designed so shortcuts cannot be made, fewer loops than proposed should be developed so less area is impacted and walkers see fewer people and rangers ever present to make sure folks stay on the trails. Instead of a boardwalk all around the wetland at the north end of the lake place it just on east side.Â A hardened trail needs to be put in to get hikers from the VC up to Curry Ridge.Â A new trail should be put in to take a hiker from the VC down to Blair Lake.Â A trailÂ from the railroad on the west side of the Susitna and Indian Rivers up to the Kesugi Ridge trail would make it possible for people to hike in Denali State Park from the railroad.Â Assuming the Transportation Center is open in the winter, (a) groomed ski trail(s) for skiers should be developed on the surrounding benches and placed soÂ as to take advantage ofÂ the beautiful views.
AQRC believes in a fair and balanced allocation of the stateâ€™s public lands for both non-motorized and motorized recreation.Â 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.Â In the interests of both good stewardship and fundamental fairness, this imbalance needs to be rectified.Â A reasonable proportionÂ of public lands and facilities of all jurisdictions throughout the state should be set aside for quiet recreationâ€”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.Â Soundscape plans should be prepared.Â 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.Â 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.Â 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.Â Several alternatives should be considered, including ones that eliminate and that minimize impacts and conflicts.
3.Â Actions that would result in increased in motorized activity should be balanced with measures to increase opportunities for high quality non-motorized recreation.
4.Â 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.Â Â Even in open snowmachine areas, travel only on designated trails will sometimes be appropriate.
6.Â Motorized recreational vehicle use should be allowed only where it will not cause significant environmental or social harm.
7.Â Where motorized recreation is allowed, adequate funding for monitoring and enforcement must be provided.
8.Â Motorized recreation should not be allowed on lands designated, managed or proposed as Wilderness.
At presentÂ the entire area of Denali State Park is open to snowmachine use as long as there is adequate snow cover.Â AQRC requests that parts of Denali State Park be closed to snowmachine use for people seeking quiet recreation and for the protection of wildlife and habitat.Â In several other regions of the park AQRC requests that snowmachines be restricted to trails for the protection of wildlife, habitat, winter scenery and to make the park multiple use friendly.Â It is time to protect and restore natural quiet and the opportunity to hear and enjoy natural sounds to Denali State Park.Â There is great spiritual and restorative value in the soundscape resource of wild quiet and natural sounds in our ever increasing noisy world.Â Alaska’s State Parks need to protect this important quality that its lands can provide if managed appropriately.
To provide places for quiet winter recreation AQRC recommends that Alaska State Parks:
1)Close Byers Lake and surrounding area to snowmachines. This would make a great area for family’sÂ to ski and snowshoe in the forest around the lake.Â There are three public use cabins that are close to the George Parks Highway making them easily accessible.Â Snowmachines could be used to service the cabins.
2) Close the south end of Curry Ridge to snowmachines from Troublesome Creek parking area dueÂ east to the Susitna River with the Curry Lookout included within the closed area.Â A snowmachine trail approximatelyÂ following theÂ section line from the highway east to the ridge topÂ would form the northern boundary of the closed area. This would mean that the road to theÂ VC and all trails surrounding the VC would be closed to snowmachines. While everyone would be welcomed to warm up and learn about the South Denali region in the Transportation Hub building, travel up the road toÂ the VC and its non-motorized trails would be by snow coach not snowmachine.
3) For those areas of Curry Ridge open to snowmachines (N. of the boundary mentioned in #2), snowmmobiling would be managed forÂ family outings and sightseeing as follows: snowmachines would be required to remain on a trail, travelÂ at moderate speed,Â pull over when meeting other travelers. TheÂ trail(s) would be routed around windblown tundra, marked so that people could find the trail and riding regulations enforced.
4) In the area of the Tokositna River, snowmachines should be restricted to corridors in order to provide places and areas for wildlife to be protected from area wide snowmachine noise and presence.
A very large percent of public lands in the rail belt and the Kenai Peninsula is opened to snowmachine use.Â Enclosed is an addendum listing public lands and how many acres are open and closed to snowmachine use.Â There needs to be a better balance allocating public lands for non-motorized recreation that are closed to motorized activity.
Thank you again for this chance to offer our comments.
Alaska Quiet Rights Coalition
Brian Okonek, Vise President
Public Lands Opened and Closed to Snowmobile Activity:
In support of the Alaska Quiet Rights Coalitionâ€™s (AQRC) recommendations for closures and various restrictions to be placed on snowmachining in Denali State Park as part of the trail management plan,Â we offer these facts regarding the opportunities available to the non-motorized user of public lands in winter and those afforded to motorized users. All of the 324,270 acres of Denali State Park are opened to snowmachining once there is sufficient snow depth; there are no trails or areas designated for the quiet recreationist.Â Similarly, in the surrounding Railbelt area there are few acres of any public lands set aside for non-motorized recreation.
AQRC believes that managers of public lands have a responsibility to: designate an appropriate balance of areas and trails for quiet recreation vs. motorized recreation; protect natural sounds and natural quiet, and enforce restrictions to protect quiet areas. We note the stateâ€™s recognition of this issue in its recently released Statewide Comprehensive Outdoor Recreation Plan (SCORP):
â€œRecreation providers, user groups, and interested public should consider all viewpoints in recreation planning. Natural quiet is an essential resource and should receive specific treatment in planning documents as do other valuable resources. Quiet, like other resources, should be considered for its values and benefits; the wide variety of possible methods to protect and restore natural quiet to public lands should be considered.â€ We urge the planners to implement this strategy in developing the Denali State Park Trail Plan.
A) Final South Denali Implementation Plan/EIS
The projected construction and design budget for Alternative C, the approved alternative,Â is $28,126,000. Of that amount, approximately 10% is allocated to improving facilities for snowmachining by improving parking lots and turnouts to accommodate snowmachine trailers. Not one dime is allocated for improving trails or facilities for the non-motorized winter recreationist.
B) Allocation ofÂ the public lands in the RailbeltÂ betweenÂ non-motorized winter recreationistsÂ and motorized recreationists (Acres cited are approximate only.)
As described in the SCORP, the Railbelt is defined as including â€œ… those urban and rural communities accessible from Alaskaâ€™s limited road and rail system, generally from the southern end of the Kenai Peninsula, north to Fairbanks, and east to the Canadian border.â€ The SCORP states that the Railbelt contains:
the bulk of the state park system acreage and units (78, including 19 marine parks);
20,000,000 acres of NPS lands;
1,900.000 acres of Kenai National Wildlife Refuge;
5,700,000 acres of Chugach National Forest;
1,800,000 acres of Tanana Valley State Forest; and
16 state special areas (critical habitat areas, sanctuaries and refuges).
AQRCâ€™s analysis of which of these public lands in the Railbelt are considered open and which are considered closed, to snowmachining, follows:
Denali National Park & P: 6,000,000 acres 2,000,000 closed to snowmachines (It should be noted that snowmachines were never legally allowed in the 2,000,000 acres of the old park.)
Wrangell-St. Elias NP & P 13,200,000 acres 0 acres closed
Kenai Fjords National Park 572,800 acres 0 acres closed
Kenai National Wildlife Refuge 1,980,000 acres 730,000 closed
Chugach National Forest 5,700.000 acres, but a more appropriate acreage for this analysis is that contained in the Seward Ranger District which covers the Kenai Peninsula 890,000 acres 182,900 acres or 21%Â closed. (We would point out that though there are lands closed to snowmachining, a substantial majority of the most popular and attractive trails and areas have remained open to snowmachines.)
Bureau of Land Management hundreds of thousands of acres 700 acres (Campbell Tract) closed; plus a few trails and several RNAs in the White Mt. National Recreation Area and Steese National Conservation Area.
1) SPOR managed/owned (including the units in the Kenai, Northern and Mat-Su/Copper River Basin and Chugach State Park districts only)
Chugach State Park (21 units) 493,471 acres 432,55` acres closed, 76 of 124 miles of existing and proposed new trails to be closed toÂ Â snowmachines (Public Review Draft)
Denali State Park 324,270 acres 0 acres closed
Katchemak Bay SP/WP* 370,399 acres 370,399 acres not opened to snowmachines
State Recreation Sites (SRS)* 24 of 31 units are not opened to snowmachining; 7 units are.
State Recreation Areas (SRA)* 1 of 14 units not opened to snowmachining.Â 3 of the 13 units which are opened to snowmachining when adequate snow have some restrictions. The most notable example is Nancy Lake SRA with 22,685 acres. Approximately 15% or 3,402 acres (rough estimate) and 9.7 of 40 miles of trail are closed to snowmachining.
Kenai River SMA 44,850 acres Kenai and Skilak Lakes opened when adequate snow.
Hatcher Pass Management Area (managed in conjunction with the Div. of Mining, Land and Water) 212,380 acres 16% closed to snowmachines.
*Note: It is not clear that the Kachemak Bay SP/WP,Â one SRA and the 24 SRSs not listed in the regulations to be opened to snowmachining should be considered closed or whether they are simply not suitable for snowmachining.
2) Division of Mining, Land and Waters manages millions of acres (the exact number is unknown) such as the 208,261 acres in the Knik River PUA or the 2,334,713 acres in the Nelchina Public Use Area.Â 0 acres closed. (All general state lands are subject to the â€œGenerally Allowed Usesâ€ which automatically permits snowmachining if it can be done without resource damage.Â DMLW lacks the resources to try to assess whether such damage is occurring and, moreover, lacks enforcement authority.
3) Division of Forestry Tanana State Forest 1,800.000 acres 0 closed.
4) ADF&G 16Â state special areas unknown acres 0 acres closed
Other Public Lands
Talkeetna Talkeetna Lakes Park, 1, 040 acres and Numbered Lakes Park, 720 acres are both closed.
SUMMARY: with the exception of the trails and areas set aside in Hatcher Pass, Chugach State Park and Nancy Lake SRA, there are no closures or restrictions on state lands in the Railbelt which protect the rights of the non-motorized recreationist to a quiet, winter experience.