January 24, 2018
To: Andrew Mack, DNR Commissioner and
Sam Cotton, ADFG Commissioner
From: Alaska Quiet Rights Coalition
P.O. Box 202592, Anchorage, AK 99520
Re: The use of drones on public lands
Founded in 1996, 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, visitors, future generations, and wildlife. We believe that natural sounds and natural quiet should receive the same consideration given to other ecological values, such as clean air and water, fish, wildlife, soils, vegetation, scenic beauty, and wilderness character. 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 just 10 or 20 years ago.
In addition to protecting ecological values like the ones listed above, one of AQRC’s specific goals is a fair and equitable overall balance on the public lands between those managed for motorized recreation, and those managed for quiet, truly traditional forms of recreation like hiking, canoeing, kayaking, snowshoeing, and cross country skiing.
The purpose of this letter is to request Alaska’s public land managers to enact regulations governing the use of drones on the public lands. Drones have become increasingly available and affordable, and their use has become “immensely popular and versatile” (Kealia Pond National Wildlife Refuge website). They are being used for both commercial and recreational purposes. A number of us have encountered drones flying over the public lands or other natural areas. Drones can of course have positive attributes, such as for search and rescue, fire look-out, wildlife population counts, and certain types of photography. But they can also have significantly negative consequences, some of which we’ve documented below. We believe that drones should be prohibited (except perhaps as approved in writing by the land manager) in Alaska’s special areas (we’re using the term “special areas” to mean legislatively and administratively designated areas like Parks, Recreation Areas, Refuges, Sanctuaries and Critical Habitat Areas). On undesignated public lands, drones should be carefully and responsibly regulated in an enforceable manner.
Alaska’s special areas offer fabulous recreational opportunities, and provide protection to fish, wildlife and many other ecological values. In order to protect these opportunities and values, as well as people’s expectations, it is absolutely essential that visitor activities be managed. Being filmed, followed, or otherwise disturbed by a drone is very annoying to many people. Any regulations to control, rather than ban, drone use will be extremely difficult to enforce. Consequently, the State should adopt the cautionary approach— that is, be very conservative and cautious before considering drone use to be an appropriate activity in special areas. This is a relatively new activity, and at least until we know more about the possible and real effects we need to be very careful. Other government agencies that manage public lands (including Chugach State Park, Denali National Park, and National Wildlife Refuges such as Kealia Pond National Wildlife Refuge) have concluded that operating drones is not a desirable activity and have banned, at least on an interim basis, their recreational use.
For the reasons described below AQRC believes that the use of drones on Alaska’s public lands should be (as we said above) prohibited in special areas and at least closely regulated elsewhere.
- Noise disturbance that degrades the natural soundscape
- Disturbance and harassment of wildlife
- Privacy issues
- Causes conflicts between park users
- Degrades quality of backcountry experience
- Unethical for searching for game while hunting (even though ADFG prohibits drone use for spotting game, it is difficult to enforce)
- Already, large custom drones have been used to pull skiers and snowboarders across the snow, turning drone technology from an aerial platform into a vehicle
- Drone technology is advancing very rapidly and it is impossible to anticipate just how they will be able to be used in the future and how their use will affect other park visitors and wildlife
Alaska’s special areas have been established for the obvious reason that they are very special places. Many people visiting these areas expect a unique experience in Alaska. AQRC believes that drone use will have a detrimental affect on many park visitors, wildlife, and other resources and values. There are many square miles of other beautiful Alaska state lands that do not have such special designations where activities are far less managed, or hardly managed at all, and where a reasonable assessment might conclude that responsible drone use (use that is sensitive to other people, wildlife, etc.) is appropriate.
Thank you for your attention to this request. We look forward to working with you as the process of addressing drone use on Alaska’s public lands moves forward.
Brent Goodrum, DNR, Director, Division Mineral, Land and Water
Ethan Tyler, DNR, Director, Division of Parks and Outdoor Recreation
Bruce Dale, ADFG, Director, Division of Wildlife Conservation
David Rogers, ADFG, Director, Division of Habitat
Joe Meehan, ADFG, Special Areas Program Coordinator
Alaska Quite Rights Coalition, President