June 30, 2006
Allison Banks
BY FAX
Glacier Bay National Park & Preserve
PO Box 140
Gustavus, AK 99826
Dear Allison:
These comments are submitted on behalf of the Alaska Quiet Rights Coalition (AQRC). AQRC is a statewide non-profit organization that advocates for the protection, and where necessary the restoration (increasingly, restoration is required), of natural quiet and the opportunity to hear and enjoy natural sounds. These resources and opportunities, which are rapidly being degraded on and over the public lands and waters, are important to a wide variety of interests, including backcountry hikers and skiers, more passive recreationists and visitors, cabin owners, home owners, many tourism operators, local communities, and of course wildlife. We are also of course interested, although it is subsidiary to our primary mission, in the many non-noise impacts created by ORV use.
We applaud the Park Service’s decision to address the issue of ORV use in Dry Bay. This very important issue should not be ignored. ORVs often damage or destroy soils, vegetation, and wildlife habitat, and they can disturb wildlife; they pollute the air and water; they degrade wilderness character and often mar scenic beauty; and they shatter natural quiet and the opportunity to hear and enjoy natural sounds.
Consequently, the use of ORVs on the public lands should be minimized. Such use should be the exception, not the rule. ORVs should be carefully managed where they are allowed, and their recreational use should be prohibited on many public lands. Certainly the recreational use of ORVs, both for individual and commercial purposes, should not be allowed in National Park Service units. There are many other public lands where they are allowed (although often to a greater degree than is responsible and appropriate), and our most protectively classified (except for the possible Wilderness overlay which can be applied to other public lands as well) public lands should be managed for uses that are less destructive and that create fewer conflicts. In National Park Service units the natural should predominate, not the artificial and mechanical, and protecting resources for future generations should take precedence over gratifying recreational desires.
Uses of ORVs that might be specifically authorized by ANILCA (and even these authorizations are often qualified), for purposes such as commercial fishing, subsistence, and reasonable access to inholdings (such access by summer ORV is not necessarily reasonable if alternatives by air, water, or in the winter are adequate), should be allowed if the appropriate standards are met, but should be managed to minimize use and consequent impacts and conflicts. Travel should be on designated trails only; the number of designated trails should be minimized by eliminating redundant or minimally used routes; routes that are causing serious or irreparable environmental damage should be re-routed or eliminated; and hardening, bridges and other improvements should only be undertaken when the use of the trail by ORVs is clearly warranted and an alternative location is not feasible.
And, again, ORV use for recreational purposes should not be allowed. Even when Congress created in ANILCA a narrow special exception in Section 1110(a) for the use of motorized vehicles for certain limited purposes, the exception applied only to airplanes, motorboats, and snowmachines, not summer ORVs. And we firmly believe the courts will conclude that even with regard to snowmachines, the Congress did not authorize their use for recreational purposes, and certainly not for non-consumptive recreational purposes.
We look forward to ORV rules for Dry Bay that are consistent with the Park Service’s strict mandate to prevent impairment of the natural resources and values for which it has management responsibility so that they will continue to be available for the enjoyment of future generations of visitors. And of course where a choice has to be made between protection and enjoyment, the priority must be protection which, in the long term, results in any case not only in the protection of resources but in the maintenance of the opportunity for present and future visitors to enjoy those resources in a non-destructive manner indefinitely.
Sincerely,
Cliff Eames
Board Member, AQRC
For the Organization