February 27, 2013
BLM Eastern Interior Field Office
Attention: Eastern Interior Draft RMP/EIS
Bureau of Land Management
1150 University Ave.
Fairbanks, AK 99709
To whom it may concern:
The purpose of this letter is to offer the comments of the Alaska Quiet Rights Coalition (AQRC) on the Eastern Interior Draft RMP/EIS and its Supplement dated Jan. 2013.
AQRC is a state-wide non-profit organization whose mission is to maintain and restore natural sounds and natural quiet on our public lands through advocacy and education for the benefit of people and wildlife. We advocate for a fair and balanced allocation of areas and trails on our public lands for the use and enjoyment of the non-motorized recreationist.
First, we set forth some general observations about the overall plan. AQRC appreciates BLM’s efforts to place all of its lands in the Eastern Interior under travel management plans which requires lands to be designated as “openâ€, “closed†or “limited†to OHV use. We applaud BLM for recognizing, and attempting to mitigate, resource damage caused by recreational OHV use such as trail braiding, user-created trails, damage to vegetation, erosion and spread of non-native plants as well as adversely affecting wildlife. We support the issuance of free permits to allow the access guaranteed by ANILCA to “closed areas†as a feasible way to distinguish legitimate subsistence users and those engaging in “traditional activities†from recreational snowmachiners. However, AQRC would urge BLM to adopt transparent procedures to ensue that activities considered “traditional†were in fact occurring in each area at the time of ANILCA passage before issuing those permits. We note that as part of this planning effort the Field Office conducted a wilderness characteristics inventory which determined that 99 % of the BLM lands in the planning area have wilderness characteristics. While each of the alternatives propose protecting differing amounts of the wilderness characteristics present, we would urge BLM to go forward, in a separate planning effort, and recommend formal Wilderness designations to Congress.
AQRC supports Alternative B for the Fortymile and Steese Subunits as providing most protection for, and expansion of, recreational opportunities. We also support the Alternative B ACEC designations in both subunits for their protection of caribou and sheep habitat and strict prohibition against most summer OHV use. In regard to the Upper Black River Subunit, we certainly support this area being brought into the planning process for the first time and support the designation of the Salmon Fork ACEC and its closure to summer OHV use. Since this subunit is very remote and the text indicates that current OHV use is limited, limiting the weight of summer OHV use in the remaining 75% of the subunit outside the ACEC may provide sufficient resource protection.
We are most concerned about the White Mountains Subunit and the decision that hardrock mineral leasing could be allowed, as extensively examined in the Supplement. We realize that Alternative D, opening 160,000 acres, is not BLM’s Preferred Alternative, C, which along with Alternative B, does not lift the mineral leasing closure. However, the fact that this possibility was explored in depth indicates that there is interest in this possibility. The potential adverse impacts from mining spelled out in the Supplement are multifold: on wildlife, particularly in the current White Mt. caribou caving and post-caving areas, on the summer recreational experience in the Backcountry and Semi-Primitive management areas, the increased OHV traffic and consequence damage created by new trail creation, rutting of existing trails and trespass off trails. While the new interpretation of ANILCA may allow the lifting of the mining prohibition, we argue that the public recreation values of this area trump the mining potential. We note that the discussion about Leasable Minerals in Table 2. 22. Comparison of Impacts: Common to All Subunits would appear to indicate that there is a lack of such minerals on the BLM managed lands in these subunits whether under Alternative B, C or D. While the possibilities of mining taking place may, therefore, be slim, the consequence of opening these wild, remote lands which lack infrastructure is to invite the industrialization of these prime recreational areas and is simply incompatible with the outstanding recreational values of this subunit and the Congressional language establishing this National Recreation Area. Mining may create some benefits but too often may cause substantial damage, particularly to the wildlife and wilderness characteristics of the land.
AQRC supports Alternative B for the White Mountains Subunit. Clearly this subunit offers many accessible opportunities for recreation, both motorized and non-motorized. AQRC is under the impression that the multi-use trail system works well in winter and without the usual user conflicts between the quiet and the motorized recreationist in the rest of the state. LImiting ORV travel in summer to designated trails or by permit only will hopefully limit conflict with hikers and backpackers and will help reduce substantially the damage currently caused by by cross-country ORV use. We also supports Alternative B on the grounds that it does not permit UTV use. It is our conviction, based on incidents occurring on other public lands, that unless there is continual monitoring by BLM rangers, UTV users will “trespass†into closed areas and trails with resulting resource damage. We also support the designation of the ACEC of 589,000 acres to protect wildlife values, particularly caribou and Dall sheep habitat, with summer OHV use limited to designated trails. While we do not object to continuing the access to, and riding by OHVs, trucks and motorhomes in/on the disturbed gravel area of the Nome Creek tailings area, we do wonder how this is monitored to ensure travel does not venture off the disturbed areas.
Thank you for this opportunity to comment.
Sincerely yours,
Susan Olsen, Board Member
Alaska Quiet Rights Coalition
PO Box 202592
Anchorage, AK 99520