Denton Hamby
BUREAU OF LAND MANAGEMENT
GLENNALLEN FIELD OFFICE
P.O.BOX 147
GLENNALLEN, AK 99588
Office: 907-822-7311
Fax: 907-822-7335
Dear Denton Hamby,
Thank you for this opportunity to comment on Denali Air’s request for a Special Recreation Use Permit (SRUP) for scenic glacier landings using ski equipped fixed wing aircraft on portions of the Yanert and Gillian Glaciers near Mt. Deborah.
The Alaska Quiet Rights Coalition is a state-wide, non-profit organization with approximately 500 members/supporters which seeks to maintain quiet places for Alaskans and its wildlife on public lands.  AQRC’s vision statement is: “Alaska is a place where people appreciate and protect natural quiet and natural soundsâ€. Our mission statement reads: “The mission of AQRC is to maintain and restore natural sounds and natural quiet in Alaska through advocacy and education for the benefit of people and wildlife.â€Â  We believe that natural quiet and natural sounds–the natural soundscape–should be recognized by all public land managers as critical resources in and of themselves that deserve no less consideration than, for example, clean air and water or fish and wildlife and their habitat.  We also believe in a fair and balanced allocation of the public lands for both non-motorized and motorized recreation.
AQRC is concerned with the impacts that the sound of multiple flights a day to the glacier landing zones will have along the flight path to both wildlife and people. Â Flightseeing has become very popular over Denali National Park and Preserve (DNP&P) with thousands of tourists taking flights. Â Air taxi services with a concession permit to operate in DNP&P are authorized to land flightseers at glacier landing “portals” within the park. Â During the 2010 summer season (mid May to mid September) Â 13,000 tourists were landed at these glacier landing “portals”. Â An estimated 60,000 went on a scenic flight over the park that did not include a landing. The view of the Alaska Range peaks and glaciers is truly remarkable from the air, but the result of all the air activity is that the mountaineers, backpackers and wildlife on the ground are no longer hearing a natural soundscape. Â During clear weather the sound of aircraft can be heard on an almost continuous basis for nearly half the day. Â Currently there are ongoing efforts to initiate voluntary procedures called “best practices” Â that the air taxi services will agree to use. Â These procedures will help to mitigate, in selected areas, conflicts between those traveling through the park on the ground and those experiencing it from the air. Â ARQC does not believe it is desirable to have the heavy aircraft activity that DNP&P receives to spread to other regions of the Alaska Range.
It is important that the Yanert valley and mountains between the Parks Highway and Mt. Deborah do not receive the intense air traffic that is being experienced over DNP&P. Â The best way to accomplish this is to:
– Â Keep the number of landings to a minimum.
– Limit the number of landings to 2 per day total  (Not at each landing zone, but all the landing zones combined).
– Issue only one SRUP in the area for glacier landings of any kind (fixed wing aircraft or helicopter).
– Â Require air taxi operators to use the quietest props and mufflers available for their aircraft.
–  Identify critical habitat for Dall sheep spring lambing, caribou calving, etc.  before issuing a SRUP and require that these areas be avoided during the appropriate time of year.
–  Establish minimum above ground level altitudes for flights that will protect wildlife from stress and reduce the sound of aircraft to people on the ground.
– Â The military has proposed airspace training areas. Â The JPARC EIS draft is scheduled to be released the end of March. Â BLM should take into account the aggregated impacts that military flights will have on the area that Denali Air is proposing to operate.
AQRC understands that at this time BLM has issued no other SRUP’s authorizing  commercial fixed wing aircraft or helicopter landings in the Mt. Deborah area.  If the State of Alaska has lands in the area that may be conducive for glacier landing activities please research if the State has issued any commercial use permits for such activity.  It is important to know how many other flights and landings may be taking place in the area already.
Please take the necessary precautions when issuing a SRUP for Denali Air’s proposed activities to protect wildlife and to ensure that people seeking a wilderness experience will have that opportunity  on BLM lands.  The only way to ensure the quality of the natural soundscape is to limit or not allow mechanical noise events.
Sincerely,
Brian Okonek
Vice President
Alaska Quiet Rights Coalition