Greg Dudgeon
Gates of the Arctic National Park and Preserve
GMP Amendment
Fairbanks Administrative Center
4175 Geist Road
Fairbanks, AK 99709-9990
Re: Â Gates of the Arctic GMP Amendment
Dear Greg:
The following are the comments of the Alaska Quiet Rights Coalition (AQRC) on the preliminary alternative concepts and draft management zones relating to the revision of the Gates of the Arctic National Park and Preserve (“parkâ€) General Management Plan, as well as recommendations for designated Wilderness.  We appreciate the chance to participate in this planning process for what you correctly characterize as “this premier wilderness area.† In addition to these comments, please refer to our scoping comments dated March 28, 2010 for some additional background about our organization and the state of the natural soundscape in Alaska.
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.  AQRC believes in a fair and balanced allocation of Alaska’s public lands—overall—between non-motorized and motorized recreation; this of course includes areas of the public lands where no motorized recreation will be allowed (we would expect all motorized recreation to be prohibited in units of the National Park System).  Finally, we believe natural quiet and natural sounds—the natural soundscape—should be recognized by all public land managers (the Park Service is a leader is this regard) as critical resources in and of themselves that deserve no less consideration than, for example, clean air and water, fish and wildlife and their habitat, and scenic beauty.
A. Â General
We will almost certainly, as you might suspect, support an alternative that resembles Alternative 2 in “maximizing the opportunities for solitude and primitive recreation†(p. 5) at this “premier wilderness area†(p.1).  If wilderness will not be strictly protected at Gates of the Arctic, where will it be?  Our preferred alternative would include the largest amount of acreage reasonably possible in Zone 5, and would include the greatest amount of protection—and restoration if necessary—for the natural soundscape.
B. Â Natural soundscape; soundscape plan
We have already briefly alluded to the natural soundscape.  The Park Service has been a leader among the federal and other agencies in identifying the natural soundscape as a valuable resource and in beginning to analyze the effects of agency plans and other decisions on natural quiet and natural sounds—and therefore on both humans and wildlife. What it has not always done, however, is take the next essential step of actually protecting, and where appropriate, restoring, that quiet and those sounds.  We very much hope that this revision of the GMP will result in decisions that in fact halt the increasingly rapid loss in so much of Alaska, as well as the rest of the country and world, of these critical resources.
We don’t know how much sampling, if any, of the natural soundscape in Gates has already occurred or is occurring, but certainly before a GMP revision is adopted at least some representative sampling and analysis needs to be undertaken.  It’s a huge area, we of course realize, so a reasonable number of sampling locations that provide the best snapshot of the Park and Preserve will have to be carefully selected.  But that work needs to be part of a formal Soundscape Plan for Gates that would be ongoing and periodically revised.
C. Â Motorized/mechanized vehicles
It’s not evident from the newsletter what the existing rules are regarding the use of recreational motorized vehicles at Gates, or whether that might or might not change.  We don’t believe that recreational motorized vehicles have any place in units of the National Park System, whether Park or Preserve; this does not include well-managed traditional use of airplanes—not helicopters—as transportation to non-motorized recreation in remote areas of the Park and Preserve.  And in particular, we don’t believe that Congress ever intended in Section 1110 (a) of ANILCA to authorize the use of snowmachines for recreational riding.  The issue of motorized recreation needs to be fully evaluated in the plan/DEIS.
In regard to motorized recreation, it was disturbing to see very early in the newsletter, under The Qualities of Wilderness Character (p.2; see also p.4), that the Wilderness Act was incorrectly quoted (the proper phrasing is used later in the document (see, e.g., p.8)).  Wilderness is to offer not just outstanding opportunities for “unconfined†recreation, but for “primitive and unconfined recreationâ€â€”and snowmachining and ATV riding are hardly primitive forms of recreation.  Nor are they analogous to mountain climbing and mountaineering (p. 2).  Putting aside the special question of subsistence use of motorized vehicles (see immediately below), it is extremely distressing to see that the National Park Service, in managing many of its lands in so-called “wild†Alaska, is providing a less wild, more tame, artificial, mechanized, and noisy experience in Alaska Wilderness than can be found in what one would expect to be less wild Wilderness in the lower 48.
We are not familiar with the provisions of the Subsistence Management Plan (p.4), but we would be very disappointed if this revision did not address the use of motorized vehicles for the purpose of subsistence.  We support the special treatment subsistence harvest receives in ANILCA, and the special treatment for the subsistence use of motorized vehicles.  ANILCA clearly provides, however, that such motorized use is subject to reasonable regulation, and the possible need for such regulation should be carefully evaluated during the revision process.  The handling of motorized use/mechanization is one of the most important aspects of wilderness management, and subsistence as well as recreational use of motorized vehicles certainly needs to be addressed in planning for this “premier†wilderness park.
Fixed-wing planes can be very obtrusive, but as a rule helicopters are definitely more so. Â If used at all, helicopters should be allowed for absolutely necessary research and administrative purposes only.
And the administrative use of motorized vehicles generally should be extremely limited. Â Such use is no quieter than the non-administrative use which should of course be very strictly regulated.
D. Â Eligible wilderness
We support forwarding to Congress a recommendation that all eligible wilderness be formally designated as Wilderness. Â Gates is a special, wild place and should be designated and managed as Wilderness.
E. Â Preliminary alternative concept descriptions
Of course the proof is in the pudding, the details, which we don’t know at this point.  Consequently, we also don’t know whether Preliminary Alternative Concept #2, which would provide the greatest protection to wilderness, and which would be our preference, adequately protects the unrivaled wilderness character of Gates.
Additionally, we’re unsure whether #4 is appropriate for Gates.  As appealing as “inspiring active stewardship and creating advocates for the park and wilderness†(p. 8) is in the abstract, it’s not clear that the actual management would sufficiently protect the wilderness character at Gates; and of course it would be ironic if in creating advocates we degraded the resource for which those advocates were created.
F. Â Draft management zone descriptions
Zone 1 would be appropriate for some parks (is it true that these zones would be applied to all National Parks in Alaska?), but it would not seem to be appropriate for a wilderness park like Gates. Â We suggest that it be deleted from this process.
G. Â Activities outside the park
Activities outside of Gates could adversely affect park wilderness. Â The plan/DEIS should address what actions can and should be taken to minimize these impacts.
H. Â Specific actions
It’s not clear what you mean by this.
Thank you for the chance to offer these comments. Â We look forward to seeing and reviewing the draft environmental impact statement.
Sincerely,
Cliff Eames, Member
Board of Directors
Alaska Quiet Rights Coalition