Gates of the Arctic NP & P_ Scoping Comments.txt

March 28, 2010
Dear Superintendent Dudgeon:
Thank you for the chance to offer scoping comments for  the Gates of the Arctic National Park and Preserve General Management Plan Amendment.
 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, wildlife, visitors, and future generations. AQRC believes in a fair and balanced allocation of the state’s public lands for both non-motorized and motorized recreation.  We believe natural quiet and natural sounds should be recognized by all public land managers as critical resources in and of themselves that deserve no less consideration than clean air and water or fish and wildlife and their habitat.
Alaska’s natural beauty, wildness, wildlife, expanses of undisturbed open space, and peace and quiet are among its most cherished values, and Alaskans, our visitors, and future generations have the right to experience the natural sights, sounds and quiet beauty of our state.  Unfortunately, though, natural quiet and the opportunity to hear and enjoy natural sounds are increasingly hard to find in our state—a fact which would surprise the great majority of non-residents for whom Alaska is a potent symbol of the natural and the wild, not of noisy mechanization.  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 only 10 or 20 years earlier. We  know that natural quiet and natural sounds require our—the public, and the public’s stewards, the land managers—constant vigilance if they’re to survive even into the middle of our present century. While Gates of the Arctic NP & P has, undoubtedly, been less impacted by noisy mechanization than any other park in the country due to its location, costs of accessing, low population, size, designated wilderness, etc., it needs to be extra vigilant in order to preserve its uniqueness as a wilderness park.
We strongly support a study of the non-wilderness portions of the park and preserve for possible inclusion as formal Wilderness. We urge you to link  this study  with an analysis and regulatory process to determine an interpretation of Sec. 1110 (a) of ANILCA which is appropriate for Gates of the Arctic NP & P. We believe it is important to get this determination in place before recreational snowmachining becomes an issue in the park.  In view of  possible state legislative activities surrounding the Dalton Highway and the increasing infrastructure development in support of oil and gas  activities, it is vital to clarify this issue as soon as possible.
We recommend soundscape plans  be prepared in and around any areas currently or potentially, over the twenty year life of the plan, threatened by incursions of man-made noise. The analysis of proposed agency actions should include a determination of the possible effects on natural quiet and natural sounds and on the humans and wildlife that enjoy or depend on them.  Alternatives should be considered.  Possible mitigation measures should be developed to preserve the Park’s natural soundscape as part of this planning effort.
AQRC’s focus has been on motorized recreation, not subsistence.  And ANILCA, rightfully so, has more liberal policies for the use of motorized vehicles for necessary subsistence than for non-essential recreation.  Subsistence use of motorized vehicles should, nevertheless, be subject, where appropriate, to reasonable regulations (as provided for in ANILCA). We urge that you review this use as part of the planning effort and propose appropriate regulations as needed.
While snowmachines were used for transportation to remote cabins, for gathering firewood, for trapping, for hunting and for traveling village to village in many areas before they became national parks and preserves in 1980, recreational riding of snowmachines was not  a traditional activity .  Modern technology, larger engines, paddle tracks, increased numbers of snowmachines and a growing population of motorized recreational users has led to many changes in the backcountry.  As one of the nation’s premiere wilderness areas Gates of the Arctic National Park and Preserve’s most important goals must be to protect the lands it encompasses from the encroachment of activities that will erode its wilderness character.  Recreational motorized activity, including snowmachining, should not be allowed in designated Wilderness areas and should be subject to controls (such as confined to trail corridors) in other regions of the park. 
Thank you again for this chance to offer our comments on such an important, and too often neglected, subject.
Susan Olsen, President
Alaska Quiet Rights Coalition
PO Box 202592
Anchorage, AK 99520