Kobuck-Seward Peninsula


Bureau of Land Management
Fairbanks District Office
1150 University Ave.
Fairbanks, AK 99709-3844

To whom it may concern:

The purpose of this letter is to offer comments on behalf of the Alaska Quiet Rights Coalition (AQRC) on the Kobuk-Seward Peninsula Draft RMP/EIS (Draft). AQRC is a statewide nonprofit organization which seeks a fair and balanced allocation of opportunities for quiet recreation on public lands and to preserve natural quiet and natural sounds for recreationists, cabin and home owners and wildlife in the backcountry.

We support the creation of the Salmon Lake/Kigluaik SRMA which would appear to offer the only opportunities in this Draft for quiet recreation, such as backpacking and skiing, which are readily accessible from a road system. While we recognize that both Alternative C and the Preferred alternative propose this SRMA, we support the restrictions set forth in C, such as those imposed on OHV travel and not lifting withdrawals, so that opportunities for quiet recreation are protected. We applaud BLM for proposing this SRMA under both Alternatives C and D in view of the fact that the land involved is clearly not unencumbered BLM land. We assume that the State has indicated to BLM that selection of these lands is not a state priority. Additionally, we strongly urge BLM to take affirmative steps in regard to helicopter/fixed wing tourism activity in this SRMA by setting up a monitoring and permit system through this RMP. All practical experience shows that waiting for a conflict among users to arise before taking action, as you propose, means efforts to curtail adverse activity is extremely difficult.

Since it appears clear from the text that the conflicts in Squirrel River have yet to be resolved, we support the SRMA proposed under Alternative C as a way to deal with the problem. The vast majority of these lands are unencumbered BLM land, and we see no reason for BLM not to adopt the most strict of the proposed requirements in order to eliminate the causes of conflict. We wish to offer specific comments on two aspects. The Draft indicates that the commercial guiding/ hunting operations create conflict with subsistence hunters due to competition for the wildlife, noise from planes and the use of OHVs, which impact both the animals and the habitat. Further the text indicates that traditional Inupiat hunters rarely utilize OHVs in their hunting. BLM staff has indicated that the commercial hunting operations fly in OHVs for their clients to use. AQRC’s experience is that many hunters believe that the ever-increasing number of OHVs used in hunting drive the wildlife further away as well as negatively impact the habitat, access and the hunting experience. AQRC believes BLM has an opportunity to preserve nonmotorized hunting and to equalize hunting opportunities in this area by adopting the permit requirements and l OHV limits, set forth in Alternative C. We support Alternative C in its designation of a number of rivers as “wild” under the Wild and Scenic Rivers Act. We believe such designations can lead to expanded quiet recreational opportunities. We are puzzled, however, as to how BLM is meeting its obligations under this act when the Preferred Alternative summarily states that no rivers pass the test of “suitability”. No analysis showing how each river was determined not to be suitable is included in the Draft.

As a general matter we support the creation of ACECs and RNAs because such special designations include additional protections for the surface resources. As a practical matter, most lands included in the planning area are unlikely to be heavily impacted by either motorized or

nonmotorized recreation. However, in view of the surrounding state and native corporation lands, and neighboring NPRA, we see no reason for BLM to be eager to lift the withdrawal status on the lands it will retain or those included in the ACEC and RNA designations as specified under the Preferred alternative. As BLM knows from previous comments on draft RMPs/EISs, AQRC believes that attempting to regulate OHVs on the basis of the state’s Generally Allowed Uses is a paper exercise at best. We recommend that requiring OHVs to remain on designated trails in the non-winter season should be the standard adopted by BLM on all the lands

it manages.

Thank you for this opportunity to comment.

Sincerely yours,

Susan Olsen, Treasurer
Alaska Quiet Rights Coalition
PO Box 202592
Anchorage, AK 99520