Ring of Fire DRMP Amendment/DEIS: Sign on letter

BLM Anchorage Field Office
Attn: Haines Amendment
4700 BLM Road
Anchorage, AK 99507

March 3, 2013

Re: Sign on Letter for Ring of Fire Draft Resource Management Plan Amendment/DEIS (2012 DEIS)

The undersigned organizations support retaining the current Mountain Goat Monitoring and Control Area in the BLM Haines Block, and protecting it by creating an Area of Critical Environmental Concern (ACEC) to be managed as a Research Natural Area (RNA). We believe the higher levels of protection afforded by these special management designations are necessary because mountain goats are known to be especially sensitive to human disturbance, and because Haines’ goat populations represent a significant percentage of goat populations under BLM jurisdiction nationwide.

The Federal Land Policy Management Act prioritizes creating ACEC’s for those areas meeting Importance and Relevance criteria. BLM has already determined that the Relevance criterion applies, and we believe Dr. Aaron Shafer’s research provides significant new information that supports a determination of Importance. Additionally, the goat resource has special worth and is more than locally significant because naturally occurring mountain goat populations on BLM managed lands nationwide have become scarce.

ACEC/RNA Designation
“ACEC designations highlight areas where special management attention is needed to protect, and prevent irreparable damage to important. . . wildlife resources .…The ACEC designation indicates to the public that the BLM recognizes that an area has significant values and has established special management measures to protect those values. In addition, designation also serves as a reminder that significant value(s) or resources(s) exist which must be accommodated when future management actions and land use proposals are considered near or within an ACEC.” (BLM Manual 1613.02).

An ACEC can be managed as an RNA, where “research and monitoring are encouraged” and serve as a “baseline” for long-term change. (PRMP/FEIS page 3-186). Research and monitoring are necessary because Haines/Skagway goat populations are currently threatened by acknowledged adverse impacts of “unspecified magnitude” from the increasing use of helicopters inside and over goat habitat. Specific scientific concerns about impacts to mountain goats include displacement from prime habitat, acute or chronic reduction in foraging efficiency resulting in nutritional deficiency, reproductive failure, and increased vulnerability to predation. (1995 BLM and USDA EA for Helicopter Landing Tours in the Skagway and Haines Area pages 3-12 and 3-13).

We believe the previous BLM assessments that this area has a “particularly diverse and unique set of flora and fauna due to its proximity to both interior Canadian ecosystems and coastal temperate rainforest ecosystems” (PRMP/FEIS page 3-57), and has “remarkable natural attributes and opportunities for research and education,” (PRMP/FEIS Attachment C page 166), further support the need for a special designation. The current planning process is the appropriate vehicle for creating an ACEC to be managed as a RNA, and we fully support this option.

Thank you for the opportunity to comment.

Nicole Whittington-Evans
Associate Regional Director, Alaska
The Wilderness Society

John Toppenberg
Director, Alaska Wildlife Alliance

Pam Brodie
Chapter Chair
Sierra Club Alaska Chapter

Cindy Shogan
Executive Director, Alaska Wilderness League

Karla Dutton
Alaska Director
Defenders of Wildlife

Brian Okonek
President, Alaska Quiet Rights Coalition

Lindsey Ketchel, Executive Director
Southeast Alaska Conservation Council

Alaska Center for the Environment