Robert Lloyd, Planning Team Leader
Bureau of Land Management
Anchorage Field Office
6881 Abbott Loop Road
Anchorage, AK 99507
Dear Mr. Lloyd:
This letter is submitted by the Alaska Quiet Rights Coalition (AQRC) as a supplement to our original letter dated November 11, 2005 commenting on the Draft Ring of Fire RMP/EIS. We are writing in support of establishing a special use area in the Haines area (ACEC to be managed as a Research Natural Area) to study and protect mountain goats. We have only recently been made aware of, and read, Lynn Canal Conservationâ€™s(LCC) request to BLM to create an ACEC for this purpose. We find it to be a well written and documented request that appears to meet all requirements for an ACEC and we support their request. Further, we understand from LCC that it is their belief that BLMâ€™s policies and regulations require BLM to make public such requests as part of the planning process and we trust BLM will now provide a means for the public to comment on LCCâ€™s ACEC proposal.
AQRC is a state wide organization with more than 600 individual Â and small business supporters. We advocate for the right of non-motorized recreationists, rural Alaskans, and wildlife to natural quiet on a fair share of our public lands. Our organization was established eight years ago in response to the proliferation of unregulated noisy machines in Alaskaâ€™s backcountry. Since that time many public land managers have supported the concept of natural quiet as a natural resource in their planning processes.
Scientific studies and personal experiences show that snowmachines, helicopters and personal watercraft have harassed, stressed, displaced, and otherwise negatively affected wildlife. Â Mountain goats are a particular species that are known to be sensitive to helicopters. Evidence has been gathered that shows that the extensive helicopter activity in Skagway is not adequately mitigated, monitored or controlled—-to the detriment of wildlife. Across the canal in Haines is the heaviest concentration of mountain goats on BLM managed lands in North America and fewer helicopter activities. This is a not-to-be-missed opportunity to study and protect the mountain goat population on BLM lands with a special use designation that would prohibit heli-playing and other invasive activities. As recently as 2002, BLM and USFS, in their joint request to the National Fish and Wildlife Foundation for a grant to study helicopter effects on wildlife, indicated that they did not have comprehensive, scientific guidelines to successfully protect wildlife populations, including goats, from helicopter impacts.
AQRC urges BLM to designate the BLM-managed public lands in the Haines area as an Area of Critical Environmental Concern and manage it as a Research Natural Area for the purpose of protecting wildlife, especially mountain goats, by prohibiting helicopter, snowmachine and other mechanized intrusions. This will also allow an opportunity to obtain definitive data which in the future would permit the scientific management of mountain goats. Whether or where BLM could permit helicopter activity in the future would be determined, for the first time, by the results of research on this specific goat population. In supporting LCCâ€™s request, we recognized that it is in conflict with designating the Haines Block as an SRMA and, accordingly, withdraw our previous support for that area to be a SRMA.
Thank you for this opportunity to Â comment.