Susitna Forestry Guidelines: Revision

May 28, 2009

James Schwarber, SFG Project Manager
Div. of Forestry
3700 Airport Rd.
Fairbanks, AK 99709

Dear Mr. Schwarber and DNR Planners:

The purpose of this letter is to offer comments of the Alaska Quiet Rights Coalition (AQRC) concerning revision of the 1991 Susitna Forestry Guidelines (SFG).

AQRC is a statewide nonprofit organization dedicated to protecting the rights of Alaskans to quiet places. We consider natural quiet and natural sounds to be resources of our public lands which are to be protected like other values. AQRC believes in a fair and balanced allocation of the state’s public lands for both non-motorized and motorized recreation.

While we have a few concerns regarding set-backs and wildlife corridors, our main concern is the development of roads and the resulting negative effects due to motorized access. The 1991 SFG acknowledges impacts to marten, moose, bear, fish wetlands as well as to recreation values. These impacts are usually due less to the actual forestry harvest than to the after-harvest access provided by roads, particularly to ORV access.

We commend the 1991 SFG (pg39) requiring the Forest Land Use Plan (FLUP) to “state whether or not roads will be permanent or put-to-bed and whether or not roads put-to-bed will be open to off-road vehicle use.”

We request that the FULP directly consider quiet rights values in making such determinations, just as wildlife and scenic values are directly addressed. We worry that DNR will not provide for significant non-motorized recreation opportunity settings or that there will not be effective enforcement for a non-motorized, put-to-bed road. When roads are put-to-bed it is important for the protection of wildlife and fish habitat that the closure to the area of the use of motorized vehicles is enforced by DNR.

The present SFG specifies the size and shape of timber cutting areas(see SFG, section 11, pg.17). These are important requirements. Please retain these prescriptive cuts.

On a different topic, we suggest the 100′ stream setback rule should be enlarged to 200′. The setback along streams provide a continuous wildlife corridor besides protecting the water resource. The setback also provides older growth habitat for marten. Trails following streams often are further than 100′ away due to topography.

To reiterate, just as bears, moose, eagles, or whatever need protecting from disturbances other than logging itself, so too do people need consideration by providing non-motorized recreation opportunities.

Sincerely Yours,

Dan Elliott, member, Board of Directors
Alaska Quiet Rights Coalition
950 E. Fairview Loop Rd.
Wasilla, AK 99654
(907) 376-5196