April 26, 2010
Alaska Quiet Rights Coalition
P.O. Box 202592
Anchorage, AK Â 99520
Ray Burger
Alaska Department of Natural Resources
Resource Assessment & Development
550 West  7th Avenue, suite 1050
Anchorage, AK Â 99501-3579
Ref: Susitna Matanuska Area Plan
Dear Ray Burger,
Thank you for this opportunity to comment on the Susitna Matanuska Area plan draft.  Two photos  of ORV damage in the Petersville Road region will be emailed separately. (See the next to last paragraph for an explanation.)
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. 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.  In the vast majority of cases, the obtrusive noise, summer landscape degradation and winter snowscape defacement, exhaust, and dangers of motorized recreation are incompatible with those special natural experiences and with quiet homes and neighborhoods.  We are concerned with the damage that ORVs are doing to state land in the Susitna Matanuska Area.
While the use of ORVs continues to grow the state continues to ignore the harm being done by these vehicles.  It is very disconcerting to discover that the Susitna Matanuska Area Plan draft, the document that is going to guide use of state land in this region for the next 20 years, does less than the 1985 Susitna Area Plan did to regulate ORV use, protect the environment from their use or even acknowledge the fact that there is harm being done to the environment today by their use. The ruts created by this unfettered use of  ORVs on state lands mars the scenic beauty of the backcountry and harms wildlife habitat.
There is language in the SMAP that should protect state land from the destruction being done by ORVs, but the Generally Allowed Uses (11 AAC 96.020) are too broad to be enforced and no single department has the authorization or ability to enforce such regulations. Â The end result is that although there is damage being done to wetlands by repeated use of ORVs this plan will not regulate their use nor is there an agency that will protect the goals of this plan. Â The SMAP needs to address that there is damage being done to state land by ORV use and recommend ways to minimize their environmental impact.
The goals of  Environment and Habitat and Quality of Life stated in the SMAP draft of “protect natural ecosystems, sensitive species, and wildlife habitats” (Page 2-1, Lines 32 -33),  “maintain or enhance the quality of the natural environment including air, land and water, and fish and wildlife habitat and harvest opportunities; provide opportunities to view wildlife and the natural environment” (page 2-2, Line 4-7) as well as the  Public Access goal (page 2-50, line 7-11)  “to ensure continued public access consistent with responsible wildlife and fish habitat conservation”  are certainly being infringed upon today.
Unregulated ORV use is in conflict with all of these important goals.  ORV use in wetlands, muskegs and alpine regions do particular damage.  The ground becomes so rutted that ORVs have to use different routes creating braided trails. These numerous ruts harm natural ecosystems and wildlife habitats.  These ruts reduce the quality of the natural environment and spoil the opportunity to view the natural environment.  Coming across ORV trails while hiking spoils the wilderness quality of experiencing Alaska.  An ORV user  vandalizes the land destroying the beauty of the vegetation  often harming wildlife habitat and shatters natural quiet.
Chapter 2 lists the management guidelines for areas that the draft identifies for Settlement. #6 of these guidelines is Ensure Access to Remote Settlements. (Page 2-36)  The only reference in the plan about the impact access has on habitat is that associated with parking areas or trailheads.  The plan should acknowledge the fact that past land sales disposed of  private parcels that are only accessible overland by crossing wetlands (often miles of wetlands).  What started out as winter routes are now being used by ORVs in the summer resulting in the creation of rutted, braided trails. There would be far less damage to state land if ORV were used only when the ground was frozen and snow covered, but this is not the case.  Summer use of ORVs is increasing and so is the damage being done to wetlands.  The plan needs to include language that driving ORVs across wetlands is not an acceptable practice as it goes against the goals of the plan.
When the state plans future land sales it needs to take into account the topography that is required to access the land disposal area. Â Designing land sales that require crossing wetlands in order to get to will only exacerbate the ORV damage to wetlands. Since the use of ORVs is so popular now any land disposal requiring wetlands to be crossed to access will go against several of the goals stated in this plan.
The 1985 Susitna Area Plan, Transportation chapter, Management Guidelines, J. Off-road Vehicle Activity states that  statute and regulation do not require a permit for ORV use if it is occasional and infrequent or intermittent.  It goes on to state, however, that a permit  may be required to cross anadromous fish streams and for repeated off-road vehicle activity in a given area.  Both the these situations are regularly happening today.  Trails that cross wetlands are being used on a regular basis and many trails cross anadromous streams.  This section from the 1985 SAP should also be in the Susitna Matanuska Area Plan. It can be argued that repeated use of an ORV trail is not a Generally Allowed Use and should require a permit.  If people were required to obtain a permit perhaps some of the habitat harm ORVs are doing could be avoided through a rerouting of a planned trail and an educational program.
The paragraph about access (page 3-40, lines 3-8) to the Petersville Road Region is not totally correct and is misleading.  It states that “north/south trails to accommodate the predominant drainage pattern, skirting wetlands in summer”  giving the impression that the wetlands are not being impacted by ORV use. The plan fails to  mention that there are many trails running east/west that cross numerous wetlands and many north/south trails actually go directly on the wetlands rather than “skirt” them.  The plan needs to acknowledge this fact.   This region has been through many prior land disposals resulting in numerous private parcels that now have cabins on them. Since the area is accessible from both the Parks Highway and the Petersville Road there is a tremendous amount of off-road vehicle activity  for accessing cabins as well as hunting.
Two Google Earth images that show what the impact  ORVs are having on the wetlands will follow this email.  One shows a road that is the Petersville Road.  The ORV tracks in the muskeg are paralleling Kenny Creek.  The other photo shows an ORV trail that goes west from the Parks Highway to the lake at the head of Moose Creek.
If the Susitna Matanuska Area Plan is truly going to guide how state lands are used and  protected in the future it must address the impacts of ORV use.
Sincerely,
Brian Okonek
Vice President
Alaska Quiet Rights Coalition