Whistle Stop Letter

March 9, 2006
Glacier Ranger District
Attn: Adam McClory
P. O. Box 129
Girdwood, AK 99587-0129

Dear Mr. McClory:

The purpose of this letter is to offer the comments of the Alaska Quiet Rights Coalition on the DEIS for the Whistle Stop Project.

The Alaska Quiet Rights Coalition (AQRC) is a statewide organization with a supporter/member basis of approximately 600.  Our mission statement states: “Quiet Rights is dedicated to protecting the rights of Alaskans to quiet places for the benefit of public land users, home owners, communities, businesses, wildlife, visitors and future generations”.  We believe natural quiet and natural sounds are resources to be protected on our public lands.

We are supportive of the project which expands the opportunities for nonmotorized summer recreation in the Chugach National Forest (CNF).   However, we find the DEIS raises four very substantial concerns which adversely affect the very purpose of this project: mining; state land at Grandview; Brown Bear Corridor; and, though not addressed, the issue of increased commercial recreational activity.

We think there is a distinct possibility that putting in improvements at Spencer Lake will act as an incentive to the miners to exercise their claims on the grounds that they better do so as quickly as possible before they are prevented from doing so. Additionally, it is still not clear how and whether the sound, sights and presence of the current level of mining can be harmoniously accommodated with a visitor’s experience utilizing the development contemplated for Spencer Lake.  We believe putting in a Whistle Stop at Grandview will accelerate commercial development on the surrounding state lands.  At the very least, no Whistle Stop development should take place at Grandview until the state has a management plan in place and the Forest Service has an agreement with the state that limits private development. Additionally, development at, and south of, Grandview would inevitably adversely affect brown bears and be in violation of the Brown Bear Corridor restrictions.  Moreover, Chugach National Forest’s inability to control development at Grandview mandates that it not open up Grandview as a Whistle Stop if it intends to honor the requirements of the Brown Bear Corridor. Finally, we found no reference to increased demands for permitting for commercial recreation should the Project go through.  We are concerned that there appears to be no consideration of the “carrying capacity” of the area included within the Whistle Stop Project.  With peak day use estimated to be 538 persons, it is inevitable that requests to operate commercial recreational activities will be “coming out of the woodwork”. There is nothing in the DEIS that even suggests the Forest Service has contemplated how to deal with this, much less the idea of “carrying capacity”.

In light of all these concerns, AQRC believes the only responsible alternative is Alternative D which offers the most protection to brown bears and compels the Whistle Stop Project to scale down its development. By offering only three Whistle Stops and associated less miles of trail and only one group campground for 50 persons, perhaps the Project has more of a chance to meet its goal of offering “primarily backcounty recreation opportunities”.  We are still puzzled by the size of the group campground at Spencer Lake.  The DEIS states that at maximum capacity, 80% of the 672 persons visiting daily will be day visitors only.  The remaining 20% or 134 individuals are estimated to stay overnight.  The question is, who are these people who have tents, sleeping bags and cooking gear for a one or two night stay?  The only answer is that they are members of tour groups wherein the tour company supplies such equipment. If so, they will all stay at Spencer Lake. It will become a destination and immediately will lose all its significance as a backcountry experience. We suggest that a much smaller group campground be substituted so that tour groups come to Spencer Lake for the day to admire the scenery and backpackers who truly want to experience the countryside are free to stay the first night at Spencer Lake without facing tour groups and then can disperse down the trails to other destinations.

Finally we note, as stated in our scoping comments, that the scope of this Project overwhelms the proposed experience.  For example, anyone in sight or sound of the tracks will experience, at a minimum, twelve trains passing each and every day. The DEIS states that the Project will be developed as money becomes available. We strongly urge that regardless of the Alternative selected, the FS proceed to develop the Project at a very modest pace, putting in the Whistle Stops without other improvements, except trail building, so that at least in the first number of years, a backcountry experience can be achieved.   As proposed, it seems to us that the Project will simply turn into another tourist destination which tour companies can promote.

Thank you for the opportunity to comment.

Sincerely yours,
Trisha Herminghaus, President
Alaska Quiet Rights Coalition
P.O. Box 202592
Anchorage, AK 99520