White Mountains National Recreation Area


December 6, 2005
Bureau of Land Management
Northern Field Office
1150 University Avenue
Fairbanks, AK 99709-3844

Re: White Mountains National Recreation Area
Resource Management Plan Amendment

Dear Planners:

The following are the belated scoping comments of the Alaska Quiet Rights Coalition on the proposed RMP amendment dealing with summer OHV use in the White Mountains NRA. We learned somewhat late about this planning project and hope that we can still be of some help. Please send us a copy of the EA when it’s completed, so that we can comment again at that time, to Cliff Eames, one of our board members, at HC 60 Box 306T, Copper Center, AK 99573.

AQRC has more than 600 members and supporters throughout the state. We believe that natural sounds and natural quiet are resources deserving of the same sort of protection that land managers provide to other natural resources, such as fish and wildlife, clean air and water, and scenic beauty; furthermore, with regard to natural sounds and natural quiet, which have become increasingly hard to find, restoration is as important as protection. We also believe that the management of recreation on the public lands needs to be both fair and balanced, and that quiet recreationists deserve equal consideration with motorized recreationists in the allocation of high quality recreation opportunities; at the present time, quality motorized opportunities far outweigh non-motorized ones. Finally, AQRC seeks to protect wildlife, other natural resources, private home and cabin owners, and a wide array of non-motorized users from the noise and other impacts of nearly ubiquitous motorized recreation on the public lands, waters and in the air.

We would like to respond primarily to “the modifications to be considered” described at page 6 of your September 2005 Scoping Report. But first we’d like to briefly put this amendment in context, which we have already done to some degree above.

Relatively accessible opportunities for both wildlife and humans to escape the obtrusive noise and other impacts of motorized recreation on the public lands are quite rare in Alaska; similarly, the soils and vegetation on the great majority of the state’s even moderately accessible public lands are subject to significant long-term damage from non-snow season OHV use that is either not managed or is poorly managed. State-owned lands are probably the best example of this general lack of management, but at least in the Glennallen District, for example, BLM management is only marginally better (in that district only in the Tangle Lakes Archaeological District are there any meaningful restrictions on such use). Consequently, the White Mountains NRA can–and we believe should–be a place where OHVs on the public lands are responsibly managed.

Finally, in this broader regard, although we know it’s not an issue BLM is addressing in this planning process, we would like to note for your future consideration our belief that winter motorized use should also be more strictly managed on the public lands. As part of the multiple use spectrum, there should be sizeable areas where both humans and wildlife can find a refuge, through either space or time zoning, from the impacts of motorized recreation. Without zoning, most so-called “shared” areas, or multi-use trails, instead become the domain, sometimes almost entirely exclusive (dependent on the magnitude of the motorized use), of the most technologically powerful and obtrusive form of recreation–which of course is motorized recreation.

Regarding the modifications you intend to consider, we believe that non-snow OHV use should be restricted to designated trails only. And of course not all existing trails should be designated; only those trails that are in locations where impacts to natural resources and to other users will be minimal should be designated. In fact, we believe that such a policy should apply to virtually all of Alaska’s public lands, regardless of who manages them. The damage that’s done by cross-country travel and by the braiding of existing trails in wet or otherwise unsuitable locations is an embarrassment and should not be tolerated by either land managers or the general public.

We are often very skeptical of trail hardening. In most locations a hardened trail just makes it easier to get further into the backcountry and damage soils, vegetation and other natural resources over a larger area than was previously the case. Hardening, if it is to occur at all, should be done only on designated trails in locations that are generally hard and dry and where staffing is adequate to enforce a requirement that travel occur only on the designated trail, and not off it (including beyond it).

A non-degradation threshold for summer OHV use should only be in addition to a designated trail policy (that is, if the designated trail is degraded beyond the applicable threshold, some protective measure or measures would be taken).

Finally, we understand that BLM had earlier been seeking comment on three alternatives. We believe that Alternative C is the only one that could lead to adequate protection of the resources for which BLM is responsible.

Thank you for the chance to offer these thoughts beyond the end of the formal scoping period. We look forward to reviewing and commenting on the upcoming EA.


Trisha Herminghaus
Board President, AQRC