Willow Mt. CHA Management Plan Scoping Comments

April 24, 2012


Habitat Division, ADF&G

333 Raspberry Rd.

Anchorage, AK 99518-1555


Re: Willow Mountain Critical Habitat Area (CHA) Management Plan Scoping Comments


The Alaska Quiet Rights Coalition (AQRC) offers the following comments for the scoping phase of the planning process for the Willow Mt. CHA.  The mission of AQRC is to maintain and restore natural sounds and natural quiet in Alaska through advocacy and education for the benefit of people and wildlife. It is our concern for the wildlife in the CHA that prompts these comments.


  • Adverse affects from noise and the presence of motorized activity

Wildlife will avoid areas of motorized use and unfortunately some motorized users disregard rules and guidelines that stipulate that they stay on designated trails.


  • Habitat degradation from the use of ORV’s is an ongoing problem

AQRC supports the continuation of the existing stipulations:

April 1 to Nov. 30 restriction of authorized vehicles to authorized trails; requirements for 12″ of snow cover and sufficient ground frost before any off-trail use; limit of 1000 lbs. dry weight for off-road use without a special permit.


  • Signage is not enforcement

While we understand signage has been installed, we question whether these restrictions on off-road activity are observed and strongly urge that the plan include enforcement mechanisms. Without enforcement we strongly doubt that people operating in conformity to the “generous” provisions of the “Generally Allowed Uses” in the area, e.g., up to 10,000 pound vehicles or no depth limit on snow cover, stop and turn around at the borders of the CHA.  We wonder if hunters leave their ORVs on the trail and retrieve their moose on foot.

Hatcher Pass Management Plan

  • The plan states that summer ATV and ORV use is causing “degradation to the wetlands and alpine tundra” in the Willow Mt. Management Unit, of which the CHA is a part.

The statutory purpose, to provide protection for moose post-rut, requires that ADF&G protect both the moose and their habitat from unregulated ORV use disrupting either the animal or its habitat.


  • There are discrepancies between the maps used by ADF&G and DNR in regard to trails in the CHA.

The Plan states: “There are currently no improved routes for ATV or off-roading in this management unit” and as a result wetlands, marshy lands and creek drainages have been degraded, etc. (p. 3-18). However, your map shows  “designated and approved ORV trails” to and through the CHA, including in part the RS 2477 trail.  Further, the Plan map (Map 3-3) indicates only snowmachine trails going into the CHA (except for RS 2477); it does not identify any ORV trails to the east or south of the CHA. Though we understand that ADF & G is solely responsible for management within the CHA , DNR has the management responsibility for trails outside the CHA located within the boundaries of the Hatcher Pass Management Plan.

It is important that the two agencies clarify the existence and location of the various trails as part of the planning process so that the appropriate state agency knows, accepts and manages all trails within its jurisdiction.


In closing, AQRC hopes that the agencies will do the right thing and implement strategies for real enforcement and active management of the area.  Plans are not enough to manage Alaska’s amazing resources and natural assets.


Thank you for the opportunity to comment on this important wildlife and habitat issue.





Kathy Wells

Alaska Quiet Rights Coalition Board Member