December 9, 2020
Mr. Bruce Hagedorn
Acting South Central Manager
Alaska Department of Natural Resources, Division of Mining, Land and Water
Dear Mr. Hagedorn,
Thank you for your October 5 reply to the Alaska Quiet Rights Coalition’s letter of September 3, 2020 requesting remedies and offering to work with ADNR to approach an equitable balance of shared uses in the Knik River Public Use area.
Supporters of the Alaska Quiet Right Coalition (AQRC) are especially interested in the concerns of area residents and user groups regarding the noise levels coming from the Kenny and Patti Barber Shooting Range. We are glad to see your letter close with “We endeavor to find the balance of multiple uses within the KRPUA.”
In that spirit we think there is still more to do. A number of people feel disregarded and that ADNR is blatantly favoring one use over another. AQRC’s intent is to listen to and advocate for the rights of user groups that prefer and benefit from quiet recreation, per our mission statement.
Everyone agrees to the well-documented and extraordinary recreational and habitat values of the Jim Swan Wetlands area and the Knik Watershed overall, and that there exists a history of shooting problems in the area. The Susitna Plan of 1985 listed Jim Swan Wetlands among “first priority areas” and Commissioners of ADNR and ADF&G called the wetlands “critical to the habitat” in 1984, notwithstanding subsequent decisions. Many user groups deserve consideration in all major decisions concerning the KRPUA, including noise levels.
We still have four concerns at this time: the high noise levels, the lack of equity in the designated quiet days, the noise emanating from the range when it shouldn’t be, and impacts of noise to wildlife.
The noise levels:
We have ascertained via testimonies and by in-person visits that the noise from the range can be disturbing at least as far as Brimar St. off Maud Rd., approximately 3.5 miles away. Under some atmospheric conditions, the range noise is heard on the Matanuska River flats south of the Palmer bridge, and on Lazy Mountain. Since the noise from the shooting range impacts the area so much, there is justification for a sound monitoring study followed by an acoustical engineering study to design barriers that will significantly reduce the noise impacts.
We have specific suggestions to improve noise abatements, since the side berms promised for the range have not been completed. On the west side there is no earthen berm except some exposed slope on the far end, simply due to leveling the site. There is no berm behind the firing line. Engineered berms completed along all boundaries would help. Properly designed acoustical barriers behind and at the end of the firing line have also been suggested, perhaps in combination with a berm to solve the problem of proximity to the road. The sound deadening material in the roof helps at the bench, but does not mute or direct sound escaping in all directions other than up. (This is very apparent out on the waters of Mud Lake.) Acoustical designs and materials can be engineered to be directional. An acoustical engineer could advise.
The lack of balance for quiet users
We again ask that ADNR create an additional range-closed weekend day for quiet users. Your response was that that issue had been resolved based on public input, yet ADNR indicated during the planning process it would be responsive over time to the public as it worked through regulatory changes at the range. The gun range was expanded after its initial completion, so we believe other changes deserve consideration as well. Gun range use numbers increased ten-fold from 2,774 in 2015, to 28,940 reported so far in 2020. Certainly ADNR should consider the noise impacts of such increased use.
One day out of seven is not adequate for users. Additional days should include a weekend day as well as adjacent days rather than discriminating against working people. Eklutna Lake management is an example of equity and such a model could provide meaningful compromise for user groups.
In addition, dangerous, off hours, and illegal shooting is still occurring in spite of the range in a wide area surrounding the actual range, creating both noise and safety issues. Dangerous encounters to persons by near misses persist. While ADNR holds no direct control over all of this, the stated intent in the KRPUA Plan is to coordinate with other agencies, so this issue deserves revisiting.
The impacts to wildlife
Your letter indicated that wildlife is increasing. Is there data showing increasing wildlife despite the noise levels, and if so would you please share that with us? Jim-Swan is an Audubon Important Bird Area which points to its importance for a number of bird species at the state level, and breeding bird populations have been shown to be adversely impacted by noise.
In addition to the specific noise issues above, AQRC asks that the state consider user fees. Thanks to Sen. Lyda Greene the KRPUA Plan provides, consistent with the Letter of Intent AS 541.23.180-230, the ability to charge fees. Generated revenue from nearly 30,000 gun range users this year could have made a huge contribution towards funding noise abatements and/or management/enforcement presence on this side of the KRPUA. More active on-site management for Jim-Swan has been requested for decades.
In closing, we would like to reiterate the intensity of noise and what we perceive to be blatant inequities in the KRPUA user experiences. Out on the wetlands, the reverberations of each shot from
a high powered weapons lasts approximately six seconds, which translates to a constant dull roar with just a handful of shooters engaged. It is increasingly apparent to quiet users of KRPUA that the present rock amphitheater is a problematic choice, making mitigations and ADNR follow through on their noise abatement promises even more important.
While nearly 30,000 users were polled at the range this year, that does not legitimize depriving alternate (unpolled) users identified in the KRPUA Plan a quality experience. A quiet canoe paddle, hike or other quiet activities are impossible 6 days out of the week. This is not what balance looks like. Your letter referred to the rebuilding of the Maud Road Extension that allows better access, parking and camping to Jim Lake for campers, boaters, and watchers of the abundant and increasing wildlife. The problem is that there is no recognition on ADNR’s part of a legitimate issue–that excessive noise ruins the experience for many users.
We look forward to your response and more discussion on these issues.
Alaska Quiet Rights Coalition