The comment deadline is October 31st. You have just over 2 weeks. But what's in the plan and what are you going to say?
First when it comes to sending letters one should note that volume does not matter - however the salience of the comments does. In other words... don't expect results by getting your friends to send hundreds of letters. It's better off to choose key issues and write about them. That said below I've outlined a number of key issues that you can base your comments off of.
Following my notes I have summarized comments from two commentary pieces and two environmental groups. I'm rather discouraged by the lack of discourse we're seeing for this plan. Anchorage is home to almost 300,000 people and Chugach State Park is the crown jewel of our community yet few groups are getting involved. Where are public comments the Alaska Conservation Alliance, Conservation Foundation, Wilderness Society, Wildlife Alliance? All of these groups have websites, blogs, Twitter feeds and Facebook pages yet none of them have so much as mentioned the management plan. I imagine (and hope) that many of these groups have already formally submitted comments but their lack of transparency and communication with Anchorage residents is disheartening.
That said... Kudos to Alaska Center for the Environment and Alaska Quiet Rights Coalition for addressing the plan and posting comments and guidelines on their site. Likewise thanks to Bill Sherwonit and Barbara Winkley for their commentaries in ADN and the Dispatch. You can learn more about the comments from the groups / people below.
As for the plan itself... To begin there are overall issues with the tone of the plan (see my note's from ACE's comments below for more on this). Throughout the document two important elements are lacking: priorities and data. A guiding document that lacks these key elements falls short of being a guiding document and the public should make note of that.
Beyond the tone the document there are three key issues that one should make a note of: (1) a reduction in wilderness, (2) development of facilities and approval of commercial uses, and (3) a multi-million dollar plan to build a new road within the park.
With that said... on to my notes. Please take these for what they are... notes. If you have questions contact the environmental groups you usually correspond and work with. Get them involved and make them comment. You have two weeks.
The plan is colossal (145 pages) yet it totally lacks priorities. The plan acknowledges that during the planning process " the public consistently identified certain areas of interest that need to be considered as implementation priorities " yet the document neglects to incorporate any of those priorities.
For example, when identifying the issues involving access at Ram Valley (p. 66) the plans states, "this area has consistently been identified by the public as a priority for securing access." However later in the document (p 92) the plan states that for Ram Valley "a separate site planning process will be needed to determine the size and type of facilities needed depending on the area secured for access."
In other words... the park is aware that the public has clearly identified and requested priorities, however the plan does not address them.
- The final plan needs to list priorities.
DNR / Alaska State Parks has released a 145 plan that will serve as a guiding document for 3 decades - however there isn't a shred of data within the plan. How is this possible? No visitor numbers, no surveys of park usage, no wildlife counts. Nothing.
Much of the plan revolves around improving existing trails, adding trails and building new parking lots - yet the state has offered zero evidence to show that they are necessary.
For example, on page 107 when talking about the Upper O'Malley trailhead the plan states, "Conservative expansion of parking in this area could help disperse use and alleviate pressure on other hillside trailheads" .
I have never seen more than 3 cars parked at this trailhead so I don't understand how adding a parking lot would alleviate pressure elsewhere. The state has no data to back up statements like this - yet the plan consistently uses wording like this.
- It is unlikely that the final plan will include any data, however there should be a public record of complaints about the lack of data.
- The state should not be able to release plans that will shape the way our parks are managed for decades without a datasource that can back up their varied claims.
The draft plan removes entire Crow Pass trail corridor from the wilderness zone. As other have pointed out this removal does not account for a large amount of land, however is key for two reasons: (1) it splits the existing wilderness area of the park into two pieces instead of one continuous piece. And (2) there is a concern that this removal will serve as a precedent for future removal of other areas from wilderness.
Given the amount of traffic Crow Pass sees there is little chance this portion of the plan can be reversed - however public comments should request that any reduction in wilderness areas be met with an addition in other areas. For example - if Crow Pass is removed then the alpine areas above Symphony and Eagle Lakes should be added.
- Request that any reduction in wilderness be complemented with an addition of wilderness in areas not currently zoned as wilderness.
Crow Pass trail.
Sheep above Eagle Lake.
High above Eagle Lake.
Facilities and Commercial Uses (P55-58)
Upper Peter's Creek.
Best experienced with tent.
Key points that struck me include:
- Public use cabins in wilderness: The plan adds two public use cabins; one in Bird Valley and one in Peter's Creek. Of those cabins the Peter's Creek one would especially change the nature of the area. Bird Valley is already heavily trafficked and a cabin would be placed in an area frequented by many users. Peter's Creek on the other hand is a very wild valley. We don't need a public use cabin in one of the more wild areas of the park.
- Commercial Lodges or Resorts: (P57) The park plan says "Allowed only under concession contract and when compatible with park purposes, when consistent with a management plan, when enhancing public use and enjoyment of the park, and when a similar experience cannot be provided outside the park." I don't see how commercial lodges can possible "enhance public use". Commercial lodges should not be compatible within the park.
- Commercial power development: (P58) The plan states that power development should be "Compatible by permit". Power development should not be compatible within the park.
- Resource Extraction: (P58) Resource extraction for commercial use should not be compatible within the park.
Wildlife issues are also mentioned in this part of the plan. So if you are concerned about hunting and trapping within the park you should read pages 61-62 and refer to ACE's comments.
- No new cabins should be developed in wilderness zones.
- Request the plan be changed so that commercial lodges, commercial power and resource development are listed as not compatible within the park.
Glen Alps (P103-110)
On page 105, the plan (in regards to Glen Alps) states, "Additional parking lot expansion and enhancing of recreational opportunities at this trailhead is not the preferred solution." However the plan then goes on to announce a bold new development that will inevitably draw more people to this portion of the park. On page 107 the plan announces their vision for a new Chugach State Park. This vision includes the following:
- Upper Huffman Trailhead: Redesign and enlarge parking area to better accommodate winter use and future connection through the park to the Glen Alps Trailhead. Include winter shelter, picnic pavilions, trailhead kiosks, and scenic overlook enhancements.
- Glen Alps Access Road & Associated Parking Areas: A road approximately 2 1/2 miles long between the Upper Huffman and Glen Alps trailheads. Various smaller parking areas, and at least one that can accommodate vehicles with trailers, should be established along this road to disperse use.
- Glen Alps Day Use Trailhead: After the Glen Alps access road is completed, establish a group use area and picnic pavilions at this trailhead.
- Glen Alps Maintenance Compound: Develop a maintenance compound in the vicinity of the Glen Alps Trailhead to service the area once the connector access road (see above) is developed. The maintenance area should include secured storage for tools and equipment.
Four small paragraphs announce this plan but beyond that nothing is said. No cost estimates, no time frame, nothing.
Powerline Pass and Glen Alps Trailhead. A road, picnic shelters and maintenance yard would not improve this view.
On top of Flattop.
The road to Glen Alps has been a contentious point for homeowners in the area for many years now. The Glen Alps Limited Road Service Area maintains the roads in the area and residents are quick to point out that they "pay 100% of the maintenance associated with those roads". However - it is important to note that in the past public money has been allocated for this area (e.g. 2.5 million in 2007) so the claim that residents pay for 100% of road services is not entirely true. That said, $2.5 million is not enough given the amount of traffic this area sees.
A better plan for Glen Alps would be to (a) spend money on developing other access points to visitor use is spread out and (b) allocate additional funding to improving Toilsome Hill drive so residents do not unfairly shoulder the majority of costs for these roads.
I have linked to two articles below that have more information and talking points about this proposed road. It is important that you mention this proposal in your comments.
- The proposed expansion of Glen Alps and Upper Huffman contradicts the parks desire to alleviate pressure at this trailhead.
- The road will likely cost upwards of $30+ million. Given the chronic funding shortfalls for Alaska State Parks it is unlikely that the park will acquire the money.
- The park has not adequately analyzed or considered the impact of this project.
- The only way to alleviate pressure at Glen Alps is to encourage users to go elsewhere. Currently trailheads such as the Honey Bear Lane parking area discourage visitors due to signs placed by homeowners. Remove these barriers to public access and visitors will frequent other portions of the park.
Sign at McHugh Parking Lot.
This is an access to CSP.
McHugh Lot: Residents only allow users to
park between those signs. Thus there is
only room for 5 cars in a lot that
would hold 30.
Bill Sherwonit: Glen Alps Parking Appropriation: Yes, with Reservations
Sherwonit's June compass piece was the piece that first alerted many Alaskans to the original Upper Huffman road extension proposal. The piece focuses primarily on the new lot scheduled to be developed next summer. However Sherwonit goes on to point out that this lot is only the first step of the Upper Huffman development. Sherwonit writes:
...this would be literal overkill and raises the question: is this the best way for state park funding to be used, when there are so many other pressing needs, for instance long overdue trail repair and maintenance, the upkeep of existing facilities, and improved access at other entry points into the park? Aren't these more important than a new road and parking areas that will almost certainly cost tens of millions of dollars?
Sherwonit then goes on to say that other alternatives exist - namely a parcel of land on the other side of the road from the existing parking lot that a current resident is trying to sell the to the park.
Barbara Winkley: Residents should speak out about planned 'Chugach State parking lot'
Barbara Winkley's recent piece in the Alaska Dispatch outlined a number of issues dealing with the proposed road. Her key points are:
- There have been no studies regarding the impacts of this extension.
- DNR does not provide a cost estimate for this extension.
- The proposed road conflicts with the park's goals of protecting the park's unique scenic values and providing for public display of local wildlife.
Read it here. Pay attention to the comments. They illustrate what landowners will be saying once this project moves more into the spotlight.
Alaska Quiet Rights Coalition Statement
As can be expected AQRC focuses on ORV usage in the plan. However in addition to ORV usage they comment on the key point that while CSP has a goal of "Protecting park resources to allow for diverse visitor experience" the plan neglects to implement any type of tool that will monitor impacts within the park. Likewise they point to the lack of data and analysis within the plan as noted in the quote below:
Our first question is why this data was not gathered during the planning period? How can this plan guide management decisions for twenty years when DPOR lacks the basic data to inform managers as to how people, in what numbers, use the park today and the visitor trends for future years.
Another key point they identify is the lack of specific priorities. The plan is 145 pages and identifies numerous projects, yet no cost estimates are included.
Their final point is a lengthy comment regarding the proposed road from Upper Huffman Trailhead to the Glen Alps Trailhead:
The road would be plowed in the winter and, once completed, would be the only vehicular access to the Glen Alps Trailhead. What is proposed is a far cry from the original proposal in the 1980 Master Plan. That called for a 1/2 mile road to be constructed from the Upper Huffman Trailhead out to the existing road (which was the Gas Line maintenance road). The current proposal makes no use of the existing Gas Line trail, but instead would lay bare a 2 1/2 mile by 100 foot (minimal) swath, bring major construction activity into CSP and scatter the wildlife.
ACRC goes on to say that they understand the problems that have arisen from the Glen Alps trailhead, yet point out that this proposal makes no sense.
Alaska Center for the Environment
ACE is more interested in policy then in addressing issues - thus their comment mostly has to do with tone rather than specific issues. Like AQRC they begin by pointing out the issues with the overall tone of the document, their overall impression being that the plan:
... make(s) way for an entire menu of new development. The plan lists no priorities, lacks data, includes no figures on visitor numbers, does not attempt to consider carrying capacities, nor monitoring requirements. The proposed 2.5 mile road leading from Upper Huffman to Glen Alps through a cherished portion of the park will be an extremely difficult project to sell to the public. The deferred maintenance bill for this park alone is very large ($60m) and funding shortfalls are chronic.
Regarding wilderness ACE is again quick to point out the overall tone of the plan. Since wilderness is a key issue within this plan the whole paragraph is worth quoting:
The plan fails to define wilderness in a comprehensive way, and is eager to point out that they are not talking about Wilderness as defined by the federal government, but wilderness Alaska style-where all kinds of uses and activities may occur.
ACE has a short blurb about access, namely pointing out that park managers should continue to support Title 21 (the municipal code requires landowners to provide an easement to park lands).
And finally ACE comments specifically on the Upper Huffman extension pointing out that:
Glen Alps access road (P108)-is controversial and even though it is unlikely that the park will acquire the kind of money required to build such a road, alternatives need to be explored. It would likely cost 30-40 million dollars and would bring even more users to this part of the park.
And that's all I have to say regarding the plan. To learn more about the plan visit:
Comments are due by October 31, 2011
Send Comments to:
Alaska Department of Natural Resources
Chugach State Park Planning
550 West 7th Ave., Suite 1050
Anchorage, AK 99501
Tel: (907) 269-8145
Fax: (907) 269-8915
Update 10/16: Following are links to Anchorage Ski Club's comments on the plan. In short they are concerned because the plan states that after 2022 CSP intends to open up Arctic Valley to a concession contract and allow anyone to bid.
- Points Regarding the Discussion and Treatment of Arctic Valley
- Open Letter to Actic Ski Club Members
Update 10/20: Today Bill Sherwonit published another piece in the ADN: "Proposed Road Is Only One of Several Problems in New Chugach Park Plan". This piece gives more insight into the over-all tone of the plan. He also adds more to his previous commentary on the Huffman road.
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