October 31, 2011
Alaska Department of Natural Resources
Chugach State Park Planning
550 West 7th Ave., Suite 1050 Anchorage, AK 99501
RE: Comments on the Draft Chugach State Park Management Plan
Dear Ms. Alvarez:
Thank you for the opportunity to provide comments on the draft Chugach State Park (CSP) Management Plan. Following are my comments submitted October 31, 2011.
To begin I want to comment on the overall tone of the draft plan. Specifically there are two predominant issues throughout the plan: (1) lack of priorities and (2) lack of data. A management document that will guide CSP planners for the next 2-3 decades needs to list priorities and back up proposed projects and changes within the park with data showing that those projects and changes are necessary.
Lack of Priorities
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. Please include a list of CSP priorities within the plan.
Lack of Data
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. 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. Please implement some sort of data collection requirement before projects can move forward.
Aside from overall tone I would like to comment on 4 keys issues within the plan: (1) Wilderness (P40-42), (2) Facilities and Commercial Uses (P55-58), Glen Alps (P103-110) and (4) the proposed anchor ban (P51).
The draft plan removes the entire Crow Pass trail corridor from the wilderness zone. 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) this removal could serve as a precedent for future removal of other areas from wilderness. Please maintain the same acreage in each zone as existed previously. For example - if Crow Pass is removed from the wilderness zone then consider adding the alpine areas above Symphony and Eagle Lakes to wilderness.
Facilities and Commercial Uses (P55-58)
I would like to comment on four key points within the plan.
- 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 and would be a welcomed addition to the park. 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.. Please remove the proposed Peter’s Creek cabin. Cabins should not be developed in wilderness zones.
- Commercial Lodges or Resorts: (P57) Commercial lodges should not be compatible within the park.
- Commercial power development: (P58) Power development should not be compatible within the park.
- Resource Extraction: (P58) Resource extraction for commercial use should not be compatible within the park.
I recognize that the road to Glen Alps has been a contentious point for homeowners in the area for many years and that the Glen Alps Limited Road Service Area shoulders much of the burden for road maintenance. However, instead of building a new access road 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.
It should also be noted that:
- The proposed expansion of Glen Alps and Upper Huffman contradicts the parks desire to alleviate pressure at this trailhead.
- The road will likely cost millions. 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.
Please remove the proposed Upper Huffman expansion and Glen Alps Access Road from the plan.
Proposed Anchor Ban (P51)
The draft plan has recommended "permanent rock anchors" be prohibited in Chugach State Park (CSP).
If the proposed ban is not removed from the final plan then all technical climbing within CSP will essentially be banned. Permanent anchors are an integral part of climbing and are used by climbers to safely protect portions of climbs that would otherwise require a high degree of risk. Given the poor rock quality and lack of natural protection in Chugach rock, permanent anchors are a necessity for climbers’ safety. Likewise permanent rappel anchors are needed on any technical mountaineering, ice, or rock route that lacks a walk off descent.
It is also likely that the ban would prohibit replacement of existing fixed anchors, thwarting efforts to upgrade old bolts and other fixed gear (some of which have been in place for over 60 years) and prohibit any new route development that requires fixed anchors (bolts, fixed pitons, slings left behind, fixed nuts, etc.).
Currently all of the rock and ice climbing areas along Turnagain Arm from Anchorage to Girdwood lie within CSP boundaries and many of these climbs utilize permanent rock anchors – either for protection or for top-rope / rappel anchors. Other affected areas include Ptarmigan, The Wedge, O'Malley, Yukla, Dew Mound, Eklutna Canyon, Pioneer Peak, Hunter Creek, and any other CSP technical mountaineering route that requires a rappel.
It should be noted that:
- Technical climbing is a customary and traditional use of Chugach State Park and many technical routes require permanent rock anchors.
- A permanent anchor ban in Chugach State Park would effectively end technical rock and ice climbing and mountaineering within the park – an activity that hundreds of people enjoy year round.
- Permanent rock anchors have been in use within Chugach State Park since the early 1950s.
- Permanent rock anchors are a necessity in Chugach State Park due to poor rock quality.
- Banning permanent rock anchors would make many routes dangerous and increase the likelihood of accidents due to inadequate protection.
- Permanent rock anchors are not just used to aid in climbing a route. For example, in some areas bolts have been placed in rock to reduce the impacts of climbers using vegetation for anchors and rappel stations.
- Permanent rock anchors need to be replaced or improved occasionally.
- New routes may require some permanent anchors.
- Permanent anchors are NOT illegal under the Wilderness Act.
Permanent anchors are essentially invisible except to climbers actually climbing a route.
Please remove "except the use of any permanent rock anchors is prohibited" from the plan.
Once again thank you for the opportunity to comment.
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