Goal of the Plan
Need for the Plan
Management Goals
Actions Common to All
Permits and Registration
Alternative B
Alternatives C, D & E

May 30, 2003

Superintendent Anderson,
The Northern Alaska Environmental Center [NAEC], which represents a diverse cross-section of individuals concerned with the well-being of Alaska's wilderness rich lands, urges the National Park Service [NPS] to select some close approximation of actions reflected in Alternative B of the Draft Backcountry Management Plan [BCMP] for stewarding Denali's wilderness backcountry. The NAEC asserts that the NPS, in order to restore the wilderness character of the Park's additions and to head off future impairment to Park resources, should not move forward to sanction recreational snowmobile use in Denali's backcountry until such time as Congress has made a determination on the wilderness review process and a Wilderness Plan for the Old Park, the Soundscape Preservation and Noise Management Plan, and a Subsistence Plan have been implemented. To take any other action, at this time, as proposed in Alternatives C, D, and E is premature and runs contrary to the Organic Act, ANILCA, the Wilderness Act, NPS Management Policies, Directors Orders, and Executive Orders, which instruct the Service to protect and preserve the wilderness qualities and the tangible and intangible resources of the Park for present and future generations.

The NAEC recognizes that the NPS is under tremendous political pressure to produce an industry friendly plan and thus provides some input on regulating snowmobile use, but does so with the clear disclaimer that any use of snowmobiles in the backcountry beyond that mandated by ANILCA to ensure the continuance of a rural Alaskan lifestyle, which is dependent upon access for traditional and subsistence purposes, is not condoned by the NAEC.

The NAEC appreciates the efforts that the NPS has gone through to solicit input from the public and stakeholder groups on this essential planning process. The NAEC would also commend the NPS on the quality of information that is included in the Draft Plan. One notable point of reference lacking, from the voluminous, 466-page document and that was sorely needed to address the complex and multitude of issues contained therein, was an index for cross-referencing purposes.

The following comments on specific issues contained within the draft are put forth for consideration. The NAEC is hopeful that the NPS will modify to a great extent the evident trend exhibited in their preferred alternative to promote excessive motorized access options with little effort to restore the already marred wilderness character of Denali National Park and Preserve.

GOAL OF THE PLAN
"The goal of the backcountry management plan is to describe how the NPS will act to provide future generations with a variety of opportunities to experience the park backcountry while protecting park wildlife and other natural resources, wilderness values, and subsistence uses."

The stated goal for the Denali Backcountry Management Plan causes concern to the NAEC for the following reasons:

· The NPS priority as defined by this goal is managing for "opportunity" over the more fundamental mission "to protect and preserve the resource." Congress has clearly specified that the primary role of the NPS is to protect and preserve the resource: from the Organic Act of 1916, "…to conserve the scenery and the natural and historic objects and wild life therein…" and later reemphasized this assertion in the 1978 Redwoods National Park Expansion Act, "protection, management, and administration of these areas be conducted in light of the high public value and integrity of the NPS system and shall not be exercised in derogation of the values and purposes for which these various areas have been established…" As written, the BCMP goal indicates that the primary role that the NPS is undertaking is to "provide future generations with a variety of opportunities to experience the [park] backcountry," and that secondarily, the resource will be protected. The stated goal of the plan would better reflect the agency's primary mission and resonate in a less objectionable way if it were stated thus,

"The goal of the backcountry management plan is to protect park wildlife and other natural resources, wilderness values, and subsistence uses, while providing for opportunities to experience the backcountry."

Although this nuance may appear to be inconsequential, the NAEC maintains that the distinction is paramount to the basic premise of the stipulated NPS mission to protect and preserve the vast, undeveloped Denali wilderness. In other words, the imprudent focus of the BCMP is on "recreation" rather than "resource stewardship".

· The NPS assumes to comprehend the needs and desires of future generations in regards to what types of opportunities they will deem appropriate to occur in a wilderness park. The NAEC would argue that it is not the role of the NPS to predetermine what "variety of opportunities" future generations will have but rather it is the fundamental role of the NPS to ensure that the opportunity to enjoy the natural resources, wilderness values, and subsistence uses embodied in Denali's backcountry remain viable. The NPS BCMP should focus on restoring and preserving the opportunity to experience wilderness and all its associated values rather than providing for prescribed uses that may or may not be deemed appropriate at the present time or in the future. Again, there is a subtle, yet meaningful distinction between "providing for opportunities in the wilderness backcountry" vs. "providing for the opportunity to enjoy the wilderness backcountry."

· As the goal is written, it appears to be a reaction to and a means to validate uses presently occurring, some with questionable legal authority, in Denali's backcountry. Restoring and preserving the wilderness character of Denali should be the foremost goal of the BCMP. Instead, the plan highlights and caters to the 21st century American demand for fast and easy access and immediate gratification and fails to recognize the need to retain places that embrace our American wilderness heritage. The conservationists who came before us traversed a long and difficult road, one that incorporated vision and foresight and imparted on Americans a unique system of public lands. Within that system, including National Forests, National Wildlife Refuges, National Seashores, National Recreation Areas, etc., there are unique mandates, of which administrators are held accountable, to provide for a "variety of opportunities" through which the American public can experience the great outdoors. Our National Parks are one part of that system. The American public has come to understand that our resource-based National Parks are different, that they are our "crown jewels," and as such, they require more stringent restrictions on resource use. What should be paramount to the BCMP planning process and what appears to be only a secondary function of the plan is taking the utmost care to protect Denali's wilderness and all that it symbolizes for the present and future generations.

NEED FOR THE PLAN
1) The NAEC notes that, to date, there has been inadequate planning for the protection of resources in the 1980 Park Additions and that visitation and uses that are degrading those resources have increased, at an alarming rate, unimpeded by the NPS. Therefore, the NAEC agrees with the NPS that these resources and associated uses need to be addressed in an open, planning process.

2) The fact that "visitation has grown dramatically for some backcountry activities," some of which are deemed to be illegal, does not require "new" methods of management as described in the plan rather what is warranted is that some approach to managing these activities be set in motion. "Throughout the history of the park, management decisions have been oriented to the preservation of the intangible values of wilderness." The NAEC encourages the NPS to maintain this historic precedent and to not be compelled to create "new methods of management" that cater to the "pressure for comfortable, convenient, and predictable access" to an outstanding wilderness resource.

NAEC agrees with and commends the NPS on its efforts to address activities that heretofore have gone unchecked; of particular concern is the boom in airplane overflights and landings and recreational snowmobile use in the Park Additions. Although the NPS does not control the airspace, they do have jurisdiction over landings in the park and as such limiting this source of access will do much to mitigate the degradation of the park's soundscape, subsistence resources, and other natural assets. As far as the snowmobile issue is concerned, the NAEC asserts that the NPS could have addressed this activity, as the use became more widespread and the industry promoted Denali as a destination, back in the early 90's. At this late date, with the use of parklands by recreational snowmobilers strongly entrenched, the various stakeholders are at great odds as to what should or should not be allowed to occur in suitable wilderness areas. This is unfortunate; the extent to which the NPS, in the preferred Alternative D, espouses to support the use of motorized recreation in these wilderness lands is perceived as a political decision rather than one that is based on sound science and restoration and retention of the wilderness character of Denali National Park and Preserve.

3) NAEC supports the foresight that NPS is exhibiting in addressing likely demands for increases in the following activities: mountaineering, off-road bicycling, motorboats, stock animals, and hiking and backpacking.

4) In maintaining the perceived consistency of the BCMP placing needs and uses of the visiting public over resource protection, under the needs statement, "Changes in backcountry use require National Park Service action to protect park resources and wilderness character," is listed fourth. This is not noted as a criticism per se but is used to further illustrate the concern the NAEC has on the focus of the plan. The NPS might suggest that this underlying concern is unfounded and that the focus of the backcountry plan logically lies in addressing users and their activities as they pertain to the backcountry; but the NAEC would argue, as it has in its scoping comments on the Backcountry Plan for Gates of the Artic that, "We believe that by firmly establishing an attitude of "Stewarding Wilderness" rather than "Managing Park" [in the minds of the personnel, particularly at Gates of the Arctic,] the likelihood of making poor wilderness decisions decreases substantially."

MANAGEMENT GOALS

General Vision
It is deemed appropriate that the vision statement should include a simple statement that defines the commitment of the NPS to restore and preserve the wilderness character of Denali's backcountry. The vision statement alludes to the wilderness character of Denali only in professing to allow the public to use the wilderness. A clear and concise statement referencing the dedication of the NPS to restore and preserve the wilderness character of Denali's backcountry, as defined by the Wilderness Act and ANILCA, would explicitly guide planners in determining what uses should or should not be permitted and would ensure public understanding of how and why those uses were identified.

Objectives
1. The NPS stated objective to "protect and preserve the park's natural and cultural resources and values, and wilderness resource values, including natural soundscapes and intangible values such as solitude," are fully supported by the NAEC. However, as will be elaborated upon further, the NPS, in selecting Alternative D as the preferred course of action, falls far short of fulfilling this lofty objective.

2. The NPS stated objective to "provide for the maximum freedom of use and enjoyment of the park's backcountry and wilderness in a manner that is consistent with park purposes and the protection of park resources and values," is problematic. The NAEC questions the NPS use of the extreme phrase "maximum freedom" as it relates to the "use and enjoyment of the park's backcountry and wilderness." Once again, the underlying principle being espoused by the plan is one of a very liberal interpretation of "providing for the enjoyment." This objective would better reflect the mandated NPS role in managing for the backcountry if it accentuated protection over recreation:

"Provide for the maximum protection of park resources and values and provide for the public's freedom of use and enjoyment of the park's backcountry and wilderness as long as those uses remain consistent with park purposes and the protection of park resources and values."

3. NACE agrees with the NPS objective "to define the recreational opportunities provided in Denali's backcountry in the context of a spectrum of recreational opportunities available on public lands in the Denali region," however, we question whether or not this objective was actually pursued or if it has been achieved in the NPS preferred Alternative D. Alaska is 375 million acres large; Denali National Park and Preserve constitutes 1.6% of that land area. In a regional context, motorized recreational use of public lands is sanctioned and thus, the NAEC questions how the NPS defines the Park as unique, except in Alternative B, when the uses promoted to occur in the backcountry are available on lands outside the bounds of the Park. NPS does not justify the need for allowing certain recreational uses [emphasis on snowmobiling] within the bounds of the Park when there are hundreds of thousands of acres available for this type of recreation in the region. The NPS does not make the case for treating Denali any differently than the surrounding land areas and as a matter of course there appears to be no difference. The NAEC would encourage the NPS to expound upon how they actively pursued this objective, what other agencies were contacted, were there meetings held to address this issue, if so what were the results of these meetings, in a regional context was it agreed upon that this 1.6% of Alaska's land area would be treated differently, if so define different and how this objective is treated within the context of the plan.

On page 181 of the plan, the NPS declares that that it will "redirect non-wilderness dependent uses or more developed forms of outdoor recreation towards lands with management goals that are appropriate for those uses," the NAEC would question the NPS on what developed forms of outdoor recreation have been redirected. The NAEC contends that the desire of the NPS to have snowmobile users practice "best behavior", follow speed limits, restrain from high-marking, etc., which is part and parcel to the argument that recreational snowmobiling in the National Park will provide for a "different" experience than what is offered these users on other lands within the region, is a weak argument for allowing snowmobile use in the Park as this type of snowmobiling can certainly be practiced elsewhere. Additionally, the NAEC has grave concerns over the ability of the NPS to enforce behavioral limitations.

4) Provide for the means to achieve public understanding and support of backcountry and wilderness values.
· If the Service implements any Alternative except B, NAEC questions the credibility of the NPS to espouse upon the subject of "wilderness values." The NPS commitment to wilderness values will be clear if the final plan reflects some close facsimile of Alternative B, where the basic premise is to prudently await a Congressional decision regarding wilderness designation so as not to jeopardize the future inclusion of these lands as Wilderness; implementation of any other Alternative runs the risk, both politically and environmentally, of excluding regions of the park now deemed suitable for wilderness from eventual designation. The American public has a general understanding of what the term 'wilderness' connotes and a general understanding that certain uses, i.e., motorized vehicles, are prohibited in wilderness areas, [with exceptions]. Any attempt by the NPS, to espouse upon "wilderness values" within the context of the proposed recreational use of snowmobiles and increases in Dispersed Scenic Air Tour landings in wilderness lands will only result in confusion and a potential negative backlash on the entire wilderness system in the Lower 48 and other Alaskan CSUs. The definition of what wilderness is and what uses lawfully may occur in wilderness lands is clearly defined and needs to remain consistent and not be muddied by the precept that such uses will be allowed now and if wilderness designation is granted that use may cease to be permissible.

ACTIONS COMMON TO ALL

Wilderness Management
The NAEC appreciates the stated intent of the NPS to manage Denali's backcountry in order to protect the wilderness character of all lands, suitable, proposed, recommended and designated, as wilderness. The NPS BCMP claims [p. 30] that "in implementing this plan and with future management actions, would with every decision forego actions that might have no seeming physical impact but which would detract from the idea of wilderness as a place set apart, a place where human uses, convenience, and expediency do not dominate." The NAEC supports this management philosophy, but alleges that the NPS preferred alternative does not adhere to the stated intent. The phrase "with every decision" the NPS will "forego actions…which would detract from the idea of wilderness…" is not in keeping with the proposed widespread use of motorized access into Denali's backcountry. Whereas the NPS appears to assume that "reasonable access" as written in ANILCA Sec 202 (3) (A) grants managers permission to allow for the extensive use of motorized vehicles for recreational purposes in the wilderness, wilderness that is accessible via dogsleds, skis, snowshoes, hikes, etc., the NAEC contends that "reasonable access" does not equate to undermining the precepts of the Wilderness Act or the very liberal interpretation of ANILCA as set forth by the Service. The NAEC urges the NPS to implement a plan that is in keeping with the "Wilderness Management" precepts as written on p. 30-31 and to not veer so far off course from the stated objective.

Although the wilderness review process mandated by ANILCA has stalled in Congress, the NPS claims that it will manage suitable wilderness according to the edicts of the Wilderness Act and therefore will not take actions or promote actions by Park visitors that would in anyway degrade the land or the character or values inherent therein and run the risk of their future exclusion as Wilderness. It is the opinion of the NAEC that if the NPS chooses any alternative except Alternative B they will indeed be risking future Wilderness designation for much of the 2.25 million acres that have been proposed. The NAEC would go further in stating that based on the condition of the Park Additions in 1980 compared with today that the NPS might have already jeopardized their inclusion. There has been ample research that demonstrates that snowmobile use degrades air and water quality, negatively impacts wildlife and vegetation, destroys the natural soundscape, and results in conflicts between user groups. The NAEC is certain that the NPS understands that although they may suggest that their proposed recreational snowmobile access scenarios in Alternatives C, D, and E may be rescinded at some future date if the land in question is designated Wilderness that the political pressures to undo such a use as exemplified by the attempts of NPS managers in Yellowstone-Grand Teton National Parks to phase this use out, which gained overwhelming support from the American public but which was overturned by the Bush Administration anyway, will be formidable and unlikely and thus the NPS under their preferred alternative jeopardizes the present and future protection of Denali's 1980 ANILCA Additions.

Because the majority of the Park Additions, with the understanding that a new inventory would add more land, are proposed wilderness areas, the NPS must manage these areas so as to protect both the resources from impairment and to ensure a wilderness type experience within the parameters of these lands. The proposed standards to monitor impacts to wilderness are: predominance of natural sounds, absence of reminders of human civilization, opportunity for solitude, and absence of signs of human presence, trails, campsites, litter, sounds, tracks in the snow, trampled vegetation, etc., all of which if employed to assess impacts from recreational snowmobiling, corridor or dispersed, would validate the NAEC position that recreational snowmobiling should not be allowed to occur in Denali.

The "wilderness resource values" for which the park is set aside are clearly those values of wilderness identified in the Wilderness Act [and ANILCA], which include the absence of reminders of civilization and mechanized devices. Although ANILCA contains "special access" provisions that were intended to preserve a rural Alaskan lifestyle by allowing limited motorized access for traditional purposes, it was clearly not the intent of Congress to undermine the basic decree of the Wilderness Act Sec. 4 (C) "there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport and no structure or installation within any such area," nor to open up the bulk of the ANILCA additions to recreational snowmobile access. Further, the "wilderness recreational opportunities," such as hiking, canoeing, fishing, and sport hunting, identified, as a purpose of the park under ANILCA clearly does not intonate that motorized activities are condoned. The NAEC contends that the proposed corridor riding of snowmobiles could easily be construed as the NPS enabling the establishment of "temporary roads" and that the proposed use of snowmobiles in the dispersed use areas contradicts long-established NPS management policies that restrict snowmobiles to frozen waterways and established roadways [36CFR2.18]. The NPS will fail in their attempt to "forego actions that might have no seeming physical impact but which would detract from the idea of wilderness as a place set apart" if they allow snowmobile access for recreation in the manner proposed, which can only be permitted to occur if the NPS pursues authorizing unprecedented regulations that fly in the face of the stated purposes of the Park, existing law, regulation, and policies that have been established to protect National Park and wilderness resources.

"Appropriate" uses are those that require, yet do not degrade, the wilderness environment [p.177]. The NAEC would question the NPS assumptions that recreational snowmobiling requires "wilderness" and the presumed conclusion that snowmobiles do not degrade the environment. "Existing access by snowmobiles in the park additions is presently leading to a decline in wilderness character in the Bull River/Broad Pass area and on the fringes of other parts of the southern additions." [p. 323]

In conclusion, the NAEC strongly recommends that the NPS promote Alternative B, as "This alternative would not lead to impairment of wilderness character at Denali because these actions would improve the quality of wilderness character in a manner consistent with the vision of ANILCA and the Wilderness Act." [p. 329] The NAEC refutes the NPS assessment of impacts to the wilderness under Alternative D "Overall there would be minor to moderate adverse impacts…" and "This alternative would not lead to impairment of wilderness character at Denali because the resource would still fulfill the purposes set out by the Wilderness Act and ANILCA." [p. 336] Instead, the NAEC suggests that "major" impacts to the wilderness as compared to 1980 standards have already occurred and that implementation of Alternative D will exacerbate this degraded condition. The NAEC asserts that one of the primary purposes of the BCMP, which the NPS has not undertaken, is to advance efforts to restore wilderness values that have been allowed to erode since 1980. Minimally, the NPS should use 1980 as a baseline year for wilderness quality, attempt to characterize the soundscape and landscape conditions that existed at that time, set goals for restoring wilderness quality to that level, and propose actions for accomplishing these goals. Promoting Alternative B would go a long way towards beginning to accomplish this necessary task.

Permits and Registration
The NAEC appreciates that although the NPS is managing for wilderness, which connotes freedom from regulation, in order to assure that detriment to Park's resources or visitor experience does not occur, the NPS must have at their disposal some management tool to assist them in altering use in order to prevent impairment of the same. The NAEC would recommend the following changes for Permit and Registration Requirements [Table 2.1 p. 32]:

Alternative B
Day-hiking registration should not be mandatory. This would be an extremely cumbersome system for visitors and NPS administrators. The advent of such a system would severely limit the serendipitous quality of a park adventure by the visiting public. A possible mechanism for establishing a voluntary system could be routed through the concessionaire's Visitor Transportation System [VTS]. The NPS could supply each bus with post-card sized surveys that individual's fill out as they board the VTS along the Park Road. NPS could school drivers in the need for gathering the information and the logistics of passing the same back to NPS, possibly via the Savage Box, during Driver Training in the spring. Another simpler solution, which would also entail VTS driver cooperation but would garner less precise visitor data, would be to have drivers simply record how many and where passengers are dropped off [not recorded at the present time] and picked up along the corridor. A mandatory system may be deemed necessary in the future, but at the present time anything beyond a voluntary registration for day-hikers is premature.

Non-motorized winter activities should not require mandatory registration. Present use levels do not merit this restrictive management approach; however, a voluntary system, as proposed in Alternatives C, D, and E would serve the Park well. If circumstances change and NPS detects a large increase in users, then it may be necessary to move towards a mandatory system.

Alternatives C, D, & E
All general aviation airplane landings in the Park Additions should require mandatory registration. As stated above and on p. 30 of the plan, the need for requiring registration is to determine use levels and as airplane landings and takeoffs create substantial noise and impacts to backcountry users it would be wise to incorporate mandatory registration of this activity at an earlier rather than later date. This may appear to be a double-standard approach to managing user groups in the backcountry, but the NAEC asserts that motorized access to wilderness destinations has far greater impacts than non-motorized access. The NPS should proactively attempt to determine levels of this type of use in Denali's backcountry and actively monitor for impacts, with the notion that at some future date a Limited Permit system may have to be employed.

Alternatives D & E
Although the NAEC strongly favors Alternative B as the basis for managing Denali's wilderness, any allowed snowmobile use in Denali's backcountry should be by Limited Permit ONLY regardless of whether it is in a Backcountry, Natural, or Primitive Area, and regardless of whether it is labeled as dispersed or corridor use, as enumerated in Alternative C. NAEC recommends that concerted efforts must be put forth by the NPS to limit the total number of snowmobile users into Denali's backcountry to attempt to offset the many known negative impacts that snowmobiles cause both to tangible and intangible resources.

Limited Permit
The NAEC is disappointed that the BCMP as presented does not "establish carrying capacities for particular activities or particular locations to achieve desired conditions in designated management areas," which would then guide the NPS in defining the number of permits that should be issued for that activity or location. [p. 30-31] The NAEC asserts that any recreational snowmobile accesses that NPS permits into Denali's wilderness should be capped at the get go.

Management Areas
1) The plan lacks specific analytical information or rationale to justify or explain how decisions were made to identify proposed management areas as reflected in each of the alternatives. The lack of resource based facts for validation in allocating the management areas in the plan makes it difficult to comment on whether the proposed management areas and their associated allowed uses and encounter rates are relevant or where there might be potential for substantial impacts to water, air, soundscape, wildlife, subsistence, vegetative or other park resources as a result of proposed backcountry uses. A clear and concise explanation detailing how these units were determined under each alternative would have provided the public [and perhaps the NPS] with more meaningful information with which to make substantive comments [sound management decisions] on the proposed management areas and to offer suggestions for possible changes.

2) "Allocation of management areas is a prescriptive process that describes the desired conditions rather than existing conditions." [p. 31] This statement may be true or false. A map depicting, or a description of, the present uses in the Park and where they are occurring would have assisted the pubic with a means of comparison from which to draw its own conclusions. As it stands now, the reader and presumably the NPS, is uninformed about present uses and use levels that are occurring in the Park Additions. However, it is noted that some of the types of uses and where they might be permitted are suspected to be based on existing conditions rather than desired conditions, i.e., concentrated use corridors for snowmobile access described for Unit 70, under Alternatives C, D, and E, which is a known high use area for snowmobilers.

3) In keeping with the above assumption, the NAEC queries why the NPS chose to designate varying portions of Unit 83 as a Backcountry Area under Alternatives C and D. [Alternative E goes much further by designating all of Units 83, 84, and 85 for the highest use Management Area.] This region of the Preserve is at present receiving very little use, is relatively inaccessible, and retains high wilderness value and as such it is deemed most appropriate that this region not be identified as a new destination to receive high use levels, but rather that NPS should attempt to preserve the wilderness qualities, with emphasis on the soundscape, of this remote region. Additionally, the NAEC opposes the "cherry-stemming" type management proposed for the West Fork of the Yentna River, in Alternatives C and D. This method of dangling areas of high-use, with emphasis on the proposed corridors for snowmobiling, into a region that is proposed to be a Natural Area offsets any benefits that may be gained under the stricter management guidelines. In conclusion, the NAEC recommends that the entire southwest portion of the Preserve, inclusive of all of Units 81, 82, 83, 84, 85 and the West Fork of the Yentna River be managed as a Natural Area. Taking this action would also preserve the opportunity for a wilderness mountaineering experience, something that is not tenable in the extreme high use zones of Units 74, 75, 76, 77, and 78, where overflights, scenic tour landings, and air taxis create an almost constant, loud drone throughout the day.

4) The NAEC has similar concerns regarding the Backcountry Areas designated in Units 79 and 75. These areas receive selective use at the present time, "most of this use is on state lands north of the trailhead and in the Dutch Hills and Peters Hills. Some use extends into Denali NP&P lands north of the Dutch Hills." [p. 209] AS the NPS states that in a regional context Denali will be treated uniquely, the justification for creating high-use corridors on Federal lands is not apparent. These two small areas within the aforementioned Units should be managed in the same way that the entire unit is managed, i.e., either as a Natural or a Primitive Area, instead of subjecting these small regions, the resources therein, and the quality of the visitor experience in the remainder of the Units to potential impairment.

5) NAEC is disappointed that the Backcountry Management Area has remained in the Draft BCMP. The stated management objective, to "protect and preserve the park's natural and cultural resources and values, and wilderness resource values, including natural soundscapes and intangible values such as solitude," cannot possibly be met by the criteria enumerated for this management area. In the NAEC' s comments on the preliminary draft of the plan, we espoused that the encounter rate proposed for the Backcountry Area was too high because the opportunity for solitude or a wilderness type experience was negated. The encounter rates, for this zone, in the Draft Plan have not been altered and thus we are compelled to once again stress that a potential encountering of 10 parties with from 12-15 hikers or snowmobilers per party, which equates to the possibility of meeting up with 150 other users, far exceeds the potential for a wilderness backcountry experience. Although this management area is designated in only a small fraction of the Park [Alternative D 3%] even that is deemed too much, as it is not the purpose of the Park nor of the plan to provide for the "maximum" number of people in the backcountry.

Additionally, NAEC questions the Park's clarity and viability of their conclusion that "minor impacts may be common at access points, but resource impacts are infrequent elsewhere." Logic would suggest that this deduction errs on the conservative side. How can the NPS possibly hope to achieve protection of wildlife, the soundscape, the air quality, the water quality, the opportunity for solitude, etc. in the Backcountry Areas? NAEC would aver that these land areas couldn't possibly absorb the amount of impacts from the high use levels ordained for this management area and that severe impairment of the resources will occur and the potential for a wilderness experience will be invalidated. Additionally, much of the land proposed for this zone will loose all potential for wilderness designation under this management scheme, which runs contrary to the NPS stated objective for managing wilderness, to "protect and preserve…wilderness values such as solitude," [p. 8] and policies and laws that protect, from impairment, lands identified as suitable or those recommended for wilderness designation. Once again, the NAEC recommends that this management area not be included in the final plan, as in Alternative B, or the encounter rates be lessened to no more than five encounters per day in order to meet the management objective that speaks to protecting resources and the opportunity for a wilderness experience. Or, if the Park determines that the Backcountry Area should remain in the plan as written, please explain how the above stated management objective and adherence to laws protecting wilderness will be met in areas zoned as Backcountry.

Note: The NAEC concedes that there may be exceptions as to where a Backcountry Area designation might make sense. The middle Kahiltna and upper Ruth Glaciers where there is so much aircraft traffic, both on the ground and overhead, that the proposed Backcountry encounter rate and desired condition is the one that most aptly reflects or more realistically presently exceeds those conditions. Unless the NPS has plans to aggressively ratchet down scenic air tour landings at these two sites, the Primitive Area management zone, as per Alternative D, is speciously applied to these two high use areas. Furthermore, the present level of use and the amount of air traffic experienced in all of the Units [74, 75, 76, 77, 78, and 79] south of Denali most likely exceed the Primitive Area conditions. Perhaps it is these Units, as opposed to the high quality wilderness Units to the southwest, which should be considered for Backcountry Area designation.

5) Natural Area
Natural Areas should have a distinct character based on very low encounter rates and no motorized activities, except for those stipulated under ANILCA for the retention of a rural, subsistence lifestyle. Natural Areas should not be designated in places where high levels of air traffic and snowmachine use have been allowed to develop or where it will be impossible for the NPS to attain the specified encounter rate of 3 or less parties per week. The NAEC maintains that more of the 6 million acre Park beyond the Special Resource Protection Area merits motor-free recreational opportunities.

6) Northern Additions
The NAEC has grave concerns regarding the proposed dispersed use of recreational snowmobiles and the vast increases in airplane landings, a non-traditional use, for the Northern Additions as defined in Alternatives C, D, and E. Congress annexed the Northern Additions to the Park in 1980 via ANILCA because of their importance for ensuring an intact ecosystem for the greater Denali region, acting as a buffer for the Old Park, and to provide critical winter habitat for wolves and caribou. The NPS document, Statement of Finding: Permanent Closure of the Old Park, argues against opening the Northern Additions to snowmobile use, "Where snow depth is shallower, as is generally the situation on the north side of the Alaska Range or in wind-scoured, snow-free zones, widespread damage to exposed soil, plants and lichens likely would occur." [p. 51] and "…the fact that wolves consistently avoided snowmachines indicates it is prudent of the NPS to close important wolf foraging areas to winter use until a better understanding of wolf/snowmobile interactions can be determined." [p. 38] In conjunction with the high wildlife value of the Northern Additions, the region also possesses numerous, at least 100 known, cultural resource sites some of which have been determined to be eligible for listing on the National Register of Historic Places by the Alaska state historic preservation office. Dispersed use of snowmobiles in the region would run the risk of intentional or unintentional harassment and/or destruction of the natural and cultural resources within the region. The Northern Additions receive relatively low visitor use at the present time. The NAEC maintains that the NPS should attempt to maintain not elevate the level of use in this region. The NAEC has closely followed the North Denali Access issue and has fully supported the NPS in opposing a new access corridor in this region in order to protect the high resource and wilderness values of the Northern Additions and is therefore disturbed by the proposed uses, as outlined in the NPS preferred alternative, for this region.

For these reasons and in order to fulfill the Management Goal objective to "protect and preserve the park's natural and cultural resources and values, and wilderness resource values…" the NAEC recommends that the entire Northern Additions be zoned for the most restrictive protection possible under the management area schematic, Natural Area, to ensure that this region retains the highest quality wildlife habitat and wilderness recreation opportunities possible. Although the "plan does not make recommendations for wilderness designation," [p.1] the NAEC advocates that the NPS reconsider this decision and within the context of this plan the NPS make a strong recommendation that the Northern Additions be designated as Wilderness so as to afford this vital region, the wildlife and cultural resources therein, and the outstanding opportunities for wilderness recreation the greatest possible protections under Federal Law.

The NAEC supports the following proposed actions for All Alternatives:
· The NAEC fully supports the NPS decision to limit airplane landings in the Special Resource Management Area to emergency landings only. Airplane landings were banned in the Old Park prior to ANILCA, so the NPS would simply be returning the condition of the Old Park to previous levels of wilderness purity. The option of landing in the Old Park described in Alternative E is a bad idea. Denali's designated Wilderness Area offers users the unique opportunity to enjoy remote and self-reliant travel where one can trek for days in untrammeled lands. The NPS should do all it can to guarantee that this wilderness opportunity remains steadfast at Denali.
· NPS pro-active efforts to prevent the advent of "extreme biking" in Denali's backcountry. Restrict bicycles to established routes and clearly define which "mining" roads in the Kantishna District could support this type of use. [The NAEC agrees with the NPS assessment that mountain bikes are "a mechanical reminder of civilization and would constitute a negative impact to wilderness character" [p. 324] and asserts that the same standard should be applied to snowmobiles].
· Implementation of a backcountry unit system for the park additions.
· Consideration for the development of trails in high use areas where the resource has been negatively impacted and conditions are continuing to erode due to the presence of the road, which creates ease of access.
· Restrictions on the use of pack animals in the backcountry.
· Temporary closure system to prevent negative or adverse impacts to resources.

The NAEC recommends these further actions for All Alternatives:
· The NPS has failed to define within the context of the BCMP the need to address the ANILCA term "traditional activities" for the Park Additions. Without defining this term for the additions, the NPS is failing to guide what uses may lawfully occur on the land in question and leaves the term open to interpretation by each and every individual. The NAEC sympathizes with the "difficulty in differentiating between traditional and other snowmobile uses in the field," [p. 390] but contends that this perceived difficulty does not relieve the NPS of their responsibility to address this complicated task. It is the strong opinion of the conservation community that the intent of Congress in ANILCA was to allow for motorized access into the 1980 CSUs for the clear and unambiguous reason to permit for the retention of a rural, subsistence based lifestyle and for access to homesites and villages. The NAEC does not condone the NPS skirting this issue, which lies at the heart of the controversial NPS position to support recreational use of motorized vehicles throughout the backcountry of the Park Additions. Further, as the "majority of commentators supported applying the NPS definition of the term "traditional activities" from the final rule to all of the park additions and preserve," [p. 23] the NPS should either act on behalf of the publics' wishes or provide some rationale, beyond expressing that the challenge is too great, as to why they have chosen inaction on this issue.
· An action that should be considered for all alternatives that is omitted from Alternative B is the notion of establishing a joint Public Lands Information Station in the Cantwell area. Purportedly this action is not included under Alternative B because this alternative requires Congressional action on the wilderness review process prior to opening up the bulk of Denali's Backcountry to recreational snowmobile use. NAEC would argue that under Alternative B this action is most urgently needed to ensure that the general public, which has been accessing wilderness lands with no guidance from the federal steward, is educated on: the laws that govern the land, the law that established the Park Additions, the justifications for NPS actions, the wilderness review process and the lawful need to go forward with the review before actions are taken that might jeopardize the lands inclusion under wilderness designation, the role of the superintendent in making decisions that may go against industry opinion but must be made in order to protect the resources and the intangible values of wilderness, that at some future date, after the review process has been completed some areas of the Park may be open to recreational motorized access, and a host of other related issues. Without an attempt to educate the public on these issues, the political backlash, which will be substantial in any case, will revolve around ignorance and the premise that the NPS has closed portions of the Park that are legally open to recreational snowmobile users.
· The NAEC supports the continued ban on campfires in the Denali Wilderness between April 15 and September 30. The NAEC would recommend limiting campfires in the additions to seasons where wildfire threats are not imminent. The plan should incorporate a disclaimer that allows for the Superintendent to restrict campfires in the Park Additions when conditions warrant such action.
· The NAEC feels that it is important to limit hiking group sizes to no more than 12 per party. [In the case of motorized users this level should be dropped significantly, perhaps to no more than 6.] NPS appears to be taking great pains to ensure that group hiking is closely monitored, i.e., guided, "leave no trace", etc., which is condoned, but fails to impose similar guidelines on motorized users, which have the potential of creating far more conspicuous and widespread impacts than foot travelers. The NAEC recommends that the NPS incorporate similar or more stringent guidelines on any proposed motorized users, regardless of the number of machines per party.
· The NPS states in the BCMP that Off-Road Vehicle use for the purposes of subsistence, as per Sec. 811 provisions in ANILCA, will be addressed in the Subsistence Management Plan; that ORV riders can continue to use the state right-of-way in the Dunkle Hills; and that ORV use to access inholdings will remain an option. [p. 23] According to Denali Staff, there are presently ten identified ORV/ATV user trails in the Park most of which are multi-purpose trails: five for recreation, eight for subsistence purposes, and two to access inholdings. Allegedly, these routes are unplanned, user developed routes with dispersed use also occurring. The NAEC questions under what authority these ORV/ATV users are accessing Parklands. According to our knowledge, the staff at Denali determined that ORVs were not traditionally used in the Park for subsistence purposes and there has not been promulgation of a special park regulation to authorize this form of motorized use. Additionally, ORV use is permitted only in Preserves not in Parks and only when a finding determines that ORV use is compatible with park purposes. The NAEC is concerned that if the NPS does not address ORV/ATV use sooner rather than later that their inaction will lead to a perceived understanding that the agency is acquiescing to yet another motorized form of recreation taking hold in the Park, which will lead us down the same contentious path that we now find ourselves in regards to the snowmobile issue and that park resources will be degraded in the meantime. The NAEC recommends that the NPS address ORV use, minimally the developing recreational access trends, within the context of the BCMP.
· The NAEC generally supports the development of the Denali Science and Learning Center [DSLC] but has some concerns regarding its intended purpose and potential impacts it might have on Park resources particularly in the Old Park. The NAEC highly recommends that any fieldwork or hikes that originate from the DSCL be coordinated with other "group" users with direct management coming from the NPS. Hikes originating from the DSLC to non-durable surfaces should be limited to those that are necessary to advance our understanding of the natural processes occurring in the Park's ecosystem. Additionally, there is confusion as to what is meant by a "durable" surface, this term should be more clearly defined so as to promote responsible group hiking in the backcountry.
· "When current use levels match the management vision for a particular unit, levels of use would be capped. " It is not clear in the content of the plan how and when such determinations will be made.
· Ideally, programmatic plans such as Soundscape, Wilderness and Subsistence should be done before activity plans such as the BCMP. The NAEC is concerned that by implementing an action plan prior to the finalization of the aforementioned programmatic ones that the programmatic plans will be constrained by the latter. For example, will the eventual Soundscape Plan be based on sound science or will it merely be contrived as an acknowledgement of the precepts outlined in the BCMP? The NAEC recommends that the NPS approach planning for use in Denali's Backcountry after it has finalized the resource protection plans and not the other way around.
· The NAEC is concerned with negative impacts on Denali's Wilderness Area as a result of the presence of the Park Road, which bisects this region and allows for ease of access by visitors. The NAEC strongly recommends that the NPS do a separate Wilderness Plan for the Old Park. The NAEC supports NPS in their continuing efforts to control Park Road dust, which is an environmental hazard particularly for drivers but also for bus passengers, Park Road users, vegetation, and wildlife. It is advised that monitoring efforts be performed to determine what impacts the dust palliative being used has or potentially will have on vegetation and wildlife.

RECREATIONAL USE OF SNOWMOBILES IN OUR NATIONAL PARKS
The Northern Center opposes NPS continuing to ignore or sanctioning the use of snowmobiles as a means of recreating or as a means of accessing wilderness in Denali National Park and Preserve as put forth in four out of the five alternatives proposed in the Draft BCMP. The NAEC supports the edicts of ANILCA that allow for the use of snowmobiles in the Park Additions for "traditional activities", as defined for the Old Park. The NPS has opted to not transfer this definition or to create a new definition for the Additions and thus has chosen to leave a void with no clear direction or justification as to what uses the Service construes as legitimate. The NAEC is thus in concert with the majority of conservation organizations in supporting Alternative B.

In order that the NPS provide a fair assessment of the impact recreational snowmobiling imparts to Park resources, the NAEC recommends that the Denali Planning Team use 1980 as the beginning point for assessing the levels of impact the Park Additions have already experienced as a result of this use. At the time of the passage of ANILCA, there was very little substantiated use of snowmobiles in the Park Additions. Use that was occurring was focused more on utilitarian rather than recreational pursuits. Twenty-three years have elapsed since the annexation of the additions and in the meantime the number of snowmobiles entering Denali's wilderness has skyrocketed and the machines are traveling further and faster and accessing more remote regions. Until the Backcountry Management planning process was initiated, a few years hence, the NPS made no overt attempt to determine whether this type of motorized use was in keeping with the purposes for which the 1980 additions were appended to the Park. Further, the NPS went through no regulatory process to allow, restrict, or rescind the increasing use of recreational snowmobiles, did little to nothing to monitor impacts that were inevitably occurring, nor put forth any rulemaking that would sanction the unprecedented dispersed use of these machines in a National Park. By using the date of annexation, the NAEC is certain that the NPS would concede that impacts have already occurred to Park resource values, i.e., soundscape deterioration, subsistence use conflicts, stress to large mammals, displacement of mammals, as well as changes in soil temperature, vegetation, etc. Additionally, the findings would clearly show that the cumulative impacts have resulted in probable impairment to Park resources. The NAEC contends that the use of snowmobiles, the purported purpose, the number, and the amount of land area affected, as proposed in Alternatives C, D or E will result in further detriment to Park resources.

The NAEC avers that as the NPS has clearly recognized the need for and was mandated to create a management plan for the Park Additions and that they have had ample time to monitor many of the uses that have been occurring and should have more quantitative data and analysis of the same to back up the proposed actions within each of the alternatives. As it stands, so much of the plan suggests that monitoring will occur in the future. The NAEC finds this suggestion flawed and deems that decisions presently being made for the Backcountry should be based on past and present monitoring not on future attempts to monitor the very resources that are already impacted or impaired by NPS decisions regarding appropriate backcountry uses. To go further along this line, the NPS does not describe a clear program for how they will monitor the affects of certain uses, with emphasis on recreational snowmobiling, on the park's resources or non-motorized visitor experiences and that such a plan not a projection that a plan will at some time be formulated should be included in the BCMP.

The NPS has no authority to allow dispersed use of snowmobiles as proposed in Alternatives C, D, and E of the plan. There is a long history of regulations, laws, management policies, director and executive orders, etc., on the books describing what is deemed appropriate use of snowmobiles in our National Parks. The NAEC avers that nowhere in any of these documents is there any indication of condoning dispersed use of snowmobiles. The NAEC questions the wisdom of Denali Park Planners in going so far astray from the edicts that have been employed to control this use and why Denali Planners are suggesting that dispersed use should be legitimized. This is an unprecedented NEW USE FOR MOTORIZED RECREATION IN OUR NATIONAL PARKS and the NAEC would recommend against using Denali as a testing ground for creating regulations that would allow cross-country use of recreational motorized vehicles in our National Parks.

The NAEC is very concerned that the NPS has not exhibited a unified front regarding this controversial issue. On the one hand managers of Yellowstone and Grand Teton National Parks have made a concerted effort, to eliminate the use of individual snowmobiles on the Parks' road system in favor of providing a mass-transit alternative, based on extensive research and study of the negative impacts snowmobiles have had on the Parks' resources as per the "original" EIS, and on the other hand Denali Park Planners promoting widespread, cross-country use of these same harmful machines. The NAEC is troubled by the stewards of Denali not heeding the lessons learned in other National Park Units regarding the use of snowmobiles and the lack of consistency exhibited by NPS Planners.

In conclusion, it is the opinion of the NAEC that recreational snowmobile use as an activity in and unto itself or as a means of accessing other activities is not in keeping with the purposes of the Park or the many laws established to guide NPS in protecting resource and wilderness values. Any attempt by the Service to contrive to make this use legitimate will violate the aforementioned edicts and the American trust in the NPS to act as stewards for our most treasured public lands.

Environmental Consequences of SNOWMOBILE USE
The NAEC is committed to preserving Denali as a wilderness Park. It is clear that snowmobiles create negative impacts to resources. The NAEC is concerned that the NPS is promoting snowmobile use in the Park Additions despite sound scientific evidence that forecasts that allowing this use in Denali's wilderness will erode the very resource the NPS is mandated to protect. The NAEC provides the following brief synopsis, as there are countless others points to be made, of conclusions largely obtained from the Statement of Finding: Permanent Closure of the Former Mt. McKinley National Park Area of Denali National Park and Preserve to the Use of Snowmobiles that weigh heavily against sanctioning the use of snowmobiles in the Old Park or any other National Park including the 1980 Park Additions. The NAEC has serious concerns that the NPS is misinterpreting the Congressional intent for the Denali Additions and is discounting their own arguments, which were used to protect the Old Park against the use of recreational snowmobiling, by promoting this use in one of America's premier National Parks. It is the hope of the NAEC that the Denali Planning Team reconsiders what appears to be their inevitable decision to allow recreational snowmobiling in the additions sans further assessment of what the implications of that decision will mean for not only Denali, but for all National Parks and all wilderness units across America.

Further, the NAEC asserts that the public has the right to know "now not later" how the NPS intends on monitoring the inevitable impacts to the resources that will occur if recreational snowmobiling is to be sanctioned and what their plans are to mitigate the following impacts so as to prevent impairment of the resources.

Air Quality
Denali National Park and Preserve is the only National Park unit in AK "designated as a mandatory Class I airshed." Air quality data has been collected near Trapper Creek since 1998 and North of the Alaska Range since 1980. These two sites are inadequate to assess negative impacts to the airshed as a major source of air pollution, snowmobiles, has been left largely unmonitored. "Snowmachine use negatively affects air quality," [p. 52 Permanent Closure of the Old Park].

Vegetation and Wetlands
"Even when there is adequate snow cover to prevent direct abrasion of vegetation, the compacted trails formed by snowmobiles affect the subnivean environment by causing major temperature reductions and changes in snow pack characteristics. These changes alter species composition, change plant density, delay the melting of compacted winter trails and provide moisture over a longer period of time to the vegetation in the trail area." [p. 47 Permanent Closure of the Old Park]

"Damage to vegetation…would be impossible to prevent over large areas [of the Old Park…]. 'Adequate snow cover' is not a reasonable solution because snow depths are rarely adequate due to frequent wind scouring." [p. 49 Permanent Closure of the Old Park]

"Therefore any level of use allowed in an area will cause damage to vegetation at some locations."
[p. 50 Permanent Closure of the Old Park]

"Impacts from snowmachine use to the sensitive vegetation and permafrost soils of the subarctic found in [the Old] Park would increase the creation of permanent trails, soil erosion, damage or loss of vegetation and the delay or permanent prevention of recovery once the impact to soils and vegetation occurred."
[p. 52 Permanent Closure of the Old Park]

Wildlife
"Snowmachine impacts to wildlife can be both direct and indirect. Direct impacts include intentional harassment, injuring, and killing of wildlife. Indirect impacts include stress from disturbance. Impacts from harassment both purposeful and unintended will be unavoidable.

The large area that would be open to snowmachine travel would make the preventions of intentional harassment through patrols essentially impossible. The random cross-country nature of travel and the rates of speed that likely would occur would make unintended harassment of wildlife inevitable"
[p. 35- 36 Permanent Closure to the Old Park]

"Studies indicate that exposure of wildlife to snowmachine use can result in behavioral alteration, habitat avoidance and increased energy loss. These changes would occur at critical times when animals can be under extreme stress from winter privations." [p. 36 Permanent Closure to the Old Park]

"Impacts to moose, hares and red fox will be more pronounced along river drainages because these animals tend to congregate there and snowmobile users frequently use drainages as travel routes. Effects will include stress, displacement and temporary abandonment of preferred habitat."
[p. 45 Permanent Closure to the Old Park]

"Compacted trails also change distribution patterns of animals by providing energy efficient travel routes that alter winter survival rates, predation rates, distribution patterns, availability of carrion for use by other species… Compaction of snow increases energy expenditure by ungulates such as caribou that must dig for vegetation in extremely stressful winter months." [p. 43 Permanent Closure to the Old Park]

The NAEC disagrees with the NPS regarding their conclusion that "The impacts to wildlife and fish populations and habitats under Alternative D would be minor…Impacts…would not be widespread." [p. 291] The NPS preferred alternative promotes for recreational or subsistence snowmobile use in 62% of the Park, with the only excepted land being the Special Resource Protection Area, and 100% of the Park Additions. For the NPS to conclude that impacts would not be widespread is unfathomable. The NPS assessment on the impacts to wildlife from the Statement of Finding for the Old Park, clearly illustrate that threats imposed on wildlife from the use of snowmobiles in the backcountry are imminent and the potential for "long-term changes in wildlife and fish populations or habitats" are bona fide. The NPS is downplaying the potential negative impacts to wildlife from snowmobiles.

The NAEC also refutes the NPS assumption that, "The expansion of recreational opportunities in the park may also reduce regional negative impacts on wildlife by decreasing unmanaged uses in adjacent non-park lands." [p. 291] The analogy and the attempt to identify a cause and effect relationship are bogus.

Indicators listed on page 70 for Impacts on Wildlife Behavior and Habitat Usage fall far short of what should be required of the managers of DNP&P, which was originally established as a Game Refuge. How will the NPS monitor negative impacts to wildlife such as nutritional stress in time of need, displacement, effects on birthing rate of large mammals due to increases in allowed motorized access, mortality of subnivean creatures, etc. These questions and many more need to be addressed prior to implementation of a BCMP that condones recreational snowmobile use in the Additions.

Subsistence
The Denali Subsistence Resource Commission at their February 2003 meeting in Healy, AK identified numerous concerns regarding recreational snowmobiling in the Park Additions many of which mirror those held by the conservation community:
· The questionable ability of the NPS to enforce their proposed limitations and desired behavior from snowmobilers;
· Proposed high use corridors, which funnel snowmobilers into river valleys, which provide winter habitat for moose;
· Potential negative impacts to large mammals, i.e., nutritional stress in time of need and the noticeable trend of displacement of large mammals that is already occurring under present use levels;
· Displacement of furbearers during the spring trapping season;
· Inadequate studies, with scientific basis, to understand the impact of recreational snowmobiling on wildlife in this region.

Subsistence use in the southeast portion of the park has been identified in numerous documents and has been substantiated by the Denali Subsistence Resource Commission as being of a level of importance to the Cantwell area residents. As such, it is striking that under all of the alternatives, except B, motorized recreation with high use corridors are proposed in unit 70 [and in the case of Alternative E, in unit 71]. In April of 2001, the Denali Subsistence Resource Commission specifically advocated for the area between Windy Creek and the Bull River for subsistence use only [p. 394] yet the NPS preferred alternative promotes this as a Backcountry Area. The Northern Additions are another area of import to subsistence users yet the preferred alternative advocates for dispersed use of motorized vehicles throughout the region. The NAEC would recommend that the NPS grant the Commission's requests to protect the Bull River from high use corridors and the Northern Additions from any recreational snowmobiling.

Enforcement and Monitoring of Snowmobiles
The NPS does not have an adequate plan in place to address how they intend on enforcing what they suggest is behavior that is expected of snowmobilers using the Denali backcountry. The assumption that a BCMP that the "public supports in a way that they will act on their own without intervention from the park service," is woefully inept and places the responsibility for resource protection with user groups instead of where it rightfully and lawfully resides, which is with the federal agent charged with the mandate to protect and preserve Park resources for present and future generations. The expectation that the Service will be able to execute "changes" in use and behavior patterns, established over two decades of non-regulation, to prevent high-marking, wildlife harassment, destruction of vegetative cover, off-trail riding, conflicts with subsistence users, etc., through an education-registration program is inadequate given the history of the continued occurrence of many of these abuses in parks where roadways are clearly defined and the presence of law enforcement officers is predictable.

Factors that contribute to the difficulty the NPS will have in enforcing proper use of machines in the backcountry are: 1) the land area, where recreational snowmobiling is proposed to occur, under Alternative D, is so magnanimous as to make patrolling the area, without contributing excessively to the impacts, untenable and 2) the number of potential snowmobilers in the backcountry are too many to ensure that more than a minimal number would experience any administrative exposure or presence. If the Park Service cannot fulfill its duty to protect and preserve the resource because of budgetary constraints or other reasons, then the Park Service should not be advocating for these uses or they should reduce the amount of area where such uses would be permitted so as to be able to fulfill their primary function as stewards of the resource.

Although the budget provides for increased funding for law enforcement under the topic 'Snowmobile Use' for Alternatives C, D, and E, what action will the NPS take if these dollars are not budgeted? Will the NPS close the Park to recreational snowmobile use until such time as funding is allocated or will the NPS allow the use to occur with minimal enforcement capability? What are the potential repercussions to the Park Service if a snowmobile user or his machine becomes incapacitated and the Service was either not aware of their presence in the Park or failed to have adequate patrols to protect the visitor? The NAEC foresees the very real potential of lawsuits inundating NPS resources.

Under Research and Monitoring for all Alternatives there is no allocated funding expressly for monitoring the impacts of the use of snowmobiles in the backcountry. As this 'on the ground use' has many known negative impacts to resources and social conditions, the NAEC suggests that a gradation of funding resources, with B requiring less although not zero and E requiring the most, be added to the budget specifically for this purpose. The NAEC is concerned that the NPS has not adequately addressed a monitoring program for determining impacts from snowmobile use. The proposed widespread use of snowmobiles, particularly in the Preferred Alternative D, causes concern for the ability of the NPS to monitor the vast amount of land area for resource impairment. The BCMP should define how, where, and what the NPS plans are for a monitoring program to measure impacts from snowmobile use in the backcountry.

AIRCRAFT USE
The NAEC recommends that NO SCENIC LANDINGS be allowed to occur EXCEPT ON THE RUTH AND THE KAHILTNA GLACIERS. If the NPS insists on permitting Dispersed Scenic Tour landings these should be relegated to Units 74, 75, 76, 77, and 78 as described in Alternatives B, which reflects the region of the Park where this activity is already occurring. However, it is recommended that the level of landings be ramped down to closer reflect 1980 user numbers or that the encounter rate described by the Primitive Area management zone for these units under Alternatives B, C, and D be adhered to: encounter rate of up to 2 parties per day. The NAEC stresses that Dispersed Scenic Landings not be introduced as a new use in the Northern Additions and that this type of recreation should be kept to the South Side where it is presently embedded.

The NAEC supports the NPS effort to influence and lessen the use of the airspace above the Park, with emphasis on protecting the soundscape resource in the Old Park, and the notion of creating a working group to address the many contentious issues surrounding this growing industry. The NAEC recommends that the working group composition be modeled after the National Working Group, which included environmentalists at the table. The NAEC proposes the following ideas as possible actions that could be employed to help mitigate overflight noise intrusions on the Park's resources:
1. Curfew hours
2. Identify motor-free zones
· Limit travel over designated wilderness, Old Park,
· Seasonally limit travel over critical wildlife habitat areas, to protect nesting birds, especially birds of prey, nursery herds of Dall Sheep, Caribou calving grounds, wolf denning sites, etc.
3. Recommend a minimum altitude for flights
4. Recommend that air taxis follow the highway corridor and take the shortest possible path to enter the air space over the park to minimize travel over these public lands.

SOUNDSCAPE RESOURCE
As the natural soundscape resource in Denali National Park and Preserve is "threatened" [p. 3], the NAEC opposes actions proposed in Alternative D, which will further erode the natural soundscape in the Park. The NAEC contests the NPS finding that Alternative D "would likely result in minor to moderate adverse impacts on the natural soundscape." The NAEC suggests that the natural soundscape in select areas of the Park as compared to conditions that existed in 1980 has already suffered impairment and actions proposed in Alternative D will further exacerbate the degraded condition of this resource. The NAEC asserts that rather than promoting actions that will further degrade the Park's natural soundscape, by implementing their preferred alternative, the NPS should implement Alternative B for reasons stated, but also to attempt to establish baseline data that reflects the natural soundscape condition in the Park prior to the enactment of ANILCA. With this information in hand, the NPS would be better equipped to assess what impacts their proposed actions will truly have on the wilderness backcountry of Denali.

Although the NPS initiated soundscape monitoring in 2001, to date the number of sites monitored and the dates that data have been collected are not representative of the present soundscape conditions in Denali and are far from conditions that existed in 1980. From DO # 47: information provided from inventory and monitoring is essential to understanding the relationship between the baseline natural soundscape and human-made components of the soundscape--existing and proposed. The plan appears to be using present soundscape conditions, the status quo, for its baseline vs. using the natural soundscape from which to begin to measure impacts. Thus, soundscape is treated merely as an impact topic instead of a resource.

Director's Order #47 obligates the NPS to protect, maintain, and restore the natural soundscape. Although the BCMP plays lip service to this edict on p. 390 "NPS agrees with the concern for protecting natural sounds in DNP&P and has incorporated actions to protect or restore natural soundscapes in all the action alternatives." The NAEC would contest this evaluation, as there is no evidence under any of the alternatives, except Alternative B, for any real attempts to incorporate restorative actions. The mitigation actions outlined on p. 412 focus on NPS "changing its own operations, equipment, and procedures" while mitigating actions, regarding other activities that negatively impact the soundscape resource, are insufficient or non-existent.

The DO also states, "Where natural soundscape conditions are currently not impacted by inappropriate noise sources, the objective must be to maintain those conditions." It is therefore troubling that the NPS preferred Alternative D proposes to introduce and expand snowmobile use into more remote areas of the park and preserve that presently receive little if any recreational snowmobile traffic and it proposes to open up a large portion of the Northern Additions and the southwest region of the Park to unprecedented Scenic Air Tour landings. The NAEC asserts that the only ostensible conclusion it can draw from the NPS's preferred alternative is that the Service is promoting expanding motorized uses into areas that currently are minimally impacted by inappropriate noise sources and thus they are choosing to not maintain existing near pristine conditions as advised in DO #47 and are not adhering to their own "concern" for protecting natural sounds in DNP&P. The NAEC would recommend that some real attempts be made by the NPS in the BCMP to address restoring the natural soundscape over most of the 6 million acre Park and that decisions to open up new areas to intrusive motorized sounds be reconsidered.

At the present time, NPS managers have inadequate direction in how to assess impairment. This is unfortunate, however efforts are presently underway to remedy this shortcoming. A draft policy document on impairment direction, NPS Guidance on Assessing Impacts and Impairment to Natural Resources, was recently presented at the George Wright Society Biannual Conference. The National Leadership Council is presently reviewing the document and if approved it will provide the NPS with draft guidelines to begin to standardize and define the terminology and practices to be employed to assess impairment. Presenters at the Conference distributed a hand out that concludes "impacts on the natural soundscape are more likely to constitute impairment if the natural soundscape is:
· Linked to the park purpose in the enabling legislation and/or subsequent general management plan and
· If the area of audibility is large, or
· The sound level is at or above the natural setting, or
· It occurs frequently, continuously or indefinitely over long periods of time.
An impact that achieves higher levels in most or all these areas is likely to constitute impairment." Given these proposed guidelines and the present soundscape conditions in certain regions of the Park, the NPS must conclude that impairment of the soundscape has already occurred in areas such as the Ruth and Kahiltna Glaciers and quite possibly in all of the Units south of Denali. The NPS should be working towards restoring this impaired resource and not promoting further degradation.

The BCMP [p. 1] is to function as the Soundscape Preservation and Noise Management Plan [SPNMP], required under DO #47. The BCMP does not come close to meeting the requirements outlined in the DO for a SPNMP:
1. Describe the baseline natural ambient sound environment in qualitative and quantitative terms
2. Identify sound sources and sound levels consistent with park legislation and purposes
3. Identify the level, nature and origin of internal and external noise sources
4. Articulate desired future soundscape conditions
5. Recommend the approaches or actions that will be taken to achieve those conditions or otherwise mitigate noise impacts.

The Interim Plan for Soundscape Preservation [Appendix C p. 411] does not articulate the future desired soundscape conditions; research and planning needs; or the basis for monitoring the natural soundscape. The Interim Plan does not enumerate quantifiable soundscape objectives/standards and thus negates the possibility of performing a quantified analysis of impacts. The plan does not explicitly define a soundscape monitoring protocol. Questions that need to be addressed include:
1. What standards are to be used to measure impact and or impairment?
2. How, where and when is soundscape monitoring to be conducted?
3. What exactly is the soundscape-monitoring program attempting to assess?

On p. 70 of the plan, the NPS lists the following indicators that might be used to measure whether objectives or desired future conditions for the soundscape are being met: % time motorized noise is audible, % of area over which motorized intrusions can be heard, amplitude of motorized sounds, and number of motorized sound intrusions heard over time. The NAEC would suggest the following indicators be considered: sources of noise, types of noise, seasonal impacts, and number of people affected.

The terms used for Desired Future Conditions in Management Areas Table 2-2 [p. 33-34] are not defined, i.e., rare, infrequent, maybe be frequent, almost never, etc. Undefined, these terms are meaningless and offer no guidance for visitor expectation or means of monitoring impact. Qualitative and quantitative measures need to be spelled out.

In order to evaluate whether the standard, "greater part of every hour" is being met, the NPS would be required to monitor the soundscape every hour of the year AND determine that 30 minutes plus 1 second of each of those hours experienced natural quiet. As a result, the standard chosen to measure desired conditions is impossible to implement.

As written, the desired conditions for the soundscape resource are unsatisfactory as they fail to protect wilderness values, one of which is the opportunity to escape from a mechanized society. In stating that "natural sounds are undisturbed the greater part of every hour," the plan allows for backcountry users to be subjected to motor noises for up to 50% of the time. This condition negates the opportunity to have a wilderness experience as defined by the Wilderness Act and ANILCA, which classify a wilderness experience as one that is entirely devoid of motorized noises. Although a 0% intrusion of motorized sounds is certainly the ideal for Denali's backcountry, the NAEC concedes that attaining that ideal is near impossible however, as protecting the natural soundscape is a clearly defined NPS mission, the NAEC asserts that a more aggressive plan to protect and restore the natural soundscape of Denali be pursued. Certainly, the goal for the Old Park Special Resource Area and the Natural Areas should be the most stringent and some close proximity to achieve the desired condition of natural sounds predominating near 100% of the time should be defined. The goal for the Primitive Areas should be that natural sounds predominate at least 95% of the time and for the Backcountry Areas 85 to 90% of the time. As already stated, the NAEC opposes the inclusion of the Backcountry Areas as written and would further argue that this management zone be designated only in locations that are already heavily impacted by motorized users and which as a result of this use will likely not qualify for future Wilderness designation.

The soundscape resource maps erroneously mirror the management area maps, which in turn mirror the snowmachine maps. As sound travels beyond the bounds of lines drawn on a map, the soundscape maps should reflect this factor, i.e., motorized sounds, such as from snowmobiles, can travel up to and beyond a three mile range, which would significantly trim down the areas where non-motorized users could expect to experience a soundscape composed predominantly of natural sound. This situation is further exacerbated by the fact that the zones are intermingled, proposed islands of quiet as it were. In the preferred Alternative D, such a case exists in the southwest corner of the Preserve, which is proposed as a Natural zone in which "natural sounds are almost never interrupted by human noise" but which is bisected by a Backcountry zone, where "frequent intrusions of human noise" would be expected.

The NAEC asserts that the NPS, under Alternatives C, D, and E, will be unable to achieve the objective to "protect and preserve the park's natural and cultural resources values, and wilderness resource values, including the soundscapes and intangible values such as solitude." The only alternative that adheres to DO #47 and has a viable chance of successfully achieving the stated objective is Alternative B, "Overall the park and preserve would have fewer noise intrusions under this alternative, and visitors would have a greater chance to experience an undisturbed natural soundscape." [p. 307]

CONCLUSION
It is understood that the wilderness review process has been stalled and that the present political climate in Washington, D.C., would not favor adding to Denali's designated wilderness lands, however, it is also recognized that the NPS has identified 3.75 million acres as suitable for wilderness inclusion, that a new review would likely add to that inventory, and that 2.25 million acres of the 1980 Park Additions have been recommended by the NPS for wilderness classification. As such, although the process is in limbo, law obligates the NPS, to manage the land as wilderness. The NPS preferred alternative does not meet this obligation nor does it fulfill the stated objectives of the plan [p. 8].

The mandate for Park Administrators to preserve the wilderness qualities of Denali is well defined. The BCMP appears to be driven far more by what is politically acceptable to the present administration rather than by sound science or the philosophical imperative for preserving wilderness for present and future generations. One senses that Denali is being used as an ideological battleground and, as implied by the NPS preferred alternative, the defenders of wilderness are losing. It is the opinion of the NAEC that the NPS, as stewards of one of the last great wilderness tracts in the United States, in supporting Alternative D, has failed to recognize the distinction between "providing for the opportunity to enjoy the wilderness" vs. "providing for opportunities within the wilderness." In the case of Denali's Backcountry it is the former that should guide the precepts of their stewardship, not the latter, which is overly accommodated for in this plan.

Although Denali is often "accused" of having only one access road, the Park is in actuality more accessible than most Alaska National Parks: the George Parks Highway, Stampede Road, and Petersville Road provide points of access to Denali's wilderness lands. Lands adjacent to the Park allow for motorized recreational pursuits that afford access to Denali. The Park boundary should be a steadfast line of demarcation, which once broached, should lead to a shedding of the mechanized and highly politicized world in which we live. By all means, allow people to drive to the boundary, park it and then enter our sacred lands sans motors in order to experience the humbleness of humanity in the face of the wild.

The NAEC urges the NPS to take the following actions prior to implementing a backcountry plan that will have consequences over the life of the Park:
1. Support the prudent precepts enumerated in Alternative B, resource protection is the first and foremost mission of the NPS and make no decisions regarding the appropriate or inappropriate use of motorized vehicles in our wilderness Park until Congress acts on the NPS wilderness recommendation.
2. Use 1980 as the baseline for determining types and levels of use that are in keeping with the legislative intent of ANILCA and for establishing a starting point from which to measure impacts, those that have occurred over the last 23 years and those that the NPS deem are appropriate for the future, to the Park's resources including wilderness.
3. Prepare and implement programmatic plans [Soundscape, Wilderness, Subsistence] prior to the BCMP to ensure that these plans are not constrained by the action plan and that resource protection precedes planning for recreational use of the backcountry.
4. The NPS Planning Team should postpone defining a Final BCMP until a thorough review of the draft document, NPS Guidance on Assessing Impacts and Impairment to Natural Resource, is undertaken. At the present time, NPS policy for assessing impairment is inconsistent and decidedly subjective. It is highly probable that if this far-sighted step is taken Planners will negate the necessity of having to reevaluate actions proposed in the Final BCMP after these guidelines become policy.

The Northern Alaska Environmental Center appreciates the time, effort and consideration that NPS Planners take to review comments from concerned stakeholders.

Respectfully,

Linda A. Paganelli
Denali Watch Coordinator
Northern Alaska Environmental Center