DCC Comments on Spruce 4 EA

Superintendent June 17, 2002
Denali National Park and Preserve
PO Box 9
Denali Park, Alaska 99755

Dear Mr. Anderson,

I appreciate the opportunity to speak for the Board and members of Denali Citizens Council on the EA for Spruce Creek Access. The scope of this access changed significantly when the owners sold 18 acres and commercial use rights to the National Park Service in February 2002. While the change in scope does reduce the enormity of impacts, we have concerns regarding cumulative impacts of the EA's preferred alternative. We recall that in the DEIS for Spruce 4, use of the Moose Creek streambed for motorized access did not even appear as an alternative because of the potential for damage from the size and type of vehicle use anticipated. Although this access will now be on a much smaller scale, we note that the potential for impact has been recognized and must be addressed with specific monitoring and mitigation plans.

Our concerns about the preferred alternative center around unknown cumulative impacts associated with instream motorized travel on Moose and Spruce Creeks. We would prefer that the EA contain an alternative involving minimal motorized access, perhaps a "Fly and Hike" alternative, or a "Hike from Mile 89" alternative. In addition the number of motorized trips up Moose and Spruce Creek seem excessive to us. A more specific discussion follows.

· Future ownership
We understand that the purchase agreement for Spruce 4 finalized in February 2002 provided the National Park Service with the first opportunity to buy the remaining two one acre inholdings in the event of a sale. Is this true? We would like to see a copy of the purchase agreement included as an appendix in this EA. Does the NPS have a plan to make purchase offers periodically to the owners?

· Cumulative impacts of instream motorized travel
Perpetual motorized use of the Moose Creek streambed by inholders and by the National Park Service can and will create impacts on the soil, plant and animal communities there. Although the ROW permit is renewable (and therefore revocable) every five years, this permit would trigger construction activities of a magnitude heretofore not authorized. It would move away from, and not toward, the eventual reclamation of the Moose Creek bed that was the intent of prior Park policy.

The EA as it stands is incomplete in addressing these cumulative impacts and rationale for departure from prior Park reclamation policy. Does Section 1110b of ANILCA require provision of access that is contrary to NPS intent for Kantishna?

Certainly, any such contemplated access must have adequate justification and must be proactive in describing mitigation activities. Before motorized use of the streambed can be authorized a criteria-based monitoring strategy for vehicle impacts to the streambed and associated habitat and wildlife should be in place. The EA should establish clear criteria that would trigger a re-evaluation of the ROW permit. An example of the type of monitoring is given below.

Mitigation of Effects on Aquatic Resources: Grayling
Especially on the North Fork of Moose Creek, grayling populations use the streambed for spawning activities. The EA states that spawning occurs "immediately after breakup," which will vary, but perhaps will occur in mid May? The EA goes on to state that fry hatch about three weeks after spawning (into June?) and occupy "quiet waters near their spawning sites." Where are these waters? Have they been mapped for Moose Creek? Since the North Fork is, according to the EA, a "high density area" for grayling, have spawning grounds there been mapped? Perhaps this sort of mapping, if not already done, should be required before final number and timing of trips are determined. Such mapping would establish a baseline from which to judge the effects of in-stream travel by wheeled vehicles upon grayling fry. The number of trips on the North Fork authorized by the preferred alternative, sixty, may be way in excess of what is appropriate. We think that allocation of permit numbers in this EA is premature.

It is unclear to us that ADF&G would support a ROW for instream motorized travel, especially considering the number of trips that are currently authorized under the preferred alternative. Is the determination of a preferred alternative actually premature without ADF&G authorization?

· Size and Type of Vehicle
The EA describes the motorized access as 4WD vehicle. However, the nature of these vehicles is not completely specified. We assume that NPS does not want ORVs or track vehicles to be used because of the potential for their use off the right of way, with attendant damage. The EA should be more specific in describing the exact type of motorized vehicle authorized.

· Need for Diversion on Spruce Creek?
In the EA it is unclear why NPS accepts the proposed diversion of access up Spruce Creek away from the streambed. What is the major purpose of this diversion? Is it being done to protect aquatic resources or to make access for larger vehicles (for example, 4 WD pickups) easier? We would prefer to see a more thorough discussion of why the diversion has been recommended. Is this more for the convenience of the inholders or for environmental concerns?

In addition, we would hope that any road construction activities advocated by this EA would "make sense" in terms of a more long term vision of the future of Kantishna, a vision that could very well include the NPS purchase of the two remaining acres of the Spruce 4 claim.

· Impacts on Public Use Before the first crossing of Moose Creek.
Although the EA states that the preferred alternative covers the entire access to Spruce 4 from Park Headquarters, the ROW permit in this EA does not include that section of access up Moose Creek from Mile 89 to the first crossing of Moose Creek, approximately three miles.

This section is considered "public access," I am told. Does this "public access" include motorized access, and if so is the amount of motorized access on this section subject to limits or controls? There are several inholders on Rainy Creek who would also use this section, but the EA offers no discussion of the amount and potential impact of their traffic. The document should address the fact that access across these first few miles is likely to be much greater than beyond them.

The "public access" into this area that needs protection, in our mind, is pedestrian access, not motorized access. These first three miles, before the first ford, contain the area where most of the daytime pedestrian activity, including hiking, photography, bird watching and berry picking, occurs. The impact of dust, noise and traffic upon these activities was at the heart of our objections during the Spruce 4 DEIS process and is at the heart of our current concerns.

Because of the potential for user conflict in this specific area, may we suggest that during the months of June and July, the applicants' (and all inholders') motorized access be permitted only between 6 PM and 7 AM? During these two months, days are long and the 6 PM - 7 AM time frame provides adequate light for the trip, while reducing conflicts with pedestrian activities along the road.

· Park Road Access for Kantishna inholders
According to the EA, there are only 100 permits to travel the Park Road from Headquarters to Kantishna per summer for inholders in the Kantishna. Under the preferred alternative, these two inholders will use 30 of these permits. Is this considered a fair proportion of the total? Is it true, as implied in the No Action alternative, that these inholders currently qualify for 40 Road permits?

· Gravel
The EA indicates that construction of the Spruce Creek diversion can be accomplished with nearby gravel. We wonder about the long term viability of these gravel resources. In addition, we wonder who has the responsibility of maintaining the Glenn Creek airstrip and what will be the impact of this maintenance on gravel resources. In addition, if the owners are charged with the responsibility of maintaining the instream Moose Creek portion, where will the gravel for this section be gathered? Can gravel maintenance of the instream portion along Moose Creek be accomplished using vehicles that remain within the vehicle weight guidelines of the permit? Would matting be necessary, eventually? If the owners sell their claims, does NPS intend to reclaim the Moose Creek bed?

In any case, DCC maintains steadfast opposition to the establishment of any gravel pit along upper Moose Creek above the bridge at Mile 89.

· Air Access and Soundscape
We wonder if any access alternative can control air impacts, as long as the Glen Creek Airstrip exists. Several categories of air travel to Glen Creek and to Spruce 4 by both airplane and helicopter remain outside any of the ROW permit guidelines. For instance, are air trips between Kantishna and Glenn Creek airstrip subject to permitting limits if they are not part of a completed trip to Spruce 4? Can the owners fly into Glenn Creek strip without limitation if the trip is for ferrying and storing gear? If the owners fly to Glenn Creek but hike to their claim across Unit 41, is this trip subject to permitting guidelines?

The EA implies that the preferred alternative will have fewer aircraft associated impacts on the Kantishna area, but we see no real way to prevent an increasing amount of aircraft- associated impacts with any alternative, as long as the Glen Creek Airstrip exists.

· Parking and Storage
The EA does not address the fact that parking provisions for inholders could become a problem in the future. We assume that the inholders, if they plan to use the park shuttle system, could be leaving vehicles (and possibly storage containers?) somewhere in the Kantishna "as directed by the Superintendent." The parking area adjacent to the North Face Lodge is not appropriate for the task of providing long- term storage for inholder property, especially when you consider that other Moose Creek inholders may wish to use it in that way. Nor is any part of the "public use" section before the first ford appropriate for storage of inholder property. This problem, while not specifically a Title 1110b matter, is part and parcel of the entire inholder access issue and should be addressed.

· Comments on Draft Spruce 4 EIS
In the Summer of 1999, NPS conducted hearings on the Draft EIS for Spruce 4. Because the Spruce 4 claims were purchased and this EIS was never finalized, the Park Service analysis of these public comments, and the comments themselves, may be lost to the public. While these comments do not specifically address the current ROW request, they are pertinent to the larger issue of Spruce 4 access, road construction and transportation at Denali, and the future of Kantishna.

We recommend that these comments and their analysis be codified in some way, as they contain valuable historic background and public input on the entire issue of the appropriateness of new road construction in the Kantishna area. We recommend inclusion of this record in an appendix to the EA or as another NPS document, or available on CD or other digital document format.

Conclusion
May we suggest that a programmatic EA be substituted for this EA. This programmatic EA would address a broader array of pertinent issues, some of which we mentioned above. This EA would address the entire subject of inholder access, the use of the "public access" portion of the pioneer road up Moose Creek, and future development and reclamation goals for the Kantishna. Without such a larger perspective, decisions regarding two inholders could propel Park policy in untenable directions. In the interim, temporary access permits would continue to provide access to Spruce 4.

Sincerely,

Nancy Bale
President, Denali Citizens Council