1.The Wilderness review process for Denali's additions is a first priority.
ANILCA Section 1317 (a) required the National Park Service to conduct a Wilderness suitability review for the Park additions. The review found 3.373 million acres suitable and recommended 2.25 million acres for Wilderness designation This process was stalled in the late 80's. We support the completion of this review and recommendation process before other management decisions occur. This philosophy appears in Alternative B of the plan.

2.The plan goals should emphasize the "National Park Difference."
The goals of this plan indicate that Denali should be managed as part of a spectrum of public lands in the area. National Parks, of all our public lands, have the mandate and history for restrictive management. Parks are there not simply for recreation but for resource protection and as symbols of wilderness character. This principle should be the foundation of the plan.

3.The Old Park Special Resource Area, Denali's only designate Wilderness, needs protection.
It is somewhat ironic that the one area of the Park that is designated Wilderness, the Old Park Special Resource Area (tan), is the most "at risk" for future impairment of resources. The gradual migration of the Front Country into the Backcountry is happening as more and more visitors enter Denali each year. The management designation Old Park Special Resource does not describe this area in a detailed way. The encounter rate of two parties per day does not reflect the conditions in midsummer.

The Backcoutry Day Use and Hiker summer management areas help in describing more crowded areas along the Park Road. However, the impacts they measure are fluid and changeable. The slow expansion of the crowded areas into the backcountry is likely to occur. We therefore support limits on the number of vehicles on the road, limits on overnight camping and limits on hiking group size.

4.The purpose of the Northern Additions must be acknowledged in management decisions.
The management classification of Natural is most appropriate for Denali's northern ANILCA additions, considering the reason for their addition - cultural, subsistence and ecosystem protection.

5. Recreational snowmachining is inappropriate in Denali's backcountry.

• The Park Service relies on questionably legal guidelines for allowing snowmachine use in Denali's additions, now and in the future.
• We are concerned about the long term implications of allowing dispersed use of snowmachines, as in the Preferred Alternative D. Dispersed use contradicts long standing national park policy and stretches existing regulations regarding snowmachine use in out National Parks. Dispersed use is a departure from policy.
• The use of snowmachines in Denali's Backcountry has the potential of impairing the wilderness character of Park lands proposed for wilderness designation. Impairment would jeopardize future inclusion in the Wilderness protection system.
• The NPS should apply the "traditional activities" definition that applies to the Old Park to the Park additions. This definition protects the true intent of ANILCA's special access provision in protecting consumptive rural lifestyles, not mechanized recreation.

6. A Soundscape Plan must be realistic and enforceable. We support the completion of a practicable soundscape plan for Denali in accordance with Director's Order #47. The park service must specify the cost of such a program of monitoring and consider whether it can afford to mount a satisfactory soundscape plan for the range of uses advocated in the preferred alternative, D.

7. Enforcement is a problem area.
With the wide range of uses allowed in Alternative D, the park service should specify how the plan will be enforced, both to ensure that management guidelines are achieved and to avoid adverse impacts from the enforcement itself.

Particular Concerns with Alternative D

1. Backcountry Management Zone (red) allows inappropriate crowding.
This management Zone, which allows for backcountry encounter rates of up to 10 parties per day, with party size of 12-15 persons that equates to the potential of meeting up to 150 persons per day.

2. Alternative D allows extensive dispersed use of recreational snowmobiles.
About 50% of the additions' area would be open to some form of recreational snowmobiling. Recreational snowmobiling in Denali is not an ANILCA guarantee and is an inappropriate backcountry activity.

3. Alternative D opens up much of the North Additions to airplane landings of all types, which is unprecedented.
Limiting "scenic tour landings" throughout the additions is important, but they should be eliminated from the North.

4. Alternative D emphasizes recreational uses and falls short on protecting the wilderness character of the Park.

5. Alternative D, and in fact the entire plan, does not define "Traditional Activities."
This ANILCA term was defined for the Old Park, and the same definition, which bases traditional on Congressional intent to protect rural consumptive lifestyles, should be applied to the Park Additions. This term was meant to grant limited access for snowmachines, motorboats and airplanes, not blanket access for recreation.

6. Alternative D does not develop a scientific, practicable Soundscape Plan.
NPS needs to present a soundscape management plan that mitigates noise intrusion and that can realistically monitor for adverse impacts to this resource.

7. Guided Hiking
In view of the potential for impact from larger groups, we recommend a hiking group size maximum of 12.

Reasons that we prefer Alternative B

1. Emphasizes wilderness values, including the opportunity to experience solitude and natural sounds, and opportunities for a self-reliant non-motorized recreation that depends on the wilderness character of the resource.

2. Requires Congressional action on Wilderness before considering motorized backcountry access.

3. Omits "Backcountry" Management Zone.

Park Service actions in the Plan that we support...

1. Extending the backcountry unit system form the core park into the additions.

2. Introducing Soundscape as a resource, just like flora, fauna and cultural/historic resources. Using soundscape measurements to help negotiate with air services regarding preferred routes, for instance, is a positive step.

3. Closing all airplane landings in the Old Park. This is a closure that should have happened after the Park was designated Wilderness by ANILCA, and is most in line with the mandates of ANILCA.

4. Restricting bicycles to established roadways. In addition, we feel that using bicycles MAY be appropriate on some Kantishna mining routes, but that these should be individually identified and not opened as a group.