Friends of Glacier Bay

PO Box

Gustavus, AK 99826

December   , 2009

Mr. Joseph Calnan                                                     Ms. Cherry Payne

Commander, USCG Rescue 21                                Superintendent

Project Resident Office Alaska                                  Glacier Bay National Park & Preserve

100 Savikko Road                                                      PO Box 140

Douglas, Alaska 99824                                               Gustavus, Alaska 99826

Dear Commander Calnan and Superintendent Payne:

Subject:          Friends of Glacier Bay Comments on Rescue 21 Scoping Phase for Glacier Bay National Park and Preserve

Thank you for arranging the public scoping meeting in Gustavus on November 21, 2009.  Ms Alison Banks representing the National Park Service, and Commander Calnan and Environmental Protection Specialist William A. Freeland representing the US Coast Guard, patiently led the attendees through the Rescue 21 proposal, elucidating the initial considerations regarding its deployment at two sites within Glacier Bay National Park and Preserve. 

The US Coast Guard and the National Park Service are two great Federal agencies with critical roles in Alaska.   Every person who ventures onto the water in Southeastern Alaska values the triple role of the Coast Guard to assure maritime safety, security, and stewardship.  Among their eleven statutory missions, those of marine safety, search and rescue, and marine environmental protection are especially appreciated.   The heroism, professionalism and importance of the Coast Guard were never better demonstrated than on the night of October 4, 1980  when the MS Prinsendam sailed out of Glacier Bay and caught fire in the Gulf of Alaska.  The ship’s call for help was received at the Coast Guard Station in Kodiak, and rescue mounted by the Coast Guard saved all 520 passengers and crew.

By the same token, all who cherish the natural wild character of our National Parks—and of Glacier  Bay in particular—appreciate the work of the National Park Service and its mandate “to conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.”   The Park’s staff has drafted a Foundation Statement in which they identify a primary interpretive theme:  “Glacier Bay is a place of hope – for it preserves a sample of wild America.”    In wilderness “(t)he park preserves the natural sounds, views, and the opportunities to see pristine night skies…The park’s marine and terrestrial areas provide exceptional opportunities for solitude, challenge, inspiration, and primitive, unconfined recreation.”  Friends of Glacier Bay shares the values expressed in the Foundation Statement and looks to them to inform our consideration of the Rescue 21 proposal.

The Coast Guard and the NPS have important, but differing, public service mandates.  In a marine national park like Glacier Bay, they overlap but don’t necessarily align.  When the roles conflict or suggest differing approaches in a national park, Friends of Glacier Bay believes traditional national park values must be given the greatest weight.

At the scoping meeting in Gustavus, Ms. Banks asked for ideas from the public regarding alternatives for consideration in the environmental assessment to be developed for the project proposal.  To that end, Friends of Glacier Bay suggests separate sets of options for the outer coast (Deception Hills) and Glacier Bay sites as follows:

Options for outer coast Deception Hills site

1.  No Rescue 21 addition to Deception Hills site

2.  Integrate Rescue 21 tower into existing Deception Hills site scientific facility

Options for Glacier Bay proper

1.  No Rescue 21 addition to site, no other changes to NPS repeaters

2.  Willoughby Island site serving West Arm and Muir Inlet main stem

3   Beartrack Mountain site, integrated with NPS repeater

4.  Falls Creek site serving only lower- to mid-Glacier Bay

5.  Upgrade NPS repeaters to include channel 16 and perhaps channel 12 or other public use channel, but do not install Rescue 21 coverage for Glacier Bay at all

Preliminary Friends of Glacier Bay Views on alternatives

Friends of Glacier Bay understands that at this stage the implications of these alternatives will need to be fleshed out before they can be fully evaluated.  There may indeed be other alternatives to be suggested, perhaps involving advances in technology, that may achieve the intent of Rescue 21 without violating National Park values or NPS management policies.  We look forward to learning more about such options.  In the meantime, however, we offer our preliminary feelings about the options we have suggested, as follows.

Outer Coast options

Addition of a Rescue 21 tower at  Deception Hills would fill a gap in radio coverage for the Fairweather fishing grounds where usage is mainly by commercial vessels and large ships, not Park or Preserve visitors.  Weather conditions, hazardous cargoes and occupational safety hazards associated with commercial activities are significant problems, unrelated to the Park.  The proposed antenna site is in non-wilderness Preserve and already has a scientific installation to measure gravity changes.  Friends of Glacier Bay believes that installation of a Rescue 21 tower at the Deception Hills site does not represent a significant intrusion on the values and purposes of the National Park and Preserve and would indeed contribute to better response to emergencies offshore.  To that end, we support the addition of a tower at the Deception Hills site, but recommend that the NPS and USCG work together to integrate the installation and operation of the new tower with the existing scientific site to minimize impacts.

Glacier Bay coverage options

The National Park Service Wilderness Management Policy is relevant to the installation of any communications facility within Glacier Bay.  Specifically it states:

Wilderness considerations will be integrated into all planning documents to guide the preservation, management, and use of the park’s wilderness area and ensure that wilderness is unimpaired for future use and enjoyment as wilderness.

Paragraph 6.3.5 Minimum Requirements of the wilderness policy provides key guidance:

All management decisions affecting wilderness must be consistent with the minimum requirement concept. This concept is a documented process used to determine if administrative actions, projects, or programs undertaken by the Service or its agents and affecting wilderness character, resources, or the visitor experience are necessary, and if so how to minimize impacts. The minimum requirement concept will be applied as a two-step process that determines

Ñ         whether the proposed management action is appropriate or necessary for administration of the area as wilderness and does not cause a significant impact to wilderness resources and character, in accordance with the Wilderness Act; and

Ñ         the techniques and types of equipment needed to ensure that impacts on wilderness resources and character are minimized.

Friends of Glacier  Bay supports the NPS application of this policy as it considers the Rescue 21 proposal.

Option 1.  No Rescue 21 addition within Glacier Bay

At this juncture, Friends of Glacier Bay believes the USCG Rescue 21 VHF coverage enhancement is probably unneeded for Glacier Bay.  Weather and sea conditions in the relatively quiet inside waters of the Bay do not present the hazards to marine users commonly experienced in other parts of SE Alaska.  Hazardous cargoes are not conveyed in the Bay and park visitor activities are far less hazardous than is maritime work offshore along the outer coast. 

Glacier Bay has been explored by visitors via ship, private vessel, personally powered craft, and on foot for over a century without the assurance of ready contact with the US Coast Guard.  Self reliance and being “out of touch” in an environment away from the “safe” modern world are important attractions to wilderness travel.  Even visitors on cruise ships entering a visually untrammeled Glacier Bay can imagine they are exploring for the first time a wild frontier area with no sign of human facilities.  Nevertheless in a real emergency a cruise ship can communicate with the Coast Guard by side band radio, as did the Prinsendam, or by satellite phone when needed.   Backcountry users and boaters now have available  the SPOT technology with its emergency notification capability.  There are generally numerous vessels in Glacier Bay, including those operated by the NPS, monitoring channel 16 that can relay an emergency call or respond to help a mariner in distress.

NPS employee safety improvement has been mentioned as a possible consideration.  However, NPS employees have been patrolling Glacier Bay since the 1950’s without serious incident and without ready contact with the USCG.  Indeed when Ranger Bruce Black worked in Glacier Bay in the early 1950’s he worked alone, safely, with no ready emergency contact.  Today park rangers on patrol have available sideband radio, and VHF repeaters for park frequencies covering much of Glacier  Bay.  Rescue 21 facilities will not provide any needed or significant improvement to the safety of NPS employees deployed in Glacier Bay.

Option 2.  Willoughby Island site

Friends of Glacier Bay views the Willoughby Island site as totally unacceptable for a Rescue 21 installation.  A 60 ft tower mounted on Willoughby Island would be visible throughout much of Glacier Bay and would be a serious intrusion on the scenic value of the bay.  Unnecessary installation of such a tower in such a highly visible site would be a violation of the NPS mandate to preserve the scenery of the parks unimpaired for the enjoyment of present and future generations.   An installation on Willoughby Island, above the popular camping site at Johnson Cove, would also be a violation of the Wilderness Management Policy as it is not necessary for Park functions.  Furthermore, the site construction and maintenance would require disruptive helicopter flights in the central Bay during the summer visitor season.  For these reasons an installation at Willoughby would be very unpopular with park visitors, even those on cruise ships.  The NPS should reject an installation at Willoughby out of hand.

Option 3.  Beartrack Mountain Site 

FOGB believes the Beartrack Mountain site, which already hosts an NPS repeater and is not easily visible to most visitors, would be much less objectionable to park visitors.  Coverage of Tarr Inlet, which has the largest share of vessel traffic, is expected to be better from Beartrack Mountain than from Willoughby Island.  Muir Inlet would not have coverage, but there is comparatively less vessel traffic there.  Visitors wishing to remain within contact range of the Coast Guard can choose to travel only in the covered area.  That said,  Friends of Glacier Bay is not yet persuaded that the NPS and Coast Guard can demonstrate a real need for a Rescue 21 tower at this site, as required by NPS wilderness policy.   Construction and operation would require repeated helicopter flights to the site.   If a need for Rescue 21 coverage within Glacier Bay is demonstrated in conformance with the limitations of NPS wilderness policy then the Beartrack Mountain site appears preferable to Willoughby Island.  If this alternative is chosen, the NPS should work with the Coast Guard to integrate their facilities onto a single tower, to minimize the additional impact.

Option 4.  Falls Creek Site

Friends of Glacier Bay sees the Falls Creek site as the least impacting alternative providing any Rescue 21 coverage for Glacier Bay.  No new construction in Park wilderness and no helicopter access for construction or maintenance would be required.  Road access makes this the least expensive to build and operate.  A Rescue 21 facility might be integrated with equipment for cell phone and internet service on a single tower.  Coverage would be limited to lower Glacier Bay but we understand cruise ships may have service from mid-Bay.  Coverage for Icy Strait would be redundant, but there is much more traffic in Icy Strait than in Glacier Bay and redundancy does add reliability.   A cost/benefit comparison may find the Falls Creek site to offer significant advantages. 

Option 5.  Upgrade the six existing NPS Repeaters 

Upgrading the NPS repeaters to include Channels 16 and 12 would allow vessels in much of Glacier Bay to reach the NPS at Bartlett Cove when the NPS radio is being monitored.   No additional construction may be necessary for Rescue 21 but the NPS presumably would bear the expense of the upgrades.  Upgrades could be made during scheduled maintenance on the various repeaters.  While at first this option may appear to be less impacting than, say, the Beartrack Mountain site, we know little about the impacts that may be associated with the upgrade installations. 

The National Park Service and the US Coast Guard have developed an excellent cooperative working relationship that serves the public seamlessly and well.  Regardless of the option taken for Rescue 21, the two agencies should focus attention first on prevention of incidents, rather than on rescue or response to them.  The Coast Guard provides essential training in safe vessel operation, inspects vessels for compliance with their expectations, and provides critical weather and marine condition information to mariners around the clock.  The NPS at Glacier Bay does an admirable job with backcountry and boating orientations.  Rangers communicate the specific hazards in the Park and how visitors can care for their own safety.  Visitors also learn the necessities for protection of park resources and of the rights of other visitors.  As suggested at the Gustavus scoping meeting it may be useful also to provide visitors with a map indicating the areas within radio contact of Bartlett Cove and the US Coast Guard.  Visitors could then choose to stay within covered areas or not if either matters to them.  It is also essential that the NPS select, train, and deploy in the backcountry, park rangers who exhibit the best examples of park values, wilderness ethics, backcountry travel skills, and visitor communications, in addition to enforcement skills. 

Thank you again for the opportunity to learn about the Rescue 21 proposal at the Gustavus public scoping meeting.  Friends of Glacier Bay looks forward to working with both agencies through the environmental assessment and decision phases to learn more about the options and how they may affect visitor appreciation and the superb natural resources in Glacier Bay National Park and Preserve.

Sincerely,

FOGB Board