November 20, 2009

William Freeland, US Coast Guard

Environmental Protection Specialist

Rescue 21 PRO Alaska

100 Savikko Rd.

Douglas, AK  99824

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RE: Scoping for Proposed Coast Guard Communication Sites in Glacier Bay

Dear Mr. Freeland,

Thank you for the opportunity to provide scoping comments for the proposed search and rescue communication facilities in Glacier Bay National Park & Preserve.  The National Parks Conservation Association (NPCA) is a nonpartisan advocacy organization dedicated to protecting and enhancing America’s national parks for our children and grandchildren to enjoy. Today we have over 330,000 members of which 900 are in Alaska.  Communication and equipment sites in Alaska’s national parks are a topic of great importance to NPCA and we’ve been following it closely.  Many of the recent environmental assessments (EAs) have not included scoping, so we are especially appreciative that the Coast Guard has provided us this opportunity.

NPCA became alarmed at the rapid increase in remotely located communication equipment in 2007 when we realized 50 new or upgraded sites had been approved in Alaska’s national parks in just seven years.  This includes many types of equipment from a wide variety of agencies including radio repeaters, web cams, weather stations, navigational aids, and seismic stations.  Some parks have as many as 20, 30 or more installations – most of which are in designated Wilderness. While every individual project has merit, the cumulative effect is alarming, especially those sites in Wilderness. NPCA is very concerned that the fundamental purposes of Wilderness (a place untrammeled by man where structures and installations are prohibited) are being lost in the very place you would expect to find it most – national park Wilderness in Alaska.

Nonetheless, NPCA recognizes that there is, and will continue to be installations in parks and also that some of it is allowed through exceptions in ANILCA.  So the next question becomes how do you properly evaluate requests so that only the truly essential are allowed?  This is not a new problem and it is not unique to Alaska.  A multiagency task force has been working on this for nearly ten years.  As you may be aware, they have recently finished an assessment process titled An Interagency Framework to Evaluate Proposals for Scientific Activities in Wilderness.  We strongly

encourage you to use this process to evaluate this proposal.  While this proposal may not strictly fit under the category of “science” we believe it to be a very useful evaluation tool.  Since this will be the first proposal in Alaska to use it, we recommend staff apply the framework even if the only purpose is to evaluate the pros and cons of the process itself, and make recommendations on how it can be implemented in Alaska parks in the future. 

NPCA recommendations to evaluate in the EA:

• Give strong preference to sites located outside of designated Wilderness
• If locations in Wilderness are evaluated:
• Use the Framework to Evaluate Proposals for Scientific Activities in Wilderness
• Thoroughly complete the Minimum Requirements Decision Guide.  Remember that the first question is whether the project is necessary for administration of the Wilderness.
• Include a map of all communication and equipment sites currently in Glacier Bay
• If possible, quantify how much safety will be improved by the proposed installations
• What will be the motorized access (i.e. boat, helicopter, etc.) for construction and maintenance? 
• How often will maintenance be performed?
• Will any outdated equipment in Glacier Bay be removed?
• Is this considered a navigational aid per the ANILCA exceptions?  If yes please include the solicitor’s written opinion.
• What are the visual impacts to the visitor experience?
• What are the impacts to soundscape?
• What are the impacts to wildlife?
• What are the cumulative impacts for all equipment sites?  (For example, how many motorized intrusions into Wilderness will be necessary per year for maintenance of all sites)
• What efforts will be taken to avoid introducing invasive plants species to the construction sites?
• How will you insure the equipment will be removed once it becomes outdated?

Thank you again for the opportunity to comment before the EA is written.  We truly understand and value the importance of the “Rescue 21” system.  We also believe in the value of Wilderness.  Part of the purpose and joy of wilderness is the element of risk - the need to be self reliant because help is not always a simple call away.  While of course safety is important, it can always be improved.  We are hoping your evaluation is able to make the difficult distinction between what is absolutely necessary and what is not.

Sincerely,

Joan Frankevich

Program Manager

cc: Allison Banks, Glacier Bay National Park, sent via e-mail:  This e-mail address is being protected from spam bots, you need JavaScript enabled to view it