PO Box 220196
Anchorage, AK 99522-0196
Jaclyn L. Brock
Alaska Department of Natural Resources
Office of Project Management & Permitting
Alaska Coastal Management Program
302 Gold Street
Juneau, AK 99801
Physical Planning Division, Planning Department,
Municipality of Anchorage,
P. O. Box 196650,
Anchorage, AK 99519-6650.
Re: Comments on Anchorage Coastal Management Plan final amendment
July 26, 2006
Dear Ms. Brock & Mr. Tobish:
Thank you for the opportunity to comment on the Anchorage Coastal Management Plan final
amendment. I appreciate the hard work that has gone into this document. As I wrote in my
comments on the draft, the previous version served the city well so it is critical that everyone
who considers these revisions also ask what harm could be done by these efforts to streamline
development. That is, in essence, why we are being faced with these changes now. I referred
to both national & state executive orders, which set this dangerous cascade of requisite
changes in motion. These requirements put everyone in a tough spot as they try to make the
requisite changes, yet try to make sure that the resources are well protected while allowing
foreseeable wise & careful development. What we must all keep in mind is that this document
must last through changes of administrations great & small, partisan & non-partisan, good times
& bad times. In short, it must withstand the test of time for us to maintain a healthy, living
coastal zone where we live. The changes recently made to the Alaska Coastal Management
Program are not compatible with this goal. I hope that the MOA will do everything possible to
bring balance to the chaos, which has ensued. Rapid development does not equal wise
development. I am thankful to everyone who endeavors to judiciously consider the
consequences in these decisions.
You may consider the bulk of my comments in the public record on the draft still valid & refer to
them where they will be useful. They contain an appendix rich with valuable information &
suggestions regarding the Cook Inlet Beluga Conservation Plan from Bob Brock, myself & Cook
Inlet Keeper with Others. I hesitate to repeat myself, but include these critical statements so
that they will be in order for you to reference in the plan.
It is great that this plan addresses the increasing problem of invasive species. As in many other
instances, it would be more effective, however, if the phrases “avoid, minimize AND mitigate,”
were used, instead of “avoid, minimize OR mitigate.”
Some of the numbering has changed in the draft version making it awkward to comment in an
easily comparative way. Forgive me if I inadvertently confuse any numbers. What is written
should communicate my intent. I reassert some poignant issues & call to your attention these
In all areas, as in 5.4, “Proper & Improper Uses,” be reminded that the Alaska Coastal
Management Program does not supercede or negate existing authorities, be they federal, state
or other. For example, ADF&G manages the Anchorage Coastal Wildlife Refuge & shall be
involved early & often in any plans involving access to it.
Chapter 3—Issues, Goals & Objectives
Word block 4—At this date some of these "locally adopted plans" have not actually been locally
adopted or are in the process of discussion & revision.
6. There are uses & activities that are economically or physically dependent on a waterfront
location. These uses & activities must be given priority.
Comments: Include this caveat: These activities shall not be given priority where they are likely
to interfere with wildlife habitat needed by such as the depleted Cook Inlet belugas.
3.3.1 Every effort must be taken to make accurate designations of important habitats to these
whales which are, once again, under consideration for Endangered Species Act listing. The
NOAA/NMFS annual beluga count is NOT LOOKING GOOD again this year folks! Criticisms
leveled by several knowledgeable entities in the comment period for the draft Cook Inlet Beluga
Conservation Plan, stated that not enough care was undertaken in labeling such areas in Cook
Inlet. Complaints suggested that these areas were chosen as a matter of some political
convenience for commerce. Likewise, waterfront location for uses & activities that are
economically or physically dependent on a waterfront location, shall not displace ACWR wildlife
by disturbance or diminishment of habitats. [see appendix of comments on draft for letters from
Bob Brock, Cook Inlet Keeper with Others, & Barbara Carlson]
7. Adequate, safe, & maintained access to the coastal land and water resources, upon which a
number of activities & uses depend, is essential to sustaining & enhancing future economic
growth and development.
Comments: This is acceptable if it is not intended to promote commerce that would diminish
the integrity of the ACWR. This particular refuge is unique in many ways. A few of those
ways significant to this discussion are the following:
1) It is a richly productive salt-marsh, which has not only become a rare in the world, but it
is rare in Upper Cook Inlet (It is especially critical for migratory birds as it is a south
facing marsh that melts earlier after thick ice winters.)
2) This refuge is small & activities that would leave a seemingly small footprint in larger
areas, will leave a comparatively huge effect here due to the small amount of land.
3) The habitats that are the most valuable to the wildlife are the areas closest to the coastal
bluff, which is, coincidentally, the area where earth compaction, tree cutting,
development or humans & dogs would have the most detrimental impact. Although this
strip of refuge varies somewhat along its length, some characteristics that make it
particularly important to the wildlife follow. It is where certain nutrient rich grasses &
other plants grow. It is where fresh water seeps abound. It is where Sandhill crane
parents rear their young to keep them slightly more safe from raptors. It is where a
certain vole population is the thickest, voles being the basis of a food-chain that spreads
much farther than the refuge itself.
4) No other city in the world can boast to have such a functioning refuge in such close
proximity to so many people. The old growth, natural mixed deciduous coastal bluff
buffers protect the ACWR from numbers of people that are too great, by its very nature.
In doing so, it also preserves the habitat necessary to sustain the life it supports in &
around the refuge. Many birds & other animals come from further inland to hunt, forage,
nest, & take shelter. Such resources in many parts of Anchorage have been destroyed.
5) It is not necessarily the rareness of the wildlife that thrives here that makes it so
important. Comments to the effect that there are no species that will go extinct if we
change the uses of the ACWR are woefully misplaced. The fact that such diversity in a
refuge can survive a few hundred meters from West Dimond Blvd, in the largest city in
Alaska is absolutely amazing! We must do all that we can to maintain this very unique
refuge. That feat will serve the people well.
9. Public access to streams & lakes must be retained as land is subdivided or developed.
Maintaining & enhancing connectivity between & among parks, public facilities,
neighborhoods, natural areas, & the coastline have consistently been most valuable to the
Comments: This can & should be done where it is appropriate. ADF&G manages the ACWR &
has stated repeatedly that more access to the refuge along the coastline could endanger the
resource. It is also not a given that improved access is necessary or advisable for the uses for
which it was intended. Any such increases or improvements would need to be cleared with the
wildlife biologists responsible.
10. The Anchorage Coastal Wildlife Refuge (ACWR) is an important natural resource area &
local natural feature of the Anchorage Coastal zone. A large representation of wildlife species
can be found in the ACWR & adjacent coastal sections, & in similar environments in both
Chugiak-Eagle River & Turnagain Arm, providing both opportunities for scientific study,
education, & tourism.
Comments: Caveat: The ACWR is managed by ADF&G. Any activities that take place here
must not decrease the sustainability of this resource. Truly, to allow study & appreciation by
more people will be great, as long as those activities, first, do no harm.
3.1.2—Goals & Objectives
Goal 2: To Encourage development & construction practices that minimize adverse impacts to
the important habitat within the MOA coastal zone.
Objective B: Develop enforceable policies for those activities likely to result in erosion, generate
stormwater runoff, or generate sedimentation that has potential to impact local streams & lakes.
Comments: Add “saltmarshes & wetlands, especially those designated preservation A.”
Goal 3: To give high priority to, & preserve space for, water-dependent facilities requiring direct
access to water.
Comments: I agree that these are important uses for Anchorage, however, the depleted
Cook Inlet belugas are known to feed in Ship Creek & Campbell Creek. There is
documentation of beluga calves in both. For this reason it is important to consider the
many possible ways to give them the space they need when that can be determined. [To
learn more about belugas in the waters of the ACWR & in Campbell Creek see the
appendix of the public record draft comments, especially the appendix to bc’s letter
which contains 34 pages of log excerpts to accompany her comments on the Draft Cook
Inlet Beluga Conservation Plan.] The letter from Cook Inlet Keeper with Others provides
a number of possible suggestions to some of the problems Anchorage faces as it
prospers in development AND endeavors to sustain its nearby wildlife diversity & the
abundance of unique creatures such as the CI beluga. Imagine us being successful in
this way. It is possible.
4.1.10 Important Habitats
Marine Fisheries & Marine Mammals
Comments: Beluga presence is also well documented in & around Campbell Creek,
mainly from May through October. The only month of the year that belugas have not
been seen or tracked via radio telemetry in this area is February. In addition to harbor
seals we have also seen the occasional sea lion, swimming & feeding with belugas in
front of the refuge & in Campbell Creek itself.
Belugas spend a lot of time in Knik Arm. It is important to find the most useful
information possible regarding trends & actual long term data. Specifically, numbers of
them habitually observed at the mouth of the Susitna River during the early summer,
appear to move to the Knik Arm mid-to late summer & early fall.
Threatened & Endangered Species
Comments: I find it unconscionable that the Cook Inlet beluga is depleted is not even
mentioned in this section despite the fact that it is currently being considered, once
again, for ESA listing. Citizens & tourists alike will want to know that we do everything
we can to steward these whales especially in light of the rapid increase in development
in the wings. Please add the appropriate information & work with NOAA/NMFS marine
biologists & Enforcement to develop a cooperative partnership to help insure their
Terrestrial Resources & Habitats
4.1.11 Recreation Resources
Comments: Once again, there is an error of designation & this should be rewritten carefully so
as to not imply dual designation of Important Habitat Areas with Recreation Use Areas.
Omissions: Please note that several large water birds were not mentioned in this section. I refer
to their presence in the ACWR because that is the area with which I am most familiar. They are
a special presence & every year people all over the Sand Lake community listen to hear the
distinctive calls signaling their arrival.
1) Sandhill cranes are not only a migratory presence, but we have 8-10 pairs of these 4 „ tall
birds that return to nest & raise their broods here. During this period they are very sensitive,
but they can be seen at several access points, with the aid of lenses, if one is there at the
right time. It takes nearly the entire summer for the chicks to grow enough to be able to fly.
Some are still here in September.
2) Snow geese were another oversight. They utilize the ACWR with vigor in their desperation
to forage enough fuel for their long trip to Wrangell Island, north of Siberia. They must arrive
there with sufficient fuel reserves to be able to immediately lay eggs, for if they do not, the
chicks will not be big enough to survive the long migration south come fall because they
must leave early being so far north.
3) Both Trumpeter & Tundra swans frequent the ACWR. In fall of 2005 there were more than I
had ever seen here that chose to rest, preen & feed in groups over a longer period of time
than I had noted in the 7 years past.
4) Great blue herons are also here occasionally. I have seen 4 at different times in a 3-year
There are numerous other types of birds, including greater white fronted geese, & animals that
aren‟t mentioned as part of the ACWR inventory. A more representative list could be obtained
Revisions to the MOA Coastal Atlas
4.2.1 It is helpful to see the added description on the Anchorage Sensitivity Index Decision
Support System Model (ASIDSS), however, I find the maps currently available on the website
inadequate to follow what is written. These should absolutely be in place at this stage of the
4.2.2 There is, once again, no mention of concern about the Cook Inlet beluga which is about to
become listed under the Endangered Species Act. As citizens of Anchorage our family, like
most, has been thrilled to be able to share with visitors to our city the close proximity of these
amazing cetaceans. One could view them along the Port of Anchorage, the Tony Knowles
Coastal Trail, Point Wornzoff, the motocross, Carrs/Gottstein Park, Beluga Point, & many spots
along the way. As a person who has been watching from a the high bluff with a scope around
both high tides of nearly every day this year since the ice went out in spring, I can tell you the
concern is very real. Where in the past 8 years I have seen many pods of many belugas most
years, this year I have seen fewer than ever. I have seen just one group of 3 and one group of
12. Pay attention to the elephant in this room!
4.2.3 Habitat Impacts
Loss of Aquatic Habitats
Comments: Last wordblock: When “considerable public recreation activity” is focused
along the habitat of a wildlife corridor, rather than provide a connection, they sometimes
displace them, chasing moose & bears out into the traffic or closer to houses through
neighborhoods, for example, so care should be taken when planning such uses.
Omission: There is potential for great destructive changes can take place in a saltmarsh
with the emptying there of large amounts of stormwater runoff. The effects of such
dramatic changes in water levels, the potential for the introduction of pollutants, & the
possibility that increased saturation could de-stabilize the adjacent coastal bluff, upon
which there is already municipal supported development, taxpayers, if you will, can be
far-reaching. Regarding the changes in biological requirements for various species that
are linked to the food web of not just the saltmarsh, but also the entire watershed, the
coastal waters, the wildlife from inland areas that travel to the coastal zone to forage,
hunt, rest, preen & hide. Detrimental impacts can be vast. We do not know that this is
affecting the Cook Inlet beluga, but we should include it here as a precaution, because it
is an incredible resource to Anchorage.
Qag^aasakung, I thank you for your time & consideration. Together, we can do so much more
than any of us could do alone. Let us move forward by making this the best-designed plan
possible to help us make Anchorage the model of a prosperous northern community who has
succeeded in preserving a healthy, living coastal zone. Please contact me if I may be helpful
with any of the items I have discussed.
Very truly yours,
cc Randy Bates, Acting Director, Department of Natural Resources, OPMP/ACMP