Comment Response Page 1 of 22 March 2015

Transcription

1 Letter/Comment Comment Response 1A I am concerned about allowing the electric tour boats on Mendenhall Lake and its effect on the nesting gulls and terns....in my opinion the increased number of boats, lack of enforcement, and desire to get close enough for photographs will cause harm to the nesting gulls and terns and may eventually cause them to vacate the area. In addition many of the terns forage for fish along the lake shore and small clearer water inlets. An increase use of boats and tours on the lake may also disrupt this process. I oppose any increase of tour boats on Mendenhall Lake. Increasing commercial use of the lake is not expected to increase impacts on nesting gulls and terns. This plan proposes using the 250 meter buffer guidelines for nesting seabirds included in the Tongass Forest Plan (page 4 93, WILD1 XI A1b), which were designed to minimize adverse effects on nesting birds. MGRA has found that commercial operators are more responsible regarding complying with restrictions on buffer areas around nesting areas than non guided groups. The overall amount of commercial use along the lake shore consists of both visitors accessing the lake proper and the river mouth. The overall commercial allocation for these two uses combined has been lowered in the proposed action. Although some foraging in the lake occurs, most foraging is believed to occur in salt water, such as in the Auke Bay area. The boat tours are not expected to result in more effects on the lake shoreline or clear water inlets, so effects on foraging in the lake shore are expected to be minimal. Again, commercial use is anticipated to have minimal effects on nesting gulls and terns as commercial operators have demonstrated better compliance with required setbacks than non commercial use. 2C You base your tourist industry plans and decisions around cruise ship numbers. If more come each year, you seem to think you have to expand and accommodate those.... if the ship numbers keep increasing, will you always scamper to accommodate thousands more, no matter what the quality of the visits might become? Someone should take the initiative, when necessary, to just say no more.... So many tourist areas are too crowded, but please try to keep in mind that AK is special, mostly because it is not overcrowded...yet. The MGRA was designated as a recreation area for public recreation use. The greatest demand for access to the MGRA occurs during the cruise ship season; the vast majority of visitors to the MGRA over the year are cruise ship visitors. The Forest Service manages the MGRA to provide a variety of recreation services to all visitors. The Forest Service has conducted a capacity analysis for MGRA and the proposed action is within the capacities determined to meet the established standards for MGRA facilities, consistent with ROS classifications, and with resource conditions as noted in the Capacity Analysis on pages B I have been told by various USFS personnel to forget it, don't even apply, that there would be no chance for me to be approved to bring 50 people in a summer. I think that is not right. We have proven to be good stewards in the Tongass for a long time and I think it is unreasonable to disallow us to bring 50 people a summer when there is obviously many many many less environmentally conscious commercial outfitters flooding the trails with large numbers of people only you know [sic]. This EA does not address the allocation of use permits or service days to individual companies. The purpose of the project is to meet visitor demand for commercial services to the extent possible within the capacity of the existing infrastructure and in a manner that protects the natural resources and range of recreational opportunities and experiences called for in the management designations of various areas. 3C 4A 5A The MGRA is the property of the American people. The USFS makes provisions for Americans to see the Tongass on a guided trip. Within reason and given small enough numbers these people on guided trips should be able to see the Mendenhall Glacier. There is only one way I'd like to see electric boats on Mendenhall Lake, if their design engineering and execution are Steampunk. Electric boats: This seems like a "no brainer". What a great place to showcase the use of electric power to preserve the environment, The proposed action would increase the commercial allocation for guided trips on MGRA trails and Mendenhall Lake. Detailed design requirements for commercial electric boat permits are outside the scope of this analysis. Your support of electric boats is acknowledged. 6A I am writing to add my voice in support of limited commercial use of electric boats on Mendenhall Lake. Your support of electric boats is acknowledged. Comment Response Page 1 of 22 March 2015

2 6B 7A I believe that the current size of vessel (20 passenger) under consideration is too small to be economically feasible and to meet the demand of the potential market for the service...i strongly believe that the proposed vessel limitation size of 20 passengers will create unintended negative consequences for the Juneau Ranger District. If the vessel usage is popular there will be a significant number of vessels required to meet demand. Smaller vessels will mean more vessels and more scenic disruptions. Larger vessels as suggested will limit the amount of vessels plying the waters and provide a more aesthetically accommodating experience. Limiting the size to 20 passengers will increase the expense of the experience by failing to create economies of scale that the average visitor can afford. We support Alternative #2 within the Proposed Action Plan for commercial use capacity within the MGRA. Alternative #2 will allow a significant, yet sustainable approach to meet the increased demand of guided recreation within the MGRA, without decreasing the experience that is currently enjoyed by both out of state visitors and Juneau residents. The proposed capacity of visitors as a whole within Alternative #2 appears adequate and reasonable to meet the demand for use within the area. The Mendenhall Lake surface is designated as Semi Primitive Motorized under the Recreation Opportunity Spectrum (Forest Plan, Appendix I, page 3). Under this designation, group sizes are limited to 20. Your support of Alternative 2 is acknowledged. 7B Our position is that motorized vessels should only be permitted for use as a safety vessel, not for guided tours. We feel strongly that allowing any other motorized commercial use on Mendenhall Lake would only serve to detract from the users' experience and should not be permitted. However, if it is ultimately permitted as a commercial activity offered for sale, it will diminish the value of our current tour as the peaceful dynamic of the lake experience will be changed and we will have to look at alternate proposals for lake activity with motorized boats so that we can try to maintain our current business volume. The Forest Service has seen an increasing demand for guided excursions on Mendenhall Lake. The proposed action allows for commercial guided excursions using electric boats for visitors that want to get closer to the glacier. This proposal is designed to address the visitor demand for this type of recreation opportunity and to reduce safety hazards associated with visitors trying to access the lake and glacier on their own when they are not prepared for the difficult conditions that can be encountered on the lake. The proposal increases the variety of lake recreation opportunities available by adding the electric motor boat opportunities; it does not restrict or limit the opportunity for the existing non motorized excursions. The Forest Service acknowledges that this may change the recreation experience for some visitors that are currently enjoying paddling experiences on the lake. 8B Page 14. The 1996 MGRA Management Plan identified the season of commercial use as reflected by the cruise industry and proposes changing to also reflect the cruise industry. As now presented all emphasis is on summer tourism, with strongest emphasis on cruise tourism. Sheer numbers from cruise tourism can overrun everything and cause one to forget that there are other options. A few hundred overnighting commercial visitors in the off season generate much more benefit to the community than a few hundred summer cruise visitors. There can and should be more to commercial use than cruise oriented activities. Small scale winter commercial services (such as proposed below for West Glacier) could enhance Juneau as a winter destination, make us a more attractive capital city during legislative session, and enhance experiences for locals I submitted comments to consider allowing equipment rentals, lessons and/or a mobile snack bar (hopefully operated by a non profit, perhaps the Juneau Nordic Ski Club) to serve the winter users. Why is this idea given no discussion or consideration? It could enhance and expand recreational and business opportunities for locals and support winter tourism in a small way. This lack of consideration of commercial winter services on the West Side is not responsive to the local community and precludes such activity until the next update of the management plan. This is not acceptable. Forest Service policy requires that capacity analysis be conducted when the level of visitor use is such that it could adversely affect physical or social resources or when visitor use demand exceeds facility capacity. It is estimated that over 95% of visitors to MGRA are associated with the cruise ship industry and therefore the cruise ship season is the timeframe that is the focus of the capacity analysis that was completed and this study on commercial allocations. This project addresses the season that has the most demand for commercial use. Since the demand for commercial access is lower in the off season, and off season commercial use demand does not exceed desired conditions for the area, that use can be managed by the Forest Service outside the scope of this project (FSH ). This commercial capacity analysis for the high demand commercial use season does not preclude the Forest Service from considering and allowing commercial uses in the off season if they are deemed to be consistent with the management goals and policies in the Forest Plan and the MGRA management plan. Comment Response Page 2 of 22 March 2015

3 8C The Season of Commercial Use. I repeat my scoping comment objections that this extended season of use as proposed only serves to pad the user days of operators for peak times of year. The shoulder season does not have the same visitor volume as summer. To maintain the quality of experience for the visitors and residents alike, there should be a daily cap for each permit that does not include moving allocations between days. While it is true that the commercial allocations are based on daily averages and that commercial operators do not have to spread the use of their allocation over the entire commercial use period and can instead use less than the daily average in shoulder periods and more of the allocations in the peak period, the proposed commercial allocations are not anticipated to result in unacceptable adverse effects on natural resources or the overall visitor recreation experience. The Forest Service has found that trying to manage commercial use allocations on a daily basis is not feasible and does not allow staff to adjust to changing visitor use and demand characteristics and conditions using adaptive management strategies. Overall, the total commercial allocation for the season being proposed in the Visitor Center Unit (the highest use area) is being held steady at the commercial use level that was identified in the 1996 EIS despite the increase in the length of the commercial use season. 8D Page 18. Regarding the Moraine Ecology Trail. First, three days of monitoring are not adequate to assess use. Secondly, on a day with 385 hikers, it is no wonder that locals were avoiding this trail. Thirdly, I understand that the Moraine Ecology Trail is closed during the bear season and thus I do not attempt to access it in late summer. Was it during this closure that the monitoring found 1 hiker? Is there a flaw in the monitoring that there is such variability? Using an average daily total from three sample points with two extremes creates a nonsensical average. And, commercial use was slightly over the commercial allocation in 2013 state what slightly over is, especially in light of the prior paragraph on monitoring. The same comments apply to other trails mentioned continuing onto page 19. I reference Ken Post s comments dated November 11, 2014 regarding trail use, monitoring, and encounters. The duration of the monitoring conducted on the trails is corrected in the Decision Notice/Errata pages 8 and 9. Monitoring was conducted using an automatic counter which was compared to data collected by an observer recording people to calibrate the counter information. Monitoring was actually conducted for 129 days over a three month period on East Glacier Trail and for 58 days over a two month period on Moraine Ecology Trail. This is a total of 187 days. The Moraine Ecology Trail is not closed during bear season; a portion of the Steep Creek trail is closed. Additional information has been added to the EA via the Decision Notice/Errata (page 8) regarding the use level versus the allocation (13,441 vs 13,000). 8E Page 17. Regarding West Glacier Trail rate of increase (and other places in document where a rate is used), the rate of increase should be translated into absolute numbers as well, as that is what we all experience on the trails. Compounded increases add up. The absolute number has been added into the EA via the Decision Notice/Errata page 8. 8E Further, you report that commercial use of the trail has been increasing at a rate of approximately 3 percent per year over the last five years. One can get different results by picking where one starts.... I expect that the Juneau Ranger District now has final use figures for Perhaps they should be included to start with base year of 2010, rather than introducing the apparent anomalies of Right now as I look from 2010 to 2013 there was an overall increase of 2.8%, or less than 1 percent per year. Around we were experiencing [sic] Given that the cruise industry has reported that we can expect flat growth in the upcoming years, perhaps 1 percent increase in allocation is more appropriate until the Forest Service gets a handle on the true uses of the trails... 8E Given that the cruise industry has reported that we can expect flat growth in the upcoming years, perhaps 1 percent increase in allocation is more appropriate until the Forest Service gets a handle on true uses of the trails (reference to Ken Post s comments dated November 11, 2014). Again, this feels like the padding of numbers. It is true that the rate of change can vary depending on the length of time looked at and a number of other factors. Commercial use on West Glacier Trail in 2014 was 2,623. Adding 2014 data and evaluating the rate of change on West Glacier Trail from 2010 to 2014 still results in an approximately 3% increase annually. Looking at a longer term trend, use has increased by approximately 10% per year from 2005 (when it was 1,655) to The proposed increase in commercial allocation is appropriate given the capacity determination, the longer commercial season and the increased demand for active recreation tours. Comment Response Page 3 of 22 March 2015

4 8F 8G Page 29. Regarding the electric boats you have incorporated part of my scoping recommendation (electric boats) This EA evaluates the potential effects of allocation of commercial use from the proposed levels of use without incorporating the balance which is that this boat operation should be operated as a concession that does in/on each area/facility to determine whether the level of use would have significant impacts. not presell aboard the cruise ships but that would allow any and all to purchase tickets that were not at an inflated Implementing the proposed levels of use is an administrative action undertaken by Forest Service staff price to accommodate the cruise commission and that were open to anyone equally regardless of how they after the level of use is decided. This administrative action (prospectus/permitting) is not subject to NEPA accessed the visitor center, resident or nonresident. I will and do strongly object to allowing electric boats on review. Mendenhall Lake if run as a shore excursion option. The idea is to have a gentle egalitarian footprint that provides access for all. That will be an acceptable addition to traffic on the lake. As a profit center for the cruise industry it is not something that I want to see. I suggest the Forest Service first approach Alaska Geographic to see if they have interest in developing an electric boat service as part of their interpretive services as a cooperating association.... The Forest Service does not have the responsibility to make every option available to every cruise visitor. In fact, it would benefit the Juneau destination tourism if there were clearly opportunities that favored those who come and overnight and spend time in the community rather than just passing through quickly. This would serve the community interest in expanding overnight visitors.... Again, I will oppose and organize opposition to any use of electric or other motorized vessels on the lake to serve commercial shore excursions that are sold onboard the cruise ships. See response to comment 8F above. 8H 8I Further, having any powered boats on Mendenhall Lake is a big change from current management and something that is worthy of having a full and open community discussion rather than a small line tucked within a planning document that most will never read. I expect that generating community opposition will be easy if you proceed from this document to permitting a commercial operator. I find nothing in this document that addresses hours and days of commercial activity. My recollection is that there are some restrictions at this time. The community has been clear in the past that we want to have some days and times when trails around the glacier are not overrun by guided commercial groups. The suggestion to evaluate commercial electric boat tours on Mendenhall Lake was put forward during public scoping. The Forest Service decided to incorporate the concept into the proposed project based on that feedback during scoping. Although the previous management plan included restrictions on days and hours, MGRA staff have found that specifying this level of detail in the management plan does not allow Forest Service staff to use adaptive management to adjust to changes in patterns of visitor use and changing visitor demand for different recreation opportunities. The management plan provides overall direction and policies for resource protection and visitor experiences. The management plan is not updated often and cannot be revised and updated quickly to deal with changing visitor use characteristics and changing natural resource and social conditions whereas special use authorizations can be amended as often as necessary to address changed conditions. MGRA staff need to have flexibility to address changing visitor use characteristics within the higher level parameters and policies set in the management plan. The current proposals for commercial allocations are reasonable and that management of the MGRA under these allocations would still provide opportunities for Juneau residents to use trails during periods of time when guides are not present with clients, such as in the evenings and on days when there are fewer cruise ships in port. In addition, the Dredge Lakes Unit continues to be closed to commercial use and this proposal would remove commercial use from Steep Creek Trail. Thus, there are still times of day and trails that are available for visitors that want to avoid commercial groups. Comment Response Page 4 of 22 March 2015

5 8J There is an issue with tragedy of the commons and some limits are required to protect the experience for everyone (and for the wildlife). The cruise industry decision to bring ever more visitors has resulted in displacement of a welcomed destination tourism industry. The proposed action holds the overall level of commercial allocation in the Visitor Center to the level approved in the 1996 management plan but reallocates this commercial use to allow more of the commercial use to occur as guided excursions on the trails to help disperse visitors in the Visitor Center Unit. This level of use on trails can be managed without adverse effects on recreation experiences and wildlife (EA, page 44). 9A The Juneau Economic Development Council supports the growth of the Juneau visitor industry... We support improvements to the site such as electric transit to reduce congestion, as well as electric motor boats to tour the lake surface and other low carbon operations in the vicinity of the MGRA. This study only sets the overall level of commercial allocations during the commercial use season and does not set any parameters on how those commercial allocations are awarded to various commercial users. Therefore, this document does not restrict smaller destination tourism operators from applying for special use permits to use areas at MGRA. Support for the growth of the tourism industry and for electric boats is acknowledged. Specific requirements associated with transport equipment may be addressed through the prospectus and permitting process. 10B 10C Is there any way to encourage more efficient diesel or hybrid vehicles transporting tourists to and from the MGRA? is there any chance pie will again be sold at the visitor center, especially during the winter? is there any chance subtle architectural details could be added that allow users to do pull ups? Would MGRA consider construction of huts or refuges to aid climbers/hikers or winter mountaineers as an expansion of their offerings? Is there a conceivable future in which a biathlon range could be connected to existing or proposed Nordic ski trails in the MGRA? This project is focused on commercial allocation of visitor use. Specific requirements associated with transport equipment may be addressed through the Forest Service prospectus or special use permitting process. This project is focused on commercial use allocations during the summer commercial season. Infrastructure improvements are outside the scope of this project, and would be better addressed in the upcoming MGRA master plan process. The MGRA is not proposing allowing food sales at the Visitor Center in this project. 11A Gastineau Guiding Company believes that Proposed action alternative number 2 is the best alternative. Your support of Alternative 2 is acknowledged. 12B 12C The reason for a recreational plan is to find balance between large and small scale commercial operators and local residents. In considering the three options presented, we would like to voice our support for alternative 3, an increase in use for the lake and trails. We oppose the introduction of mechanized use on the lake or any restrictions involving mountain biking or running for local users on the trails. Your support of Alternative 3 is acknowledged. Your opposition to motorized use on the lake is acknowledged. The ROS designation on Mendenhall Lake is Semi Primitive Motorized, so motorized uses are consistent with the management guidelines for the area. Providing motorized boat tours on the lake will provide increased and safer recreational opportunities for the increasing number of visitors that want to recreate on the lake and get tours closer to the glacier. This project does not propose changes to allowed or restricted uses on trails. 12D 12E Allowing for guided non mechanized trips such as kayaking will increase the overall safety of the lake....allowing guided use... will dramatically increase the safety on the lake and incidents will decrease because of it....trained guides on the lake will create a safer lake for everybody. Everyone (including the elderly and disabled) should be given an opportunity to view our natural wonders.... It should be pointed out that many trips already exist that enable participants with mobility issues to view glaciers up close. Cruise ships and small boat operators dominate many of the nearby tidewater glaciers. Helicopters and fixed wing planes are conducting daily flightseeing over the ice field. The visitor center is setup to accommodate all ages and abilities, as so to [sic] is the rest of tourism infrastructure in Juneau. Canoes and kayaks are able to comfortably carry any ability passenger with a trained person piloting the vessel, thus negating the need for electric motorboats. Your support for an increase in guided trips on the lake and the potential to decrease safety hazards from unguided use on the lake is acknowledged. The proposal to allow for motorized boat excursions on the lake is not solely intended to provide access for disabled visitors. The proposal to allow for these excursions is designed to provide an additional recreational opportunity for visitors that desire lake recreation and opportunities to get closer to the glacier, but that are not suited for kayak or canoe outings. Comment Response Page 5 of 22 March 2015

6 12F 13B 13C 13D Non mechanized wilderness use areas are becoming more rare as each year passes. The true minority are those who can experience nature without a motorized vessel operating nearby. The Mendenhall Lake is the only location in Juneau where there is no mechanized use allowed. This is an important part of the overall experience and allure: an experience that will be forever changed if electric boats are allowed to operate. No Electric Motor Use on the Lake Surface I appreciate the movement toward a holistic approach to the management of the MGRA that includes emphasis on green sustainable technologies including use of electric vehicles. However, this is not a case of replacing a fossil fuel based use with a more sustainable technology but instead replacing limited muscle powered commercial tours in canoes and kayaks with vessels that area larger scale and more visually impactful from all areas of the lakeshore. These kinds of vessels (pontoon boats?) would also create a much larger footprint while on shore and would most likely lead to additional infrastructure needs such as docks or pilings to reduce shore side impacts. Of particular concern is that the embarkation points for these trips would probably be on the west side of the lake with these larger motorized boats will have significant visual impacts when we are enjoying the views on a summer evening around the campfire at Skater's Cabin or even from the campground. While it is true that existing tours in "war canoes" and in the future possible groups of guided kayakers also have visual impact it would be much smaller than the probably motorized vessels that could handle the passenger volume and winds that kick up on the lake as well as a probable desire for a canopy or other shelter from the wind and rain that are abundant in Juneau. If stipulations were created that would limit the size of proposed motorized vessel's length and width to keep their profile/outline comparable to existing canoes then I would be more supportive. As it stands, I would much prefer to have smaller muscle powered vessels that blend into the stunning glacial landscape. [sic] precentent that would be created. Once this motorized use is authorized it will be more difficult to not allow recreational use of electric boats creating the potential for large numbers of additional users jockeying for position at West Glacier trailhead to get their john boats outfitted with electric trolling motors into the lake for a nice close up look of the glacier face. This of course would be a disaster for maintaining visitor experiences in the area and minimizing impacts to the seabird colony on the rock peninsula. An additional concern with authorizing use of electric motors on the lake is that this authorization would make it difficult to not allow the use of underwater submarines or other drone/rov technologies by members of the public.... One of the few tools the Forest Service currently has available to restrict this potentially damaging activity would be the existing ban on motorized vehicles on/in Mendenhall Lake. Please do not create the precedent that would take away this important management tool for managing Mendenhall Lake. The Forest Service acknowledges that adding motorized boat use on Mendenhall Lake may have adverse effects on some non motorized users due to increased activity on the lake and the change in the type of boats that may be encountered, however it results in positive effects on recreation through providing additional recreation opportunities for most visitors. The ROS designation for the lake is Semi Primitive Motorized (Forest Plan, Appendix I, page 3), so motorized uses are consistent with the management designation for the lake. The Forest Service acknowledges that there may be some adverse effects on non motorized users of the lake due to allowing motorized boats and increasing the allocation for boat tours on the lake. However, these proposed changes increase recreation opportunities and experiences for many visitors. Electric motor boats can be used without additional infrastructure development. If boat operators propose to add new infrastructure, additional environmental review would be required for specific infrastructure proposals. Again, the ROS designation for the lake is Semi Primitive Motorized (Forest Plan, Appendix I, page 3), so motorized uses are consistent with the management designation for the lake. The Forest Service acknowledges that there may be some adverse effects on existing recreation experiences, including changes to the view of the lake, from allowing motorized boats and increasing the allocation for boat tours on the lake (see Decision Notice/Errata page 11). However, these proposed changes increase recreation opportunities and experiences for many visitors. Vessel specifications beyond the requirement for quiet electric motors would be addressed through the Forest Service prospectus or special use permitting process. This project addresses only commercial use that would be authorized via a special use permit. The Forest Service issued a motorized vehicle closure order for MGRA in 1997 (JRD ) that remains in effect. This closure order prohibits motorized use on MGRA trails and lakes unless specifically authorized by a permit. The proposed actions in the EA do not take away any management tools the MGRA has for addressing motorized or commercial uses. 13E Reduce Commercial Allocation on Lake Surface As an MGRA user who also believes in the importance of creating opportunities within the MGRA for commercial visitor products that offer a richer experience for visitors I am glad to see a significant increase in commercial allocations on the lake surface. However, these allocations are too large a leap (2200 to 16,000?) and should be doled out with more restraint. The proposed commercial allocation of 16,240 user days for the commercial use season for Mendenhall Lake results in an average of about 106 commercial visitors per day, between kayaks, canoes, and electric boats. The passenger limit on commercial electric motor boat is 20 people, and so there could be no more than 5 commercial boats per day if all boats were that size and if the entire lake allocation went to that use. It is more likely to be a combination of kayaks, canoes and electric motor boats. The Forest Service conducted a capacity analysis for MGRA and the proposed action is within the capacities determined to meet the established standards for MGRA facilities, consistent with ROS classifications, and with resource conditions as noted in the Capacity Analysis on pages Based on this determination, the lake can accommodate this level of use while maintaining resource protection and quality recreation experiences on and around the lake. Comment Response Page 6 of 22 March 2015

7 13F There is a need for additional analysis on the impacts to Locals and other non guided users whose recreational opportunities and experiences would be negatively impacted while on the lake shore or the lake surface. The need for additional analysis is evident in the Social Resources table on page 34 that only categorizes the impacts of Alternative 2 as positive for visitors because of easier access thanks to increased commercial capacity but ignores the impacts to non guided visitors from this additional commercial use. The table in fact completely ignores the negative impacts to Local's recreational opportunities from increased commercial lake use. The analysis of recreation effects has been revised to more clearly document the potential for adverse effects on the existing local resident recreation experiences from allowing more activity and electric motor boat use on Mendenhall Lake, including the change to views onto the lake (see Decision Notice/Errata, page 11). 13G There is an assumption that increased commercial opportunities for visitors to access the lake surface will satisfy most of the demand of visitors. In fact, getting more visitors on the lake (for example in electric powered boats) is likely to actually increase demand once these folks share their amazing experiences out near the face of a glacier (250 yards)?...the ice cave lesson is that increased exposure whether through photos online or by glossy tour operators brochures or a Facebook posting by a happy cruise ship passenger will only increase demand to access the lake by non commercial visitors. Given this likely scenario the commercial allocation should instead be scaled back to ~8000 to account for this potential increase in other users. About 95% of the visitors to MGRA use commercial transport or commercial tour guide services (Capacity Determination, page 15). The amount of non guided use on the lake and elsewhere at MGRA is very small compared to the level of commercial use and so effects from any potential increase in non guided use would not be expected to result in any substantive effects. 14A I am concerned about adding 20 passenger electric boats to the already heavy summer boat use on Mendenhall Lake. Nesting gulls, terns, other small birds and wildlife are all dependent on the lake edge and lake for their survival in this area.... In my opinion the increased number of boats, the apparent lack of any way to enforce rules, even if they were in place, is why I oppose any increase of tour boats on Mendenhall Lake. There has been an increasing demand for access to lake excursions. Guided excursions often have less adverse effect on nesting birds than non guided visits (EA page 38) and setbacks established in the Tongass Forest Plan (page 4 93, WILD XI A(1b)) will be implemented to help minimize adverse effects on nesting birds. Forest Service staff typically observe nesting colonies during the breeding system to count birds and document breeding success. If adverse effects are seen, permit conditions would be revised to address effects. 15A 15B Please find below my comments regarding the Environmental Assessment of the Mendenhall Glacier Recreation Area Management Plan Revision. With regards to the West Glacier Unit the proposed alternative recommends the Service Days (SDs)on the Tolch Trail be 3,672 or 10% of capacity. I would ask that the SDs be increased to 20% of capacity or 7,344 SDs. The reason I ask for this change is that with the development of the trail from Skaters Cabin to the West Glacier parking lot it would be a great interpretive option for us to take our bike riders down the Tolch Trail. The transition would be easy since the new trail will intersect the Tolch trail. I realize this trail may need work to handle an increase in load but I would be willing to help upgrade it. The one trail that is not mentioned in the Plan is the Bus Parking Trail. This trail again offers us the opportunity take our guests into an area with ideal interpretive opportunities. I would ask that this trail be added into the plan with capacity, SDs, etc. outlined. A 10% allocation to commercial use is appropriate. A higher commercial allocation for trails, including Tolch Rock Trail, was evaluated in Alternative 3. This alternative was not selected as it had greater adverse effects on local resident recreation opportunities and experiences than Alternative 2 (EA, page 34). This analysis is not proposing infrastructure improvements, but evaluating appropriate use levels for existing infrastructure conditions. The spur mentioned is considered part of the Moraine Ecology Trail and falls under the commercial allocation for that trail. 15C As I have mentioned in the past please build flexibility in the plan to recognize that the next revision may be 20 years out and that activities, guided options, etc. may change during that time. This could be done on a case by case revision via unit, trail or total capacity. It may also be worded to allow the District Ranger to increase overall capacity by a certain amount depending on the upgrading of infrastructure. A great example of this would be the Visitor Center Unit when it is expanded. 16A We have concerns that the proposed Environmental Assessment (EA) for the Mendenhall Glacier Recreation Area (MGRA) Management Plan Revision, Commercial Outfitter and Transporter project will have negative impacts on our organization's ability to provide our guests the opportunity to visit this public attraction. The proposed current solution is to stifle growth potential instead of fixing issues associated with capacity. This project addresses only the commercial allocation of visitor use based on the recent capacity determination by the Forest Service. As future infrastructure improvements occur, the Forest Service would evaluate and amend the capacity analysis to reflect those changes. As stated in the EA, the existing visitor infrastructure in the Visitor Center area is currently near capacity. Given that, the Forest Service can not increase the overall commercial use allocations in the Visitor Center Unit. The Forest Service is proposing to start a Visitor Center Master Plan process in the near future which could result in infrastructure improvements that would increase the overall capacity in the future, allowing for increases in commercial use allocations. Comment Response Page 7 of 22 March 2015

8 16B With regards to the baseline for the visitor's center, we recommend using 2014 which is more in line with current passenger volume. The estimated volume for 2014 is 418,000 for transport. This number is expected to increase in 2015 due to larger ship capacities. We suggest establishing the capacity for 2016 and beyond for transport at least 440,000 which represents an annual increase of 3.5% per year from 2014 actuals. This percentage matches the annual increase from 2013 to As stated in the EA, the existing visitor infrastructure in the Visitor Center area is currently near capacity. Given that, the Forest Service can not increase the overall commercial use allocations in the Visitor Center Unit. The Forest Service is proposing to start a Visitor Center Master Plan process in the near future which could result in infrastructure improvements that would increase the overall capacity in the future, allowing for increases in commercial use allocations. 16C 16D Increasing guided trail and lake use capacity is a good idea because there appears to be demand for it. Making the general assumption that doing so would automatically take away from transport numbers isn't correct as many of these tour programs do not include the visitor's center. We suggest using the 2015 and 2016 seasons to track usage of these two uses to see how they increase or decrease versus the overall visitor mix. From these findings a fact based equation can be developed to allocate these use categories. As described in the Capacity Determination document and the EA, it is the core portion of the Visitor Center Unit that is currently at capacity. The proposed action holds the commercial allocation overall at the level established in the 1996 management plan but increases the commercial allocation on trails to help disperse visitors away from the core area. Future proposed changes to visitor infrastructure in the Visitor Center unit could increase capacity in this area, allowing commercial allocations to increase in the future. Please note that our Juneau HAP Division has taken serious steps to address these issues in past seasons and is Comment acknowledged. The Forest Service appreciates the willingness to work with MGRA staff to open to considering other measures to include the following: continue to implement measures that can help address crowding in the core of the Visitor Center Unit. Micromanaging routing to spread out our fleet throughout the day to the extent we can. Promoting more tours that spend 2+ hours at Mendenhall so guests can utilize more of the area and not feel compelled to add to bottle neck situations that shorter stays create. Schedule tours within tours to minimize the number of coaches accessing the area (Driver who drops off a group would immediately pick up an earlier group without staging). Continue to work with our parent Cruise Lines to combine excursions where possible resulting in fuller, but fewer buses accessing the glacier area. Possibly look at more tours in 2016 that have "visitor center not included" in their descriptions with the assumption that only a small percentage of guests will try to access the center on their own vs most of them that currently pay for it up front. This may get more guests out on the trails, and fewer guests in the center. The result would be less revenue for the Center, but worth considering if it eases congestion. Search out alternative venues to offer in lieu of the Mendenhall Glacier. We redesigned the staging parking lot in 2014 to allow for better flow in that area and less congestion coming out to the street. Other Operators bought into this, and the USFS agreed with our changes. Historically, we have talked with local USFS staff about congestion and accessibility at the area. However, there have not been many solutions or changes made. A few years ago a third party contractor was brought in to study traffic access and they came up with an "intelligent traffic system" that we were on record stating was too elaborate for the need, and wouldn't solve the problem. It was installed anyway at a hefty cost and hasn't worked as we predicted it is not in use today. We are in favor of working with the USFS on a long term solution to this issue and agree that ideas such as a transportation plaza and tram system warrant research and consideration. We would also like to potentially see the Visitor Center fee extended from the building to the entire corridor because those funds should stay with the local district, could be expanded by impacting all Operators, and solutions to the access problem could be funded based on direct impact and use. Comment Response Page 8 of 22 March 2015

9 16E We agree that a review of the access to the Mendenhall Glacier Recreation Area must be completed so a proper long term solution can be developed. The cruise/visitor industry has grown over the past 20 years, yet access to the area hasn't. This has lead us to developing alternative venues for guests to visit that don't include Mendenhall. However, the Mendenhall Glacier remains the top attraction to guests visiting Juneau. HAP took 201,617 our of an estimated 418,000 guests to the Mendenhall this year, so we feel we have a great stake in this issue and seek a valid solution. HAP has paid $495,792 towards Visitor Center fees in 2014 and an additional $322,587 in general outfitter guide fees to access the Tongass quite an investment on an annual basis. Cutting capacity would not only impact our business, but that of every local operator we work with including the USFS. The high demand for access to the MGRA is acknowledged. The Forest Service is proposing to begin a Visitor Center Master Plan process to evaluate the potential to improve infrastructure such that visitor capacity may increase. The current analysis, however, is based on existing infrastructure which is currently at capacity. Therefore, the Forest Service can not increase the overall commercial allocation for the Visitor Center Unit at this time, and is attempting to disperse visitors more to reduce crowding in the core area. An acknowledgment of the potential for this change to adversely affect some commercial operations has been added in Decision Notice/Errata page A I would like to register comments in support for electrical vessel transportation and electrical vessel visitation to the Mendenhall Glacier via Mendenhall Lake. There would appear to visitor demand, need and justification for the use of electrical vessels on Mendenhall Lake to provide that up close experience that is no longer naturally available and diminishing. Your support for electric motor vessels is acknowledged. 17B...The proposed Environmental Assessment wisely recognizes that our local "national asset" is disappearing and that electrical vessel operation on Mendenhall Lake can assist in preserving the unique visitor experience that many local citizens take for granted. Therefore I find myself in agreement with the electrical vessel use at the Mendenhall Glacier visitor area and on Mendenhall Lake. However, I would like to make the following additional and specific comments related to vessel use on Mendenhall Lake: The USFS should only permit USCG approved vessels with handicap access to the vessel, Vessels should be of modern electric vessel technology including a sleek exterior design that is aesthetically pleasing to passenger and to non passenger observers... Propulsion systems should be safe and have access to adequate power and quick chargers to ensure that stranding cannot occur... Boats should be silent as not to disturb wildlife, birds or create a nuisance. This EA addresses the commercial allocation of visitor use and the allowance of electric vessels on the lake. Specific requirements for the vessels would be developed by the Forest Service through the prospectus or special use permitting process. Commercial boat operators would be required to comply with U.S.C.G. licensing requirements. Commercial boat operators would need to use quiet electric motors and observe buffer areas as documented in the EA (page 29). Vessels should provide safe and comfortable visiting experience that is acceptable for all ages from minors to our most senior of citizens. Vessels should have an enclosed cabin for inclement weather and heated on days when temperatures are below 69 degrees. Vessels should be equipped with video (HD) Screen safety briefing that provides visual instruction for life vests, preservers, and safety information. Video system could also provide historical, cultural, geological and climate change information related to the Mendenhall Glacier to improve the visitor experience, but such system would ensure that safety briefings occur every voyage. Vessels should be built and able to assist distressed Kayakers if a kayaker emergency should exist.... Electrical vessel design should provide for deck, step or other design infrastructure to facilitate man overboard mishaps or distressed kayakers. Mendenhall Lake and vessel use should be limited to shallow draft vessels so that any potential dock system would require less extensive lake bottom and water environmental disturbance that would be required for deeper draft vessels. The shoreline of the Glacier is shallow and vessel dock system should conform to the natural environment rather than vice versa. One bathroom on vessel or within 150 feet from dock. The current bathroom protocol and location is unacceptable for vessel visitor use. See response above. No infrastructure improvements (such as docks) are authorized under this project. If new infrastructure is required, additional environmental review would need to occur. Comment Response Page 9 of 22 March 2015

10 17C Vessel size use should be increased to 48 persons (crew and passengers). The proposed vessel limitation size of 20 passengers will create unintended negative consequences.... A larger 48 passenger vessel provides marginally increased safety during windy days and provides a safer more comfortable experience for the visiting public. Mendenhall Lake is designated Semi Primitive Non Motorized under the ROS guidelines. Group sizes are limited to 20 persons in this ROS designation. 17D 18A 19A 20A The USFS should provide access to adequate power to high speed recharge batteries (level 3 recharging) to ensure that vessels can meet demand and be available for emergency response on Mendenhall Lake during the visitor season. We support the use of clean, quiet electric vessel and vehicle use at the Mendenhall Glacier visitor center. The US Forest Service can provide a quieter and cleaner environment by encouraging electrical vehicle and bus use by providing access to electrical chargers and by encouraging electrical vessel usage on Mendenhall Lake. This EA addresses the commercial allocation of visitor use and the allowance of electric vessels on the lake. Specific requirements for the vessels would be developed by the Forest Service through the prospectus or special use permitting process. Commercial boat operators would be required to comply with U.S.C.G. licensing requirements. Your support for electric motor vessels is acknowledged. I am a Juneau resident that is in full support of the electric board initiative at the mendenhall glacier visitors Your support for electric motor vessels is acknowledged. center. I believe this is a first step in the right direction toward adopting electric transportation in the area The changes purposed in the MGRA are to help relieve some of the over crowding at the visitors center by The Forest Service requires commercial permit holders to report use and does periodic monitoring of trail spreading out the use of the various trails and resources and to increase the visitor experience at the same time to use. MGRA staff are on site every day during the commercial season and make observations on trail preserve the fragile Eco system that has drawn the millions of visitors to Juneau. Their [sic] has been a lot of talk conditions and natural resource conditions. These methods are appropriate and adequate for managing on the use of the trails but little talk on how to implement this.their [sic] is technology that could be used to do commercial use levels. this like installing cameras in high use areas that could be a accessed from a smart phone, this would give FS personal [sic] real time info to increase traffic flow and visitor safety, these cams could placed were they could not be detected. 20C It has been said that the MGRA belongs to all the people of the US and that everyone should have the same opportunity to enjoy this vary [sic] diverse place. When it is said that everyone should have this opportunity, that would include the people that live in Juneau also. Their [sic] have been comments from people saying that thy do not even go to the Glacier in the summer do [sic] to all the people and buses at the Glacier and the thousands of people that are on the trails all day 7 days a weak [sic]. The MGRA has turned into a giant business for tour operator's [sic] to make a lot of money with little regard for the people who live here. One thing that could be done is to set times that commercial operations can be run, allowing tour operators to run tours late into evening does not give the local people a chance to enjoy all that the MGRA has to offer. I have seen tour operators running until after 8,30pm... The EA acknowledges that increasing use on trails at MGRA may adversely affect the recreation experience for some visitors and some local residents. The overall commercial allocation for the Visitor Center is not proposed to increase, but more of the commercial allocation is assigned to trails to help disperse visitors from the most crowded areas. Specific operational restrictions would be addressed as needed through prospectuses or special use permit conditions. Comment Response Page 10 of 22 March 2015