Lynn Canal Conservation, Inc. PO Box 964 Haines, 99827 Phone: 907-766-2295 Fax: 907-766-2295 Email: [email protected] Website: www.lynncanalconservation.org

Regarding Ordinance 17-04-457

Dear Assembly Members,

First, the vote taken by the Tourism Advisory Board and Parks and Recreation Committees in August was improper, if not illegal. Directing the two distinct entities to vote jointly was a political attempt to prevent the Haines Borough from utilizing the standards for managing helicopter supported recreation in mountain goat habitat elsewhere in and should be disregarded. Given the fact that no one in Haines government or the heli-skiing industry has expertise in such management, it makes sense to utilize standards used elsewhere.

The standards of the professional scientific organization Northern Wild Sheep and Goat Council are utilized by the State of Alaska Dept. of Fish & Game, US Bureau of Land Management, the Province of British Columbia and the Province of the Territory. (Wildlife Mitigations report, Sept. 2016, Skeena Region; 3/29 Nass Region AECOM Ltd. Management Document; personal correspondence with Len Vanderstar, Ministry of Forests, Lands and Natural Resource Operations, January 2017 – all documents available upon request). The only exception to use of these standards that we have found is by the US Forest Service in the Chugach. This is because the NWSGC Standards appeared in the same year as the EIS governing the Chugach. Their current standards will incorporate NWSGC standards at the time of the next EIS (Jessica Ilse, USFS Kenai District, pers. correspondence January 2017). The most important requirements are for helicopters to maintain a 1500 meter horizontal distance and 500 meter vertical distance from critical mountain goat winter habitat, and a similar distance for brown bear denning areas. For the Haines Borough to not utilize the same standards as other areas that manage thriving helicopter skiing industries sends a message that the Adventure Capitol of Alaska does not value the exceptional wildlife we are blessed with in our area, and risks causing harm to wildlife populations.

The Haines Borough has been waiting for years for ADF&G maps of critical winter goat habitat and brown bear denning areas. These are now available and map overlays should be placed on the Borough’s heli-ski management map. The Borough should then create a map adding the 1500 meter horizontal distance to mountain goat habitat. Map overlays of proposed map changes should be placed on the map, and all factors considered jointly. Ordinance 17-04-457 needs to include language that requires utilization of the ADF&G habitat maps and Northern Wild Sheep and Goat Council Standards. Note: It may be possible in some areas to utilize terrain features to mask helicopter disturbance and allow greater use of terrain by helicopters. It may also be necessary to increase the horizontal distance to 2,000 meters as is done in some specific areas by the management agencies cited above.

Neither the Alaska Department of Natural Resources nor the US Forest Service manages heliskiing in the Haines Borough and there is no need for comments from those agencies. Agency comments from ADF&G should not be cut off at the time of the first Committee of the Whole meeting on this issue.

Thank you for considering these comments.

Eric Holle Lynn Canal Conservation, Inc.