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Summary Public Comments Folder Commenter Contact Email Contact Address Comment Tally Notes Retain Repeal PWC PWC Ban Ban Other 1 Friends of mako haggerty 95 Sterling Dear Mr.Green Kachemak Bay <[email protected]> Highway, Suite Friends of Kachemak Bay State Park opposes the lifting of the Personal Water Craft (PWC) ban in Kachemak Bay. State Park 2, Homer, Alaska We have heard arguments for and against PWCs for the last 20 years and there has been no new information that has changed 99603 our view that PWCs disturb wildlife and upset the general Park experience. We understand that you have received many letters and emails in strong opposition to the lifting of the ban. There is little more that we can add. Please register our voices in the "NO” column. Respectfully, Mako Haggerty, chair Friends of Kachemak Bay State Park is a local non-profit whose mission includes educating Park visitors and supporting Park volunteers. Our current membership stands at 107. 1 organization 1 Audubon Alaska Culliney, Susan Audubon Alaska See message: Audubon Alaska comments on proposed repeal of 5 AAC 95.310.msg in PWC1 <Susan.Culliney@audu 431 W. 7th Ave. bon.org> Anchorage, AK 99501 1 organization 1 Center for Elizabeth Trowbridge 708 Smokey Bay January 21, 2020 Alaskan Coastal <[email protected] Way, Homer, To: Commissioner Doug Vincent-Lang, Alaska Department of Fish and Game Studies >, Alaska 99603 Cc: Rick Green, Alaska Department of Fish and Game beth@akcoastalstudies On behalf of the Center for Alaskan Coastal Studies (CACS), I am writing in opposition to any change to 5 AAC 95.310, with .org regards to the prohibition of the use of personal watercraft in the Fox River Flats and Kachemak Bay Critical Habitat Areas (CHA). We strongly oppose any change that would allow personal watercraft use and management in this critically important habitat for marine life. CACS is a non-profit organization dedicated to promoting marine and coastal education and stewardship of Kachemak Bay through place-based ecology education. We were formed in 1982 because of the recognition of our unique and special environment and the need to educate about and stewards this amazing habitat. Our mission is to foster responsible interactions with our natural surroundings and to generate knowledge about the coastal and marine ecosystems of Kachemak Bay through science-based environmental education and stewardship. We believe the conservation of our coastal marine habitat allows people to enjoy a sustainable lifestyle based on a healthy ocean. CACS educational and citizen science programs are designed to provide highly effective experiential education opportunities and model environmental stewardship. They are designed to engage people of all ages and use appropriate methods of delivery aimed at increasing our understanding about the necessity and means to sustain the health and productivity of local environments. Many of our programs provide the opportunity to participate directly in stewardship activities. We host over 1,000 elementary aged students for a 2 night, 3 day Alaska Coastal Ecology program at our Peterson Bay Field Station each year, and have been doing this since 1982. The noise and disruption of habitat that the use of PWCs in this area (and other areas of Kachemak Bay) would be detrimental to the quality of the educational outdoor experience for these students. Many activities involve making a personal connection to the environment as well as time out exploring the tidepools. During the summer we host college groups, youth for residential camps and visitors to Homer and Kachemak Bay. These participants are seeking special outdoor experiences. Having PWC use irt the bay would reduce the number of birds and marine life that could be seen, and would add unnecessary noise to an area that is known for peacefulness and quietness. • The science clearly shows Jetskis and PW C's are NOT compatible with the purpose of the Kachemak Bay & Fox River Flats Critical Habitat to protect fish and wildlife, including a recent 2019 National Park Service EIS, a detailed 2017 literature review bv ADF&G, and in the opinion of ADF&G's own staff experts 1 organization O 99% f Al k J ki h i l l f K h k f h d f 1 Kris Holderied Kris Holderied I appreciate the opportunity to comment on the proposed change by the Alaska Department of Fish and Game (ADFG) to 5 <[email protected] AAC 95.310, dealing with the prohibition of the use of personal watercraft in the Fox River and Kachemak Bay state-designated m> Critical Habitat Areas. As a resident of Homer, AK in the Kachemak Bay region, I’m writing to express my opposition to the proposal by the Alaska Department of Fish and Game (ADFG) to repeal the regulation because use of personal water craft is incompatible with the purpose of these critical habitat areas to protect and preserve habitat areas especially crucial to the perpetuation of fish and wildlife. I have had the opportunity in the past year to review updates to the state management plans for the Fox River and Kachemak Bay CHAs (ADFG) and the Kachemak Bay State Park, including policies on use of personal water craft. While the proposed CHA management plan does not have a policy for personal water craft use (since personal water craft use was prohibited in the critical habitat areas under 5 AAC 95.310), the issue received a lot of attention because of the importance of personal water craft use and impacts to multiple public users. Based on concerns for the potential of PWC traffic to decrease populations of fish, wildlife and birds, I agree with the recommendation to maintain regulations under 5 AAC 95.310 and continue to prohibit use of PWCs in Kachemak Bay. My primary concern is that personal water craft traffic is more likely to routinely and repeatedly occur in nearshore and shallow waters than other small boat traffic, because of the shallow draft and nature of personal water craft use. The Kachemak Bay and Fox River Flats Critical Habitat Areas have extensive nearshore areas which support high concentrations of marine mammals, fish, seabirds, shorebirds and waterfowl. This creates the potential for increased, adverse impacts on multiple marine species within the critical habitat areas from personal water craft traffic, particularly if water craft are operated for extended periods of time in one area. I also recognize that the ability to evaluate potential impacts from personal water craft use is limited by the lack of information on how these water craft may be used in the critical habitat areas, since their use has been limited in the bay since 2001 under 5 AAC 95.310. A survey of personal water craft users and industry to gain information on potential uses within Kachemak Bay is one way that ADFG could obtain information needed to evaluate trade-offs between public recreation access with personal water craft and adverse impacts to fish, wildlife and bird populations that the critical habitat areas were designated to protect. 1 1 Laurie Daniel Laurie Daniel PO Box 3713 Dear Commissionerl h ld b Vincent-Lang, January b d f 21, 2020 l b h d f <lauriedanieltnc@hot Homer, AK 99603 mail.com> I submit these comments in opposition to the Dunleavy administration interest to repeal the ban on personal watercraft (PWC aka jet skis) in Kachemak Bay. As you well know, ADF&G established the Kachemak Bay and Fox River Flats Critical Habitat Areas (CHA) in 1974 (AS 16.20.590) and 1972 (AS 16.20.580), respectively. The purpose of these CHAs is to “protect and preserve habitat areas especially crucial to the perpetuation of fish and wildlife and to restrict all other uses not compatible with that primary purpose”. To that end, and after extensive public involvement, in 2001 the state enacted and has since then repeatedly upheld (2011, 2016-17) the ban on PWC in the Kachemak Bay and Fox River Flats CHAs. The science (observations, studies and published literature) clearly indicate that the use of PWCs in these waters is inappropriate and risks damaging the protected coastal habitat and therefore their use is not compatible with the purpose of the Kachemak Bay and Fox River Flats CHAs. This includes a 2019 National Park Service EIS, a detailed 2017 literature review by ADF&G, and the opinion of ADF&G’s staff experts. Further, in 2017, ADF&G concluded in a written memo: “In summary, based on our review of information available since the PWC prohibition was adopted in 2001, we feel there is no new information that would warrant rescinding the prohibition, and in fact the newer information highlights most of the concerns identified when the prohibition was adopted.” (emphasis added). The clearly evident special interest in this action by Gov Dunleavy flies in the face of governing public resources through the accepted and expected public process we rely on to manage our state. There appears no documentation of consultation with the biologists and management staff who are in the best position to evaluate the impact of, and disturbance from, PWCs on the habitats, fish and wildlife that occur within the CHAs and for whom these protected areas were established. The unique natural and ecological values of Kachemak Bay draws many thousands of tourists, as well as other Alaskans, to visit the area, which significantly drives the local economy. Alaskans have strongly and publicly supported the ban, both when it was established and again when it’s been under review. It is simply bad governance, and very apathetic, to single-handedly try to reverse decades of work that protects commonly-held natural resources for the benefit of all to instead benefit a small special interest group that would damage those resources in practicing their recreational activity.
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