We, Ahtna, Inc., with the approval of Native Village of Cantwell, would like to see access to hunting areas be kept open on State lands, and use of All Terrain Vehicles (ATV) off of designated trails, during the moose and caribou hunting season.

We, Ahtna, Inc., with the approval of Native Village of Cantwell, would like to see alternative energy developments be planned for and implemented by the State of Alaska. The cost of fuel and electricity is a major expense in the rural areas. The State of Alaska must take the lead on promoting and developing alternative energy on State lands as well as on private lands.

We, Ahtna, Inc. and Native Village of Cantwell, would like to see the Unit 20A Moose hunt closed, and access on private lands protected from the public. We have tremendous problems with trespass on Ahtna, Inc. lands, and would like to see the State of Alaska promote protections of private lands.

We, Ahtna, Inc., with the approval of Native Village of Cantwell, are opposed to Agriculture and Settlement development as this will conflict with areas for hunting and fishing in the Kantishna areas and along the Parks Highway.

Ahtna, Inc. does not acknowledge RS2477, nor does it support RS24477 for Public Access on State lands or private lands.

We, Ahtna Inc., also object to the State's Standard Buffer Width on side of a stream to be 100-200 ft. on each bank of a stream that affects private property.

We worked closely with the State of Alaska during the recently completed amendment process to the Tanana Basin Area Plan, a process that enabled the Denali Borough to select additional lands to satisfy its legal land entitlement. At that time we recommended that the state retain approximately 4,900 acres in state ownership, not changing their original designations as Wildlife Habitat or Wildlife Habitat/Public Recreation. Our comments were submitted to Merry Johnson on July 31, 2008, and are available upon request.

We felt at the time, and feel now, that public lands immediately adjacent to Denali National Park should not be reviewed for changes that would alter their primary uses as designated in the TBAP. The state of Alaska agreed with most of our recommendations at the time. With this in mind, DCC requests that the revised TBAP/YTAP incorporate decisions made in the 2009 TBAP amendment. An exhaustive public process was conducted as part of this amendment, and repeating the process for these controversial parcels in the Panguingue Creek, Otto Lake, and Nenana Canyon areas would not be a good use of either the public's time or DNR staff time and energy. Please refer to the public record on the TBAP amendment for details. We are particularly concerned that lands in these areas classified for protection of wildlife habitat retain this classification.

We hope to be involved as more detail emerges regarding the YTAP revision process. With thanks for the opportunity to comment, DCC President Nancy Bale

Please keep our Community Organizer informed of this process, at mail@denalicitizens.org, in addition to myself at nancy@denalicitizens.org

Also we use state land for recreation - wilderness trekking, picnics, dog sledding, horseback riding, etc., which again means it must be open to public use.

How would you like to see state lands used? As public-use lands for the activities listed above. In this area the State has locked up so much land (as private & Mental Health) that people often trespass while continuing the daily routine activities that have been going on since before Statehood.

What issues, if any, do you have with the current uses or management of state lands? Too much private & Mental Health lands is making it hard to continue these activities. More land should be set aside for subsistence, especially within 20 miles of villages.

DNR needs to follow up its land sales to determine the impacts, & should work with communities on long-term growth projections so we can better plan for orderly developement. This has been a big problem after 1980s land sales around here.

Any other comments? DNR would do well to take local needs into consideration & give weight to the preferences of villages. Some villages want more land sales to boost the economy, some want less to protect subsistence. Locals are also familiar with critical habitat & resources that need protecting, as well as good sites for public works such as schools, runways, gravel pits, land fills, springs, etc. DNR has been inconsistent in communicating its plans to us.

Our greatest concern is that you protect natural resources that are used by the public, especially areas used for wood lots, berry picking, hunting and trapping.

General comments:

A plan that projects estimated land sales in each area over the long-term (10 to 20 years) is necessary for local villages to plan for orderly development. As you will see if you manage to wade through this thesis, selling land near a small village puts great pressure on any existing government to manage the needs and problems of newcomers. It is logistically difficult and psychologically shocking every time another land sale in our area is suddenly announced. Having a firm plan in place will allow us to anticipate future needs and grow in a more responsible way.

The impact of cumulative land sales must be studied. During your April meeting at Lake Minchumina, we got the impression that DNR does not follow up on what happens to the land that it sells. It doesn't seem possible to develop an orderly, intelligent plan for the future without knowing the consequences of your past sales. What percentage of the parcels have been developed? Are they still being used? What percentage was never developed, or appears abandoned? Have covenants such as green belts been respected? Are other DNR restrictions (such as required development, or restricted commercial uses) being adhered to? Are easements respected and used appropriately? Is the land respected? That is, are human-caused wildfires an increasing problem; is timber and other resource harvest excessive both on and off-parcel; are there abandoned buildings, numerous dump sites, areas of toxic waste, run-off issues etc? Is there friction between landowners, especially in regards to local resources, which you might address by offering more widely scattered parcels? How have the land sales impacted long-time locals, traditional land uses, wildlife, and habitat? How have these sales affected local and state economies? Are parcels being used for commercial purposes? Is the economic investment offset by the economic benefits, considering the espense of offering lots, providing emergency services such as fire suppression or trooper protection, and other costs,? Are some areas being developed to the point where landowners need to organize as communities, and are they doing so in an orderly way?

Since I assume you do not have the budget for long-term follow-up of the many impacts of your land sales, this is something you need to request from the legislature. It is ridiculous to distribute this much land without knowing the long-term impacts (good and bad), and irresponsible of the State to neglect this important consideration.

When planning land sales, DNR should consider more carefully the future needs of new and existing residents.

Over the long term, DNR has been rather careless in not protecting local resources from damage or over-use when new landowners come with little local knowledge and add a cumulative consumptive impact to the local resources. Perhaps the best example of this neglect is the problem of woodlots. According to UAF, it takes 30 acres of good woodland to provide a continuing supply of firewood for a single-family home. (See the enclosed reference #1.) This means that if you don't set aside 5,000 acres of decent woodland for every 100 homesites, landowners will over-harvest forest resources trying to heat their homes. Otherwise, in addition to being detrimental to the forests and habitat, it pressures people into harvesting low-quality firewood from sensitive habitat (like black spruce) or cutting wood from protected or inappropriate lands including parks, green belts or undeveloped private property including native or Mental-Health property.

Furbearer habitat and existing traplines have not been adequately protected. With the rural economy in its current ragged condition, it doesn't make sense to cut up valuable furbearer habitat into rarely-used private recreational parcels when this eliminates economically viable and beneficial traplines that may be a primary source of income for local residents. An effort must be made to identify traplines, especially historic lines that have been used for decades, and protect them and the furbearers with an easement of several miles to protect the habitat. Other critical resources that may be over-harvested when too many lots are concentrated in one area include cabin logs, fish and game, gravel, sand, berries and other wild edibles. These must be identified with the help of locals, and protected from development.

Case Example, Lake Minchumina. Being intimately familiar with this area, we can see by the impacts of past land sales that better planning must be done before a land sale, as well as government follow-up to mitigate problems resulting from the sales. Several land sales during the 1980s produced numerous long-terms consequences.

Of all the parcels disposed of in this area, the majority have never been developed. Most of those that were developed have subsequently either been abandoned completely or are rarely used. A small minority are used for a few days each year. A couple are used seasonally. Only one has been used full-time. Some of the undeveloped lots have been encroached upon by neighboring landowners. Abandoned shacks blight the area and reduce land values. The only long-term homeowner developed a wilderness lodge that boosted the economy but reduced our quiet quality of life with its constant intense activity. The lodge began to fail after 9/11 and is now basically closed.

The failure to provide adequate woodlots in the Lake Minchumina area has resulted in some homeowners harvesting firewood and logs on Mental Health land. With most of the lakeshore now private or Mental Health lands, we must either trespass or restrict other subsistence activities including berry-picking, hunting and trapping.

In response to imminent land sales in the 1980s, the scattered area residents felt compelled to organize a community government to assure orderly development. Considering its small size, the local community has proved remarkably responsible in fulfilling its civic duties. Understandably, part-time and vacation landowners find it hard to dedicate their time on public service such as trail-brushing and clean-up. In other areas where concentrations of homesites make local government necessary, it might be more difficult to find adequate volunteers because so many people move to the bush to get away from all that.

For the first 5 to 8 years after the land sales, Lake Minchumina saw a steady rise in population as new landowners arrived. The number of residents had nearly doubled by the early 1990s. In response, this community made a major effort to accommodate the larger population. A school and landfill was critically important, but neither the state nor the federal government had thought to set aside public-use land when classifying their holdings. All suitable sites were tied up as FAA (runway), Mental Health, private property, etc. It took an Act of Congress to transfer land to the school district for the school when a bit of foresight on the part of State planners could have avoided burdening both Congress and community planners. The local volunteer government also succeeded in having the runway upgraded and the local trail system expanded.

Most of the newcomers were financially unsuccessful. By the late 90s the school was closed for lack of students. The handful of people remaining in the community today cannot keep up with maintenance of the new trails, and we struggle to keep up with the landfill. We almost lost our Post Office. A few dedicated volunteers turned the school into a library/community center but it is at the mercy of the school-district landowner. Air service went from 6 days a week to one (unreliable) day a week. There is only a single remaining full-time resident on any of the DNR lots.

Aside from government jobs, trapping has been the only viable long-term source of income. After the land sales of the 1980s, most of the newcomers who stuck it out began to trap. The area within a radius of 50 miles of Lake Minchumina was already regularly trapped, and the new trappers were able to obtain traplines only because several old-timers were retiring and selling out. (Severe conflicts have occurred between trappers in the past and could occur again if newcomers did not respect local trappers' lines.) One of the newcomers to the DNR sales began running dog-team expeditions for tourists out a local trapline trail which also caused conflicts until the business failed. Today, only one seasonal family that bought state land still traps.

Overharvesting of certain resources in this area has always been a problem. Home builders have traveled 20 miles by boat or snow machine to find decent cabin logs. When the price of beaver pelts spiked in the 1960s, a mere handful of local trappers decimated local beaver populations. Moose have also declined when heavily hunted in this area.

When new landowners moved into the area, they often maintained dog teams, which are extremely expensive if not fed locally-caught whitefish. This can deplete the fish supply, which is already dwindling. (Whitefish also crashed here during the 1930s fur-farm boom.) The last of those dog teams was dispersed this year due to economic pressures. Another influx of landowners would likely see the cycle start anew.

Land and the Subsistence Way of Life

Many people who purchase DNR lands in the bush want a vacation home, but people with roots dating back 20, 50, or more years have a much deeper connection to the land. The subsistence way of life requires vast areas of undeveloped land for harvesting furbearers, game, berries, building materials and other resources. My sister and I have lived at Lake Minchumina since birth and we range over a thousand square miles gathering supplies. We travel up to 20 miles for berries and moose, 40 miles for furs, 12 miles for logs, 5 miles for fish-net sites, 1 mile for moss or sod, and 1/2 mile for firewood. With the bush economy collapsing statewide, it behooves the state to protect all it can of the subsistence way of life so that villages can survive this depression. This means permanently setting aside large areas critical to subsistence, especially woodlots, big-game and fur-bearer habitat, and berry patches. This should have been done before any land sales took place, and the sooner it is done the better. It is ironic that subsistence harvest is more likely to continue within the boundaries of Denali Park additions than on state land that is rapidly being privatized.

Attached please find reference #2, with depict critical subsistence areas around Lake Minchumina. These areas should be protected. Areas marked on Mental Health lands are critical areas that the state should have protected rather than transferring it to an institution whose sole reason for disbursing land is to make money. Mental Health should not be responsible for community development, but as major land-owners they should be considering the public consequences when they sell property.

When planning its land sales, DNR needs to consider the ongoing needs of new and existing landowners. Because DNR is mandated to sell so much land every year, some areas of prime land will inevitably become saturated with private property. DNR needs to take steps to avoid problems such as those encountered by the community of Lake Minchumina. This means DNR should consider where communities might emerge from clustered land sales, and provide public lands for future needs such as schools, community centers, landfills, powerplants, health clinics, law enforcement, sewage treatment facilities, recreation, boat landings, etc, not to mention potential routes for interties, connecting roads, or runways if population centers might some day require this. Unless DNR carefully protects land for these purposes, future communities will be saddled with the same headaches that Lake Minchumina has suffered. And again, DNR must set aside suitable woodlot areas accessible by all landowners, new and old.

Finally, when planning land sales, DNR needs to give considerable weight to local input because:

1. Locals know where good land, springs, habitat, and other natural resources are; they know which land to sell and which to protect.

2. Some villages are struggling to survive and WANT more people moving in; others are more interested in protecting lifestyle and subsistence by classifying the land as habitat and wood lot.

3. Locals know whether previous area land sales were successful (ie, the land is being used and enjoyed, not ignored yet unavailable for public use).

4. Locals are familiar with access and transportation issues and often have plans in place for orderly development, that might be tripped up by unexpected or inappropriate sales.

Thank-you sincerely for considering our many concerns. We apologize for the length of this letter, but the impact of your past actions on this community demands that we are thorough in comments that might directly affect our future.

Enclosures: Ref. 1, UAF document on sustainable wood lot size; Ref. 2, map documenting critical subsistence lands near Lake Minchumina

The Nenana River is very important to paddlesports enthusiasts, and draws people from all over the world. Having access to the river is very important. Currently, there is access to the Nenana River at the following points that I know of:

Denali Hwy. (approxiimately 18 miles east of Cantwell) Windy Bridge (north of Cantwell) Slime Creek/Panorama Peak area north of the Windy Bridge The area just south of Carlo Creek McKinley Village Parks Hwy. bridge just S of Glitter Gulch, and Kingfisher Creek access Two-Rock Rapid area (just north of Glitter Gulch) Healy Ferry Rex Bridge Anderson Nenana

It is important to keep all these access points and not let development close any of them off. In particular the public access at McKinley Village has been seriously threatened several times over the last couple of decades (I understand by people wanting to build hotels or restaurants on the site). This is a very important access point and needs to be kept open to the public. I am not sure of the status of the access at the Parks Highway bridge just south of Glitter Gulch. This site is an important alternative to the Kingfisher Creek landing which is small and very steep and heavily used by the commercial rafting companies. It would be very nice to be able to access the river from the south side of that bridge, but I suppose that land is under the control of the National Park Service. Access at the Rex Bridge, or at least parking at that access, is pretty much at the mercy of the owner of the gift shop and campground there. This has worked well with the current owner, but it would be nice to have a larger dedicated access point there.

As an aside, I really appreciate DNR's decision to remove the commercial jet-boat operation lease from Brushkasna Creek and replace it with one farther upstream. It is really nice for the canoeing public to have free access to camping at Brushkasna Creek again. Thanks for giving that site back to private citizens!

HIking trails that I have used in this area include the informal trails up ridges adjacent to Bison Gulch and Antler Creek south of Healy. I hope these trails can be dedicated and not blocked by future development. I have also skijored on the Yanert Valley trail. This trail gets heavy use from a wide variety of users. I hope it, as well as the trail up Dean Creek into the Wood River valley, is already dedicated.

Many years ago I have hunted sheep on Mt. Fellows and would like to see the capability for such activities continue into the future. I'm not sure now if that is DNR land or Ahtna land.

Campgrounds: There are no state-maintained public campgrounds on the Parks Hwy. north of Byers Lake that I know of. The closest non-NPS campground to Denali Park is at Brushkana Creek on the Denali Hwy. 30 miles or so east of Cantwell. Especially since Ahtna has closed their lands along the Denali and Parks Highways to the informal camping that has traditionally been done there, and since the informal camping area at Bison Dome has, I believe, been given to the Borough and has also sprouted "No Camping" signs it would be nice to have an alternative to the overcrowded campgrounds within Denali Park itself. There are a couple of nice private campgrounds in the area (specifically at the Rex bridge and across the road from Crabbe's Corner/McKinley Village) but I think more alternatives would be nice.

Thank you.

The Tanana valley contains the largest blocks of undeveloped agricultural land in the state.

Less than 5% of the food grown in Alaska is consumed in Alaska. More land needs to be put into production to support a growing population and new land must be made available so food production can increase.

How would you like to see state lands used? for many generations in the future I would like to see state land used as a resource for future generation. Why not set aside land for recreational use for 2050 and 2090. State land should be used as a green belt so people can travel long distances without worrying about fences and no trespassing signs. By travel I mean winter use & just trails.

What issues, if any, do you have with the current uses or management of state lands? I would like to be able to get fire burn spruce for firewood without worrying about a wood cut permit. I hope you are setting up land use areas for new settlers then make darn sure you aren't allocating the only blueberry patch or the only area for wood cutting for a future private dwelling.

Any other comments? When you have a land sale - be sure and include a check list that covers the financial issues. People need a more realistic picture of what they are buying. The price of the land, plus do they pay for survey or not, cost of flying back & forth with building supplies, say whether there is firewood or building logs available - You should not have land sales where there is not enough firewood for all who stake. Warn people maybe no fish in lake. Not all lakes have edible fish, e.g. Deadfish Lake by Roosevelt Mtn only has black fish. Have available information on the depth of the lake. Maybe it is too shallow for airplanes to land at certain times of year. Say whether it is a better place for a winter use than summer use. Does anyone already live there year around - find out where the blueberry & cranberry patches are and leave them so everyone can share. People should know if the area is already being trapped. People that get land in the wilderness want to get out and explore. It is shameful to allow 20 more people to build around a lake that already has one family and they are using the meagre wood lot and picking the blueberry patch clean each year. Then there is already an overpopulated area without anyone else moving in. People don't want a wilderness home if they have no resources to go with it. If they can't do wilderness recreation why bother to build and live remote.