These comments are submitted by the Southeast Alaska Conservation Council regarding permit application #1-99047 or "Rudyerd Bay 1." SEACC is a coalition of 17 volunteer conservation organizations in 13 Southeast Alaskan communities, including Tongass Conservation Society in Ketchikan. This After-the-Fact application for a 7,275 square foot float by Alaska Cruises, a subsidiary of Goldbelt Incorporated of Juneau, should be rejected. This float is used to serve cruise/fly tour packages offered by Alaska Cruises. While this operation has been in place for several years, the Rudyerd Bay float utilized by Alaska Cruises was never authorized through a permitting process by either state or federal agencies. Essentially, Alaska Cruises has squatted in an established Forest Service Wilderness Area in pursuit of profits. SEACC requests the Corps engage in a thorough Public Interest Review of this project. We feel that granting this permit will seriously compromise the Wilderness values of Rudyerd Bay, which was recognized by Congress for its national and global significance. The, "Wilderness values," and the potential for this float and its associated flying and floating activities to negatively impact and compromise these Wilderness values, should be given "great weight" as is called for in 33 C.F.R.§ 320.4(3). 

The U.S. Forest Service, which manages the uplands and non-saltwater sections of Misty Fiords Wilderness and National Monument, has determined no permanent facilities or day use facilities are allowed in Wilderness and/or Wilderness Monuments.(1997 Tongass Land and Resource Management Plan, Ch.4-40) Furthermore, USFS TLRMP standards and guidelines prohibit equipment storage or campgrounds of any kind in Wilderness Areas and Wilderness Monuments. The Forest Service standards and guidelines limit the number of flight-based sightseeing landings per site, per day at a maximum of six. According to the Alaska Cruises application to the Corps as many as 180 people per day will be boated to Rudyerd Bay and then flown back to Ketchikan. If Alaska Cruises plans to use traditional DeHavilland Otters, Cessna Caravans or other similar aircraft, far more than six landings per day will be required to transport 180 passengers back to Ketchikan. The State of Alaska, which has management responsibilities for tidelands and submerged lands recently released draft management guidelines for Misty Fiords and Rudyerd Bay which generally reflect the management directives of the Forest Service.

The Corps should refer to State Department of Natural Resources’ Central and Southern Southeast Alaska Area Plan Public Review Draft, for further guidance and information. (December 1999) The DNR has proposed Rudyerd Bay be managed under the Habitat and Recreation/Undeveloped land use designations. In Chapter 3-3 of the Draft CSEAP, the Habitat Designation description reads: "This designation applies to areas of varied size for fish and wildlife species during a sensitive life-history stage where alteration of the habitat or human disturbance could result in permanent loss of a population or sustained yield of a species." DNR’s Recreation and Tourism-Undeveloped land use designation reads: "This designation applies to those areas that offer or have a high potential for dispersed recreation or tourism and where desirable recreation conditions are scattered or widespread rather than localized. Developed facilities are generally not necessary other than trails, trail signs, primitive campsites and other minor improvements." Permitting this floating dock, will clearly pave the way for the establishment of a tourism operation that is of a size, scale and concentration inconsistent with the management guidelines crafted by both state and federal agencies for the Misty Fiords Wilderness uplands and waterways. SEACC would like to echo the suggestion of Tongass Conservation Society that the Corps explore practicable alternatives to this float in areas outside of Rudyerd Bay. Careful planning among tourism operators, the Forest Service and the State of Alaska is needed at this time. Granting this permit to Alaska Cruises could lead to an avalanche of permit applications for similar facilities in other anchorages within the Misty Fiords and other Tongass Wilderness areas. It would also send a terrible message that squatting in remote and pristine anchorages is ignored, possibly even condoned, by those responsible for managing the public’s resources.In closing SEACC also supports the Tongass Conservation Society’s request for a public hearing in Ketchikan prior to any decision to permit this facility. Thank you very much for this opportunity to comment. 

Respectfully, Tim Bristol/SEACC
 tim@seacc.orghttp://www.seacc.org
(907) 586-6942 phone
(907) 463-3312 fax