OLYMPIC PARK ASSOCIATES
12730 - Ninth Avenue NW, Seattle, WA 98177-4306
September 14, 2006
Carla McConnell
Olympic National park GMP
NPS Denver Service Center -- Planning
P.O. Box 25287
Denver, CO 80025
Re: Olympic National Park General Management Plan DEIS
Olympic Park Associates appreciate this opportunity to comment on
Olympic's Draft General Management Plan (GMP). We offer these comments
in the sincere hope that they will lead to a sound plan and a positive
future for this magnificent, world-renowned natural preserve.
As we stated in our scoping comments in 2001, we of OPA share a
vision for the park that would protect and restore the outstanding
natural and wilderness qualities for which Olympic National Park was
established. These qualities are articulated in U.S. House of
Representatives: House Report 2247, April 28, 1938 that accompanied
creation of the park.
" . . . preserve for the benefit, use and enjoyment of the people
the finest sample of primeval forests . . . winter range and permanent
protection for the herds of native Roosevelt elk and other wildlife
indigenous to the area . . . conserve and render available to the
people, for recreational use, this outstanding mountainous country . . .
and a portion of surrounding verdant forest together with a narrow strip
along the beautiful Washington coast."
Our goal for Olympic National Park over the next 20 years is a fully
restored ecosystem with its original components, processes and habitat
functions intact. Human use would be managed to insure enjoyment of the
park while protecting the healthy functioning of its ecosystems into the
future. We believe, given the park's legal mandates and agency
policies, that this should be your goal as well.
As you know, much has changed since the park was established in 1938
-- or since the last management plan was completed in 1976. Olympic is
no longer surrounded by vast areas of undisturbed forest. Roads,
logging, and residential development of forest lands now define much of
the park boundary. Increased recreational use of all types place
demands on resources. Cumulative impacts on lower rivers and salmon
streams and illegal hunting pressures have impacted park wildlife,
fragmented habitats, and impaired ecosystem functions. Visitation to
the park is increasing dramatically (doubling since the 1976 master
plan). Added to this, climate change is already affecting hydrologic
regimes and natural processes in the park and threatens to have major
impacts on wildlife habitats from river systems to subalpine meadows.
For a general management plan to deal with these kinds of threats to
the future ecological integrity of the park, it must be bold, visionary,
and encompass a broad view of Olympic's role in maintaining the larger
Olympic ecosystem. Your 1976 master plan provided this kind of guidance
for most of the past few decades. We feel the preferred alternative in
the current draft falls woefully short.
We appreciate and support those recommendations in the preferred
alternative (D) that move the plan in this direction. Particularly, we
support the establishment of intertidal reserves. This issue has been
exhaustively discussed by the Olympic Coast National Marine Sanctuary
advisory committee. Recommending establishment of the reserves is a
bold step, and one to which we hope you will remain committed.
We support the park's intent to recommend boundary expansions to
protect habitats for threatened and at-risk wildlife populations. As
you know, it will be up to Congress to legislate any additions to the
park. We urge you to take a broad, long-term perspective on these
recommendations and let the political process do the compromising.
We strongly support a wilderness study for Ozette Lake, Pyramid Peak
ridge, and future additions. Ozette is the last coastal wilderness lake
outside Alaska and richly deserves protection. We support wild and
scenic river designation for the Elwha, but we fear the significant
expansion of the development zone in the valley works against watershed
restoration.
We support the Kalaloch Lodge, facilities, and highway relocation.
And we support the park's intent to expand educational and interpretive
programs, develop short interpretive trails, and encourage mass-transit
in high-use areas. We request a shuttle be required on the Obstruction
Point road during peak season to alleviate constant clouds of dust,
parking overflow, and engine compartment temptations to marmots.
All of these recommendation make a good start toward a GMP worthy of
a World Heritage Site and international biosphere reserve.
On the whole, however, we find the preferred alternative of the
draft GMP to be lacking in the critical qualities mentioned above:
boldness, vision, and sense of the park's place in the larger Olympic
ecosystem.
The draft is timid in its approach to resource protection, and many
of its protective measures are compromised and inadequate to protect
park resources into the future.
Specifically, the preferred alternative (D):
* offers inadequate measures for recovering threatened and
endangered or at-risk wildlife species
* offers boundary expansions that fail to conform to watershed and
topographic features, and are inadequate to protect and restore target
wildlife populations
* fails to protect irreplaceable habitats such as low-elevation and
floodplain forests, and offers inadequate protection for rivers,
riparian areas, and critical salmon habitats
* inordinately expands front country development zones far beyond
current uses or any reasonable future use
* favors roads and motorized access at the expense of fish and
wildlife habitats
* is overzealous in approach to cultural resource protection
throughout the park, and
* threatens the integrity of the Olympic Wilderness.
Further, we feel the draft plan misses the opportunity to address a
number of larger issues that would insure sound ecosystem management in
the face of an uncertain future. We ask park planners to reconsider
these recommendations, outlined in our 2001 scoping letter, for
inclusion in the final GMP.
* an ecosystem study from which to base critical resource
management decisions
* a recommendation to reintroduce wolves into the Olympic National
Park
* wild and scenic river recommendations for at least 12 park rivers
that qualify for congressional designation, and
* a wilderness management plan that will address numerous
controversial decisions regarding wilderness management in light of
requirements of the Wilderness Act.
We will address these and other issues under some general headings.
We will supply rationale where appropriate and recommend changes in the
draft that may improve prospects for sound ecosystem management.
Wilderness
The discussion of desired conditions for wilderness in chapter 1 (p.
26) is flawed. The interpretation of "lower standards" as displayed in
your matrix has been refuted by two recent U.S. federal court decisions,
including Olympic Park Associates v. Mainella (2005). In that decision
Judge Burgess found NPS managers guilty of "a clear error of judgment"
in their interpretation of historic preservation in wilderness. The
lower standards clause in no way gives priority to the National Historic
Preservation Act or DOI or NPS administrative policies. Wilderness
designation places "a new value" on the land, in Judge Burgess' words,
i.e. a clear mandate to preserve wilderness character.
The plan states the NPS will maintain all existing and potential
national register properties in wilderness. Appendix E lists
"classified structures," to be maintained. Twenty-nine (by our count)
are located in wilderness. This list includes at least one structure no
longer standing. Another 21 are to be evaluated, "properties" that
include some weathered piles of logs, an obsolete research facility, and
a sawmill ruin. We have little doubt that all of these will make the
cut.
For the GMP to decree that some fifty structures and eight "historic
landscapes" (including the "USFS trail system") will be maintained in
wilderness in a forthcoming wilderness management plan -- without
addressing necessity under the Wilderness Act or their impacts on
wilderness character -- is contrary to the Wilderness Act, NPS
wilderness policies, and the scope of this plan.
Similarly, to zone the Olympic Wilderness into use zones, including
some 500 miles of trails, campgrounds, primitive trials, and
cross-county routes without providing any detail or specific rationale
for is clearly beyond the scope of the present plan. We prefer the
wilderness uses sketched in alternative B, but we are unable to comment
on your alternatives for wilderness zoning due to the plan's lack of
specific reference or rationale for these designations.
The GMP seems to be attempting to make up for the park's lack of
wilderness management plan by front-loading several controversial
decisions -- decisions that deserve full discussion of rationale and
impacts -- in the current plan. This shorthand planning process
shortchanges wilderness management and does a disservice to your
wilderness planning effort. It will not meet a legal challenge.
The GMP should direct the park to produce a wilderness plan that
will guide management under the clear mandates of the Wilderness Act.
If specific wilderness decisions are to be put forth in this plan, then
a complete discussion of their legality under the Wilderness Act and
impacts on wilderness character must be fully explored. Information on
which the public can assess decisions affecting wilderness is
nonexistent in the current draft GMP .
Rivers
With the increased frequency of flooding and resulting road washouts
experienced by the park and national forest in recent years (possibly
linked to global warming's effect on rain and snowfall regimes), river
and road management deserve careful planning.
The park's rivers provide habitat for 70 stocks of salmonids, a
number of which are in decline and considered at risk by fishery
managers (1992 Washington State Salmon and Steelhead Stock Inventory),
as well as critical habitat for several special status fish.
With salmon declines regionwide, rivers should be afforded the
highest levels of protection. We urge you to reconsider your river
protection zones (offered in Alternative B). Mitigative measures for
all alternatives quoted on p. 76 include "Delineate 100-year floodplains
and minimize development in these zones." This directive would seem to
require that the river zone concept be incorporated into the preferred
alternative. It is the only measure in the GMP that offers adequate
protection for fish habitat and naturally sustainable river ecosystems,
restricts bank armoring, and and protects the fisheries resource
"unimpaired for the enjoyment of future generations." We also ask that
you review river reach analyses (done for several west end rivers) to
identify future trouble spots in advance of flood events and plan road
and transportation systems accordingly.
The plan's assurance in the preferred alternative that roads will be
maintained "using methods that minimize adverse effects on river
processes and aquatic and riparian habitats, to the extent possible"
fails to convince. In light of the recent rock armoring of the Sol Duc
River Road without habitat mitigations, the park's insistence on
reconstructing the Dosewallips Road regardless of impacts on critical
habitat for federally listed threatened Puget Sound chinook, and the
GMP's decision to continue destructive channelization of Finley Creek
indefinitely, we have little confidence that future road reconstruction
will be any different without strong protective measures made explicit
in this plan.
At the very least, we urge you to include language in your preferred
alternative that will restore some of the protections offered by the
river zones: "Prime fish and wildlife habitat will be protected in
naturally sustainable river ecosystems" (p. 57). "Natural resources may
be minimally but not permanently modified for access purposes" (p. 57).
"River bank or meanders would not be hardened or altered. Natural
flooding and hydrologic processes would be allowed to occur" (p. 57).
And "The riparian and floodplain habitats of rivers, streams, and
estuaraies would be protected" (p. 58).
Salmon habitats have been and continue to be impaired by the park's
road program. The GMP planning process offers the possibility to
reevaluate in light of current scientific findings and change course.
We are dismayed that the preferred alternative's emphasis on maintaining
road access takes precedence over protecting one of the park's most
threatened and irreplaceable resources, it's diversity of wild salmon
stocks.
We object to the draft's decision to continue the annual bulldozing
of the Finley Creek channel. The Finley Creek situation would be aided
by bridge removal and summer grading of the stream crossing during the
dry season, as considered in an earlier EA. Again, the draft plan
front-loads a future planning effort with an unfortunate and
short-sighted decision. The current situation is harmful and
unsustainable. Eventually, natural stream dynamics should be restored
in this area.
Wild and Scenic Rivers
In our scoping comments OPA requested that park rivers be evaluated
for eligibility for inclusion in the national Wild and Scenic Rivers
System, and that the GMP make recommendations to Congress. The Wild and
Scenic Rivers Act requires federal agencies to study rivers for
eligibility in their planning efforts. NPS management policies also
require this (Section 2.3.1.10). We support the GMP's recommendation
for the Elwha, but we are at a loss as to why the other eligible park
rivers were not studied or considered.
The 1990 Olympic Forest Plan evaluated rivers for eligibility and
made recommendations on rivers primarily in their jurisdiction. The
forest service deferred to the park recommendations for rivers that were
predominantly in the park's jurisdiction. We believe those evaluations
are available for review and urge park planners to review them. We also
request the Queets and other park rivers not reviewed by the forest
service be evaluated in the final plan.
The Wild and Scenic Rivers Act was passed in 1968. Olympic National
Forest published its recommendations in 1990. The park service has had
ample time to review the exceptional wild and free-flowing rivers in its
jurisdiction and make recommendations to Congress. If the final GMP
must be delayed to complete this obligation, it will be worth the
effort.
Boundary adjustments
We commend the park service for planning for the future by
recommending land additions in critical habitat areas to help protect
wildlife species. We realize that these are controversial
recommendations on the local level, but given impacts to park wildlife
from destructive activities outside the park, we recognize that boundary
adjustments are often the only way to insure permanent habitat
protection.
The boundary adjustments offered in Alternative B appear to be
informed by wildlife science, and we support them in every sense. Park
managers should keep in mind that these are agency recommendations.
Final boundary adjustments will result from congressional action and the
political give-and-take that accompanies that process. Park
recommendations should be sufficient to accomplish the objective of
wildlife protection and ecosystem restoration.
Ozette Lake. The proposed boundary expansions for Ozette Lake in
alternative B follow the hydrographic divide of tributaries making up
the Ozette Lake watershed. The wisdom of including the entire watershed
within the park allows restoration and planning activities to be
determined by a single agency -- one dedicated to protecting natural
systems. By removing abusive (albeit legal) logging practices that have
resulted in siltation to the lake and its tributaries and harm to its
threatened sockeye population, the advantage to the recovery process for
Ozette Lake sockeye would be enormous. It would take years, possibly
decades for the land to be acquired on a willing seller basis and
restored to natual conditions. But the last wilderness coastal lake in
the world would be fully protected, and park planners would have room to
manage adequately for future uses.
The addition recommended in the preferred alternative fails to
address the impacts of industrial logging on the Ozette watershed.
While an improvement over current boundaries, proposed boundaries do not
make sense ecologically, and by allowing continued logging abuses in the
basin, they offer little hope for ecosystem restoration for the Ozette
watershed.
We cannot endorse the proposed land acquisition and exchange with
Washington's Department of Natural Resources. More details would be
needed to fully evaluate this proposal, but turning federally purchased
land over to the kind of maximum timber harvest practiced by the DNR
without the minimum ecological protections assured by Forest Stewardship
Council (FSC) certification is self-defeating. The timber-industry
certification offered represents the same kind of abusive forest
practices that condemned the Ozette sockeye to the endangered species
list in the first place. It is disturbing that the National Park
Service is advocating such a measure.
Lake Crescent. The fortunes of the Cresecenti and Beardslee trout
of Lake Crescent have been dire in recent years. Both populations
declined markedly during the 1990s with Beardslee numbers dropping below
100 in 2000. Major impacts to both fish's spawning areas in the Lyre
River occurred when a 1997 slope failure resulting from logging steep
unstable ground in the Boundary Creek drainage sent thousands of tons of
sediment into Boundary Creek and the Lyre River drainages.
Expanding the park boundary north at Lake Crescent to include
critical spawning reaches of the Lyre River and all of the Boundary
Creek drainage (as recommended in Alternative B) would ensure that
critical spawning habitat for these fish would be protected. Most of
Boundary Creek is already in federal (forest service) ownership.
Additional private acquisitions beyond the preferred alternative would
be modest.
By offering inadequate protection for the Boundary Creek watershed,
the preferred alternative opens the door to further impacts of Lyre
River spawning areas. With the reduced Beardslee and Crescenti numbers
of recent years, this does not insure the future of these unique fish.
Quinault. The modest adjustment of the south boundary to include
the rivers floodway would be an improvement, insuring comprehensive
management of the river zone. We're aware, however, that prospects for
armed insurrection in the area must be taken into account.
Queets and Hoh. We endorse the inclusion of the northern drainage
of the lower Queets River within the park as proposed in Alternative B.
to protect important seasonal habitat for Roosevelt elk and coho salmon
habitat. The addition would afford much more protection for the
compromised Queets corridor, and more than the modest boundary
adjustment offered in the preferred alternative.
The South Fork Hoh River. Wouldn't that be nice.
Developed areas
The development zone standards and the size of development zones in
the preferred alternative are entirely out of scale for a wilderness
park like Olympic. Descriptions of development zones should be scaled
down to comply with current uses at Olympic, and development zones
should be expanded only when there is no other way to accommodate
necessary visitor services outside the park.
Development zones in Olympic should accommodate campgrounds of no
more than 100 sites (200 for Kalaloch). The 250 campsite figure (which
more than triples the size of some of your largest campgrounds) is
wildly out of scale with current and projected needs at Olympic.
Campground expansion, where it occurs, should emphasize tent and small
vehicle camping, leaving the accommodation of large, self-contained
recreational vehicles to commercial facilities outside the park. It is
unwise to sacrifice low-elevation, floodplain and old-growth forests,
where most campgrounds are sited, in order to accommodate large,
polluting, noise-generating RVs.
The preferred alternative's dramatic expansions of developed zones
at Elwha (two miles along the Elwha River Road and a mile of Lake Mills
shoreline), Sol Duc (one-half mile of floodplain west-northwest of the
resort), and Hoh (approximately 300 acres of old-growth temperate
rainforest north of the visitor center) are both worrisome and baffling.
No justification for this level of increased development is offered in
the draft, or any indication of the types of development (existing
services or new commercial development) is given. Further, no acreages
for these zones are provided, thus limiting the public's ability to
evaluate these proposals. A simple table comparing acreages for these
zones for the various alternatives would be extremely helpful.
These zone expansions represent a radical departure from existing
uses and a level of future development inappropriate for a natural
preserve like Olympic. As we suggested in our scoping letter,
development on this scale should be located outside the park where local
communities can reap the economic benefits of providing visitor
services.
Proposed development expansion in the Elwha is particularly
troubling given the effort and expense being undertaken for dam removal
and ecosystem restoration. One of the conditions that helped drive the
restoration was the pristine nature of the watershed inside the park.
With dam removal imminent, is this the time to alter the natural
conditions of the watershed with miles of expanded development zone for
the Elwha? We think not.
We commend the park on its decision to remove the Kalaloch
development away from the coastal area. We urge moderation in planning
replacement facilities.
Extirpated species
Restoring extirpated species should be a high priority for the park.
We suggest that "Reintroduce extirpated special status species" be
added to mitigative measures on p. 77, and that the restoration of
extirpated species become a desired condition for the future of the
park. We appreciate the park's cooperation with Washington Department
of Fish and Wildlife's effort to restore fisher to Olympic National
Park. It would be appropriate for the GMP to give guidance and approval
to this restoration.
Similarly, a good case has been made for wolf reintroduction at
Olympic. The U.S. Fish and Wildlife Service's 1999 feasibility study
for wolf reintroduction found that there was sufficient prey and habitat
to support at population of some 50-plus wolves in the Olympics. An
earlier survey by Defenders of Wildlife found the idea was popular on
and off the peninsula.
The experience at Yellowstone has demonstrated the tremendous power
of ecosystem revitalization brought about by wolf reintroduction. The
same could be true for Olympic, particularly regarding coyote population
control and reducing coyote predation on declining marmot populations.
In time, wolf reintroduction could stand beside Elwha River ecosystem
restoration as the capstone of a revitalized ecosystem. We request the
GMP provide guidance that wolf restoration be a desired natural
resource condition and recommend reintroduction.
Non-native species
The park's draft environmental impact statement on non-native
mountain goats has been in limbo for more than a decade. Our members
have reported increasing numbers of goats in many areas of the park,
obvious goat damage to plant communities and have witnessed goat-human
interactions at several locations. In short, the goat problem is once
more rearing its horny head.
We understand your reticence to offer management direction for goats
in this document. But your discussion of nonnative species (p. 111-112)
is wholly lacking in direction for any nonnative wildlife. The park has
a recognized mandate to manage nonnative populations and where
appropriate, remove them. This issue requires a much fuller discussion
in the Final EIS.
Conclusion
While the DEIS offers considerable discussion of balancing resource
needs with human use, we find the plan is distinctly out of balance.
The preferred alternative displays a pronounced bias toward motorized
access, increased development, and a preoccupation with cultural
resource protection. On nearly every critical issue, natural resource
protection is compromised to accommodate the above uses. Habitat needs
of special status species are too-often ignored, and wilderness
protection is compromised by peremptory management decisions.
An example of this bias is evident in development zones. Nearly all
the expanded development zones in alternative C (visitor opportunities
emphasis) have been included in your preferred alternative (Hoh is much
larger in the preferred, though Kalaloch is slightly smaller). In
contrast very few of the natural resource protections offered in
alternative B appear in the preferred unaltered. Ecological boundary
adjustments, river zone, and "primeval" wilderness zone have been
compromised or dropped. At the same time, radical cultural resource
protections (blanket preservations of "classified" lists of structures
and landscapes) are treated as sacrosanct.
Similarly, we find the draft's analysis of impacts of the preferred
alternative inadequate and lacking in clarity. Language such as found
in your conclusion of impacts on hydrologic systems, "Implementing
alternative D would have a long-term moderate beneficial effects and
long-term minor to moderate adverse effects on hydrologic systems" (p.
315) is not useful.
OPA would like to see a final plan that is indeed balanced, and
affords natural resources the protections needed to insure that a
healthy ecosystem can survive the challenges of the coming decades.
Thank you for this opportunity to comment on the plan.
Sincerely,
Donna Osseward,
President, Olympic Park Associates
cc: Regional Director Jon Jarvis
U.S. Congressman Norm Dicks
U.S. Senator Maria Cantwell
U.S. Senator Patty Murray