News Archives

NPS Management Policy Revisions (ONP)
Shelter Flights (ONP)
Conservationists Challenge Decision to Rebuild Dosewallips Road through Ancient Forest (USFS)
Dosewallips Road Bypass (USFS)
Replacement of Wilderness Shelters (ONP)
Olympic National Park General Management Plan Scoping (ONP)

Propose Revisions to National Park Service Management Policies
Comments urgently needed by Feb. 12, 2006

National Park plan degrades its mission
by Tim McNulty

It's been said that the national park idea is one of America's greatest gifts to the world. The 1916 Organic Act that established the National Park Service states the core mission of the parks is to protect and preserve park resources "unimpaired for future generations."

It's a visionary approach that has proven durable for most of a century.

But the Bush administration, its political appointees in the Interior Department and park service, and its allies in congress would like to change the way the parks do business.

>From bleeding the park budget, threatening to sell off low-visitation parks to highest bidder, inviting corporate branding of our national treasures, and "screening" potential superintendents for loyalty to the Bush agenda, the Bush crowd has waged war against the parks.

The revised National Park System Management Policies currently being promoted by the park service (Jan. 4 PDN, New York Times editorial, "Want Segways in Olympic National Park?") are merely the latest in a string of attempts by this administration to abandon 90 years of preservation.

In August Paul Hoffman, a deputy assistant secretary of interior, circulated an earlier revision of the management policies.

Hoffman is a Bush political appointee whose qualifications for the post at Interior were running the Cody Wyoming Chamber of Commerce and serving as a congressional aide to Dick Cheney.

Hoffman's rewrite redefined "unimpaired" and other terms so as to open up national parks and monuments to use by dirt bikes, jet skis, and snowmobiles, not to mention helicopter sightseeing, grazing, mining, and other forms of commercial profiteering.

Following an outcry from across the political spectrum, the Bush administration backed away from the Hoffman revision. The draft policies released in October lack the more outlandish measures of the earlier version.

But supporters of the parks' mission will find no shortage of measures to criticize in the new policies.

Twenty-five former park managers, including past superintendents of Olympic and Mount Rainier, wrote to park service director Fran Mainella objecting to the new policies and questioning their need.

The current management policies, developed in 2001 after six years of public involvement and review, present clear and adequate management guidelines.

They state in part "...when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant."

That and pages of similar statements have been stripped from the new policies. The new directives make conservation and public use equals.

The result will be more noise, pollution, motorized recreation, corporate branding -- some of the same things many visitors come to the parks to escape.

The biggest need of our national parks today -- one long ignored by the Bush administration and Congress -- is adequate funding. The National Parks Conservation Association has identified a $600 million annual budget shortfall service-wide, including a $6 million shortfall at Olympic alone.

Supporters of our parks should contact the park service at http://parkplanning.nps.gov/waso. Tell park managers the new management policies are ill-advised, unclear, unnecessary, and wrong.

The Park Service should be protecting our parks, not opening them to degradation, privatization and profit.

Tim McNulty is a trustee of Olympic Park Associates and author of several books on national parks.

This Point of View originally appeared in the Peninsula Daily News, January 11, 2006.

"U.S. Court Rules New Shelters Illegal in ONP Wilderness"

In August, U.S. District Court Judge Franklin D. Burgess handed down a resounding victory for wilderness in Olympic National Park. He ruled that Olympic National Park's decision to helicopter two newly constructed trail shelters into the Olympic Wilderness is a clear violation of the Wilderness Act.

"The Home Sweet Home and Low Divide shelters have collapsed under the natural effects of weather and time," Judge Burgess wrote. To reconstruct and fly in new shelters by helicopter, he declared, "is in direct contradiction of the mandate to preserve the wilderness character of the Olympic Wilderness."

The decision follows court action brought by OPA, Wilderness Watch and Public Employees for Environmental Responsibility in October of last year. Plaintiffs challenged a park decision to fly two preconstructed shelters into remote, subalpine sites in the Olympic Wilderness (see "OPA Sues Park Service over Shelter Flights in Olympic Wilderness.").

In October the Park Service appealed Judge Burgess' ruling. The case will now go the U.S. Ninth Circuit Court of Appeals. OPA has every expectation that the Ninth Circuit judges will uphold Judge Burgess' decision.

For years, park mangers contended that the park was required by law to preserve these and other deteriorating structures in the Olympic Wilderness as historic resources. The park dismissed conservationists' concerns about wilderness preservation insisting instead that the new shelters were essential for visitor safety and would enhance the areas' wilderness character. Project proponent and cultural chief at Olympic, Paul Gleeson, stated that shelters are "an organic part of the Olympic wilderness."

Judge Burgess disagreed on all counts. In a strongly worded 13-page decision, he found the Park Service guilty of "a clear error of judgment."

Attorney Gil Reavis of Foster, Pepper and Shefelman who represented OPA and Wilderness Watch in the suit said the court's ruling upheld the integrity of the Wilderness Act. "While the Park Service is required to consider the effects of its actions on historic structures, the rules change when those structures are in wilderness areas," he said. "Judge Burgess' decision says that new structures are not allowed since they do not preserve the wilderness character of the area."

"This decision resolves a long-standing, contentious issue at Olympic," said OPA president Donna Osseward, "and it's a landmark victory for Wilderness everywhere."

The 876,669-acre Olympic Wilderness was created by Congress in 1988. In the 17 years since designation, the park has failed to produce a wilderness management plan for the area. In spite of that, park managers have promoted controversial actions in wilderness, from reconstructing "historic" buildings and landscapes to flying in newly constructed trail shelters. Judge Burgess' decision gives clear direction to the park that it must comply with its legal obligations under the Wilderness Act.

"[F]or a wilderness user to come across a brand new structure in a subalpine meadow would surely be disconcerting and obviously detract from experiencing, in the Park Service's words, Świlderness on its own terms,'" Burgess wrote. He determined that, if the shelters were placed in wilderness, the Park Service "would not be administering the area in accordance with its mandate under the Wilderness Act... Śto preserve its wilderness character'."

"The Court ruled that the creation of the Olympic Wilderness placed a Śnew value' on the land, one that is more important than reconstructing old buildings," said Osseward. "That's something we've been been telling park managers for close to a decade," she added; "I hope they finally get the message."

Decision document attached (PDF).

OPA SUES PARK SERVICE OVER SHELTER FLIGHTS AT OLYMPIC
by Tim McNulty

Olympic Park Associates and two national environmental organizations filed suit in U.S. District Court in Tacoma challenging Olympic National Park's plan to fly two prefabricated shelters to remote sites in the Olympic Wilderness. The suit, which was joined by Wilderness Watch and Public Employees for Environmental Responsibility (PEER) was filed October 29 by attorney Gillis Reavis of Brown, Reavis & Manning of Seattle. It charges the park service with violating several provisions of the Wilderness Act and the National Environmental Policy Act (NEPA).

Olympic National Park recently finalized its plan to airlift the shelters by heavy-lift Chinook helicopter to Low Divide and Home Sweet Home meadow in the heart of the Olympic Wilderness. The park issued a Finding of No Significant Impact" on the action in in September.

The shelters are not "historic" as the park claims; they were constructed in the Elwha maintenance yard in 2001. Nor are they essential for visitor safety, another claim made by the park.

Our suit charges that installing these shelters in the Olympic Wilderness violates the park's duty to preserve the area's wilderness character under Section 4(b) of the Wilderness Act. The proposed action also violates the "no structures" and "no use of motorized vehicles" directives and the "mechanized equipment" restriction in Section 4(c) of the act. Because the structures so not serve the purpose of the Wilderness Act "as necessary to meet the minimum requirements for the administration of the area" they are specifically prohibited from wilderness.

"Flying new buildings with heavy-lift helicopters is a misguided way to manage one of the world's premier wilderness parks," said OPA president Donna Osseward. "The Wilderness Act is clear on this; new structures simply aren't allowed in wilderness."

By law, a designated wilderness is "an area where the earth and its community of life are untrammeled by man." The park service mistakenly contends that newly constructed shelters airlifted to subalpine sites are historic cultural features that will enhance wilderness character. The park's environmental assessment even stated that the wilderness would be adversely impacted if the former shelter sites were to allowed to revert to a natural condition.

This kind of convoluted logic has permeated other planning efforts underway at Olympic and threatens the integrity and effectiveness of the park's upcoming general management plan. That plan will set direction for park management for the next fifteen to twenty years. In the meantime, park managers have once again pushed Olympic's long-overdue wilderness management plan onto the back burner.

OPA, Wilderness Watch and PEER petitioned the Court to declare the park service in violation of the Wilderness Act and NEPA, to block any action toward installing the shelters in the Olympic Wilderness, and to order the park service to complete a wilderness management plan and EIS for Olympic National Park.

With this suit we look forward to a legal resolution of this long-simmering issue at Olympic.

For additional background information, see our EA Comment Letter below.

CONSERVATIONISTS CHALLENGE DECISION TO REBUILD DOSEWALLIPS ROAD THROUGH ANCIENT FOREST
by Tim McNulty

If Dr. Edward Miles and his team of atmospheric scientists at University of Washington are correct, near-record floods like the ones experienced last fall in the Olympics and Cascades will become commonplace. Warmer, wetter winters will pitch Northwest rivers into flood stage with alarming frequency, exacting an increasing toll on roads, trails, bridges -- and salmon. More and more, land managers will be faced with tough calls as recreational access clashes with resource protection.

In this sense, the controversy swirling around the Dosewallips River road may be a portent of things to come.

The upper Dosewallips road washed out in January of 2002, ten miles in from Highway 101 and five miles below the park service campground and trail head at road's end. The washout cut off motorized access to Elkhorn Campground in Olympic National Forest and Dosewallips Campground in Olympic National Park as well as the popular trail head to Anderson and Hayden passes.

Since then, Olympic National Forest has grappled with how to address the washout. OPA, Olympic Forest Coalition (OFCO) and several other environmental groups have urged the forest service to decommission the road at the washout and convert the upper road to a forest trail. A similar solution is being promoted for the problematic Carbon River road at Mount Rainier.

Local business interests and some recreationists want the forest service to rebuild the road. They say motorized access to the 20-site Elkhorn Campground and 30-site park service campground and trail heads are critical to the local economy. The rub -- and it's a large one -- is that road reconstruction poses unacceptable costs to endangered species, forests and fish. It is also in violation of the 1994 Northwest Forest Plan, the strongest legal protection we have for the old-growth forest ecosystem.

In March, Olympic National Forest announced its decision to construct a three-quarter mile bypass road up-slope from the washout. Unfortunately, the new road would cut a swath through a spectacular grove of ancient forest that borders the Buckhorn Wilderness, destroying more than 200 old-growth trees. This area has been identified as habitat for federally threatened spotted owls and marbled murrelets (though no recent surveys have been conducted). Further, bulldozing its steep, unstable slopes pose a threat to critical salmon habitat. Puget Sound chinook and Hood Canal chum salmon (both listed as threatened under the Endangered Species Act) spawn in the Dosewallips. Coho salmon are known to spawn in an unnamed tributary just below the construction route.

OPA and OFCO plan legally challenge this decision. We see the action as setting a dangerous precedent that will undermine the Northwest Forest Plan and further imperil Endangered Species Act-listed wildlife and salmon stocks along one of the Olympics' most spectacular wild rivers. While we are sympathetic to those who wish to drive to upvalley campgrounds and trail heads, we believe the environmental costs of rebuilding this road are just too severe.

In the decades before the creation of Olympic National Park, commercial interests pushed hard for a road across the Olympics. The Brinnon to Lake Quinault route was at the top of their list. Photographer Asahel Curtis was conscripted into the promotional effort, and by the 1930s CCC crews blasted a road up the steep grade of Dosewallips Falls to Muscott Flat. With the creation of Olympic National Park in 1938, road construction was thankfully halted.

This legacy of early road building abounds in the Olympics. Hikers today seldom notice that stretches of scenic hiking trails at Staircase, the North and East forks Quinault, Obstruction Point, Deer Park or Duckabush were at one time early roads. Trail conversions have lessened ecological impacts and created new recreational hiking opportunities that few regret. A Dosewallips trail would provide nearly year-round hiking, biking, and equestrian access though a magnificent valley forest. It would access two quiet, streamside campgrounds and a spectacular falls. After examining the options, we feel that this is by far the best choice for the Dosewallips.

The river seems to think so, too.

When floodwaters receded in 2002, the Dosewallips River had shifted its channel, flowing in a broad meander against a steep cutbank where the road had been. Soon after, salmon were seen spawning in the freshly deposited gravels. Last fall's floods extended the washout considerably.

The forest service released two environmental analyses over the past two years proposing to rebuild the road in its original location using extensive rock riprap, fill and constructed log jams. But during the agency's biological review, scientists determined that reconstruction would harm critical fish habitat and be in violation of aquatic conservation standards set forth in the 1994 Northwest Forest Plan. Last fall the agency withdrew plans to reconstruct the road in place.

The Northwest Forest Plan, which attempted to resolve the contentious issue of old growth logging on federal lands, identified the Dosewallips as a key watershed. As such, it is to be managed to preserve its native salmon, riparian forests and streamside habitats. Along with federally listed chinook and chum salmon, the river supports pink salmon and steelhead stocks that have been classified as "depressed' by state and tribal biologists. Federally listed bull trout may also be present.

The forest plan designates the upland forest as late-successional reserve, to be managed as habitat for old-growth and mature forest species, spotted owls and marbled murrelets among them. According to the forest service, road construction in reserves "is not generally recommended." The riverside forest is also a bald eagle management area.

The proposed bypass would construct a steep road grade across unstable hillsides, impact a coho salmon-spawning stream and destroy a four-acre swath of extraordinary old-growth forest. When OPA trustees visited the proposed bypass this past winter, we found several Douglas-firs larger than six feet in diameter. Impressive examples of western redcedar, western hemlock, and bigleaf maple were also present. Small fish were seen flitting through a tributary stream and there was sign that the forest was used by Roosevelt elk.

The Dosewallips forest exhibits all the characteristics of classic old-growth: a diversity of species and ages, a deep multi-storied canopy, standing snags for nest sites and numerous down logs. We crossed several small streams tumbling down the mountainside, and bald eagles (feeding on spawning coho salmon) sailed past along the river corridor.

Low-elevation forests like this have been identified throughout the Olympics as critical habitats for threatened spotted owls (which are declining rapidly in this part of their range), threatened marbled murrelets and other sensitive species. The Northwest Forest Plan is clear that old-growth forests in late successional reserves should be preserved.

We agree. OPA will continue its efforts to promote an ecologically sound and recreationally beneficial solution for the upper Dosewallips valley. For background and updates on this issue check the OPA web site at http://www.drizzle.com/~rdpayne/opa.html and Olympic Forest Coalition's web site http://www.olympicforest.org/.

OLYMPIC NATIONAL PARK
NEW BUILDING CONSTRUCTION SLATED FOR OLYMPIC WILDERNESS
Letters and Emails are Needed to Keep the Olympics Wild

Olympic National Park officials have determined that new, replica Forest Service shelters now take precedence over wilderness protection. And they've decided they don't need a wilderness plan to guide them.

On January 10, the park released its Shelter Repair Environmental Assessment (EA). The preferred alternative (B-1) is to airlift two newly constructed shelters with heavy-lift helicopters into remote subalpine meadows in heart of Olympic's wilderness. One will be installed at Low Divide, the other at pristine Home Sweet Home meadow in the upper Duckabush.

The shelters will replace two old Forest Service structures that collapsed under winter snow several years ago. The National Park Service considers these structures irreplaceable cultural resources.

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This is a clear instance where "No Action" (alternative A) is the best choice. The park service will be accepting comments until February 27, 2004. Please speak out for a wild Olympic Wilderness.

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Olympic is a wilderness jewel in the National Park System, a World Heritage Site and Biosphere Reserve. In 1988 Congress placed 95% of the park in the National Wilderness Preservation System to insure protection of its matchless forests, rivers and stunning alpine areas.

According to the Wilderness Act, "A wilderness, in contrast to those areas where man and his works dominate the landscape, is...an area where the earth and its community of life are untrammeled by man."

Apparently, park officials disagree. They seem to think aging Forest Service structures are cultural treasures, more significant than the wildlands they were built to protect.

The EA states the shelters are needed for emergency protection. In fact, high-elevation shelters have tended to attract the unprepared in the past. The new replacement structures are neither historic nor necessary. They have built with wood floors and picnic tables; the original 1930s-era structures had neither.

OPA, The Wilderness Society, National Parks Conservation Association, The Mountaineers, Northwest Ecosystem Alliance, Wilderness Watch, Olympic Forest Coalition, Public Employees for Environmental Ethics and other organizations have written the Park Service strongly objecting to this project. So did dozens of individuals. The flights are planned for the fall of this year (2004). We have one last chance to convince park officials to cancel this misguided project.

WHAT YOU CAN DO

Write, email or fax: Superintendent William Laitner, Olympic National Park 600 East Park Avenue Port Angles WA 98362 Fax: 360-565-3015 Email: olym_ea@nps.gov Ask him to honor the spirit of the Wilderness Act by choosing Alternative A, the "no action" alternative for this project.

Points you can make:

• issues that seriously impact wilderness values should be determined by a Wilderness Management Plan with an environmental impact statement (EIS) and to full public review. Fifteen years after wilderness designation, Olympic still lacks such a plan.

• New construction is unnecessary under the National Historic Preservation Act and park service guidelines ("Historic structures . . . may be removed" p. 15, EA) and inappropriate under the Wilderness Act.

• The park has failed to demonstrate the overwhelming cultural significance of these structures or the urgency of replacing them before a general management plan and wilderness plan is completed.

• With serious budget shortfalls and more than a million dollars in storm damage to wilderness trails and bridges this year alone, the $160,000-plus being spent on this project could be put to much more beneficial use.

Remind Superintendent Laitner that Olympic National Park was created by Congress to protect the Olympic's spectacular forests, rivers, Glacier-capped peaks and magnificent wildlife — not to build monuments to past agency management.

The Deadline for comment is February 27, 2004. Please write or email today.

Olympic National Park Shelter Repair Environmental Assessment can be viewed at: www.nps.gov/olym/ea/shelter_repair/index.htm

OPA's Comments to Olympic National Park's Wilderness Shelter Environmental Assessment

February 11, 2004

Superintendent William Laitner
Olympic National Park
600 East Park Avenue
Port Angeles, WA 98362

Olympic National Park Shelter Repair Environmental Assessment (EA)
January, 2004

Olympic Park Associates (OPA) wishes to register strong opposition to the preferred alternative, Alternative B-1, Fly in Reconstructed Shelters. The only responsible action in this case is the simplest, most inexpensive, and least controversial; it is also the only action in keeping with the park's responsibilities under the Wilderness Act: Alternative A, "No Action."

That this was not chosen as preferred alternative -- or even considered the most "environmentally preferred alternative" (p. 35) -- points to a contradictory quality of this document whereby intrusions into designated wilderness and violations of the intent of the 1964 Wilderness Act are transformed into wilderness values. The EA's basic premise that newly constructed structures flown in to remote subalpine sites are historic cultural features that enhance wilderness character is deeply flawed.

We request that this action be revisited in an environmental impact statement after an approved wilderness management plan is in place for Olympic National Park.

The EA fails to addresses a number of concerns ours and eight other conservation organizations, dozens of respondents -- and NPS's own wilderness steering committee coordinator -- raised during project scoping. In the absence of an approved wilderness management plan, cultural resource management plan, or general management plan in place at Olympic, an action of this significance requires an open informed discussion in an environmental impact statement under National Environmental Policy Act (NEPA) policies. The current EA process, followed by a "finding of no significant impact," is inadequate.

Given the lack of wilderness planning at Olympic and the general management planning process currently underway, we are baffled as to why the park service is pushing ahead with this unnecessary and controversial project. In light of extensive winter storm damage to backcountry trails and bridges this year (estimated at $800,000 to date) and the apparent lack of funds currently available for these repairs and other necessary visitor services, proceeding with these expensive shelter flights and on-site construction suggests a distorted set of priorities.

As stated in OPA's scoping letter (11/25/02), the proposed action is:

• unnecessary (under the National Historic Preservation Act),
• inappropriate (under the National Wilderness Act, and
• unjustifiable (under NPS management directives).

The Wilderness Act specifically prohibits structures not essential for wilderness protection and management. The Historic Preservation Act allows structures to be documented and removed. And NPS Director's Order 41 states: "management actions affecting cultural resources in wilderness may include a variety of management options including preservation of a site of property, protection from vandalism, professional level documentation, and may include removal."

After nearly 70 scoping letters and emails were filed on this project, we find the EA singularly lacking in scope. Page 8 of the document states "...the decision in this document is how best to accomplish the proposed project, not whether to reconstruct these shelters or not." In essence, the EA takes a pass on the critical questions posed above, stating as justification for this $163,000 expenditure that the shelters were "determined eligible for the National Register of Historic Places" (pg. 9). The EA also documents a commitment of resources to a predetermined outcome prior to scoping for this project, a clear violation of National Environmental Policy Act (NEPA) process.

Cultural Significance

Surprisingly, the EA offers little more in justifying the historical importance of these shelters. In sharp contrast is the park's Historic Resource Study (1983), which found the Low Divide shelter ineligible for the National Historic Register due to recent reconstruction. The study, compiled by the Cultural Resources Division, Pacific Northwest Region, NPS, found the Low Divide shelter "lacks integrity of materials, workmanship, and some design." The Home Sweet Home shelter suffered similar modernization. Curiously we find no mention of this determination in the EA.

We do find ample documentation that the reconstructed shelters themselves are not historic. They incorporate the same recent modifications of milled floors and siding that disqualified the Low Divide shelter from historic eligibility in the earlier study. They have also been constructed with oversized and reinforced framing and center posts to facilitate helicopter transport. As cultural preservation, the project as described fails to meet its primary goal.

Parsing the "Need" section of the EA (1.3), we note that construction and helicopter transport of the two new shelters is deemed necessary so that the historic significance of these two buildings can be "evaluated in its historic context" (p. 9). In other words, the shelters have been built and will be flown into wilderness sites in order to determine if they will be listed under the National Historic Preservation Act. If listed, there is no obligation to preserve them, a point inexplicably left out of the concluding paragraph on page 9.

Selective Use of Laws and Directives

Throughout the EA, information and policies that do not support the proposed action are given scant mention. Among these, as stated above, is the fact that the National Historic Preservation Act does not require historic structures -- even those listed on the Register -- be maintained. They may be documented and removed or allowed to decay. We find this option is mentioned once in the 98-page document (under National Park Service Management Policies, Sec. 5.3.5.4.9, page 18). But it is never discussed. Why not?

Similarly, 1978 Shelter Establishment Criteria, the result of public hearings following an unsuccessful lawsuit brought earlier, clearly state "Shelters will be located below mountain passes and subalpine areas to encourage the traveler to leave these risk areas during storms." Sound advice. Criteria also state "Shelters will not be located in mountain passes, on lake shores, in meadows, or subalpine areas in order to protect the areas' fragile resources, or where they will intrude on outstanding scenery." Both of these clear directives have been omitted from this EA.

A number of management plans from the 1970s are selectively cited to justify the need to reconstruct backcountry shelters (1974 Wilderness EIS, 1976 Master Plan, 1976 Backcountry Management Plan, 1978 Shelter Establishment Criteria, etc.) Since these plans were in place during the removal of trail shelters parkwide in the 1970s, they can apparently be interpreted to support any action desired. More important is the 1992 addendum to the Backcountry Management Plan (one of the few documents that follows congressional designation of the Olympic Wilderness). It states "All shelters will be evaluated for retention/removal...during development of an Olympic National Park Wilderness Management Plan." It is disappointing that eleven years after the addendum, fifteen years after Congress designated the Olympic Wilderness, NPS can find $163,000 for elaborate shelter construction and heavy-lift flights but can not produce the required wilderness management plan to give guidance to such an action.

Lack of Wilderness Management Plan

Park decision making has been hampered by a lack of an approved, publicly reviewed wilderness management plan. Decisions made in the absence of a plan, such as this one, reflect a piecemeal and compromised approach to wilderness protection. If specific structures are considered essential to wilderness management at Olympic, it is the park service's obligation to list them along with justification for preserving them in a draft wilderness management plan. They could then be objectively reviewed by the public. As it is, critical wilderness decisions are made in a vacuum with little opportunity for public review. Even this EA evaluates means for reconstructing shelters, not whether the shelters should be preserved at all.

Olympic National Park was created (as stated in the Olympic National park Act of 1938 and Congressional Report 2297) to preserve the outstanding natural qualities inherent in its wilderness. The Washington Park Wilderness Act of 1988 reiterated and legislated this intent. Decisions such as the proposed action, which clearly impact the quality and character of the Olympic Wilderness, should be guided by the mandates of an approved plan.

Minimum Requirement

The minimum requirement worksheet, completed by Paul Gleeson in March of 2003 is incomplete, circular in its logic, and misleading. The action at hand is not addressed in an approved wilderness management plan (3), but is deemed appropriate and necessary by the project initiator (4) based on a 1974 document (language unspecified) and an unapproved draft wilderness plan (unmentioned in the EA up to that point). Also mentioned are NPS management policies (6.3.8) that specify cultural resource preservation "consistent with the preservation of wilderness character and values."

We maintain that an objective view of airlifting newly constructed structures into designated wilderness is inconsistent with the preservation of wilderness character and values. The correct box to check on item 4 was "No," leading to "Do not proceed with action." Surprisingly, the no-action alternative (A), which would allow the sites of the former shelters return to natural conditions is evaluated as having adverse wilderness impacts (on the vanished shelters themselves). Flying the new shelters in, on the other hand, "would not impact vegetation, soils, ... air or aquatic resources," etc. The wilderness, we are told, would be only "minimally impacted."

In response to worksheet item 9, which evaluates impacts, the project initiator states "No aquatic resources are within 300 feet of either [shelter] location, and would therefore not be impacted" (p. 93). This is a false statement. In at least two places the EA clearly documents a creek within 30 to 60 feet of the Home Sweet Home shelter site, (pp. 21 and 39). Further, 1978 Shelter Establishment Criteria specify no shelter will be retained or built "in mountain passes, ... in meadows, or subalpine areas ..." as mentioned above.

The worksheet is unsigned by the park's wilderness specialist (or anyone else). We must ask, did it receive review by anyone beyond the project initiator?

Visitor Use

The EA states "Visitors are sometimes confused about the park's shelter use policy..." This action raises that confusion to new levels. It has been the long-term understanding of backcountry users in Olympic that trail shelters were for emergency use only (as stated in the 1978 Shelter Establishment Criteria). Yet Section 1.3.2 of the EA goes into some detail about the historic use of shelters as "safe haven" from rain and cold for "unprepared visitors." Does this historic use now constitute permissible use? Also mentioned in the above section is a "recent 2003 Superintendent's Compendium" that allows for "first come, first serve" use of some shelters.

If this is a new policy regarding shelter use, we consider it a dangerous one. There have been numerous incidents over the years -- and to our knowledge at least one fatality (16-Mile shelter, 1969) -- resulting from unprepared hikers depending on shelters for protection. Burned-out plank floors from fires built in snowed-in shelters were not uncommon during "first come, first serve" use in the 1970s. Rather than providing for visitor safety, a convincing argument can be made for shelters posing a safety hazard by attracting the unprepared -- particularly in remote high-country locations.

Impacts to Natural Resources and Threatened and Endangered Species

Similarly, impacts to subalpine vegetation around shelter sites is dismissed "negligible to minor adverse impacts" (p. 63). That soils and vegetation would have the same impacts with or without shelters as magnets for recreational use (p. 62) is counterintuitive and contrary to research by Moorhead and Schreiner. "[N]eligible, and short-term" impacts to T and E species resulting from 3 hours of heavy-lift helicopter flights, 16 hours of light lift helicopter flights and 10 to 13 days of motorized construction seems optimistic.

We regret we could find no commendable aspects of the proposed action. Again, we urge you to defer this action -- and redirect limited funds and staff time to necessary projects -- until your long-overdue wilderness management plan is in place.

Sincerely,

Tim McNulty
President, Olympic Park Associates

OLYMPIC NATIONAL PARK
GENERAL MANAGEMENT PLAN SCOPING
Olympic Park Associates Shares Vision for Management of Olympic NP

Olympic Park Associates

October 10, 2001

Cliff Hawkes
Denver Service Center
Planning and Design Services
12795 West Alameda Parkway
P.O. Box 25287
Denver, CO 90225-9901

Re: Olympic National Park General Management Plan Scoping

Olympic Park Associates welcomes the opportunity to comment on the scoping phase of Olympic National Park's General Management Plan. As a conservation organization that has focused on the park and national interest lands on the Olympic Peninsula for more than a half-century, we are deeply interested in the direction of park management over the next 15 to 20 years. We hope you will find these comments useful in fleshing out the scope of your general management plan.

1. Purpose, Significance and Mission

We share a vision of the park that would protect and restore the outstanding wilderness qualities for which Olympic was established. As you point out in your Summer 2001 newsletter, these qualities are distinctly outlined in U.S. House of Representatives: House Report 2247, April 28, 1938.

" . . . 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."

Toward that end we heartily concur with nine of your ten "draft significance statements." We take strong exception to part of your ninth significance statement:

" . . . Olympic National Park protects cultural resources that reveal and document the 200 year history of discovery, exploration, homesteading and community development in the region, as well as the evolution of the Federal preservation ethic."

We find nothing in the enabling legislation or House Report that would suggest that the significance of the park lies in its "homesteading" and "community development" values. In fact the historic record indicates quite the opposite. Federal protection efforts on the peninsula, as early as the Olympic Forest Reserve in 1897, were aimed specifically at protecting the area from homesteading and development. Community development, as experienced in the late 19th and early 20th centuries on the Olympic Peninsula, was characterized by forest clearing -- often by destructive human-set fires, despoliation of deer and elk populations by commercial hunting, elimination of predators including extirpation of the wolf, industrial clearcut logging, mining, dam building, unsustainable exploitation of fisheries, road building and commercial development of wilderness.

These activities were precisely what Olympic National Park was established to prohibit. This was given additional weight of law in the Washington National Parks Wilderness Act of 1988, which included 95 percent of the park in the National Wilderness Preservation System. It is somewhat baffling that these activities now appear among "significant values" the planning team feels must be preserved. Nor do they "describe the park's distinctiveness," a stated rationale for significance statements. They are factors that to varying degrees have impacted every national park in the West. Including these among statements about the park's wilderness, old-growth and temperate rain forests, salmon rivers, glaciers, wildlife, etc., is like listing the outdoor sausage stands among the significant values of the cathedral at Chartres.

This criticism pertains also to your draft mission statement: ". . . discovery, exploration, homesteading and community development . . ." and your issue topics: "Many important cultural features have disappeared or are being compromised by neglect or improper use." This misunderstanding of the park's cultural mission has led to unnecessary incursions into designated wilderness on several occasions in the past and needs to be resolved in the current plan.

2. Vision

Our vision for the park in 20 years is that of a fully restored wilderness ecosystem with its original components 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.

3. Ecosystem Restoration

While the park's first priority is non-degradation of natural systems, in order to protect the outstanding natural resources for which the park was established, it is imperative that critical ecosystem functions be restored. Unlike when the park's master plan was completed in 1977, Olympic is no longer surrounded by vast areas of undisturbed forest. Roads, logging, cumulative impacts on lower rivers, residential development, increased recreational use and illegal hunting pressures have fragmented habitats and impaired ecosystem functions. Human use is increasing dramatically (doubled since the 1977 master plan). And climate change will likely affect park resources underscoring the need for healthy ecosystem process. We will comment on a number of related topics.

Ecosystem Study

For a general management plan to adequately address these issues it should include a comprehensive ecosystem study. Such a study would provide an inventory of baseline species, survey of critical habitats outside park boundaries, and include process studies to see how species adapt -- or fail to adapt -- to human-caused changes in habitat.

The need for such a study was identified in congressional discussions leading to the 1988 Washington parks wilderness bill. It remains a pressing need and should provide the groundwork for long-term decision making by park managers. Of all the agencies and government entities managing the peninsula's natural resources, the National Park Service is the only agency charges with preserving natural systems. It falls on your agency to take a comprehensive look at the whole.

Salmon Restoration

While the park is undertaking the most promising salmon restoration project in the Northwest (the Elwha River), there is a pressing need to insure that all native stocks of anadromous and resident fish are protected in park waters. The decline of wild salmon stocks is perhaps the most pressing environmental issue currently facing the park. Guidance is needed regarding the kinds of measures required to conserve our wild salmon and resident trout. Transportation plans and development concept plans should be updated to take the habitat needs of wild salmon stocks into account.

A related issue is the need for an interpretive center interpreting the ecosystem restoration of the Elwha River and telling the story of the park's wild salmon resources.

Species Reintroduction

The GMP should give direction regarding reintroducing native species that have been extirpated in the park, including the park's top predator, the wolf. The park service should be an advocate for the animal's reintroduction (and resulting ecosystem revitalization experienced at Yellowstone). Another candidate for potential reintroduction include the fisher, which seems to have been extirpated from the park's forests.

Non-native species

The draft environmental impact statement for management of non-native mountain goats has hung in limbo for several years. The scientific review panel findings are in: mountain goats are indeed non-native to the park. A final EIS should be completed and management undertaken to address the problem of non-native goats.

Non-native plants have made incursions into several areas of the park, frequently displacing native plant communities. A strategy for effectively dealing with non-natives park-wide is needed. Cooperation with park neighbors is critical on this issue.

Wild and Scenic Rivers

The GMP should include an inventory of the park's 11 major river systems to determine their eligibility for inclusion in the National Wild and Scenic Rivers System. The plan should include the park's recommendations to Congress. The Forest Service completed its rivers assessment as part of the Olympic Forest Plan in 1990, but the park is the major caretaker for the peninsula's rivers. Currently, no peninsula rivers have been included in the system. With the fate of salmon stocks at issue, future designations -- and resulting river-specific, multi-agency management plans -- may play key roles in preserving salmon habitat peninsula-wide.

4. Wilderness

A shortcoming of park management over the past decade has been the absence of a wilderness management plan. Currently, key management decisions are based on a draft policy that has not undergone public review. A detailed wilderness management plan that addresses levels and types of wilderness use, management guidelines and desired outcomes is needed. Specifically, a number of issues should be addressed to enable the park to fully protect its wilderness resource.

Minimum Tool

Strict guidelines should be established to determine what constitutes "minimum tool" use in wilderness. Do all rescues require helicopter use? Are there other options for basic maintenance activities, personnel transport, survey work etc.

Stock Use

Currently, there are no restrictions on stock access to trails. Early season stock use has resulted in resource damage of subalpine areas when pack strings have bypassed snowy sections of trail. Stock users have cut green trees in subalpine areas to facilitate access on primitive trails. Should some trails in high fragile areas be off limits to stock use? What about secondary trails that do not receive regular annual maintenance? Do all trails require reconstruction of log stringer bridges to accommodate stock or will foot logs and fords suffice on some trails? What portion of trail maintenance and reconstruction should apportioned to accommodating stock use? All are questions that need to be discussed.

Use Restrictions,

Currently, several areas within the park are limited to carrying capacity for overnight use. Are others areas exceeding capacity? There is a need to establish overnight and day-use carrying capacity for all areas of the park. The park should continue to encourage overnight users to consider alternative destinations, and should consider closing some extremely fragile areas, like remote backcountry tarns, to overnight use. Perhaps group size should be restricted to less than 12 in fragile subalpine and alpine areas, climbing camps etc.

Fire Policy

Review fire policy on wilderness fires. Establish areas where wildfires are allowed to complete their natural cycles.

Shelters

Backcountry shelter and ranger stations should be maintained only if they are deemed essential for meeting wilderness management objectives (as per NPS wilderness management general policies). Consider removing all non-historic structures in wilderness (Hayes River Guard Station, Low Divide Ranger Station, IGY Glacier Hut on Snow Dome) and allowing old shelters to continue their peaceful reassimilation into the ecosystem. Reconstruction of any structure in wilderness no longer standing should be prohibited. This should apply to all candidates or formerly existing structures listed under the National Historic Preservation Act as provided by law.

We see a distinct difference between Native American cultural sites and "cultural" sites dating back only to Forest Service management. In a park established to protect the area's outstanding natural resources, conflicts between wilderness and preservation of (European) cultural sites should be resolved in favor of wilderness. The Forest Service legacy on the peninsula is amply documented in 2,900 miles of logging roads surrounding the park and the clearcut mountain slopes and silted salmon streams they access.

Wilderness Management Areas

The plan should consider managing Ozette Lake as a wilderness lake. It is the one large lake in the park perfectly suited for non-motorized use. Motorized use for inholder access could could be grandfathered in. As demand for opportunities for canoe and kayak use increases, it would be appropriate to have one lake where quiet, low-impact boating could occur.

5. Boundaries

Since its establishment in 1976, the boundaries around Ozette Lake have proven inadequate. Logging on tributary streams continues to impact the park with siltation, affecting listed sockeye salmon and trout. Ozette Lake is a jewel, the last undeveloped coastal lake of its kind. A study should be undertaken to assess the feasibility of expanding the park boundary to include the drainage basin of the Ozette watershed. Currently, coastal forest protection is minimal along the park's ocean strip with no small coastal drainage adequately protected. The Ozette basin is in large timber holdings and its second and third-growth forests are approaching maturity. The GMP is the logical point to initiate a feasibility study for full protection of the lake basin.

Any boundary deletions, such as the one under discussion with the Quileute Tribe that would remove more than 300 acres along the Quillayute River from the park, should be aired in the GMP and open to full public review and comment.

6. Access and Roads

Road maintenance and repair on west-side rivers has come into conflict with salmon habitat. Armoring banks with riprap is known to degrade salmon and steelhead habitat and accelerate downstream bank erosion. Blacktopping of gravel roads increases runoff and pollution.

Roads and Fisheries

The GMP should survey the road system in the park and review river reach analyses now being conducted for the park's west-side rivers. The analyses will indicate which sections of road are most likely to be undermined by natural river processes, which riprapped sections of roads are contributing to accelerated downstream erosion, and which road sections impinge on salmon and steelhead habitat. There may be opportunities to construct log jams to protect some sections of road, relocate some sections, as was recently done in the Hoh Valley, or convert others to trails. The last stretches of the Graves Creek and North Fork Quinault roads should be closely examined in this regard.

Shuttles

Traffic congestion due to increasing visitor use at popular areas could be lessened by shuttle busses. Hurricane Ridge and Hoh Rain Forest are two candidate areas. Other parks, Denali, Zion, and Yosemite among them, have benefited by introducing shuttle service. Mount Rainier's GMP calls for busses to ease parking congestion at Paradise; they are required for overnight users there.

Road closures

There are opportunities to restore wilderness in a few areas of the park that are worth looking into. The North Fork Quinault and Graves Creek roads are mentioned above.

The closed road to Olympic hot springs that now serves as a trail can be restored by removing remaining blacktop, pulling culverts and restoring natural stream drainages and revegetating. The Forest Service has made great strides in pioneering these techniques. One stream (Hell Creek) is heavily eroding into Boulder Creek.

Trails

Olympic's trail system is superb and adequate to access most areas of the park. Many problem areas of erosion and rutting have been reconstructed in recent years. Currently, budgets are tight. A renewed commitment to trail maintenance and reconstruction, particularly when trails have been zoned for levels of use, would have big payoffs in resource protection as well as visitor safety

Areas currently accessed only by way trails or mountaineering routes should remain that way to preserve their undeveloped character. Similarly, old Forest Service trails that have been abandoned for decades should be officially closed (not reopened as "cultural sites"). Areas like Tshletshy Creek and Lillian River offer opportunities for true wilderness experience. The park should not allow volunteer groups to reopen these areas for their use.

Future trail development should focus on short loop trails to meet the needs of non-backpacking visitors: families, the elderly and disabled. Recently constructed loop or interpretive trails at Sol Duc, Quinault, Dosewallips and Madison Creek (Elwha) have proven extremely popular. They also provide ideal interpretive opportunities.

The wilderness management plan should zone all wilderness trails to appropriate use and maintain them accordingly: high maintenance standards for popular day-use trails like Sol Duc Falls and Spruce nature trail on the Hoh, less maintenance for "primitive" trails like Aurora Ridge, Cat Peak and Grand Pass. High use areas are appropriate in wilderness if they are managed in a way to minimize human impacts on wilderness resources.

7. Visitor Facilities

The GMP provides a timely opportunity to revisit all of the "development concept plans" for the park's developed areas completed in the 1980s. Do they meet current and projected visitor needs, and are they appropriate for a wilderness park like Olympic?

In general non-educational developments inside the park should not be expanded. Recreational services, lodges, conference centers etc. could and should be provided outside park boundaries.

Campgrounds should remain at their current capacity. New developed campgrounds should be discouraged. Developed camping facilities, RV hookups and the like are best located outside the park.

With the next 20 years in mind, this is a good time to assess the feasibility of the downhill ski development on Hurricane Ridge. Is lift-assisted downhill skiing an appropriate use in a national park? We understand that Olympic is one of only two parks in the system still accommodating a downhill ski development, and that the concession has experienced long-term economic problems. We also understand that there are no options for downhill skiing on the peninsula outside the park. A frank discussion of the future of downhill skiing at Olympic would be helpful.

8. Education and Interpretation

Olympic has one of the best interpretive programs we know of. However, funding constraints in recent years have limited expanding the program to new and under-served audiences, especially in surrounding communities. There is a need to expand education programs into surrounding schools and youth groups, organizations, libraries and local parks and recreations departments. The GMP should outline some directives and, through the accompanying interpretive plan, develop new strategies for reaching these audiences.

An additional audience for educational programs would be decision makers in governments and agencies surrounding the park. Education regarding the park's purposes, values and benefits is sorely needed as policies are established on lands and watersheds adjacent to the park that affect park resources.

Successful educational partnerships with Olympic Park Institute and the Northwest Interpretive Association should be maintained and strengthened.

9. Future Concern

Lastly, you ask in your newsletter, "What is your greatest concern about the future of the park?"

Our greatest concern is that this remarkably diverse and intact ecosystem will experience a slow, gradual and incremental degradation. Generations have worked to preserve the richness and beauty of Olympic National Park, and millions have been inspired by it. We owe it to future generations to preserve what we have and restore what we've let slip away.

Sincerely,

Tim McNulty
President, OPA