September 10, 2006

Olympic NP, Draft GMP Comment

I described the Olympic National Park’s Draft General Management Plan and Environmental Impact Statement (Draft GMP/EIS) in this post and my review of that plan in this post. Here are the comments that I sent to the Park Service today. Comments are due by Sept. 30. See this post for information on commenting on the draft Plan.

Thank you for the opportunity to comment on the Olympic National Park’s Draft General Management Plan. The draft Plan contains a wealth of information about the Park, a solid set of well-written analysis, and an exciting list of opportunities available to the Park Service for preserving and enhancing the Park and its value to the environment and the country’s citizens.

My interest in the Park and its plans is motivated by decades of hiking, camping, and climbing in the Olympics. It is my favorite place in the state for enjoying the outdoors and its wildlife. It truly is “unmatched in the world.”

My comments will focus on the balance selected for the Preferred Alternative D, between the cultural and natural resource protection emphasized in Alternative B and the increased visitor access emphasized in Alternative C. I believe that the balance selected shortchanges natural resource protection, misses important opportunities to enhance those protections, leans far too heavily toward visitor access and development within the Park, and does a poor job of explaining the process behind and reasons for those choices.

Boundary Expansions

Boundary Expansions were proposed in Alternative B in “five critical areas (Lake Crescent and Ozette Lake, and Hoh, Queets, and Quinault watersheds) to conform with watershed basins to help recovering salmon populations and protect critical elk habitat.”

The first missed opportunity in the Preferred Alternative D is the severe reduction in boundary expansions described in Alternative B and chosen for the Preferred Alternative. Some of the boundary expansions in Alt. D are even smaller than those described in the development-oriented Alt. C. It is hard to understand why the planners restricted the recommended boundary adjustments to such a degree – there is no discussion of the trade-offs or reasoning behind the selections for Alt. D.

The expansion proposed in Alt. B for the outlet of Lake Crescent and almost the entire watershed of its other major tributary, Boundary Creek, is reduced, in Alt. D, to a small area of the Lyre River around the outlet of the lake, removing the protection of Boundary Creek. The Ozette Lake expansion in Alt. B, which includes the major portion of the area that drains into the lake, is reduced, in Alt. D, to a narrow strip around the lake which bears no relation to the watershed boundaries. The Queets River expansion in Alt. B, which includes the all of the land north of the river to the top of the ridge, is reduced to a small, arbitrary segment well down the river. The Hoh River expansion in Alt. B, which would include much of the South Fork watershed, and the Quinault River expansion, which would add a good strip of land along the south shore of the river from Lake Quinault to the Park boundary, both simply disappear in the Preferred Alternative.

Boundary expansions can be expensive, of course, but they do not have negative impacts on visitor access, like some of the other elements in Alt. B. Maintaining the boundary expansions described in Alt. B is an excellent way to maintain a balance between resource protection and visitor access, considering the dramatic increase in development areas within the Park, as proposed in Alt. D.

River Zones

Several of the Park’s roads and facilities lie in the floodplains of salmon-bearing rivers. Alternative B suggests a “river zone” for the Quinault, Hoh, and Queets Rivers. In the words of the draft Plan, this would mean that the “range of management actions that might be undertaken to address changes in resource conditions include removing facilities or roads, closing and rehabilitating unwanted trails, closing areas seasonally, removing invasive plants and revegetating using native plants, and expanding educational programs.” This could mean allowing natural river meander changes to break roads and trails and subsequently moving roads and facilities out of the floodplain.

These kinds of measures create an opportunity for greatly improving the health of these important rivers and their lowland habitat. Obviously, moving roads and facilities could incur significant costs. And they could – I emphasize “could” – affect visitor access, at least temporarily.

Even so, the planners should reconsider adding the river zones to the Preferred Alternative, especially on the Queets and Quinault Rivers. The zones on those two rivers seem to carry higher benefit to cost ratios, considering where on the river they occur, the facilities that they might affect, and the area that they protect. This change would effect a significant and necessary change in the balance of natural resource protection and visitor access.

Development Zones

One of the alarming elements of the Preferred Alternative D is the selection of every “development zones” suggested in Alt. C. In one case, the Hoh area, Alt. D includes even more area than suggested in Alt. C. This is an example of a serious step out of balance in the draft Plan.

Now, I like the developed areas found in the Park today. I use the running water and flush toilets, the interpretive structures, and the park operational facilities, as well as, of course, the roads and trails. Still, I question the dramatic expansion in the development zone area in certain places in the Park. Two factors support this question.

The first is this quote from the draft Plan, which suggests that most facilities will continue to function well:
“Most existing facilities provide good visitor opportunities and, based on projected trends, will continue to function well…Certain frontcountry visitor centers are extremely crowded during the summer season, and the displays are outdated.”
I may have missed it, but I didn’t see a description of problems with the facilities, other than that one mention of crowding, which would be in August, according to the visitation data provided in the draft Plan.

The other factor comes from the visitation data provided in the draft Plan. Although the last fifteen years of data suggests a slow growth in visitation, up to 4 million visits over the next ten years (from just over 3 million 2004, the last year reported in the draft Plan), the last twelve years show a flat visitation trend, running at about 3.4 million annual visits. This doesn’t suggest the need for a dramatic increase in development in the Park and calls into question the need for the proposed dramatic increase in the development zone. The planners should reconsider the selection of development zones in the plan, in order to promote a better balance between development and natural resource protection.


The draft Plan contains excellent information about the Park, clear descriptions of opportunities for fulfilling the goals of the Park Service and the enabling legislation for the Olympic National Park, and a set of choices in the Preferred Alternative D that should be reconsidered, in an effort to create a more balanced Plan, one that expands the opportunities for natural resource protection and reduces some of the expansion of visitor capability, to bring them more into line with each other.

The boundary extensions suggested in Alternative B should be restored to the Preferred Alternative. These extensions offer the most effective means to protect watersheds and habitat available to the Park, at no cost to visitor access. The river zones, especially on the Queets and Quinault Rivers should be reconsidered for the Preferred Alternative, as an important means for repairing some of the damage done by previous settlement and park development, especially considering the increasing value placed on dwindling wild salmon runs. Finally, the dramatic extensions of the development zone in the Preferred Alternative should be reconsidered, because of the impacts these might bring to the protection of the Park’s natural resources and in light of the ambivalent nature of the information available about the demand for these developed areas.

Thank you, once again, for considering my comments on this important planning effort. I look forward to reading the final Plan and seeing it put into action over the next decades.

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