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.

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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.

Conclusion

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.

Olympic NP Draft GMP Review

I described the Olympic National Park’s Draft General Management Plan and Environmental Impact Statement (Draft GMP/EIS) in yesterday’s post. In this post, I’ll describe the elements of the plan that interest me for comment.

I started with the Olympic Park Associates’ (OPA) Preliminary Assessment. While their assessment of the draft Plan covers more ground than I’m able to, it is a good place to start for those interested in commenting on the plan. The scope of my comments includes the size of boundary adjustments proposed, the definition of river preservation zones in key areas, and the scale of the development area within the Park

Alternative D is a selection of elements from the two straw man alternatives: B, which emphasizes resource protection and C, which increases visitor access to the Park. Neither of those alternatives meets the requirements of the planning process and the Park’s purpose, but they are very useful for identifying opportunities for both of those topics. My assessment of alternative D is that it misses several of the key opportunities identified in alternative B. It also greatly increases the area available for development in the Park. The overall result of these choices is that the draft Plan creates a “balance” that leans heavily away from the protection and enhancement of the natural resources contained in the Park.

Boundary Adjustments

Alternative B contains a set of proposals that are exciting to me, as I’m interested in the ability of the Park to contain and preserve ecosystems. Much of the Park’s boundary is arbitrary. Some of those straight lines are adjusted by adjoining wilderness boundaries that provide protections along watershed boundaries. Alternative B represents an opportunity to fix more of these problems and without any cost to visitor access. So, why does Alternative D contain such a watered-down version of those possible adjustments?

In the words of the OPA’s assessment: “Park boundaries could be expanded 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 Lake Crescent (link to PDF map, around 2.0 MB) boundary adjustment in Alternative B includes the lake’s outlet, the Lyre River, and all of its major tributary, Boundary Creek. This has been reduced to a small portion of the Lyre River around the outlet of the lake.


• The Ozette Lake (link to PDF map, around 2.0 MB) adjustment in Alt. B includes the major portion of the area that drains into the lake is reduced to a narrow strip around the lake, which bears no relation to the watershed boundaries.


• The Hoh River (link to PDF map, around 1.3 MB) adjustment in Alt. B includes much of the land adjacent to the Park that is in the South Fork Hoh River watershed and extends the Park’s boundaries down the main fork of the river for another mile or two. This disappears in Alt. D.


• The Queets River (link to PDF map, around 1.5 MB) adjustment in Alt. B, which includes all of the north-side watershed of the river, is reduced to a small, square-boundary portion in Alt. D. This adjustment is sorely needed. The protected area is very narrow here – you can mostly see through it along the river.


• The Quinault River (link to PDF map, around 2.3 MB) adjustment in Alt. B would add a good strip of land along the south shore of the river from Lake Quinault to the Park boundary. This also disappears in Alt. D.

It’s not clear why the planners dropped these solid attempts to protect intact watersheds, but in doing so, they miss a golden opportunity to improve the ecological integrity of the Park. The adjustments suggested in Alternative B should be restored to the Plan.

River Zone

Several of the Park’s roads and a few of its facilities lie in the floodplains of salmon-bearing rivers. Alternative B suggests a “river zone” for the Quinault, Hoh, and Queets Rivers. (The links above for the named rivers show the areas proposed in purple.) 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 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, including the Hoh Visitor Center (should that be decided upon), could accumulate significant costs. And they could – I emphasize “could” – affect visitor access, at least temporarily.

The planners should consider the creation of river zones more carefully, 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.

Development Areas

One of the alarming aspects of the development-oriented Alternative C is the enlargement of the “development zones” in the Park, many of them in river floodplains. The zone concept, according to the Plan, is “concentrated visitor service facilities, overnight lodging, developed campgrounds (with up to 250 campsites, flush toilets, and cold running water) and park operational facilities would be accommodated. Road access is via unpaved or paved road.” (Draft GMP/EIS, p. 57)

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.” (Draft GMP/EIS, p. 74)

I may have missed it (the draft Plan is quite long and I didn’t read every word), but I didn’t see a description of problems with the facilities and how they definitely needed expansion. The other factor is 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 visit 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 over those twelve years. This doesn’t suggest the need for a dramatic increase in development in the Park.

These areas are proposed for significant development area expansion:

• Elwha (link to PDF map, around 1.6 MB) – The area around the Elwha is expanded in all of the alternatives, except the status quo. It’s not clear what plans the Service has for those development zones, as the details provided in the maps and alternative descriptions do not specify them. I’m particularly concerned about the extension of the development areas around the Lake Mills area, which will, once the Elwha dams are removed, become extremely sensitive to the disturbances that development will bring.


• Hoh (link to PDF map above) – Surprisingly, the area proposed for the Alt. D is even larger than the area proposed for Alt. C. No details about the planner’s plans for this additional area are specified, at least that I could find.


• Quinault (link above), Sol Duc (link to PDF map, around 1.6 MB), Staircase (link to PDF map, around 0.8 MB) – Likewise, I can’t tell from the materials I could find the reason for the significant expansion of the development area.

In the absence of a demonstrated need for expanded facilities and the management of larger areas for developed facilities and considering the lack of information about the actual plans for those zones, I can’t support the expansion of the development zones as proposed in Alternative D. There may be good reasons for these expansions, but the draft Plan does not make those clear.

Conclusion

The draft Plan is a well-built document, full of excellent information, with good descriptions of the Park and its alternative futures, and containing solid analysis of those alternatives. Unfortunately, the preferred alternative is timid and leans too heavily in the direction of visitor access, shortchanging the goal of protection of the unique and world-class resources contained within the Park. It should include all of the boundary changes proposed in Alternative B, not the seriously diminished and unjustified options proposed in the preferred alternatives. The Plan should also include more consideration of the River Zone designations proposed in Alternative B, though there may be significant costs associated with them. Finally, the Plan should also reconsider the dramatic expansions of the Development Areas proposed in the preferred alternative. With the excellent work put into the draft Plan by the planning team and carefully considered improvements, the final Plan can be a document that will guide the Park into the future of resource protection and visitor enjoyment and recreation.

Olympic NP Draft GMP

The Olympic National Park has released, for public comment, its Draft General Management Plan and Environmental Impact Statement (Draft GMP/EIS), the first management plan draft since 1976. The comment period has been extended to Sept. 30. I’m interested in the Park’s plans as an avid hiker and seeker of wilderness, and as a citizen, in a sense an owner of this incredible resource, I have an interest in its continued protection in the future. So, yesterday, I read through much of the draft plan (although I read some sections more closely than others) and will write about it here in three segments: a description of my reading of the plan, a description of my conclusions from the reading and from some other perspectives that I’ve seen, and, finally, a draft of the comments I will make to the Park Service’s planning process.

The draft Plan is a remarkable document, over 400 pages all told, containing a wealth of information about the park – its history, landforms, ecology, and operations. The analyses of the alternatives presented, I think, were thoughtful, well written, and useful. I applaud the planners and everyone involved in the years-long effort to think about the future of the Park and to write up plans its future.

For those not familiar with Olympic National Park, it occupies “the central core of the Olympic Peninsula, along with a narrow strip along the peninsula’s Pacific Coast.” (Draft GMP/EIS. Page 4.) It is recognized as a World Heritage Site by UNESCO. In its evaluation of the Park, UNESCO states:

Olympic National Park is the best natural area in the entire Pacific Northwest, with a spectacular coastline, scenic lakes, majestic mountains and glaciers, and magnificent temperate rain forest; these are outstanding examples of on-going evolution and superlative natural phenomena. It is unmatched in the world.

The draft Plan notes (page 9) that the enabling legislation of Olympic National Park (Act of June 29, 1938, 35 Stat. 2247) “states that Olympic National Park is ‘set apart as a public park for the benefit and enjoyment of the people.’” And that the “House Report 2247 lists the potential benefits and enjoyments of the park. According to the House report, the purpose of Olympic National Park is to

preserve for the benefit, use, and enjoyment of the people, the finest sample of primeval forests of Sitka spruce, western hemlock, Douglas fir, and western red cedar in the entire United States; to provide suitable winter range and permanent protection for the herds of native Roosevelt elk and other wildlife indigenous to the area; to conserve and render available to the people, for recreational use, this outstanding mountainous country, containing numerous glaciers and perpetual snow fields, and a portion of the surrounding verdant forests together with a narrow strip along the beautiful Washington coast.”

The draft Plan lays out four alternatives: A, the status-quo; B, which emphasizes “natural and cultural resource protection;” C, in which “park management would emphasize visitor opportunities;” and D, the preferred alternative, which balances elements of all of the other alternatives.

This dual responsibility noted above – to protect and preserve and to allow and facilitate use and enjoyment – is a key to reading the draft Plan and to understanding its conclusions and recommendations. I entered this reading with a bias toward extending the protections for the resources in the Park and for expanding the boundaries of the Park where possible. The Alternative B, where this same bias is given its reins and some real thinking about repairing impacts and increasing the Park’s protections and boundaries are considered. The other side of that question is access by the public. As I read more about this alternative, it became clear that I wasn’t likely to give up access to the extent required for Alternative B, a full implementation of which would restrict visitor access in a number of ways, some small and some large. Alternative C, in contrast, provides for significant expansion of access and development in the Park. I didn’t so much like that one, either, as I read it. So, a balancing of these two, might I say extremes, became the lens through which I read the details of the draft Plan. Indeed, that same impulse toward balance, was what produced the planners’ preferred Alternative D.

Each of the alternatives was described and evaluated in many ways. The alternatives were described in terms of their impacts using a set of management or usage zones. These are Development, Day-use, Low-use, River, Inter-tidal reserve, Wilderness trail, Primitive wilderness, and Primeval wilderness. In addition, potential boundary changes were identified for each of the alternatives.

The alternatives were considered against a series of “impact issues” and this evaluation comprised the heart of the analysis. The issues are: Air Quality, Soundscapes, Geologic Processes, Hydrologic Systems, Intertidal Areas, Soils, Vegetation, Fish and Wildlife, Special Status Species, Wilderness Values, Cultural Resources, Visitation, Visitor Opportunities, Information, Orientation, and Interpretation, Visitor Access and Transportation, Socioeconomic Environment, and Park Operations

In addition, they were evaluated against the goals of the National Environmental Policy Act (NEPA). There was a surprise here for me, as Alternative B, the most natural resource-centered option, did not fare as well as I would have expected. A quick review of the goals assigned in the NEPA tells the story. Only the first goal of the six is really focused on the natural world, while the rest talk of balance and use. Clearly, the NEPA is a compromise (as should not be a surprise). For the record, the goals are:
A. Fulfill the responsibilities of each generation as trustee of the environment for succeeding generations.
B. Ensure safe, healthful, productive, and aesthetically and culturally pleasing surroundings for all Americans.
C. Attain the widest range of beneficial uses of the environment without degradation, risk of health or safety, or other undesirable and unintended consequences.
D. Preserve important historic, cultural and natural aspects of our national heritage and maintain, wherever possible, an environment that supports diversity and variety of individual choice.
E. Achieve a balance between population and resource use that will permit high standards of living and a wide sharing of life’s amenities.
F. Enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources.

Because the scope of the draft Plan considered a great many more topics than I could readily accommodate, I began to focus on these fewer issues: the specifics of Alternative B, C, and D, especially in how they affected the protection of natural resources and processes, providing orientation and education for visitors, and providing visitor access and recreational opportunities; and how they differed on boundary changes.

Throughout my reading of the material, I was impressed by the scope of the work, the care that went into describing and considering the alternatives, and the clarity with which they were presented. Anyone interested in the future of Olympic National Park should, at least, read the Summary document and consider commenting on the proposed alternative.

All of the documents are available on-line, including the Draft GMP/EIS and the Maps of the alternatives. Review copies are also available locally (around Olympia) at The Evergreen State College Daniel J. Evans Library; at the Timberland Regional Library branches in Aberdeen, Amanda Park, Hoodsport, and Hoquiam; and in Shelton at the William G. Reed Public Library. A full list of locations with review copies is found here.

Should you wish to submit a comment to the planning process, visit this page for the form. Or, you can send a letter (on paper!), using the comment form and address here.

Good News About the Nisqually River

I’ve been absent here for almost two weeks because of the press of events, but also because I’ve spent every available computer hour with any sort of mental energy on applying for a different job. I’ve finished that now, so we’ll see how that works out. In the meantime, I’ll catch up.

About ten days ago, I attended a session of the summer lecture series at the Nisqually National Wildlife Refuge (NWR). The series is an annual, summer event sponsored by the Nisqually NWR Friends group. The session was entitled “Recovering Salmon, Restoring the Nisqually Watershed and it was presented by Jeanette Dorner, the Nisqually Tribe’s Salmon Recovery Program Manager.” It was my favorite of the year, not the least because of the energy and passion of the presenter, but because of the good news she brought. Good news is rare in the salmon recovery, environmental restoration and protection world, at least from what I can see.

It turns out that the Nisqually River is better off than the other rivers that flow into Puget Sound. Its estuary is relatively intact (thanks to the Nisqually NWR and the effort during the 70’s to prevent the estuary from being converted to a “super port” for the shipment of logs overseas. The two dams on the river probably do not constrict the salmon bearing length of the river (a now-submerged, impassable waterfall previously served as the end of salmon habitat). There are no big cities parked along its length, as is the fate of the Puyallup and the Snohomish. Most of the land along the banks of the river is in some sort of protected status, either because it’s in the NWR or because of the type of ownership. Much of the course of the river and its tributaries is still undisturbed and useful for salmon and other wildlife. Its waters are visited by several of the species of salmon native to the area, perhaps all of them that historically used the river. And, most important, the river’s banks are home to a committed steward of the river, the Nisqually Indian Tribe.

Ms. Dorner talked about several of the restoration projects that the Tribe has undertaken in recent years and also talked about plans for more, as funding becomes available. The Mashel River is the largest tributary of the Nisqually and has been channelized through some portions of its length, which greatly reduces its value to fish, because it reduces hiding places, spawning areas, and increases flow speed. She described the construction of log jams – engineered log jams! – that help restore resting and hiding places for fish, as well as spawning habitat, by sorting gravel and creating deeper pools. The project led to a dramatic increase in fish usage and survival in the year after it was installed.

Ohop Creek is a significant tributary of the Nisqually that was straightened during the 30’s, which deepens the channel and speeds the flow of water. The Tribe and its partners have gathered over a dozen landowners into an agreement to restore the creek to its previous meandering course. This project has been in planning for some time and will begin construction next summer.

A project that anyone can see just by driving through the Nisqually delta on I-5, southbound is best. Most of the delta was diked many years ago to keep the tide out and create farm land. The 100 acres on the east side of the river, outside the NWR, is now being worked on to remove the dikes and provide a fresh water connection to the wetland between the freeway lanes. This will allow most of that land to return to a salt marsh supporting the estuary habitat. A pilot project of a few acres a few years ago was very successful, with fish following the first tide onto the new wet land and birds using it that first evening.

All in all, a very satisfying evening in a world that sometimes gives me the feeling of waking up in a hand basket, wondering where I’m going.

Cross-posted at Olyblog.