Park Plans for Spruce Railroad Trail Expansion

In September, Olympic National Park released a plan to upgrade the historic Spruce Railroad trail into two new sections of the Olympic Discovery Trail, a multi-user trail that will eventually extend from Port Townsend to La Push on the Olympic coast. The plan calls for major construction, reopening two historic railroad tunnels, restoring the original 11-foot railroad bed, and paving a 6-foot trail surface to accommodate handicapped users and bicyclists. A 4-foot gravel trail will be maintained alongside the blacktop to accommodate hikers, joggers, and equestrians. OPA is supporting the park's plan (alternative 3 in the Spruce Railroad Trail Expansion and Improvement Environmental Assessment) with some important modifications. We have asked the park service:

• to mitigate a quarter-mile of bank armoring along the lakeshore with wood structures and plantings to restore natural shoreline functions;
• to construct the expanded East Beach parking area with a gravel or another permeable surface to prevent oil and automotive fluids from being flushed into the lake's outlet, the sole spawning area for endemic Beardslee trout;
• and to reserve the two existing tunnel-bypass trails for hikers only, allowing places for quiet enjoyment of the lake and its natural setting free of wheeled and hoofed traffic.

OPA feels the Olympic Discovery Trail is an important public resource on the peninsula. Its extension through Olympic National Park at Lake Crescent and in the lower Sol Duc valley will bring new visitors who will be able to experience the park's beauty and surrounding wilderness in ways not currently available at Olympic.

At the same time OPA strongly opposes a Clallam County proposal (alternative 4 in the EA) that would increase the paved trail surface to 8 feet, widen the trail shoulders, and increase the cleared width of the trail corridor to 14 feet. This proposal would also construct a new handicapped-accessible approach trail along the eastern portion that would necessitate logging and bulldozing a minimum 20-foot corridor (expandable up to 50 feet) for hundreds of feet through mature second-growth forest above the lakeshore. We agree with park planners that this type of heavy-handed development is inappropriate for a national park, particularly in an unspoiled scenic area like Lake Crescent.

You can support OPA's recommendation by going to: http://parkplanning.nps.gov/olym and clicking on "Open for Public Comment," or you can send a letter to: Superintendent Ð SRRT EA, Olympic National Park, 600 E. Park Ave., Port Angeles, WA 98382.

Deadline for comments on the plan is Friday, October 12, 2011.

The full environmental assessment, including the executive summary, is at http://parkplanning.nps.gov/srrt.

Please read OPA's letter on the Spruce Railroad Trail Expansion and Improvement Environmental Assessment

October 2011

OLYMPIC PARKS ASSOCIATES' COMMENT LETTER ON SPRUCE RAILROAD TRAIL EXPANSION AND IMPROVEMENT EA

Olympic Park Associates
168 Lost Mountain Lane
Sequim, WA 98382

October 12, 2011

Superintendent Karen Gustin
Olympic National Park
600 East Park Avenue
Port Angeles, WA 98362

Re: Spruce Railroad Trail Expansion and Improvement EA

Support for NPS Preferred Alternative (3)

Olympic Park Associates (OPA) appreciates the opportunity to comment on this plan. We have reviewed the EA for the Spruce Railroad Trail and we support the National Park ServiceÕs (NPS) preferred alternative (3). This approach strikes a difficult balance between providing for a range of trail uses, preserving natural and cultural resources, and maintaining trail usersÕ experience in keeping with the outstanding natural values of Olympic National Park. Although many of our members prefer the Spruce Trail as it is, we understand the need to extend the Olympic Discovery Trail through this part of the park, to bring the trail up to multi-use standard (in compliance with draft Accessibility Guidelines for Outdoor Developed Areas), and to offer a safe alternative for cyclists traveling the potentially dangerous stretch of US 101 around Lake Crescent.

Since road cyclists and handicapped users would use the trail, we understand the desire for an asphalt surface. Six feet in width is more than adequate to accommodate cyclists and wheelchair users if cyclists use this multi-use trail responsibly. Since hikers and stock users will also be using the trail, we support the proposal for an additional 4-foot gravel shoulder to accommodate these uses.

Opposition to Clallam County Proposal (Alternative 4)

OPA strongly opposes the wider, 8-foot asphalt surface, turnouts, and wider trail profile proposed in the Clallam County alternative (4). This standard, recommended by the American Association of State Highway and Transportation Officials (AASHTO), may be appropriate for public trails in metropolitan areas, but it is inappropriate for trails in a world-class national park like Olympic where resource protection and preserving natural character are high priorities (Management goals and Objectives, pp. 5 Ð 7). For these reasons we also oppose the level of new trail construction (Segment D) proposed in Alternative 4. For all practical purposes, this would constitute new road construction through natural second-growth forest habitat. The County proposal necessitates clearing a 20 foot-wide (up to a 53 foot-wide) corridor (p. 90) to maintain a 5 percent accessible grade on Section D. The entire County proposal would excavate 45,539 cubic yard of soil (p. 117) and cut 632 trees (p. 118), 374 more than would be cut under the preferred alternative. The total disturbed area for this alternative would be 14.4 acres, a third more than the preferred alternativeÕs 11. This heavy-handed approach to trail development reflects a misunderstanding of the mandates governing management of our national parks.

Further, the County proposal -- even a lesser, modified version of the proposal -- qualifies as having significant impacts on the natural environment and begs the question of what is legally permissible under a limited environmental assessment (EA). In our view, the preferred alternative already pushes the limits of what can be adequately evaluated under an EA. We believe the project would be better served by a full environmental impact statement (EIS). If the preferred alternative is modified in the direction of the County proposal, we are certain a full EIS is required.

Concerns with Preferred Alternative

We are deeply concerned over the level of shoreline armoring, 0.28 miles, under both the preferred and County alternatives. This treatment has deleterious impacts on the lakeÕs fisheries, which include rare and endemic stocks, as well as on nearshore habitats, which may include populations of water lobelia, a Washington state threatened species. As you know, shorelines are critical rearing and early-life habits for a number of fish species. Bank armoring eliminates shade, nutrient inputs, and protective cover for juvenile fish. Best management practices while installing rip-rap fails to address these larger habitat issues We urge NPS to seek more resource-friendly alternatives to bank armoring in these cases, and to incorporate wood (as was used in the Hoh River boat launch), plantings or other mitigations to lessen the impacts of bank armoring to the lakeÕs aquatic environment.

We also question the wisdom of paving the expanded parking area on East Beach Road. WouldnÕt a gravel parking area be less likely to flush harmful automotive fluids into the lake and present easier opportunities for cleanup? Or could not some porous surface material be used here? This is a particular concern given the parking areaÕs close proximity to the only known spawning area for the lakeÕs endemic Beardslee trout (p. 135).

Lastly, we note that the EA acknowledges the displacement of some traditional trail users following new trail construction. ÒSome current users of the SRRT may be displaced because the trail experience may be modified from a narrow unpaved trail to a wider asphalt paved trail with a gravel shoulderÉÓ (p. 112). Since OPA represents perhaps a disproportionate number of these trail users, allow us to suggest a mitigation. The bypass trails around the east and west tunnels could be closed to all but foot traffic, thereby preserving a remnant of traditional trail use and offering an opportunity for quiet appreciation of the lakeshore free of wheeled and hooved traffic. We note that the DevilÕs Point bridge is no longer safe for stock use. It should be an easy matter to close these trail sections to bike use as well. Consider it historic preservation of the Spruce Railroad Trail of the past half-century.

We hope you find these comments useful in refining your plan for Spruce Trail expansion. We urge you to resist popular pressure to comply with state and County road standards. Please manage this project in a way that reflects the trailÕs location in one our nationÕs most magnificent natural preserves. Thank you for your attention.

Sincerely,

Tim McNulty
Vice president, Olympic Park Associates

Cc: Representative Norm Dicks
    Senator Patty Murray
    Senator Maria Cantwell

December 2009

RESTORING THE WOLF TO OLYMPIC NATIONAL PARK

An important opportunity exists to help restore wolves to Olympic National Park: Your help is needed. Deadline for comments is January 8, 2010.

One of the many benefits of wolf recovery in the Northern Rockies has been the natural migration of wolves into Washington state. We now have three wolf pairs in Washington. As Rocky Mountain wolves have been removed from federal Endangered Species Act protections, Washington state is developing a plan for managing wolves in our state. The plan could eventually help return wolves to the Olympic Peninsula and Olympic National Park, but it needs your help.

This fall the Washington Department of Wildlife (WDFW) released its Draft Wolf Conservation and Management Plan for managing wolves that migrate into Washington. The plan can be viewed at http://wdfw.wa.gov/hab/sepa/sepa.htm (SEPA# 09073DEIS; Project: Wolf Conservation and Management Plan DEIS).

Unfortunately, the plan's preferred alternative is not based on the best science and it offers little hope for achieving sustainable populations of wolves in our state.

The draft plan has ruled out reintroduction to supplement wolf numbers and it limits translocation, moving wolves from one area to other areas they can't reach by migration -- like the Olympic Peninsula. As it stands, the draft plan may have the overall effect of lessening the chances of wolves returning to Olympic National Park.

Your letter or e-mail to WDFW can help. Deadline for comments is January 8, 2010.

The plan's stated goal is to reestablish a viable wolf population across a significant portion of wolves' former range in Washington. But the plan's Preferred Alternative (2) would make it nearly impossible for wolves to return to the Olympic Peninsula and Olympic National Park -- the best habitat for wolves in Washington state.

Please write a short letter or e-mail to the Washington Department of Fish and Wildlife. Ask that managers choose Alternative 3, for the final plan. That alternative creates a Pacific Coast recovery region, where wolves must be present before they can be "delisted" in Washington. And ask that wolves be translocated to the Olympic Peninsula and established there before they can be removed from endangered species protections.

To meet the plan's goal of reestablishing wolves in Washington, Alternative 3 needs further modifications. Here are some other points you can make:

• the goal of 15 breeding pairs needed to delist the wolf from federal and state protections is too low. Scientists suggest 30 to 60 breeding pairs would a more realistic minimum number.

• by taking reintroduction (from out-of-state wolf populations) off the table, the draft plan severely limits the chances for recovering wolves on the Olympic Peninsula and in Olympic National Park. Naturally dispersing wolves from the Cascades will not survive crossing the I-5 population corridor.

• Non-lethal methods, including translocation, should be used in dealing with "problem wolves" that interfere with livestock operations.

Olympic National Park offers the best habitat, the largest unmanaged elk population, and the least chances for wolf-human conflicts in the state. Returning the park's keystone predator -- the only species missing from Olympic -- would benefit the entire ecosystem, from endemic Olympic marmots to streamside forests. And the presence of wolves would bring lasting economic benefits to surrounding Olympic Peninsula communities.

Wolves need the Olympics, and the Olympics need wolves.

Please write or e-mail today.

E-mail comments to:
     http://www.wdfw.wa.gov/hab/sepa/sepa.htm

Or write to:
     Teresa Eturaspe
     SEPA Responsible Official
     Habitat Program
     Washington Department of Fish and Wildlife
     600 Capital Way North
     Olympia, WA 98501-1091

January 2010

OLYMPIC PARKS ASSOCIATES' COMMENT LETTER ON WOLF DEIS

Olympic Park Associates
12730 - 9th Avenue NW
Seattle, WA 98177

January 5, 2010

Teresa Eturaspe
SEPA Responsible Official
Habitat Program
Washington Department of Fish and Wildlife
600 Capital Way North
Olympia, WA 98501-1091

RE: Wolf Conservation and Management Plan for Washington DEIS

Olympic Park Associates (OPA) is a 60 year-old conservation organization that has a longtime interest in protecting and restoring the ecological integrity of Olympic National Park (ONP) and the Olympic Peninsula.

Our representatives attended scoping meetings and public meetings on the draft plan and offered comments at those venues. Our comments below pertain to the DEIS cited above.

OPA fully supports the plan's goal of ensuring the reestablishment of a self-sustaining population of gray wolves in Washington and encouraging social tolerance for the species. However, we do not feel that your preferred alternative (Alternative 2) will accomplish either of these objectives. Upon analysis, we find that the plan's preferred alternative is not based on the best science and it offers little hope for achieving sustainable populations of wolves in our state. We favor the approach offered in Alternative 3 with the following added points. Because our specific interest is the Olympic Peninsula, we will frame our comments from the perspective of wolf recovery in the Olympics.

Ruling out reintroduction is a serious flaw in the plan.

One of the plan's two main sideboards is flawed: The plan rules out reintroduction to supplement wolf numbers in Washington. This is a fundamental mistake. Reintroduction has proven to be key in restoring wolves to Yellowstone National Park, the northern Rocky Mountains, and other areas. It is a tool too important to be scuttled in Washington state. Further, OPA contends that the Washington Department of Fish and Wildlife does not have the authority to prohibit wolf reintroduction in Olympic National Park or other national parks in Washington. That is certainly beyond the scope of this plan.

In 1999 the U.S. Fish and Wildlife service published a feasibility study for reintroducing wolves to Olympic National Park. The study concluded that restoring wolves to Olympic is both feasible and beneficial to the ecosystem, and that minimal conflicts with humans would result. The study identified Olympic National Park as the best potential habitat for wolves in the state. (An earlier National Park Service study identified Olympic as the second best site for wolf relocation in the NPS system, after Yellowstone.) The USFWS feasibility study also concluded that reintroduction was necessary for restoring wolves to ONP, and that natural migration of wolves into the Olympics from elsewhere in Washington would not occur. Your DEIS concurs with that finding.

Rather than dismissing reintroduction, the final plan should embrace it as the only means to meet the plan's stated goal of reestablishing a naturally reproducing and viable wolf population distributed in a a significant portion of its former range in Washington.

Combining Pacific Coast and South Cascade recovery regions a mistake.

Given the unlikelihood of wolves crossing the Interstate 5 population corridor, the recovery regions described in your preferred alternative are without scientific justification. The preferred alternative unexplainably combines the Pacific Coast and South Cascade regions into a single recovery area. There is no justification given for this. As is clear in the plan, "connectivity" would not occur in this scenario. In fact, the Olympic Peninsula would be isolated from wolf recovery in Washington and effectively blocked from natural migration. With its high elk populations (8,670 for the peninsula plus 3,000 for ONP), excellent habitat, and distance from population centers, the west side of the Olympic Peninsula is a prime locale for wolf recovery. And as your source map shows, it could be an important source area for supplementing wolf recovery elsewhere in Washington. The preferred alternative not only fails to acknowledge or make use of this. It, in fact, prevents it.

In order to insure viable wolf recovery for Washington, the final plan should restore a separate recovery area for the Pacific coast.

Translocation is key to the Olympic Peninsula and to statewide wolf recovery.

The Olympic Peninsula should be identified as a primary preferred and initial site for translocation from other areas of the state to take advantage of the area's outstanding habitat and low probability of wolf-human conflicts. A recovery goal should be established for the Pacific Coast region separate from the South Cascades, which offers different habitat characteristics and does not face the connectivity challenges of the Peninsula.

Target numbers for wolf recovery are too low.

The USFWS feasibility study for wolf reintroduction to the Olympics concluded that Olympic National Park and Olympic National Forest could support up to 56 wolves distributed in five packs. Based on these numbers, your target population of 15 breeding pairs needed to transition from threatened to sensitive status seems extremely low. The plan's target number are also inconsistent with USFWS recommendations statewide (a range of 500 on the high end and 300 on the low end).Ê Clearly, further research and analysis is needed before a target population can be established for delisting wolves in Washington.

Benefits of wolf recovery to the Olympic Peninsula.

The benefits of wolf recovery to the Olympic Peninsula are many. With the recent reintroduction of the fisher, the wolf is the only species missing from Olympic National Park, a World Heritage Site and Biosphere Reserve that experiences an annual visitation of 4 million. Wolf predation would strengthen the Roosevelt elk population in the Olympics and likely redistribute elk browsing patterns, benefiting riparian forest development and aquatic habitats, as a recent study suggests. Wolves would also have a tempering affect on burgeoning coyote populations in ONP, which have had adverse impacts on the park's endemic marmots. And wolves in the park would have minimum conflicts with humans. In contrast, the presence of wolves would be a draw to park visitors and and an economic boon to surrounding communities. Wolf-inspired tourism to Yellowstone produces economic benefits to surrounding communities estimated at $35 million dollars annually.

Non-lethal methods for resolving wolf-human conflicts.

OPA favors non-lethal methods, including translocation, in dealing with "problem wolves" that interfere with livestock operations. Legal and illegal shooting are anathema to recovering wolves in Washington. We support the compensation program to reimburse ranchers for stock killed by wolves as described in the current plan.

Olympic National Park offers the best habitat, the largest unmanaged elk population, and the lowest probability of wolf-human conflicts in the state. Returning the park's keystone predator -- the only species missing from Olympic -- would benefit the entire ecosystem, from endemic Olympic marmots to streamside forests. And the presence of wolves would bring lasting economic benefits to surrounding Olympic Peninsula communities.

Wolves need the Olympics, and the Olympics need wolves. Please select Alternative 3 in your final plan with the above recommendations. Thank you for this opportunity to comment.

Sincerely,

Tim McNulty
Olympic Park Associates