March 21, 2011
Randy Kline, Environmental Program Manager
Washington State Parks and Recreation Commissioners
1111 Israel Road S.W.
Olympia, WA 98504-2650
Dear Mr. Kline:
Re: Mount Spokane Potential Alpine Ski Expansion Area (PASEA) Conceptual Proposal
The Upper Columbia River Group of the Sierra Club is located in northeastern Washington state and is part of the Sierra Club – America’s oldest and largest grassroots environmental organization. We wishto thank you for this opportunity to comment on this proposal. The Sierra Club is opposed to further expansion of the Mt. Spokane Ski and Snowboard Park into the intact ecosystem and watershed on the north and west slopes of Mt. Spokane, and support permanently designating this area as a Natural Forest Area. This area is currently being managed as a de-facto Natural Forest Area by Washington State Parks. We call on the Washington State Park Commission to permanently designate this area as a Natural Forest Area.
The Proposed Alpine Ski Expansion Area (PASEA) falls within the boundaries of a Washington State Park. It is the mission of the Washington State Parks and Recreation Commission to “acquire, operate, enhance and protect a diverse system of recreational, cultural, historical and natural sites in an effort to leave a valued legacy to future generations.” The ski area has acquired, removed and damaged at least two thirds of the upper alpine area. To allow further degradation, especially within the remaining natural vegetated area of the only alpine area in Spokane County would be contrary to the mission of the Washington State Parks and Recreation Commission
The Sierra Club opposes the ski area expansion for the following reasons:
•Negative impacts to year-round recreation - The natural forests on the north and west slopes of Mt. Spokane provide diverse wildlife habitat, as well as a wonderful year around environment for a multitude of recreational activities including hiking, snowshoeing, back country skiing, birding. These recreational activities will be negatively impacted by the fragmentation of the forest and the cutting in of ski runs. The expansion of the ski area into this unique and rare habitat will cause irreversible change to a pristine area in order to further one aspect of winter recreation lasting only 90-120 days each year, while negatively impacting the current winter recreation in the area. Cutting ski runs and building chair lifts requires clearing all vegetation and will forever alter the scenic beauty of this unique forest ecosystem. There will be significant impact to the year-round hiking and snowshoeing in the area of the proposed expansion. Winter recreation in the area will become limited to only alpine skiing eliminating access for other recreational pursuits. Spring through fall hiking will be negatively impacted by the fragmentation of the forest and the addition of a chair lift to the landscape.
•Destruction of native and old forests: Analysis by the Washington Department of Natural Resources has determined that the forests on the north and west slopes of Mount Spokane meet criteria for “Natural Forest Area”, and that natural forest processes are at work (i.e. creation of canopy opening that have increased forest habitat diversity). The forests have recovered from past impact and are on their way to becoming a mature and eventually old growth forest. Lands around the State Park have become very fragmented since the State Park was created. It is critical that these forests remain intact.
According to the Biological Survey conducted by PBI, Biological Surveys Conducted in the SEIS Analysis Area at Mt. Spokane State Park During 2010:
Polygons with characteristics of old growth forests were identified in the field and again
following our data analysis. Old growth forests were characterized as stands with more than 8
trees per acre over 20 inches in diameter, with tall trees, large snags, canopy cover greater than
50% and 2 or 3 canopy layers. We identified 14 polygons as old growth forest and noted these in the polygon database. There are many other polygons that may contain potential old-growth forest or at least some of the attributes that comprise old-growth forest conditions.
There are significant areas of old-growth forest within the BSA. These forests provide habitat for wildlife species dependent on late-successional forest condition. Much of the rest of the forests within the BSA also have some old, large trees and are moving toward old-growth conditions.
•Impacts to a rare sub-alpine ecosystem – The proposed expansion would develop the remaining top of the mountain, permanently impacting a rare and unique sub-alpine and mid-montane forest community. According to the Washington Department of Natural Resources this type of community “may be relatively common, their occurrence in a continuous forest block in a natural, un-manipulated condition is an uncommon quality.” (Letter from Rex C. Crawford, PhD, Natural Heritage Ecologist, Washington Dept of Natural Resources (DNR) to the Washington State Parks Commission)
•Invasion of noxious weeds into an undisturbed area—According to the Biological Survey conducted by PBI, Biological Surveys Conducted in the SEIS Analysis Area at Mt. Spokane State Park During 2010, there are currently no noxious weeds in the Biological Survey Area, the portion of the PASEA targeted for expansion. This is, as documented in the same report, largely due to the fact that the three predominant noxious weeds in the Park; common tansy, orange hawkweed, and Dalmatian toadflax thrive in disturbed open areas. The BSA area, the area of the proposed new chair in the PASEA, is now mostly forested, a fact that will change if the ski area expansion is allowed to proceed. (The Sierra Club in conjunction with the Save Mt. Spokane Coalition conducted an invasive weed survey in the current ski area, Mt. Spokane Ski and Snowboard Park, in 2009. See attached document.)
•Negative impacts to wildlife and wildlife corridors – The forests on the north and west slopes of Mt. Spokane provide a significant linkage corridor for a number of migrating mammal and bird species that are on the list of Washington Department of Fish and Wildlife Species of Special Status for Mt. Spokane State Park (see attached list). This area has been identified as suitable habitat for lynx, wolverine, Northern Rockies grey wolf, marten, Northern goshawk and other species needing intact native forests and un-fragmented, road-less forest habitat. Lynx have been documented in the area, and the sub alpine habitat within the boundaries of Mt Spokane State Park provide suitable habitat for wolverine, a threatened species that requires deep snow pack for successful reproduction.
In a letter to Washington State Parks and Recreation Commission dated January 29, 2007, the Washington Department of Fish and Wildlife writes:
The native mature forest habitat on the northern aspect of Mt. Spokane is an extremely unique forest ecosystem with a high value for wildlife and species biodiversity. Considering its size, its un-fragmented condition along with its stage of forest succession and structure, a similar forest could not be found anywhere else in Spokane County nor replicated.” This speaks to the uniqueness of the area. WDFW continues, “WDFW is opposed to the Proposed Alpine Ski Area Expansion (PASEA) proposal due to the unavoidable and extensive impacts to wildlife habitat and wildlife species associated with such a proposed ski expansion.
According to the Biological Survey conducted by PBI, Biological Surveys Conducted in the SEIS Analysis Area at Mt. Spokane State Park During 2010:
Nearly all the forest stands in the BSA have abundant large and small snags of various decay
classes, providing abundant habitat for wildlife species that depend on snags for nesting,
foraging and roosting. In some stands, snags are more common than live trees. Likewise, there
is an abundance of coarse woody debris in the forests of the BSA. Many polygons within the
BSA have very high levels of large coarse woody debris. There is no lack of habitat for wildlife
species that depend on coarse woody debris for any of their life stages or activities within the
BSA. Outside of the BSA, most forest stands also have abundant snags and coarse woody
debris.
•Impacts to wetlands - The expansion area proposed by Mt Spokane 2000 contains a significant number of streams and wetland area. Cutting in ski runs and adding chair lift towers will have significant impact into a fragile wetland environment.
According to the Biological Survey conducted by PBI, Biological Surveys Conducted in the SEIS Analysis Area at Mt. Spokane State Park During 2010:
-Figure 28. Polygons containing wetlands with the BSA, page 56 of the Biological Survey conducted by PBI, Biological Surveys Conducted in the SEIS Analysis Area at Mt. Spokane State Park During 2010 demonstrates that the area of the proposed new chair is highly invasive into an ecosystem that is wetland dense.
-Figure 29 of the same survey, illustrates the high number of streams that will impacted. The area of the proposed expansion by Mt Spokane 2000 will have great impact to the existing watershed on Mt Spokane, an area that has demonstrated in the past, in times of rapid snowmelt, to be vulnerable to flash flooding. Disturbance to such an area will only increase this risk of flooding.
“Several of the plant associations [in the BSA of the PASEA] are uncommon or possibly unique, particularly those in wetlands”
“Most of the polygons within the BSA contain streams, springs and small wetlands. The north side of Mt. Spokane receives abundant moisture and holds the snow-pack into the early summer. The resulting abundance of moisture is very evident throughout much of the BSA. The streams, springs and small wetlands that result provide habitat and water for many wildlife species, including many listed in Table 4 of this report.”
•Impacts to the view - The cultural significance and view is very important to many residents in Spokane and the surrounding community. The natural beauty of the west and northwest side of the mountain is a backdrop for our community, one that would be forever altered by the expansion.
It is critical that the native forests on Mt. Spokane remain intact. We would like your support for permanently designating the north and west slopes of Mt. Spokane as a Natural Forest Area, protecting it for future generations. We also request that funding earmarked for a new lodge at Mount Spokane State Park include a requirement that the lodge be available to be used as the site of an Environmental Learning Center, and that the public be given an opportunity to give input on facility design and location of a new lodge.
Respectfully submitted,
Chris Bachman, Upper Columbia River Group, Sierra Club, Spokane, WA
Cc:
Fred Olsen, Chair, Washington State Parks and Recreation Commission
Joe Taller, Vice Chair, Washington State Parks and Recreation Commission
Rodger Schmitt, Secretary, Washington State Parks and Recreation Commission
Patricia T. Lantz, Washington State Parks and Recreation Commission
Eliot Scull, Washington State Parks and Recreation Commission
Cecilia Vogt, Washington State Parks and Recreation Commission
Lucinda S. Whaley, Washington State Parks and Recreation Commission
Deb Wallace, Strategic and Long-range Planning Manager
Tom Ernsberger, Manager Resource Stewardship, Washington State Parks
Steve Christensen, Park Manager, Mt. Spokane State Park
Cris Curry, chair of the Mt. Spokane State Park Advisory Committee
For more information visit: www.savemtspokane.org, or
contact: Chris Bachman, Upper Columbia River Group, Sierra Club,
509-280-8159, chrisbachman@comcast.net