Emily Lucas, Environmental Specialist 7150 Cleanwater Drive, P.O. Box 42650 Olympia, WA 98504—2650 emily.lucus@parks.wa.gov Subject: Comments on the proposed “Mount Spokane State Park Master Facilities Plan and Master Concession Plan” Dear Ms. Lucas, Please accept these comments on the proposed “Mount Spokane State Park Master Facilities Plan and Master Concession Plan” and four preliminary alternatives on behalf of The Lands Council. While the mission of The Lands Council is to preserve and revitalize the woods, waters and wildlife of the Inland Northwest, many of our board members are avid skiers so the decision to take a position at this time on the proposal to expand alpine skiing and snowboarding on the north and west slopes or Potential Alpine Ski Expansion Area (PASEA) was not taken lightly. After careful consideration, the board of The Lands Council is opposing Mount Spokane 2000’s proposal (phase 1 and 2) to expand alpine skiing and snowboarding into the PASEA. We are in support of the preliminary Facilitates Renovation Alternative. We also support classification of the forests on the north and west slopes of Mount Spokane as Natural Forest Area in the Mount Spokane Facilities Plan. We are opposed to expanding into the PASEA for the following reasons: Mount Spokane State Park is more than a ski area, it provides year around recreational opportunities, scenic vistas, and a large intact forest habitat. The natural forests in the park are unique and provide important habitat for a diversity of wildlife species. The existing ski area already covers about 2/3 of the top of the mountain with lifts and runs. The proposed expansion would develop the remaining top of the mountain, permanently impacting a rare subalpine ecosystem. The forests on the north and west slops of Mount Spokane are representative of the subalpine and mid-montane forests of the Northern Rocky Mountains. While this forest type is not unique to this region, it is rare to have a large contiguous block of natural forests with these habitat types. Development in the PASEA will have a negative effect on the breeding habits of some species that value exclusion, cannot tolerate large openings or noise. Development in the PASEA will fragment a “core area”, which is considered roadless, high quality habitat, and regionally important. The predictions for climate change are that Northwest winter temperatures will be warmer and snowpacks will be less on average (University of Washington Climate Impacts Group). This has implications for the wildlife on Mt. Spokane as some snowpack dependent species will need intact areas to move up and down the mountain through the seasons and from year to year. Maintaining wild forests, continuous forest canopy and wildlife corridors will become ever more important for the southernmost sub-alpine mountain in the Selkirk mountain range. The proposed ski area expansion will fragment one of the last intact forests near the City of Spokane. An intact Natural Forest Area provides a significant linkage corridor for a number of migrating mammal and bird species. Ski area expansion will displace rare forest carnivores, the lynx and wolverine, and disturb WDFW Priority Species. Recreationally, an intact Natural Forest Area provides backcountry and tree skiing for the adventurous right now – something that will be lost if new lifts and runs are created across the entire mountaintop. We believe one of the marketable attractions to Mt. Spokane is the ability to find powder and rugged, natural terrain – for those willing to work a bit to take the trail back to Chair 4. The cultural significance and view is very important to some residents in Spokane. 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. Mount Spokane 2000 has made the argument that the proposed #7 lift is just replacing the runs that were developed in the 1950’s Analysis by the Washington Department of Natural Resources has determined that the forests on the north and west slops of Mount Spokane are natural forests, 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 fragment since the State Park was created. It is critical that these forests remain intact. Backside expansion would open up forest canopy that protects the snowmelt and is an important source of water for the Little Spokane River watershed. The natural forests on the north and west slopes of Mount Spokane are a very important conservation resource that provide wildlife habitat, recreational hiking, snowshoeing, back country skiing, birding and other activities 365 days a year. The impacts are too great to trade off fragmenting this unique forest habitat for winter recreation lasting only 90-120 days. The Lands Council does support much of the preliminary Facilitates Renovation Alternative: - support for new lodge #2 and remodeling lodge #1 – and why this is a critical place to invest funds – deal with current over crowding and outdated buildings. - New, faster front side lifts - More efficient lighting on front side lifts - We support the summer trails improvement - Support upgrading the parking facilities at Lodge #1 and #2. We understand Mount Spokane 2000’s need for snow making capacity, storage and distribution to help ensure an earlier opening, but it is very important that the potential environmental impacts of this proposal be fully addressed in the EIS to look at the impacts of snowmaking on the Spirit Lake drainage and other potentially effected water bodies or streams in the area. In addition, the impacts of water storage need to be analyzed. In addition: We in strong support of the soil remediation and vegetation management for areas identified by Mount Spokane 2000 in the phase 1 proposal that are in need of restoration, which involves bringing in top soil and planting with native grasses and other plants. We also support brush and small tree removal to open old trails, but do not support using herbicides. The current location of chair #4 list needs to be addressed in the EIS and we support raising the chair #4 lift to 4,200 feet or higher out of the wetland, which may increase number of skier days on the backside and allow the recovery of this wetland. Out of concern for increased light pollution, we do not support adding lights to the chair #4 trails. In Summary: We want to see Mount Spokane Ski and Snowboard Park be successful and be able to be financially viable. We do not think that this fiscal viability should be at the expense of fragmenting the last remaining large intact natural forests near Spokane. Mount Spokane 2000 has developed arguments to make the case for expanding into the PASEA that have yet to be backed up by financial analysis. They argue that 49 Degrees North’s expansion has taken away skiers from Mount Spokane and that all of the ski areas in the region are expanding and Mount Spokane 2000 needs to keep up with the competition. What Mount Spokane 2000 has failed to do is to sell what they have, spend advertising money (like 49 Degrees has) to allure skiers to ski their glades. Mount Spokane has excellent glades that they do not advertise. On clear days there is a 360 degree view that is just incredible, and backcountry quality skiing that is lift accessible. The new glades near chair four have created some new unique skiing terrain that is competitive to other areas, and Mount Spokane 2000 has failed to sell the mountains current attributes. With a new Lodge #2 and a remodeled Lodge #1, new chairs, improved infrastructure, and efficient lighting on the front side of the mountain would make huge improvements to modernizing and making the mountain even more enjoyable that it already is, and will encourage skiers to come to enjoy their local mountain. We believe that the existing terrain offers an incredible ski experience that should enable it to thrive over the coming decades – with appropriate upgrades and marketing. The area is the closest to Spokane and will benefit relatively from rising gas prices. Thank you very much for the opportunity to comment. Sincerely, Mike Petersen, Executive Director The Lands Council 25 W. Main, Suite 222 Spokane, WA 99201 509-838-4912 mailto:emily.lucus@parks.wa.govshapeimage_2_link_0