STATE OF WASHINGTON
DEPARTMENT OF FISH AND WILDLIFE
2315 N Discovery Place Spokane Valley, Washington 99216-1566 (509) 892-1001 FAX (509) 921-2440
January 29, 2007
Washington Sate Parks and Recreation Commission
Attn: Mr. Daniel Farber, Parks Planner
PO Box 42650
Olympia, WA 98504-2650
Mt. Spokane State Parks Advisory Committee
Attn: Mr. Cris Currie, Chairman
621 W. Mallon Suite 509
Spokane, WA 99201
SUBJECT: Mt. Spokane Potential Alpine Ski Expansion Area (PASEA)
The Washington Department of Fish and Wildlife (WDFW) would like to offer the following information for consideration by Washington State Parks and Recreation Commission and the Mt. Spokane State Parks Advisory Committee members during the scoping phase for possible ski area expansion. This is a preliminary set of comments. WDFW is working to prepare a more complete and detailed set of comments prior to the March 8, 2007 State Parks Commissioners Meeting.
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. There may be some commercial forest holdings of this size in Spokane County but their forest management practices would prohibit their lands to reach this mature structure. WDFW is opposed to the Potential Alpine Ski Expansion Area (PASEA) proposal due to the unavoidable and extensive impacts to wildlife habitat and wildlife species associated with such a proposed ski expansion. The following bullets list our concerns:
•Mt. Spokane and Turnbull National Wildlife Area are the two main wildlife areas in the Spokane area. Known as “Core Areas”, they are large unfragmented areas, nearly roadless, of secure (public ownership) high quality habitat connected by movement corridors that are regionally important to the wildlife. These core areas have been identified and mapped by the University of Washington, WDFW, Spokane County, and Inland Northwest Land Trust.
•The University of Washington and the Inland Northwest Land Trust as an important core area also identified Antoine Peak with existing corridors to Mt Spokane. This linkage to Mt. Spokane is critical and is part of what makes the area so unique and significant (See attached Corridor Map).
•The Inland Empire Paper (IEP) land adjacent to Mt. Spokane State Park (MSSP) on the north, northeast, and east, is managed timberland. When the property value becomes more profitable as real estate than timber extraction, it will either be traded or sold as has happened with Boise and Plum Creek on the west side. This makes the conservation of Mt. Spokane more valuable than ever.
•The IEP land is managed timberland and does not have the same ecological value as the intact forest ecosystem present on the north side of Mt. Spokane. Only under the management of a non-profit public entity like the WA State Park System could such a mature forest develop. This is what makes the MSSP property unique and able to support a high biodiversity of flora and fauna.
•Rare forest carnivores utilize the forested ecosystem of Mt. Spokane including: lynx (Federal Threatened and State Threatened), and wolverine (Federal Species of Concern and State Candidate). These carnivores are present because of the existing forest class and structure.
•The unfragmented forest habitat on the north side of Mt. Spokane provides an important area of cover for large ungulates found on and around Mt. Spokane.
•WDFW has been conducting early winter composition survey flights on moose and elk since 1990. The survey work was sporadic throughout the 1990’s. Standardized aerial surveys took place during the winter of 1999-2000, with annual winter survey work beginning in 2002. The Department has therefore collected multiple years of data on moose and elk use in the habitats of MSSP and surrounding areas.
•Moose prefer 15-25 year old clearcuts or thinned stands for foraging. However forested cover is important during summer heat and deep winter snow (Costain 1989). While moose may forage on adjacent large timberlands, they utilize the secure habitats on Mt. Spokane for cover, particularly in the winter months (WDFW, 2005). During the heat of the summertime, moose are found in the covered drainages (WDFW).
•Elk utilize Mt. Spokane year-around. Elk populations are most threatened by habitat degradation due to urban expansion, increased roads, and human disturbance (WDFW, 2005). The proposal for developing the north side of Mt. Spokane would further fragment existing elk habitats.
•The Comprehensive Wildlife Conservation Strategy (CWCS), Washington’s plan for conservation of wildlife species, lists biodiversity conservation as one of its four main strategies. The habitats within the unclassified area of MSSP support a high biodiversity of wildlife species.
•Other WDFW Priority Species and Species of Concern that utilize the intact forest on the north side of Mt. Spokane include: pileated woodpecker, black-backed woodpecker, northern goshawk, boreal owl, great gray owl, bald eagles, golden eagles, as well as numerous neotropical migrant bird species, and forest bats. (See attached table of species)
•The streams that originate in the park include Blanchard Creek, Deadman Creek, and Brickel Creek. All three streams are important fish streams and part of the Little Spokane Watershed Unit. The development of the PASEA would have additional water quality and habitat impacts to these drainages and the fish resources that inhabit them.
•Priority Habitats that occur within the PASEA include: riparian, freshwater wetlands, aspen stands, cliffs, instream habitats, rural natural open space, and old growth/mature forests.
•The north side forest meets the definition of WDFW’s Priority Habitat of Mature Forests with an average tree diameter exceeding 53 cm (21 in) dbh. These forests support high wildlife density, high wildlife species diversity, provide important wildlife breeding habitat, important wildlife seasonal ranges, and are of limited and declining availability with high vulnerability to habitat alteration.
•The northern aspect forest differs completely from other forest areas within MSSP that are currently classified as Natural Forest Areas or Natural Areas Preserves under the Mt. Spokane Park Land Classification. Due to its aspect, these areas are of a completely different forest class and structure.
•RCW 36.70A.103 requires State Agencies to comply with local comprehensive plans and development regulations and amendments. The MSSP property is zoned Rural Conservation. This category applies to environmentally sensitive areas, including critical areas and wildlife corridors and encourages low-impact uses and utilizes open space techniques to protect sensitive areas and preserve open space (Spokane County Comprehensive Plan).
•The proposed expansion must be compatible with existing zoning regulations as well as the Priority Habitat and Species information, which the County has adopted by reference.
•MSSP is a multiple-use recreational site. In addition to winter recreation the site provides economic vitality to Spokane County through passive non-consumptive uses as a Watchable Wildlife site.
•The expansion ultimately would mean year-round disturbance for wildlife. There exists a vast amount literature on the effects of recreational activity on wildlife. (See attached list of examples)
•MSSP mentions that one of the advantages to expanding to the backside is an “extended season” due to aspect. This effectively means that the ski area can stay open longer. The impacts to wildlife species from extended human use include: 1) hibernating black bears – affecting the ability to, and the coming out of, hibernation and, increases in human/wildlife contact; and, 2) effects on moose and elk calving.
•The argument that the property is already being utilized by backcountry skiing and snowboarding, as well as snowshoeing and hiking does not compare with the creation of a developed ski area. Expansion means fragmentation of the forest with wide swaths of permanent clearcuts, lighted ski runs (further affecting the wildlife even at night), the construction and maintenance of new roads and ski lifts, the expanded footprint of the ski area plus associated facilities including warming huts, lodges, parking areas, more cars on the park roads, and condominiums, as well as the impact from increased human use. There is extensive literature on the impacts to wildlife species from new and increased recreational ski areas and associated activities.
•Potential replacement property of equal ecological value would be unaffordable at today’s land prices. Case and point: Antoine Peak. This piece of property was valued at $11 million for 1100 acres. Applying the same value of $10,000 per acre to the 600 to 800 potentially impacted acres at Mt. Spokane and the figure comes out to between $6 million and $8 million.
•Replacement of such a unique and ecologically valuable core area would be impossible. The forest type is completely unique for the Spokane area.
Thank you for consideration of these initial comments and concerns about the PASEA. If you have any questions please give me call at (509) 892-1001 x 323. WDFW looks forward to working with Mt. Spokane State Parks and Recreation Commission and the Mt. Spokane State Parks Advisory Committee on this issue.
Sincerely,
Karin A. Divens
PHS/GMA Biologist
Cc: Mark Wachtel, Regional Habitat Program Manager, email
Kevin Robinette, Regional Wildlife Program Manager, email
Howard Ferguson, District Wildlife Biologist, email
Woody Myers, WDFW Wildlife Science Division
Washington Department of Ecology, SEPA Coordinator
John Pederson, Spokane County Assistant Planning Director, email
Rex Crawford, Washington DNR Heritage Program, email
Rance Block, Rocky Mountain Elk Foundation, email
Fred Zitterkopf, Inland NW Wildlife Council, 6116 N Market St. Spokane, WA
Gary Blevins, Spokane Audubon Society, PO Box 9820 Spokane, WA
The Nature Conservancy of Washington ,1917 First Ave Seattle, WA 98101
