OFCO Comments: Miller Peninsula Sequim Bay Park Development
July 13, 2021
Washington State Parks and Recreation Commission
Planning Program
PO Box 4250
Olympia WA 98504
Attn: Nikki Fields
nikki.fields@parks.wa.gov
Via electronic communication
RE: Miller Peninsula and Sequim Bay State Parks Development – Written Comment
To Whom It May Concern:
The Olympic Forest Coalition (OFCO) is a member organization working to protect and restore the environment, habitats, and threatened and endangered species of the Olympic Peninsula including its forests, watersheds, and associated marine waters. Thank you for the opportunity to comment on the development at the Miller Peninsula and Sequim Bay.
OFCO members and Board members view the need to develop the Miller Peninsula and Sequim Bay Park as an important development for the landscape, native species, our local communities and families to use recreationally including camping and horse and hiking trails, bird and wildlife enjoyment. OFCO believes that the development should result in affordable recreational opportunities for families from the Peninsula and Washington state to enjoy, of a scale appropriate to the natural resources available in the area, and that does not threaten existing recreational uses, wildlife or rare plant communities. OFCO is concerned that inadequate effort to meet SEPA and other requirements has been incorporated in the planning process thus far, and the development alternatives clearly show that all recreational interests have not been fully balanced within the plans. With that in mind, OFCO offers the following comments.
Full SEPA Review Needed for Alternatives
OFCO believes a full SEPA review process must be undertaken for the large-scale major development planned in all three alternatives. The information presented in the June 30th public meeting was conceptual in nature, non-specific, and the hand-written maps are inadequate to meet SEPA and public consultation requirements. Without the information and analysis of a SEPA review, the public cannot fully engage and provide comments with necessary specificity to meet SEPA requirements. With the information provided thus far, we cannot know if the new roads and trails, RV sites, beach trails, will impact sensitive areas and species. While lack of financial resources and prioritization in Park planning has resulted in a phased approach, SEPA review may not be inappropriately tiered on earlier decisions with a development of this scale. In 2016, Park staff indicated that the development may not require full SEPA review:
“Following review, staff has determined that the proposed “Candidate Park Selection” was identified as a future phased action within the State Environmental Policy Act (SEPA) checklist for the “Statewide Acquisition Development Strategy”. The “Determination of Non-Significance” for that action was issued on June 21, 2016. The consideration of candidate parks proposed in this agenda item is categorically exempt from further SEPA review under WAC 197-800(17). Future proposals, if any, for the selected sites will also undergo SEPA review as part of phased review under WAC 197-11-060(5). Those proposals may be categorically exempt or may require a threshold determination.”
Andy Woo, Assistant Attorney General: October 29, 2019
Peter Herzog, Assistant Director
Approved for Transmittal to Commission
OFCO requests that the Parks Department clarify if a full SEPA review will be undertaken for the alternatives presented. OFCO requests the Parks Department fulfill SEPA requirements for the Miller Peninsula and Sequim Bay Park development.
Endangered Species and Rare Plant Surveys Must be Made Available to the Public
The WA state park’s Miller Peninsula planning group has completed a rare plant survey, but did not provide that information to the public. No information on threatened and endangered species has been provided. During the June 30th meeting, responding to questions, Park staff indicated they have not done a survey of birds beyond identifying some eagles’ nests. The rush to develop Miller without full wildlife surveys may cause the Parks Dept. to overlook critical habitats. No information about birds or other T and E species was presented in any of the alternatives. OFCO’s Board member reviewed the list of birds available on the “Ebird” website seen at Miller Peninsula. In the last month eleven Marbled Murrelets were spotted. While the most likely explanation is they were probably on the water or in transit, the Parks Dept. should work with appropriate state agencies to survey T and E species. The Miller Peninsula planning group designated on maps most of the park land between Discovery Bay and Diamond Point Road as having rare plant communities. OFCO Board member and volunteer visited the site July 9th and viewed tree species that maybe suitable trees for nesting near Discovery Bay for Marbled Murrelets, eagles, ospreys, or other species of concern. There may be areas along the cliff or shoreline that would be of concern for nesting birds. The Park is also a well regarded birding site and many on the Peninsula enjoy it for the opportunity to view birds.
The Alternatives all indicate there are trails planned to the beach, and more trails, camping sites, and development planned around wetlands and rare plant communities. Members report that there is an important stand of Madrona that is not clearly protected in the planning information.
With even meeting the minimum SEPA and wildlife review necessary, the Alternatives presented could indicate more clearly that all important public interests have been considered, and any measures needed either on the landscape or seasonally to avoid sensitive habitats will be taken.
OFCO requests that the Parks Dept. clarify whether it will undertake wildlife and rare plant community reviews with appropriate state agencies and make that information available to the public, including recommendations for measures to protect existing sensitive areas and species. If the reviews are not planned, OFCO requests that the Parks Dept. include these reviews in the planning process to meet minimum SEPA, and possibly NEPA, requirements.
Scale, Scope, Balancing all Recreational Interests, Education, Specific Concerns about all Alternatives
The Miller Peninsula Park has been the subject of studies, planning and public comment processes beginning in 2006. It has been over fifteen years since the first plans were developed and input from the public was received and tabulated. It has been eight years since the first initial stages of development began. In the interim, users of the park forged their own paths. Parking is now available for cars, trucks, and horse trailers. Restrooms have been built; a few picnic tables can be found on site. People are using the many crisscrossing trails and moms with strollers as well as families pushing elder’s wheelchairs appreciate the easy half mile loop that was created. Accommodations both public and private increased considerably.
As we consider further development, we must also consider changed conditions. We can see the effects of the twenty-two-year extended drought in the western U.S. Fires have been extensive and devastating on the Olympic Peninsula in the last several years. With that in mind we need to analyze the impacts that further park development will mean for the landscape, the people who use it and live nearby, and the wildlife that depends upon the natural resources.
The major areas of consideration for development are:
- The availability of water in the Park;
- The value of the Park as a carbon sink;
- The desirability of a refuge for people and wildlife;
- The importance of a living educational tool;
- Affordability for families of Washington to use the Park, not using public resources for an expensive development for RVs, concessions and lodging that is inaccessible to moderate to low income families;
- Financially supported and adequately scaled emergency services;
- Segregate and exclude incompatible uses.
Availability of water is a critical issue to the appropriate scale for development. Before any development began at Miller in 2008, Sequim area ground water was evaluated in a report by the Pacific Ground Water Group (1). It determined that groundwater recharge resources were exceeded by withdrawals as the number of wells had increased dramatically from the 1980s. While the basic study area was that of Sequim proper it noted that water withdrawals in 2007 represented more than twice that of 1980. Much development has occurred since that time with the addition of business and hotel space in Sequim Bay and residential and business areas. If climate change represents a 15% decline in ground water recharge and growth takes another percentage, it is of concern to remove more ground water to supply additional large-scale development on the Miller Peninsula or on Sequim Bay. As overall precipitation decreases, the water table lowers and temperature increases cause greater water consumption, the natural resources may suffer. Mitigation with gray water or wastewater recycling helps and should be considered in any development but will not solve the water resource shortage. Even without any additional development, water resources will need to be expanded to supply hikers, bikers, horses, and picnickers as overall temperatures rise. The one existing well USGS reports is a residential well drilled over 300 feet down, indicating that water is not easily accessible. Any development must take into consideration the need to balance protecting and conserving water resources.
OFCO recommends that the Parks Dept. analyze fully existing water resources in the area, within and outside the Park, and scale the development to existing and future water shortages – both for the recreations users, and the landscape flora and fauna. The information should be made available to the public during SEPA review.
Managing the forest for carbon and climate change in the Park. The Miller Peninsula forest is a temperate forest that plays an important role without further change. Though once logged, this forest is significant for carbon sequestration as each tree expands and adds girth with age. A summary in a scientific paper points to this critical point: there is ‘clear evidence that natural forests are much better at storing carbon in trees and soils than in managed forests…” (2). Without any effort other than stewardship, the forest is working for people. We have done poorly in retaining forests as carbon sinks. Research again shows that only 20% of the carbon of harvested timber is retained as long-term storage. In a 150-year period wood ends up in landfills or simply decays. Harvesting wood does not ultimately lend itself to long-term carbon storage, it is a net loss.
As climate change increases temperatures overall, it affects the frequency and intensity of heat waves. Late June 2021 is a case in point. Temperature buffering beneath a forest canopy can reduce the heat of the day by as much as ten degrees. (3) To find relief more people will seek the cooler forest, the cooling sea breeze on the beach or a take a dip into the sea itself. Even without further development, more water stations will be needed to prevent heat exhaustion for both humans, their animals and forest creatures. Retaining the forest as forest is necessary for mitigating climate change by retaining the ability of the landscape to capture carbon, to capture and store water resources, and to retain the cooling effect of forested landscapes. Development should balance this public interest.
While the Miller is not an old growth forest, the Miller forest is still an excellent representation of a low land ecosystem. Plant populations and associations specific to this site are important. Species inventories could add an educational tool to enrich users’ experience through informative signs as people enjoy the forest. Its 2800 acres provides a peace and quiet that those who visit appreciate. Wildlife, too, depend on having quiet places to raise their young and seek Miller as a refuge. Managing the Miller forest for this public interest is equally important.
Management of the Miller Peninsula and Sequim Bay forest should include managing for carbon storage. Carbon management should be included in the planning documents and made available to the public for review in the SEPA process. The Planning information should also include recommendations for emergency cooling stations for animals and users.
Recreation and education for the Park experience. The development that is needed on the Miller Peninsula should also include the realm of education. Children and people of all ages can learn the effects of sun, water and nutrient recycling on the survival and interactions of plant, bird and animal species. Monitoring the effects of climate change over time on the Miller would be of great value to both scientists, decision makers, and the general public. Creativity is the hallmark of human endeavor. Encouraging the understanding and mitigation of climate change through examples in the park may impact us more than simply to use it as a recreational resource. Understanding the effects of climate change is critical to our survival. The investment would be small compared to the scale being considered. The Parks Dept. may take this opportunity to work with local school districts to develop the plans, and include teachers and students in the process.
OFCO recommends that with the scale of investment planned, that the Parks Dept. take the opportunity to also include a more robust and full educational experience that will help the public learn about the important role of the environment in our lives. This information should be made available to the public in the SEPA process.
Affordability for all Washington families to use the Park. Alternatives 2 and 3 gave conceptual information that is of concern due to scale, appropriateness for public investment, and affordability. Using tax dollars for development that only those who can afford expensive RVs, lodging, and concessions is not appropriate. Low-scale camp sites for tents, small trailers and RVs, should be prioritized for public resources. Existing private facilities for large RVs are available nearby and should not be duplicated with public dollars on site. Private profiting from public investment is not an appropriate use of public resources. The Parks Dept. must include sufficient financial information on planned revenue generation, camping and concession fees, to ensure that the development will be affordable for all families, and not just upper income recreational users.
OFCO recommends that the Parks Dept. provide full information about fees and concessions to fulfill its requirements to ensure that the Park is affordable for moderate and low income families and users.
Adequate emergency services should not be the burden of local government. No information about adequate emergency services has been provided by the Parks Dept. (fire, ambulance, police). The Parks Dept. should include information about the necessary expansion of these service, how they will be financially supported into the future, and ensure that emergency services are adequate to meet exceptional circumstances such as fire or heat domes, as well as ensure that the financial burden does not fall to taxpayers in the local municipality and county.
OFCO recommends that the Parks Dept. include full planning for emergency services and make the information available to the public, including the financial burden and the source of revenue to support emergency services for a state-wide user base.
Incompatible uses should be isolated and some excluded from the development. Some recreational uses are incompatible. Motorized bikes and four-wheelers, and the trails and infrastructure needed to support that use, are not compatible with camping, hiking, horse-back riding, viewing and enjoying nature. There are existing areas in the vicinity for motorized vehicle recreational use. We do not include motorized accessibility equipment in this recommendation. Accessibility for all areas of the Park should be an integral part of the planning and public investment. Policing motorized bikes and four wheelers’ use inside the Park so that they do not impact other recreational users would be difficult if not impossible to staff on site. Navy Seal training of combat teams is incompatible with recreational use and should also be excluded from this Park.
OFCO recommends that the Parks Dept. clearly designate areas for camping, hiking, bird-watching, and wildlife protection away from existing high quality habitat and higher use areas. The Parks Dept. should clearly establish and publish schedules and areas for amplified sound use, limiting these areas. The Parks Dept. should exclude recreational motorized bikes and four wheelers from the Park. The Parks Dept. should exclude all Navy Seal combat training from all portions of this Park.
After a full SEPA process, the Parks Dept. should plan further development of services that will protect all existing habitats and wildlife following adequate surveys, scaled for the Miller Peninsula water resources, develop serious educational programs to demonstrate the importance of the Miller forest in the mitigation of climate change and as an ecosystem, ensure affordability, emergency services, and exclude incompatible uses.
Thank you for your kind attention.
Sincerely,
Rae Deane Leatham /s/, Board Member, Olympic Forest Coalition
Connie Gallant, Board President, Olympic Forest Coalition
Patricia Jones /s/, Executive Director
References:
1. 2009, City of Sequim, 2008 Hydrogeologic Monitoring Report, Pacific Groundwater Group, Seattle Wa).
2. 2020, Moomaw, W.R., Law, B.E., Goetz, S.J., : Focus on the role of forests and soils in meeting climate change mitigation goals: summary in Environmental Research Letters 15(2020)045009.
3.2019, De Frenne, P., Zellweger, F., Rodriguez-Sanchez,F,Schaffer’s, B., Hylander, L., Luotol, M. Lenoir, J., 2019, Global Buffering of temperatures under forest canopies, Nature Ecology, Evolution, 3, 744-749.