April 21, 2018

Randy Kline Project Manager CAMP Planning Process State Parks Department P.O. Box 42650 Olympia, WA 98504

RE: Comment letter on Wallace Falls State Park Classification and Management Planning (CAMP) Stage 2 - Exploring Alternative Approaches

I would like to thank the Washington State Parks Department for the opportunity to comment on the Wallace Falls CAMP process. As the founder of the Friends of Wild Sky, I would like to acknowledge my support for the suggestions and recommendations which are contained in the conservation/recreation Joint Comment letter on Wallace Falls State Park Classification and Management Planning (Coalition) letter dated April 21, 2018. However, as the most knowledgeable person of the Reiter/ Wallace Falls area in the coalition, I would like to offer some background information and several other suggestions beyond the scope of the coalition letter.

My background of this area and the processes which have occurred north in the Reiter Forest and the Wild Sky Wilderness are extensive. I have lived near this area in Sultan, Monroe and Duvall for over 3O years. I earned a BS in Terrestrial Ecosystem Analysts, worked as a silvaculturalist for the USFS and taught Ecology for over 30 years. For years, I wrote a newspaper column on hiking, biking and history along highway 2 for the Monroe Monitor. My columns were eventually featured in a hiking guide book published by Mountaineers Press. I also founded the Friends of Wild Sky an organization which played a major role in the creation of the Wild Sky Wilderness in 2008. Based on my knowledge I was invited to testify as an expert witness to committees in both the United State Senate and House of Representatives.

In 2007, I was selected to represented non-motorized recreational as a member of the Reiter Forest Focus group which put together the Reiter Forest Recreation Plan.

My knowledge of the ground in this area is significant and over the past 10 years, I have spent over 1000 hours as a volunteer in this area, ground truthing existing trails, plotting locations of potential trails, leading hikes, building trails giving presentations and escorting press, elective and administrative officials to specific places in the area. At the request of the DNR, I have also spent considerable time route finding trails from the Snohomish County trailhead to the new bridge in Wallace Falls, and along May Creek. I have also coordinated letters from many organizations to support recreation grants.

I would like to thank the Washington State Parks Department for the opportunity to comment on the Wallace Falls CAMP process.

BACKGROUND

Wallace Falls State Park is a jewel in the State Park system. With almost 200,000 annual visitors (which does not count the number of hikers turned away because of lack of parking), it is one of the most popular recreational designations both in the State Park system as well as in Snohomish County. However, a bold long term vision for the future is critical to ensure the park continues to meet the needs of the public.

The Wallace Falls CAMP process is a once in a generation opportunity which can solve current management problems as well as future recreational issues in an area with a rapidly growing population. One of the purposes of the Camp process is to “adapt long term boundaries”. It is imperative that this process identifies and recommends the best places to designate money that meets the needs of future population growth and is fiscally responsible.

As part of the CAMP process, State Parks and the public have identified numerous problems which need to addressed. These include, but are not limited to, the lack of adequate parking at the current trailhead, the over use of current trails causing resource damage and the need for more diverse recreational opportunities.

At the March public CAMP meeting, State Parks presented 2 different potential alternatives. We would suggest that the Enhanced Recreation Emphasis Alternative would be the better option if it also included several additions included at the end of this letter.

CONCERNS WITH THE STATE PARKS CAMP PROCESS

Before I begin, I feel that I must point out some of my concerns with the CAMP process. In order for the public to offer informed comments on the potential alternatives, I feel that State Parks should have been more transparent with the public about potential threats to recreational opportunities on adjacent DNR land which would impact forests within the current park and trails which lead into the park. However, both the presentation and the materials given out at the public meeting did not bring up these threats. Without this knowledge, it is difficult for the public to offer informed comments based on this critical missing information.

For example, at both public meetings, many members of the public supported that the area which is best suited for park addition lies to the south and east of the park between Wallace Falls and the Snohomish County trailhead. Unfortunately, in its presentation and materials, State Parks did not identify that this area has been proposed by DNR for a clearcut (Singletary VRH) which is slightly under 200 acres. This clearcut which could occur as early as 2 years from today, will have significant impacts on the park ecosystem and affect the opportunities to expand recreation by building trails in this area.

The public also needs to know that the Singletary clearcut would log along the Wallace Falls boundary for more than a mile. In turn this harvest would result in resource damage to trees in Wallace Falls Park due to wind falls.

The public needs to know that a large clearcut extending from the Wallace Falls boundary beyond the Snohomish County trailhead will also have significant impacts on current and proposed new trails. For example, the proposed clearcut would destroy a currently built 3-mile multiple use loop trail leading to a beautiful mossy rock view point which was paid for by grant money and partially built by volunteers. Included in the area of the clearcut are trails for mountain bike trails, proposed trails for horses, a partially built trail leading into Wallace Falls Park eventually connecting to the new upper bridge over the Wallace River, and a proposed trail leading to May Creek which can pass the historic 100-year-old Pelton Wheel and eventually lead towards Mt Nina and Lake Isabel in the Wild Sky Wilderness. A massive clearcut which starts right at the new Snohomish County trailhead, makes it doubtful that grant reviewers for competitive trail construction grants will prioritize that trails in this area should be funded. Accordingly, it would difficult to recruit volunteers to an area which for decades would be viewed as ugly, by the average volunteer. The clearcut will also cut along the border of the new Snohomish County trailhead and will discourage the average recreationalist (especially families) to choose to hike from this site. Finally, the area of the clearcut is in a 90-year old forest which could be managed as a State Parks “natural forest” area.

It is my belief that the public strongly supports connecting this area to Wallace Falls because of the existing and potential trails which could connect the Snohomish County trailhead to State Park. These trails will decrease the overcrowding and resource damage issues on existing State Park trails and increase recreational opportunities in the State Park. Accordingly, the Wallace Falls parking issue can be solved by using the existing Snohomish County trailhead.

However, it is doubtful that many members of the public would support the Recreation Emphasis Alternative recommendation of the CAMP process if they knew this area was shortly going to be clearcut. Furthermore, members of the public who supported the CAMP process based on the inclusion of these trails and trailhead will probably feel upset when within a few years of the CAMP process, the area which the pubic thought was going to increase recreational opportunities will be logged. The omission of a discussion on this clearcut undermines the public comment component of the CAMP process. In a few years, it may be seen by the public as a BAIT and SWITCH tactic.

Allowing the Singletary clearcut to occur would negatively impact the opportunity for reducing the parking problem by dispersing recreationalists to an additional trailhead. It also will greatly reduce the potential to solve the recreational trail issues in Wallace Falls. Expanding the State Park into this area is the best way to solve most of the problems identified in the CAMP process

TRUST LAND TRANSFER

Another omission which was not addressed at the public meetings was the opportunity to increase the size of Wallace Falls using the Trust Land Transfer (TLT) process. Because TLT’s have been used to expand protection for public land throughout the state, we question why State Parks is not pursuing even the discussion of this option. In conversations with State park officials, they commented that “DNR was not interested in any Trust Land Transfers”. If this is the case, we hope DNR does not get the opportunity to veto public input.

Finally, State Parks recommended acquiring private land to the north of the park. However, the key to increasing recreation in this area is not for State Parks to try to acquire private lands for park expansion. Most of these lands have recently been clearcut. The best recreational opportunities are to expand Wallace Falls on to DNR land to the south and east where miles of trails already exist and there is a current plan to build additional trails.

State Parks should consider expand Wallace Falls south and east into DNR lands using the TLT process and let DNR acquire the private forest lands in the north as replacement lands for the Trust Land Transfer. After this is completed, State Parks and DNR could work on shared recreation on these newly acquired DNR lands. However, the trails to the south and east of the park should be the priorities for recreational development for inclusion into Wallace Falls State Park through the TLT process. CONCERNS WITH THE PARKING ISSUE

State Parks presented that one of the solutions to the parking issues was to acquire private land near the current trailhead, as well as expanding the existing parking lot into the work area. We question the decision of asking the legislature to appropriate money and the time to buy private land for a new trailhead when a location for a second trailhead already exists (Snohomish County trailhead) and is in public ownership. Furthermore, expanding the current Wallace Falls trailhead without building new trails will only increase the overcrowding and resource damage on the existing trails in Wallace Falls.

Instead of purchasing land for parking lots, I would suggest that State Parks recommend to the legislature for money to expand recreation opportunities by using the TLT process to acquire the area between Wallace Falls and May Creek. This area with its 90-year-old forest should also be recommended as a State Park “natural forest” area.

NEED FOR AN ADDITIONAL MEETING

The significance of the Singletary to May Creek area, in regards to solving the trailhead parking issue, adding new trails and diversifying recreational opportunities, combined with the State Park’s Department’s decision not to inform the public about the Singletary timber sale should require State Parks to convene an additional meeting, or propose a third alternative (discussed later in this letter) which could be used to acquire this area utilizing a TLT, before it is clearcut. It is my belief, that the public needs to understand this critical information in order to make the most informed comments on possible alternatives.

THE NEED FOR TRAILS

A recent survey by Neilson reported that 41% of the population in Seattle hikes compared to less than 25% 10 years ago. When population growth is added, the percentage of hikers has doubled in the past 10 years and totals 940,000 people in the Seattle area who hike at least once every year. Based on hikers who hike multiple times a year, this equates to millions of visitors to existing trails. Wallace Falls receives a significant number of hikers from Seattle and the percentage of Snohomish County hiker numbers are probably similar, and are not counted in 940,000 figure.

Yet even though hiker numbers have rapidly increased in the last 10 years, the number of new trails developed along Highway 2 has been minimal. It is probable that hiker numbers will continual to exploded over the next decade and it is critical to open new trails to try to keep up with the demand. If not, we must accept overcrowding of trails and resource damage. This is especially true with low elevation trails which are accessible all year and are uncommon in this area.

DNR MANAGEMENT PROBLEMS

The presentation material identifies that some current DNR lands could have shared recreation management with State Parks. Furthermore, these shared opportunities must be consistent with DNR’s “multiple use” mandate. It is my experience and concern that “multiple use” in the Reiter Forest allows the destruction of existing trails (which have been identified to convey hikers to a Wallace Falls State Park), and harvesting timber along the border of a State Park. This indicates to the recreational community that DNR is not willing to consider the value of Wallace Falls and the need to disperse recreation to a trailhead which Snohomish County trailhead purchased to give access to trails to solve recreation and parking issues. I also feel the Northwest region of the DNR has demonstrated a poor record when it comes to building new and maintaining existing non-motorized trails - especially in areas outside of NRCA’s. For example, the Reiter Foothills Plan recommended motorized and non-motorized trails in the Reiter Forest. Over the past 8 years DNR continued to prioritize motorized recreation and over $3 million of work has occurred on motorized trails in the area. Meanwhile, the area designated for hiking in the Reiter Forest is slated for a clear cut and in the past 5 years the agency has not even submitted a grant for non- motorized recreation while continuing to request significant funding for motorized recreation. As a DNR official once suggested, we don’t want to build trails because it will make the area more difficult to harvest. This statement strongly demonstrates DNR’s lack of interest in increasing non-motorized recreation.

Even if trails were built by DNR, I feel that DNR does not have the staff, or the will, to prioritize the development or management of these new trails. For example, even trails in Morning Star NRCA, which does have a policy to promote non-motorized recreation, are in terrible shape. Recently, even the popular Gothic Basin trail in the NRCA has been suggested for closure.

I feel it is best to consolidate the recreational opportunities around Wallace Falls under one agency, rather than 2 agencies with significantly different management policies. The State Parks with its mandate for recreation, its dedicated staff, a proven record of maintaining trails and a presence on-site is the better agency to manage the trails to the south and east of the park. Therefore, a TRT to Wallace Falls of DNR lands which contain non-motorize trails is clearly the best way to insure long term solutions to recreational issues in the area.

Because the CAMP process occurs so infrequently, I feel that the State Parks must make a bold decision that relies on a recommendation of expanding the park to acquire access to a second trailhead (at the Snohomish County site), and include a plan to increase miles of trails and destinations of trails.

Based on past experience, I feel that allowing DNR to develop these trails will not meet the demands for the number, or types of trails which will keep up with the demand for recreational opportunities. Therefore, I feel strongly that increasing recreational development and natural forest areas in the Wallace Falls vicinity will best be accomplished through recommending a TLT of the areas between Wallace Falls to the Snohomish County trailhead and upstream along May Creek to the USFS boundary.

OTHER THOUGHTS AND SUGGESTIONS

The area around Wallace Falls has significant ecological value. However, there exists several agencies that manage the landscape for different purposes. The intersection of protected land between Morning Star NRCA, Wallace Falls, and the Wild Sky Wilderness suggests that a joint management plan for species protection, recreation and other ecosystem services be developed to insure the best management continuity between these areas. An opportunity exists in the CAMP process for State Parks to study this process in order to evaluate other DNR areas adjacent to the Wallace Falls State Park like the Wild Sky Wilderness and Morning Star NRCA which could be managed with “natural forest” area classification. This should be included in an alternative 3.

Another benefit to the TLT process is that it allows for junior taxing district to be compensated for loss of revenue from Singletary timber sale. This opportunity allows the community which has been divided for decades over timber harvests in the Reiter area to be able to find a compromise which can make the whole community work together for mutual benefits over a larger landscape. One final thought is that based on the Reiter Forest Plan, the DNR identifies non-motorized recreation be divided into 3 areas for hikers, bikers and equestrians. Because Wallace Falls is primarily a destination for hikers, then a TLT into Wallace Falls that includes just the hiking portion of Reiter Forest (trails in Singletary, a trail to May Creek and a trail to the historic Pelton wheel) could be considered. Even though it might be best to include the equestrian and biker sections in a TLT, it is still acceptable that the DNR could develop the equestrian and biking trails on their lands.

OUR RECCOMMENDATION FOR AN ALTERNATIVE 3

I feel that the two alternatives the State Parks presented missed a golden opportunity to recommend a very logical solution which could meet the intentions of most of the visitors to the meetings, and address public comments. As such, I recommend the Enhanced Recreation Emphasis Alternative be amended or an alternative 3 be developed, to include consideration of extending the park utilizing the Trust Land Transfer process from Wallace Falls State Park to the Snohomish County trailhead, and upstream along May Creek towards the historic 100-year-old pelton wheel, towards Mt Nina and Lake Isabel in the Wild Sky Wilderness.

CONCLUSION

Most of the participants at the public meetings recognize the importance of recreation and the need to preserve natural lands in the State Park system. Wallace Falls is the perfect place for State Parks to combine these two objectives. I feel that the best way to accomplish these goals are for the State Parks to recommend the Enhanced Recreation Emphasis Alternative combined with recommendations above to extend the size of Wallace Falls State Park through a TLT process.

Finally, I would suggest that State Parks Department considers the idea of organizing a meeting with USFS and DNR, to coordinate a resource and recreation plan with public input to connect and create a State Parks “natural forest” area between Wallace Falls, Wild Sky and Morning Star NRCA in order to connect these protected areas for ecological conductivity, species protection and recreation opportunities.

Thank you again for the opportunity to add my comments.

Sincerely

Mike Town [email protected]

From: Mike Town [mailto:[email protected]] Sent: Thursday, August 09, 2018 11:41 AM To: Kline, Randy (PARKS) Subject: Wallace Falls Final comments

Hi Randy Thanks for giving me the short extension for comments for the final CAMP. With the short time line and vacations, I was not able to get a full coalition letter together, but you can reference the comments from the last letter as also representing the coalition views on the Final Camp. I am submitting the letter below to you as final comments from the Sierra Club. Basically, I would like to suggest that the Final Camp specifically has language that is consistent with the language for the 2 sentences in bold face below. Also, I wanted to submit to you the same letter that I have sent to the commissioners so you could see my concerns before the meeting.

Thanks again for everything. I really understand the difficulty it is to make everyone happy. But I feel we only get one chance every 30 or so years to accomplish something which future generations will thank us for. The 200 acres is one of the best places for a TLT in the state and any harvest on that land will defeat the opportunity to best meet the needs that the public asked for in the public meetings. Thanks again Mike

August 4. 2018

Washington State Parks and Recreation Commissioners and Director's Office

[email protected]

RE: Wallace Falls State Park Classification and Management Planning (CAMP) comments from the Sierra Club for September Commissioners meeting

Dear Commissioners

I would like to thank the commissioners for their interest in the Wallace Falls CAMP process and the time spent listening to local citizens on their tour to Sultan several months ago. I would also like to bring to the attention of the commissioners a concern that several organizations raised about the CAMP process and suggest a possible solution which could improve future opportunities at Wallace Falls. Finally, I would like to inform the commissioners about a more global problem which developed during the Wallace Falls CAMP process which diminishes the success of future CAMP processes. I am extremely interested in the future of Wallace Falls State Park and surrounding DNR areas. Over the past 10 years I have volunteered over 1000 hours for DNR and State Parks in order to find some solutions to address the concerns in and around Wallace Falls State Park. This work has included ground truthing potential trails, leading tours of the area to State Parks and DNR officials (including the last 2 Commissioners for Public Lands), serving on of a number of different DNR recreation advisory groups, testifying to the Board of Natural Resources, writing support letters for numerous non-motorized trail grants and building trails. During this time, many other members of the Sierra Club and other environmental organizations have also contributed hundreds of volunteer hours.

The environmental and recreational community was very excited about the CAMP process and the potential to solve some of the management issues associated with the park. Together members of the conservation and recreational communities submitted a coalition letter to offer comments on State Park CAMP proposals and offer suggestions which could proactively increase significant benefits for the public without negative ramifications. I am attaching the letter sent to the State Parks department by 19 separate groups which represent over 100,000 members. One of the intents of this letter was to request that in the CAMP process State Parks, would embrace the opportunity of targeted DNR Trust Land Transfers (TLT) to expand the park as part of the long-term boundary. The letter reflected the work of local citizens who for over 10 years have been proposing a TLT for the area between the current park boundary and the Snohomish County Trailhead. These strategies were also brought up by numerous people at several of the CAMP public meetings. It is believed the approximately 200 acre area between the current park boundary and the Snohomish County Trailhead has significant ecological and recreational values which meets the mandate of State Parks and could best address the numerous issues raised by the public during the CAMP process.

Many members of the recreation and conservation communities were hoping that the CAMP process would reflect concerns addressed in the letter and their public input. It was hoped that the final CAMP recommendations would recommend that this almost 200 area be recommended for a future TLT.

Instead, the recommendations from the CAMP process suggested that the State Parks was not interested in acquiring any DNR properties at present.

DNR opposition to Trust Land Transfers

Before and during the CAMP Process, the DNR publicly expressed (in the press and at public meetings) its opposition to a potential TLT. Right before the CAMP process the DNR attempted to decrease the recreation potential for this area being recommended for a TLT by offering to clearcut (VRH) the whole area. One DNR officials even expressed that DNR wanted to log this area before anyone could build trails there. This proposed clearcut also included harvesting timber along the state park boundary for over one mile. As you would expect, many members of the public were appalled, realizing that not only would the DNR clearcut cause resource damage to trees in the park due to blow down along the park boundary, but also that the DNR was proposing this clearcut right before the CAMP process was going to begin. It was also disappointing to the local community that during the CAMP process the DNR was telling the public at public meetings (and in the press) that they were not interested in any TLT with State Parks. Over the past few years, it seems the DNR has been engaged in a deliberate strategy to eliminate the potential of a TLT by harvesting this area before the CAMP process was completed. The DNR even violated SEPA regulations and a judge put the clearcut on hold.

DNR’s inflexibility demonstrated to the broader community a specific lack of respect for State Parks, the CAMP process and the input of members of the community. Based on this history there is little faith that the DNR will want to work with State Park to best meet the needs of non-motorized recreationalist. For example, they are still planning on logging the area between the trail head and the park as well as along the State Park boundary. Building trails starting at a trailhead surrounded by a 200 acre DNR harvest will not provide the solutions needed to effectively disperse recreationalists for decades.

CAMP Recommendations

Unfortunately, a clearcut or thinning operation of this area between the trailhead and the park boundary will significantly, impact the recreational opportunities for a possible trail which would lead into Wallace Falls State Park from the Snohomish County Trailhead.

Unfortunately, State Parks did not address the TLT request made both in the coalition letter and several public meetings in the final CAMP recommendations.

Several State Parks officials cited the lack of interest from DNR. They also suggested that the public write to the commissioners with our concerns.

The Bigger Problem

On a more global perspective, members of the recreational community are also very concerned that the DNR has the power to veto the idea of a TLT. Furthermore, the DNR expressing their lack of interest in a TLT at same time that the CAMP process was occurring, creates a precedent which will impact the success of TLT’s being considered in future CAMP processes. This is especially true where DNR land is adjacent to current and future state parks. The commissioners should be aware of this precedent.

Solutions

I understand that DNR has a mandate to maximize revenue from its timber based. However, Trust Land Transfers have been successfully utilized in numerous other areas where state parks have been expanded into DNR lands. As you know, in a TLT the legislature appropriates money to purchase replacement land so that the DNR can still meet its mandate. Therefore, TLT enable benefits to both agencies as well as the general public. Asking for consideration of a 200 acre TLT in a land base of over 3 million acres forest managed by DNR is a small request -especially when a TLT will compensate the trust beneficiaries. I know that the commission probably would like to avoid any controversy and approve the recommendations of the CAMP process. However, I would like to ask that the Board considers that a slight amendment to the recommendations of the CAMP be considered. This amendment could suggest that a TLT of the 200 acres between Wallace Falls State Park and the Snohomish County Trailhead be studied with public input before any timber is harvested in this area. Another suggestion to insure the best success for future CAMP processes is for the DNR and State Parks to convene a process where the agencies and the public can identify the best areas where TLT’s can be explored across the whole State Park system. The CAMP process provides a once in a lifetime opportunity for expanding state parks. Please consider the impact of the CAMP recommendations both on Wallace Falls State Park and State Parks in general. Thank you so much for your time

Mike Town

Chairmen State Forest Committee Sierra Club 425-765-5121 [email protected]

April 21, 2018

Randy Kline Project Manager Wallace Falls State Park CAMP Planning Process Washington State Parks Department P.O. Box 42650 Olympia, WA 98504

RE: Joint Comment letter on Wallace Falls State Park Classification and Management Planning (CAMP) Stage 2 - Exploring Alternative Approaches

Dear Mr. Kline:

The following organizations are writing to provide comments as part of a long-term sustainable vision for one of Washington State’s most popular and inspiring state parks. While we represent different constituencies and geographies, each of our organizations cares deeply about the Skykomish Valley and have engaged in several public processes over the years supporting conservation initiatives and recreation opportunities that in turn provide economic benefits for local communities.

Wallace Falls State Park features lakes, rivers, waterfalls and hiking and biking trails for visiting families and local residents alike. Nestled in the heart of the Valley - just minutes from the restaurants and shops of the scenic town of Gold Bar - the park is a special place to all those that visit.

We appreciate the opportunity that the CAMP process offers to take stock of what makes the park so special as well as identify the challenges it faces. At many times of the year the park is “loved to death” as crowds often overwhelm the main trail access to the falls, if they can find a place to park. Parking is a significant issue, as overflow and illegal parking on busy summer days has frustrated the relationship with local residents.

We feel the CAMP process has the potential to help solve these problems and create a more enjoyable, accessible and sustainable experience to the hundreds of thousands of visitors in the future. We believe this is important because Wallace Falls State Park attracts visitors to the scenic towns of the Sky Valley like Gold Bar, Sultan, Monroe, Index, and Skykomish. These visitors spend money on food, gas and lodging making an economic imprint on the local communities each year. For local Valley residents, Wallace Falls is their backyard and a place for relaxation, exercise and a part of the unique quality of life that they enjoy in the Sky Valley.

Comments on Stage Two - Exploring Alternative Approaches

At the March 21, 2018 public meeting held in Sultan, the Washington State Park planners outlined two alternatives based on feedback from stakeholders. The two alternatives were: (1) a current operation emphasis and (2) an enhanced operation emphasis. Stakeholders were encouraged to identify existing elements and propose new elements that they support – rather than choose one or the other alternative. In stage 3, these comments will be turned into a preliminary plan for the Park.

Elements of the enhanced operation emphasis that we support

 Provide additional recreation opportunities (including equestrian and mountain biking) – People come in great numbers to Wallace Falls State Park because of what it has to offer, its proximity to Puget Sound populations centers and the charm of the local communities in the Sky Valley. As part of the long-term planning process we would like to see consideration about new hiking opportunities either within or connected to the park. While the park access is currently primarily focused on hiking, some trail running and limited mountain biking, the park should consider accommodating other recreational opportunities moving forward. Equestrian access and potential extended mountain biking opportunities should be considered after meeting with each of these communities to understand their access and trail needs. It would be important to manage or avoid potential user conflict between different user groups moving forward. For example, allowing equestrian or mountain biking on the main trail to the falls viewpoints would be challenging for all user groups given the number of people using that trail. However, investigating the opportunity to allow equestrian access to Wallace, Jay and Shaw Lakes from Washington Department of Natural Resources (DNR) lands is an opportunity worth pursuing. Existing mountain bike trails are located in the western part of the park and acquiring lands outside of the park which provide extension opportunities should be considered in this area, as well as to the east of the park.

 Work collaboratively with DNR to provide additional trail connections – Due to the shape and limitation in size of the current park boundary, it is important to cooperate with adjacent landowners to support recreational opportunities. This strategy could alleviate some of the stress on certain trails in the parks by giving alternative options to locals and visitors alike. A key partner in this respect in the Washington DNR. The map provided shows several trail connections between the park and DNR land indicated by a cross hatched section. We agree with this focus. As was voiced at both public meetings many visitors to the park have a strong preference for forested trail corridors. It is important to consider the potential difference in trail experience if and when trails that leave or enter the park to DNR land are logged under a variable retention harvest. Additional trail connections to the park to consider should include: o Work with DNR and other public land owners to provide trail access, including consideration of any necessary bridges, from the Snohomish County owned parcel south of the park on 429th Street to Wallace Falls State Park. This option is perhaps the most compelling given the existing investment in public ownership of the property and existing trail network. o Work with adjacent public land trailheads located on neighboring public land managers including DNR and the US Forest Service to investigate whether a connection to the Wild Sky Wilderness Area is practical. o Look to provide trail connections to Stickney Lake and Mt. Stickney east of Wallace Falls State Park. o Work to provide an improved trail connection from Jay Lake to Shaw Lake. Work with adjacent forest land owners to enable this trail connection. o Consider providing a trail connection from the park to Lake Isabell in the Wild Sky Wilderness. o Investigate the potential for a trail connection between Wallace Falls and Forks of the Sky State Parks

 Potential parking options are expanded to include land outside the current park boundaries – Parking is a major issue currently for the park. Any plan moving forward needs to explore all options to address this issue. This is important for visitor experience, safety and the continued supportive relationship with local residents and the community of Gold Bar. There are a number of options to alleviate the parking issues that should be considered: o Investigate the use of shuttle vans through a concessionaire, volunteer group or park staff to provide a shuttle from downtown Gold Bar on the north side of the highway to avoid crossing the heavy traffic volume on State Route 2. This service could be optional rather than mandatory and perhaps provide some incentive for visitors to spend time in the town of Gold Bar before and after their trip to the park. Perhaps the local chamber could coordinate a coupon book for shuttle users with discounts at local restaurants, gas stations and shops. o Use web cams or other technology to alert park users prior to arrival regarding availability of parking o Include land in the long -term boundary that supports additional parking opportunities. o Work with the City of Gold Bar and Snohomish County to investigate the possibility to improve parking and pedestrian activity along Ley Road including a path or sidewalk that takes pedestrians off the road and/or potentially widens shoulders to accommodate parking. o The following additional parking locations should be considered and pursued: . Work with the county to provide additional parking at the county owned site south of the park on 429th Avenue once a trail connection to the park is created. This is especially beneficial since this trailhead is already in public ownership . Work with Camp Huston on the potential to use the in-holding parcel along the trail and below the powerlines . Relocate the existing shop and office to provide parking in that area. . The property on May Creek Road at the gravel pit

 Consider a dispersed parking scenario to spread out park access points and reduce trail impacts – Another major challenge of the park is that the vast majority of visitors use the same trail to reach the prime destination – the waterfall viewpoints. On a busy summer day this can feel more like a parade and impact visitor experience and the trail itself. The park needs to explore and invest in additional trail access points, especially to the falls viewpoints to take pressure off the main route and primary parking areas. Promising efforts have already been made to establish a new Snohomish County trailhead south of the park that could provide trail access to the waterfall viewpoints in the park from a different parking lot and trail than the main thoroughfare. There are additional opportunities that should be explored from the Reiter Forest non-motorized planning area and perhaps other future trailheads. Both coordination and/or additional land acquisition will be important tools in addressing this issue.

Additional aspects that we strongly feel should be incorporated in a preliminary Stage 3 draft plan

1. Embrace the opportunity of targeted DNR trust land transfers to expand the park as part of the long term boundary – We were disappointed to see that neither the presentation at the March 21 public meeting or the lengthy handouts provided as part of Stage 2 of the CAMP process identified even the consideration of a state trust land transfer as part of the long term boundary discussion for the park. This is an important consideration for expanding the park to include more primitive recreation areas as well as important wildlife habitat. In fact, during the presentation and other materials, discussion was limited to looking at only private parcels rather than DNR lands for potential acquisition by the park. This is surprising because there had been direct conversations with park planning staff about the interest in exploring this tool as part of the long term boundary. There is no excuse for not discussing and considering potential trust land transfers as part of the long-term planning process. The CAMP process is the appropriate venue for this discussion.

Washington DNR lands are managed as trust lands under the Washington Constitution. As a result, they are managed to benefit specific beneficiaries, usually through providing revenue from timber harvest. However, in many cases DNR lands have been transferred from trust land to other agencies where they are managed for conservation, wildlife, watershed or recreation values. This requires the State legislature (or perhaps State Parks) to buy out the trust so that the beneficiaries are compensated for the loss of working forest lands. The funds received for the value of the timber can then be reinvested in buying additional lands that can be managed as working forest and provide income to the trust beneficiaries. In order to keep the specific trust beneficiaries whole, any replacement lands purchased would need to be ensured to benefit the same beneficiaries.

While trust land transfers within DNR (or between DNR and State Parks) can be complicated or even difficult, it is an option. We would argue in this case it is a compelling one for the park, the local beneficiaries or junior taxing districts and for the local communities of the Sky Valley. The following goals are important to create a win-win for the park, its users and the relevant trust beneficiaries.

Land Choice – We suggest that much of any trust land transfer focus on DNR lands that are currently managed under logging restrictions due to geologic or ecologic concerns as well as spotted owl or marbled murrelet habitat restrictions. These lands retain their forested character making them attractive and consistent with other land in the park. However, other trust lands may be of interest to provide connectivity to other protected areas (Wild Sky, Morning Start NRCA) or a manageable boundary with the existing park as well as lands which offer significant abilities to increase recreational opportunities.

Compensation to Trust Beneficiaries – In any scenario, the trust beneficiaries or junior taxing districts will need to be fairly compensated for any DNR trust land that is transferred to the park. Generally, the appraisal of the timber that could be harvested is part of that appraisal. In the event that any of the murrelet or owl managed lands are chosen for a trust land transfer, the compensation for the junior taxing districts would include all the timber (not just the restricted amount that could be thinned by the DNR). This potentially increases revenues for beneficiaries from lands which otherwise would have restrictions on logging. This provides a value added component in the compensation that should be attractive for trust beneficiaries.

Reinvestment in Additional Working Forest Lands – Once compensation funds are received they can be reinvested by purchasing additional private lands within the boundary of the junior taxing districts. This allows for long term working forest income for the junior taxing districts over time not restricted by owl and murrelet habitat guidelines.

Additional Value Added Expansion for Park - Transferred lands to the park can provide important options for more primitive recreation opportunities, important wildlife habitat and (where access allows) additional opportunities for equestrian or mountain bike trails on forested trails.

2. Acknowledge and highlight the potential recreational connection to the park from the DNR non- motorized Reiter Forest recreational planning effort – We appreciated that the map associated with the enhance emphasis option identified areas where trails from DNR connected with the park using a cross hatch entitled State Park and DNR Shared Recreation opportunities. This is an important component to identify options to disperse access to park destinations from other trailheads and parking areas. This has significant potential to enhance recreational opportunities as well as meet many of the overuse and parking challenges that currently plague the park.

For several years, DNR has invested in the Reiter Forest recreation area which includes a non-motorized trail system (e.g., mountain bikes, equestrian, hiking) just south and east of Wallace Falls State Park. There is excellent potential to design trail systems for a variety of users to include a destination of points within Wallace Falls State Park through DNR lands. This is particularly compelling for mountain bike and equestrian user groups who cover more miles per hour than hikers and therefore prefer longer trails. The trails can also provide an alternative approach to the park for hikers as well. Such a trail system would allow access to Wallace Falls State Park by equestrian and mountain bikers while avoiding: (1) user conflict issues; (2) exacerbating crowding on the most popular trail segments in the park; (3) and adding to parking challenges at the main park entrance.

Any future maps used in this CAMP process needs to be expanded and amended to highlight this powerful recreational opportunity as part of the long term boundary. This is especially true to the southeast of the park to include areas which the DNR and the public have identified for potential multi use recreational opportunities.

Thank you for the opportunity to provide comments on this planning effort early on in the process. We hope to see an improved preliminary draft plan as part of Stage 3 that embraces some of the important opportunities that were not discussed or explored in the previous two public meetings. We are excited about the opportunity that this process can provide to meet many of the current challenges that the park faces and improve on the experience to visitors and economic benefits to local communities moving forward.

Sincerely,

Tom Uniack Kathy Young Executive Director President Washington Wild Backcountry Horseman of Washington [email protected] [email protected]

Andrea Imler Henry Sladek Advocacy Director President Washington Trails Association Skykomish Chamber of Commerce [email protected] [email protected]

Cathy Nelson Tom Hammond Director President Traildusters Chapter. Backcountry Horsemen of WA Conservation Council [email protected] [email protected]

Don Parks Katherine Hollis Co-Chair, National Forest Committee Conservation and Advocacy Director Washington Chapter of the Sierra Club The Mountaineers [email protected] [email protected]

Ann Darlington Ben Greuel President Washington State Director Friends of Heybrook Ridge The Wilderness Society [email protected] [email protected]

Rick McGuire Thomas O'Keefe, PhD President Pacific Northwest Stewardship Director Alpine Lakes Protection Society American Whitewater [email protected] [email protected]

Debbie Copple Yvonne Kraus Director Executive Director Sky Valley Chamber of Commerce & Visitor Info Center Evergreen Mountain Bike Alliance [email protected] [email protected]

Blair Corson Inessa Peerce Owner President Outdoor Adventures Sky Valley Environmental & Economic Alliance [email protected] [email protected]

Jonathan Stumpf Katherine Johnson Associate Director, River Protection Forest Practices Chair American Rivers Pilchuck Audubon Society [email protected] [email protected]

CC:

August 9, 2018

Via email to: [email protected]

Randy Kline, Project Manager Washington State Parks Post Office Box 42650 Olympia, WA 98504

RE: Wallace Falls State Park “Classification and Management Planning” Stage 3 Preliminary Recommendations

Dear Mr. Kline:

On behalf of the American Forest Resource Council (AFRC) and its members, thank you for the opportunity to provide comments on the Wallace Falls State Park CAMP process and potential expansion of the park. AFRC has serious concerns with the proposal and its likely impact on our industry, local economies, and the beneficiaries of state trust lands.

AFRC represents the forest products industry throughout Oregon, Washington, Idaho, Montana, and . AFRC’s members include over 50 forest product businesses and forest landowners. AFRC’s mission is to advocate for sustained yield timber harvests on public timberlands throughout the West to enhance forest health and resistance to fire, insects, and disease. We do this by promoting active management to attain productive public forests, protect adjoining private forests, and assure community stability. We work to improve federal and state laws, regulations, policies and decisions regarding access to and management of public forest lands and protection of all forest lands. Many of our members, rely on the timber sold from trust lands managed by the Washington State Department of Natural Resources (DNR). The success of this program ultimately dictates not only the viability of their businesses, but also the economic health of the communities themselves.

The forest products sector in Washington State continues to provide around 40,000 direct and about 100,000 indirect jobs. Many of these are found in rural communities throughout western Washington. In addition to the wages paid, the taxes and other economic activity generated by these businesses and family-wage jobs, contribute to the social fabric and well-being of the local communities. Unfortunately, many of these businesses lack enough raw materials to meet an increasing demand for wood products.

In the last few years, there have been eight mill closures in Western Washington in part due to lack of access to logs. The timber sale program, managed by DNR for the benefit of trust beneficiaries, is a significant contributor to a predictable wood supply in Washington that many mills depend on to continue operations and sustain their work force. Maintaining and enhancing the number of acres of working forests providing needed log volume is key to assuring the milling and logging infrastructure continues to provide jobs and forest products for the marketplace. The DNR timber sale program has fallen from the FY ’05-14 Sustainable Harvest Level of 550 million board feet per year to under 450 million board feet per year. At 11 jobs per 1 million board feet that equates to a loss of 1,100 jobs.

924 Capitol Way South, Suite 102 • Olympia, Washington 98501 Tel. 360.352.3910 • Fax: 360.352.3917

The demand for wood products continues to grow. In 2013 the total consumption of lumber was 45.6 billion board feet, an increase of 8 billion board feet over 2009 levels. Consumption is expected to rise 2.3% per year between 2015 and 2030. Unfortunately, U.S. production is not meeting this demand. In 2013 the U.S. imported 11.7 billion board feet of lumber and exported 2.6 billion board feet for a net 9.1 billion board feet of lumber imported. Maintaining managed forestlands is key to meeting the U.S. populations wood products needs in a sustainable and locally grown and processed manner. Logs sourced from trust lands are processed domestically.

Expansion of the park and removing acres of sustainably managed forest land – both state and private - is of great concern to AFRC and its members. Not only does the loss of acres have a ripple effect throughout the industry from lost opportunity to provide sustainable long-term supply of wood, but also impacts many of the communities where our members and their employees live and work. Loss of managed trust lands results in the reduction of revenues to the beneficiaries of those trust lands. Revenue from timber sales helps to provide essential services such as roads, schools, libraries, fire and emergency medical services, and hospitals, to name a few. Continuing to provide these revenues results in the ongoing ability to maintain and enhance these essential services. This can only be accomplished through maintaining the corpus of the trust and sustainably managing that land base. In Fiscal Year 2018 DNR generated $225,030,311.29 in gross revenues from timber sales statewide. In the case of Snohomish County last year, revenues from harvest of timber from State-managed trust lands exceeded $5.7 million. Additionally, forest excise tax revenues from harvest of timber on private and State- managed trust lands in Snohomish County have averaged $ 1.4 million annually the last five years. A significant portion of these revenues supported county and junior taxing district services.

The inclusion of approximately 1,500 acre of trust lands, managed by DNR for the benefit of the beneficiaries has real and significant negative economic impacts to those beneficiaries and the industry that relies on those lands. The Washington State Legislature is the trustee of these lands and DNR manages these lands. Both entities are obligated to adhere to their trust mandate for the management of these lands. That trust mandate was affirmed in County of Skamania v. State 685 P.2d 127 (1984). One aspect of the trust mandate includes maintaining an undivided loyalty to the beneficiaries. This undivided loyalty extends to the issue of recreation on trust lands. The Stage 3 document asserts that trust lands are “managed under the multiple use concept described in RCW 79.10.110” but fails to disclose the obligations of the State to the beneficiaries. State law is clear that the beneficiaries must be compensated due to impacts from recreation that decreases the value, corpus, or revenue of the trusts. Any use beyond revenue generation, including recreation, is not and cannot be placed on equal footing under the trust mandate. And any impacts from these other uses must be compensated.

The history of the Singletary timber sale (development, appeals, litigation) should be considered when proposing recreational facilities that would encumber additional trust lands. While it is unclear from the Stage 3 documents, it appears there is one option that would maintain DNR management of the acres in the Long-Term Boundary (LTB) with added trails. While active forest management and recreation can co- exist, the ongoing challenges of implementing the Singletary timber sale raise serious doubts about the approach being considered. As you may know, Snohomish County formally requested that DNR move forward with the Singletary sale with the adoption of Resolution 18-006 on March 21, 2018.

Unfortunately, the project remains in limbo, as does needed revenue to junior taxing districts such as the Sultan School District, Sno-Isle Library, Hospital District 1, and Fire District 26.

We are particularly concerned about any proposals to transfer working state trust lands as part of a proposal to expand the Wallace Falls State Park. Transferring these acres out of trust status would ultimately result in the loss of working forest lands and creates significant complexities, including impacts to junior taxing districts, the county, and any Federal trusts in the foot print of the LTB. Any proposal should include a detailed analysis and specifically identify viable replacement lands. The analysis should also identify necessary funding to compensate state land beneficiaries and junior taxing districts if lands shift outside of junior taxing district boundaries.

The DNR trust lands in question are covered under the State Lands Habitat Conservation Plan (HCP) approved in 1997. The HCP provides protections for a variety of species including the Northern Spotted Owl. Additionally, there are aquatic protections provided under the HCP. Prior to any further recommendations being developed, a clear understanding of the impacts of this proposal to the HCP must be understood. Addition of recreation facilities, removal from trust status, etc. may have impacts to other lands outside of the LTB under the HCP. Protections and mitigation under the HCP and Incidental Take Permit are interwoven across a broad landscape of trust lands. Modifications of the management and/or ownership of these lands may have adverse impacts to lands in other landscapes managed under the HCP.

One thing is clear from the available materials and the ongoing conversations in other forums related to the management of trust lands in Snohomish County. The underlying problem with Wallace Falls State Park appears to be the severe lack of parking to accommodate the large number of users. It is unclear how expanding the park boundaries will solve this problem. It would seem more prudent to first evaluate and implement solutions for solving the parking issue prior to permanently removing working forest land from active management.

Should State Parks continue to look for opportunities to expand recreation facilities on DNR managed lands, AFRC respectfully recommends evaluating feasible opportunities connect Wallace Falls State Park to the Morning Star NRCA with minimal to no impacts to managed trust lands. While the beneficiaries would still need to be compensated for any financial impacts, the cost is likely to be much lower – an important consideration given the limited funding available for the lands currently managed by Washington State Parks. It is also important to consider how any expansion of recreational facilities on state lands fits in with the extensive lands managed in the area by the U.S. Forest Service. As you may know, in the 2010 Reiter Foothills Recreation plan, it was stated that the Forest Service was not in favor of building trails to connect Reiter Foothills to the Wild Sky Wilderness (pg 10).

In closing, AFRC requests that prior to Final Recommendations being prepared, an explicit analysis of the economic impact of this proposal be developed. That analysis should consider at a minimum the following: 1. The impacts of withdrawing productive state and private forestland from production a. Loss of jobs from reduction in managed acres i. This includes both direct and indirect jobs

b. Loss of revenue to the county and state from timber excise tax c. Loss of revenue to trust beneficiaries, including the junior taxing districts. i. This includes current and future revenues, consistent with DNR’s obligation to maintain intergeneration equities 2. The impacts to the State Trust Lands HCP for lands located in the LTB and other lands covered by the HCP. 3. Cost of proposed land transfers (Inter-trust exchanges, replacement lands, etc.) a. Identification of replacement lands for “County Trust” lands that leaves junior taxing districts unaffected. 4. Completion of required SEPA and related documents prior to adoption of any proposal. Additionally, we would request information or clarification on the need or lack of a need to complete an EIS as part of this planning process. And any associated timeline with the SEPA process.

We look forward to ongoing engagement in the process and trust that DNR and State Parks will adhere to the trust mandate that so many rely on. Thank you for the opportunity to comment on this project. Should you have any questions regarding the above comments or would like additional information, please contact me at 360-352-3910 or [email protected].

Sincerely,

Matt Comisky Washington State Manager