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Consultin,1 Services fzlr Nat:eral Resources !1 nuly; is and Marra-ernent
1800 112th avenue N.E., Suit, '100 • Bellevue, Washington 98004 • Plume: (206) 454-3408 + Bax: (206) 4.54-,U59
May 11, 1993
Mr. Steve Moddemeyer
Port Gamble S'Klallam Tribe
Post Office Box 280
Kingston, WA 98345
Re: Environmental Checklist for Proposed Residential Development
Dear Mr. Moddemeyer;
I have reviewed the Environmental Checklist for the proposed 120 acre residential
subdivision near the Dosewallips State Park (Section 10, Township 25 North, Range 2
West, W,M.). I am familiar with that area because of two years of field studies that I
conducted on Roosevelt elk during 1984-1985. 1 have also conducted numerous other
wildlife and plant studies in this area and others on the eastside of the Olympic
Mountains from 1986 to 1992.
The proposed residential development of that area probably will detrimentally affect the
Duckabush and Dosewallips elk herds in two primary ways: 1) development of the
area will degrade and in some cases eliminate areas used for escape from hunters and
other potential harassment activities; and 2) residential use of the sites will
undoubtedly lead to long-term negative impacts to the elk as a result of stray dogs and
other residential related effects.
My studies have shown that the elk of the Duckabush herd, and to a lesser extent, the
Dosewallips herd, used the proposed development area during the fall and winter
seasons. The proposed, site is within the winter range of the Duckabusb elk herd. That
area was particularly important as an escape area from taunters and other disturbance
activities, such as those in the Dosewallips Campground. Additionally, the Duckabush
herd was observed on numerous occasions using the area of proposed development as a
travel zone between the Duckabush and Dosewallips River drainages. The proposed
development area is not a "core use" area of these elk herds, yet it plays an important
role in providing escape cover, some foraging areas, and a travel zone between the
valleys. Escape cover and travel zones are critical areas for elk and other wildlife
species. Elk rely on these areas to rest and recuperate from harassment activities.
The elk of the Dosewallips and Duckabush herds exhibit the capacity to partially
habituate to human dwellings, roads and other structures. They periodically are
observed near these types of structures during periods when direct disturbance from
humans is low, primarily at night. Activities that accompany residential living,
however, typically make habitats in and adjoining residential developments totally or
partially unavailable to elk use. Incremental residential development of the home
ranges of these hem., will result in the incremental decreased capacity of those herds to
maintain healthy populations and reproduction rates over long-term periods of time.
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Mr. Steve Moddemeyer
May 11, 1993, Pg 2
Nearly all of the existing development in the home ranges of these elk are on the valley
floors and lower valley walls, which are the same areas preferred by these elk herds
and most other elk herds that have been studied in Western Washington. The
incremental residential development occurring in the home ranges of these elk could
eventually lead to severe habitat limitations, This issue is particularly unique in the
Duckabush and Dosewallips River drainages due to the relatively limited availability of
home range area and preferred habitats. The river bottomlands and lower valley walls
in the Duckabush and Dosewallips winter ranges (autumn through spring) are much
more restricted than many other elk winter ranges, such as the broad river bottoms of
the western Olympic Peninsula. This limitation of preferred habitat areas by
incremental development is likely to have negative effects on these elk populations in
the future.
I would like to propose some management recommendations in the event that this
project is permitted for development.
1. Dogs and other pets that belong to residents of this area should not be allowed to run
free due to their potential for severe harassment pressure on elk, deer and other
wildlife. A pet leash law should be established and enforced for the residential area.
This type of impact has been shown to be some of the most destructive type of impact
to wildlife species and represents "external impacts" that go beyond the boundaries of
the direct impacts. Enforcement can be maintained by outside security services that are
paid from covenant fees.
2. All riparian ecosystems should be protected from development. This should include
a 100-200 ft minimum protected buffer zone adjacent to streams. That buffer distance
should include riparian ecosystems, which vary in distance from streams. Riparian
ecosystems vary in size depending on topography, underground water, vegetation, and
soil moisture conditions. Riparian areas are important habitats for elk, and at this
particular site they may be critical habitats to elk due to the generally dry soil moisture
conditions in that vicinity.
I A native vegetation restoration plan should be submitted to the County Planning
Department and the Washington Department of Wildlife (WDW) before a development
permit is issued. The generally thin soil depths and dry soil moisture conditions of the
proposed development site will most likely make vegetation restoration difficult. The
plan should include a three to five year monitoring effort that evaluates the success of
the vegetation restoration. Goals, objectives and standards are needed in that
monitoring plan.
4. Developments should be clustered rather than dispersed through the 120 acre area.
CIustered development will allow the opportunity for development and also help protect
the most important natural resources. Elk travel zones and other types of resources
should be identified and incorporated into the conditions of any permit via a resource
management plan. This management plan should be developed with the assistance of
qualified professionals with review and approval by the Washington Department of
Wildlife.
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Mr. Steve Moddemeyer
May 11, 1993, Pg 3
5. A comprehensive and long-term land use plan should be developed by the County or
other entities for the lower Duckabush and Dosewallips River Valleys, especially those
areas included within the elk winter ranges. These winter ranges should be considered
critical habitats and managed as such. This type of management will help to alleviate
major population declines in the future.
The issue of development effects on wildlife, fish, and water quality will be continually
raised with future developments. The cumulative effects of these developments need to
be reviewed from a comprehensive landscape perspective in order to sustain certain
wildlife and fish populations.
Please feel free to contact me if you have questions or need further information
regardingthese comments. Thank you.
Sincerely,
Greg Schroer, 'dent
Senior Forest/Wildlife Biologist
Resources Northwest, Inc.
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