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HomeMy WebLinkAbout153Michelle Farfan From: Sent: To: Cc: Subject: Attachments: Tim Cullinan <tcullinan@pnptc.org > Thursday, August 31,2017 L1:02 AM Michelle Farfan rha rder@ pnptc.org; schitwood@ja mestowntribe,org; paulm@pgst.nsn,us; romac@ pgst.nsn.us; Hansi Hals; Cha rin Godbolt; Bryan.M u rphie@dfw.wa.gov; backerman@skokomish.org RE:Wildlife Management Plan for Pleasant Harbor Master Planned Resort (MLA 08-00188 / ZON08-00056 Pleasant Harbor MPR_WL Mgmt Plan comments_PNPTC.doc Dear Michelle, Attached are PNPTC's comments submitted in response to your request for comments specific to the July 31, 2017 Wildlife Management Plan prepared by GeoEngineers Inc. for the Pleasant Harbor Master Planned Resort (MPR) in Brinnon. I have also sent a hard copy via surface mail. Tim Cullinan Wildlife Program Manager Point No Point Treaty Council 19472 Powder Hill Place NE, Suite 210 Poulsbo, WA 98370 360-731-8674 tcullinan(Donptc.org From: M ichel le Fa rfa n [ma ilto : M Fa rfa n @co.jefferson.wa. us] Sent: Wednesday, August 02,2Ot7 1:48 PM To: Roma Call <romac@pgst.nsn.us>; Leanne Jenkins <ljenkins@jamestowntribe.org>; rlumper@skokomish.org; tcullinan@pnptc.org; jmclaughlin@pnptc.org; bryan.murphie@dfw,wa.gov; margaret.bigelow@dfw.wa.gov; backerma n @skokom ish.org Cc: Patty Charnas <PCharnas@co.jefferson.wa.us>; Philip Hunsucker <PHunsucker@co.jefferson.wa.us> Subject: Wildlife Management Plan for Pleasant Harbor Master Planned Resort (MLA 08-00188 / ZON08-00056 Hello Attached please find a copy of a Wildlife Management Plan dated July 31 ,2017 as prepared by GeoEngineers for the Pleasant Harbor Master Planned Resort (Statesman Group) located on the Black Point Peninsula in Brinnon. This report was prepared as required by Ordinance 01-0128-08 condition 63(l) which states "A wildlife management plan focused on non-lethal strategies shall be developed in the public interest in consultation with the Department of Fish and Waldlife and local tribes, to prevent dlminishment of tribal wildlife resources cited in the Brinnon Sub-Area Plan (e.9., deer, elk, cougar, waterfowl, osprey, eagles, and bear), to reduce the potential for vehicle collisions on U.S. Highway '10'1, to reduce the conflict resulting from wildlife foraging on high-value landscaping and attraction to fresh water sources, to 1 reduce the dangers to predators attracted to the area by prey or habitat, and to reduce any danger to humans." We respectfully request your written comments specific to this Wildlife Management Plan on or before September 1,2017. lf you are not the correct person to review this document, please fonruard to the appropriate person(s) in your agency. lf you have any questions or need anything further, please do not hesitate to let me know Regards, Michelle Farfan Associate Planner, Pleasant Harbor MPR Lead Jefferson County Department of Community Development 62L Sheridan Port Townsend WA 98368 V: 360-379-4463 F: 360-379-4451 mfa rfan@co, iefferson.wa.us All e-mail sent to this address has been received by the Jefferson County e-mail system and is therefore subject to the Public Records Act, a state law found at RCW 42.56. Under the Public Records law the County must release this e-mail and its contents to any person who asks to obtain a copy (or for inspection) of this e-mail unless it is also exempt from production to the requester according to state law, including RCW 42.56 and other state laws. 2 POINTNO POINT TREATY COUNCIL Port Gamble S'Klallam * Jamestown S'Klallam August 31,2017 Jefferson County Department of Community Development ATTN: Michelle Farfan 621 Sheridan Port Townsend WA 98368 Subject: Wildlife Management Plan for Pleasant Harbor Master Planned Resort Dear Ms. Farfan: The Point No Point Treaty Council (PNPTC) is writing in response to your request for comments specific to the July 31,2017 Wildlife Management Plan prepared by GeoEngineers Inc. for the Pleasant Harbor Master Planned Resort (MPR) in Brinnon. The PNPTC is a natural resource management organization formed in 1974 to assist the Port Gamble S'Klallam and Jamestown S'Klallam Tribes in fulfilling the requirements placed upon them by the U.S. Supreme Court in U.S. v. Washington (the "Boldt Decision"). The Treaty Council confirms the reserved rights established in the 1855 Treaty of Point No Point, and implements goals set by member tribes for resource conservation, management, and the protection of treaty rights. The Wildlife Management Plan does not meet the requirements specified in Jefferson County Ordinance 0l-0128-08 condition 63(l), which requires that the plan be developed in consultation with local tribes "to prevent the diminishment of tribal wildlife resources." The plan does not adequately address the potential adverse impacts that the proposed Pleasant Harbor MPR will have on wildlife, particularly on the Duckabush elk herd. The project proponent seems to have missed the point of preparing the Wildlife Management Plan (WMP). The original intent was to develop a management plan that would assess and mitigate the risks resulting from the habitat changes that will occur on the Black Point property. It was also intended to specify contingencies regarding intensity of management, with an emphasis on the need to avoid lethal removal of nuisance animals. The WMP has only partially met its original objectives. The July 31,2017 Wildlife Management Plan is inadequate for the following reasonsl l. It was not developed in consultation with local tribes. 2. It relies on outdated information and reveals a fundamental lack of understanding of the life history and ecology of the Duckabush elk herd. 3. The plan fails to adequately recognize and mitigate the risk that the elk herd will shift its home range and occupy the MPR site. 4. The WMP does not describe management actions in sufficient detail to allow assessment ofrisk or probability ofsuccess. 5. It does not adequately describe the conditions under which remedial management actions will be taken, and leaves too much discretion to the developer to decide when such actions are necessary. 6. The plan does not provide assurances to the tribes that lethal control will not be used when conflicts with nuisance wildlife occur. We will address and elaborate on each of these points below, focusing on the risks to and potential impacts on the Duckabush elk herd, which is the wildlife resource of greatest importance to the S'Klallam Tribes in the vicinity of the proposed MPR. 1. The Wildlife Management Plan was not developed in consultation with the local tribes. Jefferson County Ordinance 01-0128-08 condition 63(l) states "A wildlife management plan focused on non-lethal strategies shall be developed in the public interest in consultation with the Department of Fish and Wildlife and local tribes, to prevent diminishment of tribal wildlife resources." The Wildlife Management Plan dated July 31,2017 was not developed in consultation with the S'Klallam Tribes or the PNPTC, nor does the WMP even mention the requirement to consult. We have no record of having been contacted by either Statesman or its contractor GeoEngineers Inc. for consultation during the development of the plan. We were not even aware that the WMP was being developed until August2,2017, when the final edition was forwarded to us by Jefferson County's Department of Community Development. The Skokomish Tribe also reports that it was not contacted regarding consultation. The quality and utility of the WMP are limited (see sections2 to 6 below) as a result of the failure of Statesman and its contractor to consult with the tribes. The PNPTC has been conducting research on the wildlife in our treaty area since the early 1990s. We began monitoring the home range, habitat use, and demography of the Duckabush elk herd in 1995, and we have a wealth of information regarding that herd spanning two decades. The tribes could have provided a great deal of state-of-the-art scientific information that would have vastly improved the quality and credibility of Statesman's WMP if Statesman had complied with the requirement to consult with the tribes. Statesman's failure to consult represents not only a lack of compliance with the ordinance, but a costly, missed opportunity to produce a credible, science-based wildlife management plan. Furthermore, as a result of the failure to consult, the WMP demonstrates a fundamental lack of understanding of the tribes' position regarding wildlife management on the MPR site. The WMP states "Through discussions with Native American Tribes it has been identified that tribal wildlife resources (including Roosevelt Elk) should be discouraged from using the development site" (page 6,paragraph 3). As noted above, the contractor that prepared the plan never had any discussions with our Tribes. If they had, they would have known that it was never our intention to discourage all wildlife from using the MPR site. Our concern applied only to Roosevelt elk. The plan goes on to prescribehazingof deer, bears, and waterfowl with loud noises and flashing lights, fencing off deer browsing areas, and denying waterfowl access to water by installing nets. These are not management actions the S'Klallam Tribes advocate. Management of the site should accommodate wildlife, except in the case of elk, which should be prevented from occupying the MPR site. 2. The WMP relies on outdated information and reveals a fundamental lack of understanding of the life history and ecology of the Duckabush elk herd. The plan contains outdated information and erroneous statements that indicate a lack of understanding of the biology and ecology of the Duckabush elk. This is important because sound PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 2 of 12 wildlife management is only as good as the scientific information it is based upon. Without a thorough understanding of the behavior and life history of the local elk herd, there is the risk that any management recommendations will be flawed and will prove to be ineffective. Some of the statements made in the WMP about the Duckabush elk herd describe conditions that existed l5 to 20 years ago, but are no longer extant today. In some cases statements are made without supporting evidence or literature citations. Overall it is evident that the author of the plan did not possess sufficient knowledge to assess risks and to formulate effective management recommendations. For example: a) The WMP states "Elk migrate on a seasonal pattern and can be expected to be in the project vicinity during certain times of the year" (page 5, paragraph 2). While it is true that in some parts of the West elk migrate seasonally, that is not true of the Duckabush herd. The herd is resident year-round. It has not undergone a true migration since 1993. Some individuals are nomadic, and may travel up to l3 kilometers from one end of their range to the other, but this is not true migration. This is important because the incorrect statement above implies that there will be extended periods during the year when elk will not be present. That is not the case. Most of the herd can be in the MPR vicinity at any time, so the risk that elk will cross the highway and occupy the MPR is a 365-day per year risk. b) In the same paragraph, the WMP states "Elk could potentially...inhabit [Black Point] for short durations during the year." The WMP does not define "short durations" so it is difficult to evaluate the accuracy of that statement. Our current understanding of deer and elk foraging is based on a behavioral model that predicts that animals will continue feeding in an area until the quality of the food is depleted below the quality in other, nearby areas (Hobbs and Swift 1985). Only then will the animals abandon that area and move to a new one. The use of the term "short durations" understates the risk that elk will occupy the nutrient-rich foraging areas on the golf course for extended periods. We have observed elk occupying grassy fields (similar to fairways) in the immediate vicinity for up to seven consecutive days when the quality of the forage is good. c) The WMP states on page 7 "the [MPR] site is adjacent to mapped elk crucial wintering range (WDFW, 2017)." This statement is misleading and irrelevant for several reasons. Although the citation-a link to WDFW's web site-is dated 2017, the maps on that web page have not been updated since the year 2000. The Duckabush elk herd's range has expanded since then, so the 2000 winter range map is nearly useless. Second, the reference to winter range implies that elk will be in the vicinity only during winter, which is not the case, as noted above. Furthermore, the focus on winter range is outdated by almost 20 years (Cook et al. 1998). It is now generally accepted among wildlife ecologists that elk behavior and populations are driven not by the location and adequacy of winter habitat, but by the quality of food on summer and autumn ranges (Washington Dept. of Fish and Wildlife 2004, Hutchins 2006, Cook et al. 2016). d) The WMP makes a few general statements about sizes of elk populations and bull-to-cow ratios, but contains no information about the size of the Duckabush herd. It states "a herd could be as small as 4 individuals" (page 5, paragraph2), a statement whose utility eludes us. This statement understates the risks associated with elk occupying the MPR and causing damage. Our census records show that at times the Duckabush herd has contained as manv as 80 individuals. PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 3 of12 3. The plan fails to adequately recognize and mitigate the risk that the elk herd will shift its home range and occupy the MPR site. Since 2007, when Jefferson County solicited public comments on the original FEIS for the Pleasant Harbor MPR, the PNPTC has struggled to convince the project developer that there is a high probability that changes in habitat-particularly the removal of forest canopy and the establishment of nutrient-rich grassy areas-will attract elk to Black Point. In our 2007 comments we stated: "It cannot be assumed that the current level of elk use of Black Point is a reliable indicator of future use. Our experience suggests that elk use of Black Point is currently low because most of the site is occupied by second-growth closed-canopy coniferous forest, a habitat type that characteristically produces low quality and quantity elk forage. As the habitat changes due to the construction of the golf course and the development of lawns and other open areas, the site will become more attractive to elk. Elk are opportunistic feeders, and are particularly fond of open areas with rich, abundant grass, particularly in the spring when the grassy areas are greening up." We went on to cite radio-tracking data dating to the year 2000 that showed that elk habitually occurred in the immediate vicinity of Black Point and that elk are likely to expand or alter their home range to exploit foraging habitat when it appears in previously unused areas. Since 2007 we have continued our monitoring and have been able to complete a more thorough analysis of the habitat changes and elk behavior changes that have occurred over the past 30 years west and south of Black point. The results of the analysis leave little doubt that elk will alter their range when new food sources appear on the landscape as a result of human activity. It is a well-established fact that removing the canopy of a mature coniferous forest results in greater quantity and quality of forage for elk on that site. The reason for this is that canopy removal vastly increases the amount of solar radiation reaching plants at ground level, resulting in more energy available for photosynthesis. Removal of the canopy trees also makes more water and nutrients available for the ground level plants. Both of these factors result in rapid and vigorous growth of nutrient-rich plants-grasses, forbs, and deciduous shrubs-within reach of the elk. A recent comprehensive region-wide study of elk nutrition (Cook et al. 2016) found that the abundance of elk forage in young forest stands 5 to l0 years following clearcut logging (Figure l) ranged from 3,000 to 4,500 kglha (1.3 to 2.0 tons per acre). By contrast, elk forage production in older forests with full canopies (20 to 50 years old-Figure 2) was found to be 100 to 300 kglha (only 89 to 267 pounds per acre). Furthermore, the abundance of the highest- quality, most-preferred plants was 7 to l0 times higher in the young clearcuts than it was in the 20 to 50-year-old forest stands. Based on the landscape management actions described in the MPR plan and FElS-removal of the forest canopy and establishment of grasses and deciduous shrubs-we are led to the conclusion that the amount of elk forage available would closely resemble the conditions found in young forest stands. Production of elk forage would likely be thousands of pounds per acre per year. The question then becomes, would that amount be sufficient to act as an attractant to elk, causing them to cross U.S. 101 and occupy the MPR site? Our research strongly suggests the answer is yes. PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 4 of 12 Figure 1. A forest stand in the 5 to l0-year age class. Abundant grasses and deciduous shrubs can provide I to 2 tons of elk forage per acre per year (Cook et al. 2016). Figure 2. A forest stand in the 20 to 50-year age class. The closed canopy prevents solar radiation from reaching the understory. Stands in this age class produce only a few hundred of elk acre PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 5 of 12 ', ,1, l. ^ ! ': I i f a I I e I .. \'-f \r;)*I;i i, tl l 1l The forage conditions in different aged forests cited by Cook et al. above explains why elk currently aren't found in the closed-canopy forests on Black Point. At present, there simply isn't enough food available to provide an incentive for elk to cross the highway at that location. We know, however, that when the habitat changes and abundant forage becomes available elk will alter their behavior and shift their home range to exploit the new food source. This is illustrated by our assessment of habitat conditions in the treaty area and our tracking of elk behavior through radio-telemetry. Monitoring of the behavior and home range of the Duckabush elk herd via telemetry dates back to the mid-1980s (Schroer 1986). The Point No Point Treaty Council began monitoring the Duckabush elk in 1995, and it continues to the present. In the late 1990s the Duckabush elk herd occupied a home range extending west about five miles up the Duckabush River valley, north along the ridge east of Mount Jupiter, and south to a point about 0.5 miles north of McDonald creek (Figure 3). In that decade there was little or no incentive for the herd to shift its range farther south because most of the land was in closed- canopy coniferous forest that did not provide sufficient forage to support a population of elk. The herd remained primarily in the Duckabush watershed, where riparian forest understories, small openings, and recent (less than 10-year-old) clearcuts provided adequate forage. Between 2001 and 2009 the herd expanded its home range more than six miles in a southwesterly direction. This home range shift coincided with a rapid increase in logging on the Figure 3. Landscape conditions and the range of the Duckabush elk herd in the late 1990s. Elk w€re not detected south of McDonald Creek. q ,.1.... a .:J I : .\ ....,, i l a Tdbn Head Esi, HERE. O.Lo@, M.pmylndL. O Op.nsh.tM.p onnibubB, lid h. GIS ue.cmmudry PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 6 of 12 Legend Forest dearorts < 10 years old o Elk locations 199G2000 Propos€d Pleasant Harbor MPR Olympic National Forest Hood Canal State Forest ' BPA powerline Hood Canal State Forest, a large expanse of state-owned commercial timber land managed by the Washington Department of Natural Resources (DNR). From 1960 to 2000 DNR timber harvest in this area was limited to less than245 acres per decade. Then, in 1999 DNR began an aggressive timber production effort, and logged 863 acres during the following decade. This resulted in hundreds of acres of high-productivity clearcuts where none had existed before (Figure 4). By the 2010s decade the Duckabush elk herd had shifted its range to occupy areas south of McDonald Creek where elk previously had not been detected, including the Waketickeh watershed in Mason County (Figure 4). We can conclude from these data that elk will travel long distances and alter their home range in response to habitat changes that provide new sources of abundant and high-quality forage. We can say with confidence that there is a high probability that elk will cross U.S. 101 to exploit the newly created forage on Black Point. If a six-mile expanse of forest and two major creek canyons (McDonald and Fulton Creeks) did not pose a barrier to elk dispersal, it is unlikely that highway 101 will be a barrier to the movement of hungry elk. 4. The WMP does not describe management actions in sufficient detail to allow assessment of risk or probability of success. Evaluating the potential efficacy of management actions is not possible because the WMP does not describe proposed management actions in sufficient detail to allow independent and unbiased Figurs 4. Landscap€ conditions and the rang€ of the Duckabush elk hErd 2009-2012. The elk expanded their range south and west to exploit now fiorage areas in Hood Canal State Forest. :: Fd*F'r'r'.tdt CNk S. Fod( Fdb, Cat Line ,'.-'_'-.1- - a Legend l-_-l forest dear<rrb < 10 years old Forest clearcuts 10 to 20 years old Elk Locations 2009-2012 Proposed Pleasant Hartor MPR Olymplc National Forest Hood Canal Stale Forest BPA powerline oI,/ ..--...,..-. - 't Triton Head E.ri. HERE, 0!Lom., M.pmylril., O OpenstutM.p contdbubr, .nd h. GIS u*r communily PNPTC comments on Pleasant Harbor Wildlife Management Plan PageT of12 -t a 1q J O q assessment of the probability of success or of the risks to wildlife. For example, the management strategy to reduce vehicle collisions-a matter of utmost importance to our tribes-is described in a single sentence. No further information is provided regarding the design or specifications of the warning system, how it will be deployed and maintained, and how it will function. One might anticipate from the description of methods and from past discussions with Statesman that the intent is to deploy a highway warning light system similar to the one currently used on U.S. 101 near Sequim in Clallam County (Figure 5). If that is the case, then it should be explicitly stated in the "management strategies" section. The description of the action should state where the system will be located, how many signs will be installed, how they will interface with the elk movements, who will be responsible for capturing and collaring elk, who will replace collars when they wear out, and who will be responsible for maintenance of all the system components. These questions are important. When the Sequim waming system was deployed by the Washington Department of Fish and Wildlife (WDFW) in Sequim in 2001 the cost of installing the lights was $75,000 ($104,848 in2017 dollars; Shelly Ament, WDFW Asst. District Biologist, personal communication, 2014). Since then WDFW and PNPTC have spent more than $ 10,000 to attach collars to elk. In addition there are ongoing maintenance costs, costs for power, and costs of repair. Figure 5. An elk crossing highway warning sign on U.S. 101 east of Sequim. Flashing lights are activated when a radio-collared elk approaches within 0.25 miles of the highway \ CentcrCity LYashington Street y' The perfunctory and apathetic description of the vehicle collisions reduction strategy leaves too many questions unanswered. Until a more definitive description of this management strategy is provided, our tribes do not consider the project developers to have met their obligation to develop a plan to prevent diminishment of tribal wildlife resources and reduce the potential for vehicle collisions. PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 8 of 12 II filEriF'; Other descriptions of management actions are equally uninformative. The provision for hazing wildlife from the site merely states that "Statesman will implement scare tactics...Scare tactics will include use of chemicals smell [sic], loud noises and flashing lights." Again, there is little in this statement that allows the reader to assess whether the management action will be effective. Likewise, no specific details are provided regarding the specifications of an exclusion fence. These are inadequate descriptions of actions intended to be the major tools for avoiding wildlife conflicts and adverse impacts on wildlife. Without detailed descriptions of management actions, stated in objective, quantitative terms, there is no way to reliably evaluate whether the WMP meets the requirements of Ordinance 01-0128-08, and no way to ensure accountability. 5. The Wildlife Management Plan does not adequately describe the conditions under which remedial management actions wiII be taken, and leaves too much discretion to one party to decide when such actions are necessary. The WMP describes several conditional actions, but does not adequately describe the conditions under which the management action will be implemented. For example the WMP states that 'oafter the developer has determined that noise-deterrents, smell-deterrents and visual deterrents have proven ineffective, then the developer will install a fence...to discourage [elk] presence." This leads to the question, how do we define "ineffective"? Our tribes regard this as a risky and inadequate provision because it provides no assurances that the necessary management action will ever be taken. It leaves the discretion of whether to implement a management action to a single stakeholder (Statesman), without oversight from affected parties like the County, State or Tribes. Better accountability must be built into such conditional provisions. 6. The plan does not provide assurances to the tribes that lethal control will not be used when conflicts with nuisance wildlife occur. It appears that the author of the WMP did not fully understand the reason why Ordinance 01- 0128-08 requires a focus on non-lethal management strategies. The WMP uses the term "non- lethal" only twice, but both times it is in the context of merely quoting the ordinance. No further discussion is provided, nor does the WMP discuss what recourse might be taken if none of the strategies described therein fail to resolve wildlife conflicts. In our original 2007 comments on the FEIS, the PNPTC expressed the tribes' concerns about "...the potential conflicts that will occur if and when foraging elk damage high-value landscaping. Our fear is that this will lead to increased demands to control elk damage by lethal removal of animals from the population...We do not support, and cannot accept, lethal control to reduce property damage caused by elk." Thus the genesis of the non-lethal provision in the ordinance was the S'Klallam Tribes' insistence that animals must not be killed to protect fairways, greens, and other plantings. As currently written, the WMP does not follow through and describe what will happen if hazing, fencing, etc. don't work. Consequently, the WMP does not provide adequate assurances that animals won't be destroyed. The WMP must contain an expressed, definitive, enforceable commitment that wild animals will not be killed when conflicts arise, except in cases where the animal poses a threat to human health or safety. PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 9 of 12 General Comments: Overall the Wildlife Management Plan is merely a superficial attempt to meet the minimal requirements of Ordinance 0l-0128-08. It does not represent a good faith effort to credibly address or resolve the wildlife management challenges and the concerns of the S'Klallam Tribes. Its 18 pages contain mostly background information and site descriptions that appear to be cut and pasted from the 2012Habitat Management Plan. There is little new information. The elk management strategies (of greatest importance to the S'Klallam Tribes) are poorly conceived, inadequately described, and will prove ineffective. Ultimately, there are only two elk management strategies proposed: aversive conditioning(hazingwith scare tactics) and exclusion devices (fencing). Use of the latter is conditional upon the developer unilaterally deciding whether the former has proven ineffective. Our experience with elk management leads us to conclude that both of the proposed elk management strategies will fail. Hazing is time consuming and it is effective only until the animals become habituated to the aversive conditioning techniques. Hazing was attempted two decades ago in an effort to drive the Sequim elk herd away from high-density housing areas and from high-value crop fields. Beginning in 1995 the Washington Department of Fish and Wildlife (WDFW) employed four part-time staff and a dozen volunteers to haze elk, at a cost of $20,000 per year ($32,103 in20l7 dollars). That sum does not include the cost of the time WDFW biologists and administrators spent organizing and managing personnel-the full cost was much higher. WDFW terminated the project in 1997 due to the high cost and the ineffectiveness of the effort. In response to public pressure it started hazing again in the year 2000. By 2004 efforts to control the Sequim elk herd-which comprised only one percent of the regional elk population- were consuming33Yo of WDFW's regional elk management budget (Jack Smith, WDFW Region 6 Wildlife Division Manager, personal communication2}}T; Cullinan 2015). WDFW eventually concluded that the hazingprogram was futile, terminated it, and drastically increased the number of hunting permits to implement lethal control. Fencing has proven to be a reliable means of excluding elk from occupying areas where they are not desired. It is the only credible preventive measure available to minimize the risk that elk will cross U.S. 101 and take up residence on the MPR site. The hazing strategies described in the WMP provide little or no assurance that elk will not occupy the site for long periods and damage landscaping. The need to build a fence is inevitable. We assert, based on decades of experience with elk behavior that fencing will be most effective if it is installed before elk have a chance to enter the site and feed on the MPR landscape. If the fence is built after the elk have become habituated to the nutrient-rich foraging areas on the MPR site, there is a greater risk that they will continue to cross U.S. 101 to seek ways to penetrate or circumvent the fence, thus exposing both the elk and motorists to a higher risk of collisions. PNPTC has offered on multiple occasions to assist Statesman in evaluating and designing specifications for a fence that will meet the needs of both the developer and the elk. That offer remains in effect. In conclusion, we reiterate our concerns about the inadequacy of the Wildlife Management Plan. Elk are an important food and ceremonial resource for the S'Klallam Tribes. The Duckabush elk herd is one of the two most important herds to the Port Gamble S'Klallam Tribe. It is a vital economic and cultural resource. For three decades we have managed it with utmost care. This PNPTC comments on Pleasant Harbor Wildlife Management Plan Page l0 of 12 Respectfully Timothy P. Cullinan Wildlife Program Manager cc: Randy Harder, PNPTC Scott Chitwood, Jamestown S'Klallam Tribe Paul McCollum, Port Gamble S'Klallam Tribe Hansi Hals, Jamestown S'Klallam Tribe Roma Call, Port Gamble S'Klallam Tribe Bryan Murphie, Washington Department of Fish & Wildlife Bethany Ackerman, Skokomish Tribe Literature Cited: Cook, J.G., L.L. Irwin, L.D. Bryant, R.A. Riggs, and J.W. Thomas. 1998. Relations of forest cover and condition of elk: a test of the thermal cover hypothesis in summer and winter. Wildlife Monographs 141: l-61. Cook, J.G., R.C. Cook, R.W. Davis, and L.L. Irwin. 2016. Nutritional ecology of elk during summer and autumn in the Pacific Northwest. Wildlife Monographs 195: l-81. Cullinan, T.2015. Adapting elk harvest in response to land use change-a 4}-year case study. p. 30 ir Jones, P., E. Merrill, R. Corrigan, and M. Neufeld. 2015. Proceedings of the eleventh biennial western states and provinces elk and deer workshop. Alberta Environment & Sustainable Resource Development, Canmore, Alberta. Hobbs, N.T. and D.M. Swift. 1985. Estimates of habitat carrying capacity incorporating explicit nutritional constraints. J. Wildlife Manageme nt 49 :8 I 4 -822. PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 11 of12 year, in response to concems about population declines our tribes closed hunting of cow elk in the range of the Duckabush herd, and curtailed the hunting of bull elk. The S'Klallam Tribes cannot afford losses brought about by poor planning and a lack of commitment to wildlife stewardship by the MPR developers. Every elk removed from the population by vehicle collisions is an elk that cannot serve the ceremonial and subsistence needs of tribal members. Every hour that the elk spend in high human density areas inaccessible to tribal hunters is an hour that the tribe is denied its treaty right to hunt. The WMP was developed without consultation with the S'Klallam Tribes. As a result, it was developed without state-of-the-art scientific information specific to local elk herds. Consequently, it contains inadequate and ineffective recommendations that pose substantial risks to wildlife and to S'Klallam treaty rights. The S'Klallam Tribes, Jefferson County, and the people of Washington deserve better. Hutchins, N.R. 2006. Diet, nutrition, and reproductive success of Roosevelt elk in managed forests of the Olympic Peninsula, Washington. M.S. Thesis, Humbolt State University, Arcata, California. 104 pp. Schroer, G.L. 1986. Seasonal movements and distribution of migratory Roosevelt elk in the Olympic Mountains, Washington. M.S. Thesis, Oregon State University, Corvallis, Oregon. 85 pp. Washington Department of Fish and Wildlife ,2004. Olympic Elk Herd Plan. Wildlife Program, Washington Department of Fish and Wildlife, Olympia. 52pp. PNPTC comments on Pleasant Harbor Wildlife Management Plan Page 12 of 12