www.nativeplantsociety.org    Molly O'Reilly, President, 206 N. 4^th Ave. PMB 162, Sandpoint , ID 83864

December 20, 2004

Debbie Butler
ATTN:  Hills Resort and Priest Lake Marina EA
Priest Lake Ranger Station IPNF
32203 Highway 57
Priest River , ID 83856

Dear Ms Butler,

Thank you for the time that you, Chad BaconRind, and Chris Savage spent with us recently discussing our concerns with the EAs for the Hills Resort and Priest Lake Marina term issue permits.  We would like to take this opportunity to recap some of the key areas we hope you will be able to address while considering this permit.

Protection of native plant habitat would be more adequately assured if the permit requires an SPCC (Spill Prevention Containment and Counter Measures) plan for handling fuel storage and transfer.  Such a plan is already a Forest Service Best Management Practice.

We believe that all parties involved understand the potential for significant negative impacts from storm water runoff and we applaud the Forest Service for focusing attention on the need for an effective Storm Water Runoff plan.  However, the threshold of protection currently being required of the plan, a “2 year, 24 hour” event seems inadequate to us, given that this event is likely to occur 10 to 15 times during the term of the permit, and will be exceeded often.

We encourage the Forest Service to scrutinize very closely the Storm Water Management plan developed by the permittee and hold it to the very highest standard, so potential harm is stopped before it occurs and requires costly and/or potentially ineffective clean up.  We also encourage the Forest Service to closely monitor the plan after its implementation to ensure that it continues to adequately address any deficiencies.

We cannot stress enough the threats from noxious weeds, especially Eurasian Milfoil.  Requiring, in the permit, an educational effort is a good start; but we do not believe that education alone will adequately address this threat.  Simply put – there is no effective control or eradication strategy that will be successful against Eurasian Milfoil with ongoing reintroduction. Even if contained, it is reintroduced by visiting boats.  The environmental consequences are severe and the economic costs of trying to control and eradicate Eurasian Milfoil are staggering. Its ongoing introduction must be prevented.  This permit renewal provides the opportunity to address this threat in more meaningful manner, such as requiring inspection of boats and other vessels along with mandating removal efforts whether by hand or mechanical means.

A Comprehensive Vegetation Management Plan (CVMP) would address a number of these concerns in an integrated and cohesive manner.  Such a plan could also address activities already occurring (and touched upon already in a piecemeal fashion by different parts of the permit) such as the resort’s master plan and ongoing landscaping efforts.  Specifically a CVMP, among other things, would look at:  handling diseased trees, managing the remaining healthy trees, planning for stand replacement and vegetative succession, wildfire protection, treating noxious weeds currently occurring and addressing the threats from other noxious weeds, habitat restoration efforts, landscaping efforts resulting from construction, the storm management plan’s impact on vegetation and potential landscape changes (i.e. replanting lawns into native grasses.)  These are only some of the aspects that such a plan could address.

We strongly prefer the alternative for a 20-year permit to the longer 30-year term.  Although we understand that the permittee would be obligated by any new “laws, rules, or regulations” the complexities and subtleties of new requirements may mean action is deferred until the permit is renewed.   It is human nature to wait until a deadline, such as a permit renewal, to address potential or real problems.  For example, the Clean Water Act was passed, and has been in effect, since 1972 and its protections have theoretically been binding on the permit holder since that time.  The problems with storm water runoff on these sites have also been recognized for many years. However it is only now, as the permit is being renewed, that a Storm Water Management Plan is being required to address provisions of this act and correct a problem long acknowledged. 

This example demonstrates the tendency to defer new requirements until the permit is due for renewal.   Therefore we feel the shorter 20-term provides for more effective oversight and review, and ask that this permit length be the selected alternative.

Respectfully,

Molly O’Reilly

CC:    Chris Savage
          Chad BaconRind
            Kathy Murphy
           Ranotta McNair