January 17, 2011

Nancy Ryke District Ranger Mt Adams Ranger District 2455 Hwy 141 Trout Lake, WA 98650-9046

Dear Ms Ryke,

We are writing to propose more permanent protection of South Prairie and South Prairie Bog in the Ice Caves Livestock Grazing Allotment, Mt. Adams Ranger District, in the Gifford Pinchot National Forest, and of the Big Lava Beds, lying just south of South Prairie. Members of the Native Society have a long-standing interest in the South Prairie and South Prairie Bog within the allotment because of their great botanical interest and the unusual hydrology of South Prairie. Professor Arthur Kruckeberg, a founder of our Society, led a "Botany Washington" field trip there in 2001, attended by several Society members, and members have visited the area on numerous other occasions. Members of our Conservation Committee took part in the discussions that environmental groups had with Mt. Adams Ranger District officials in 2007 when the latest Environmental Assessment was being prepared.

In August of this year, Dr. David Giblin, Manager of the Herbarium of the Burke Museum at the University of Washington led a field trip to these areas after obtaining permission from the Mt Adams Ranger District to collect there. We found sarmentosum, pale blue-eyed grass, and Utricularia minor, small bladderwort, both of which are considered to be rare species in Washington. During our brief field work at Peterson Prairie, South Prairie, and South Prairie bog we found about 20 plant species that had not previously been recorded for these areas. Several of these were uncommon or unusual. The hydrologic conditions and overall plant diversity found there suggest that other rare species may occur in these habitats. Big Lava Beds blocks drainage to the south of South Prairie and South Prairie Bog, and is probably the reason for formation of the bog and for the seasonal flooding of South Prairie during snow melt. Its flora is interesting, too, and in combination, these three features would make an excellent area for scientific study.

South Prairie and South Prairie Bog are currently designated as a Botanical Special Interest Area, and Big Lava Beds is designated as a Geologic Special Interest Area. South Prairie Bog is of interest to the Natural Heritage Program. Joseph Arnett writes: “The bog is not yet in our database, which only shows two low elevation sphagnum bogs in the whole southwest part of the state, excluding the coastal areas. . . . the bog at South Prairie, based on the sighting reports, sounds of much higher quality [than those mentioned above]." For these reasons we feel that strong permanent protection in a Research Natural Area (RNA) is warranted for these unusual native plant habitats. Andrea Raven (2006) wrote that South Prairie, together with Peterson Prairie and Cave Creek, contain the only populations of Sisyrinchium sarmentosum that are large enough to be self-sustaining in Washington State. While all 3 sites deserve protection, Peterson Prairie, a very small meadow, is 4 miles from South Prairie, and Cave Creek, equally far from the other two sites, is a transitional meadow area - now heavily overgrown with non-natives - which was created by logging large cedar trees, and it will grow back to forest if untended. It would be difficult to manage an RNA with such disjunct pieces. However, South Prairie, South Prairie Bog and Big Lava Beds are contiguous, and represent a combined area of great interest both botanically and geologically. In a map in the 2007 Environmental Assessment for the Ice Caves Allotment (fig 2.2, Location of proposed drift fence), the location of a proposed drift fence is shown that would exclude cattle from South Prairie, South Prairie Bog, and part of the Lost Creek Drainage. We suggest that an area south of that line, and including a significant portion of the Big Lava Beds as far south and west as the Crater, would make an extremely valuable unit for botanical and geologic study.

We write now to seek your interest and cooperation in securing the permanent protection of these areas. We believe an important step would be to designate a Research Natural Area. Recognizing the financial constraints of the times and if the USFS has insufficient funding for NEPA at this time, at the very least we recommend stopping the grazing and maintaining the Special Interest status until an RNA could be established in the future. We also recommend taking the necessary steps to cancel the grazing permit, altogether.

Sincerely yours,

Dean P. Longrie President Washington Native Plant Society pc: Claire Lavendel, Forest Supervisor Mary Wagner, Regional Forester Gifford Pinchot National Forest US Forest Service - Pacific Northwest Region 10600 NE 51st Circle P.O. Box 3623, Portland, OR 97208-3623 Vancouver, WA 98682

Bov Eav, Station Director Todd Wilson, PNW RNA Coordinator Pacific Northwest Research Station US Forest Service – Pacific Northwest Region P.O. Box 3890 - Portland, OR 97208-3890 3200 SW Jefferson, Corvallis, OR 97331