Washington Native Plant Society Appreciate, Conserve, and Study Our Native Flora 6310 NE 74th Street, Suite 215E, Seattle, WA 98115 (206) 527-3210;
[email protected] May 26, 2017 Re: Iceberg Point Fieldschool 1790/6240 (ORW040) P Marcia deChadenedes Monument Manager San Juan Islands National Monument P.O. Box 3 37 Washburn Place Lopez, WA 98261 Sent via email:
[email protected] Dear Ms. deChadenedes, Thank you for inviting the Washington Native Plant Society (WNPS) to comment on the draft Categorical Exclusion (CE) for the Iceberg Point Fieldschool Project. Washington Native Plant Society (WNPS) members are interested in this issue because it aligns with our mission to promote the appreciation and conservation of the native plants of Washington through study, education, and advocacy. We appreciate the opportunity to share our concerns regarding this action. Having reviewed the CE and related documents, WNPS believes that the size, scope, and disturbance of the proposed Fieldschool activities do not meet the requirements necessary for a Categorical Exclusion as specified within Title 43 CFR 46.210(e). This proposed action should be required to conduct a NEPA- compliant environmental review with applicable notifications and comment period for all interested stakeholders. Implementing this proposal may degrade or destroy the environmental, cultural, and recreational value of Iceberg Point. Washington State Department of Natural Resources specifically recommends “avoiding, or minimizing to the extent possible, activities that expose bare soil or facilitate spread of weeds” when managing balds because of their high biodiversity conservation significance (Chappell, 2006). The cultural value of Iceberg Point is primarily the landscape walked and appreciated by our Native American, European and Asian forbears rather than any remaining artifacts, which are protected as long as they stay buried within the soil.