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. The project would also likely degrade the recreational and educational value of the site; many of WNPS’s 1,800 members use public lands, including those of the Monument, by observing and studying plant life and educating others about Washington’s native plants and ecosystems. Further degradation of this ecosystem would be detrimental to our members and Washington’s citizens and visitors.

WNPS appreciates BLM calling for comments on the CE and we have included an item-by-item response as an addendum to this letter. We are concerned, however, that in its call for comments, BLM understates the environmental and cultural significance of this site. For example, BLM has evidently not requested recommendations or guidance from the Washington DNR Natural Heritage Program as a first step in assessing potential effects of the proposed action. We are also concerned that Central Washington University is currently advertising the fieldschool before obtaining the required approvals. This suggests a naive understanding about the complexity of the environmental and cultural impacts to the existing landscape and a disregard for the concerns of community members and agencies.

San Juan Island National Monument was established to protect the unique cultural landscape of Iceberg Point. This landscape includes rare plants and a threatened ecosystem of high interest to the mission and membership of WNPS. WNPS advocates for protection of native plants on Washington’s national, state, and local public lands. Botanizing is a scientific and recreational activity that has a long history in Washington. Rooted in the oral traditions of our state’s First Peoples, documented in the journal of botanist and explorer David Douglas, and continuing today on the web with the meticulous records of the Burke Herbarium and the WNPS plant lists compiled by citizen botanists, botanizing is a discipline worthy of recognition, promotion, and protection. Observations of citizen-botanists have contributed to the human knowledge base of all cultures for thousands of years. Protecting vulnerable habitats and rare plant species ensures that current and future generations will experience and benefit from functional and biologically diverse natural environments in Washington.

Having reviewed the draft CE and supplemental materials, WNPS believes this project warrants a formal NEPA environmental review— including expanded outreach and community involvement— to resolve whether the environmental, cultural, and recreational benefits of the project outweigh the possibly significant adverse environmental effects that would result from implementation of the proposed action.

Sincerely,

Rebecca Chaney, Conservation Chair Washington Native Plant Society

Clay Antieau, President Washington Native Plant Society

Attached: Appendix – Categorical Exclusion Rocchio, Joe – Personal Communication Plant Lists

Appendix – Categorical Exclusion Prepared by the WNPS Conservation Committee

WNPS has determined the Iceberg Point Fieldschool on Lopez Island in the San Juan National Monument does not meet the Extraordinary Circumstances requirements of a Categorical Exclusion within Title 43 CFR 46.210(e).

Review

Note: The CE has a typo in the Location of Proposed Action. The Township should be T34N, not 24. It is correctly identified on the map.

Numbering below is consistent with the draft CE rather than Title 43 CFR 46.210(e).

C. Compliance with NEPA. b: The proposed action would not have significant impact on such natural resources and unique geographic characteristics as…national monuments. This inventory will have a significant impact on the San Juan Islands National Monument, a landscape of environmental, cultural, and recreational significance.

WNPS has experience conducting field research and such work inevitably, even with great care, impacts existing vegetation. The San Juan Islands National Monument Analysis of the Management Situation (Analysis) notes that the monument shrublands and grass lands “tend to be very sensitive to disturbance and trampling.” A project that tramples or removes and then replaces state listed vegetation will impact not only the plants that are evident but will release seeds and propagules of invasive plant species. This vegetation community is vulnerable and sensitive species intermingled in the existing vegetation cannot be avoided (Rocchio, 2017).

Removal of vegetation will break up the soil crust that is a barrier to invasion by non-native plants. Removal and sifting of subsurface soil will destroy the existing soil structure, including soil profiles, necessary for the survival of the native plant community. Watering-in plants after removal increases survivorship and typically would be recommended, but here it may give the advantage to non-native invasive species and further destroy soil structure. Raking the vegetation “to return the grasses and vegetation to natural appearance” is an additional disruptive activity may further break the surface of the soil and result in increased viability of invasive seeds and propagules. It would be impossible to conduct the project without significant detrimental impacts on currently protected natural resources.

C. Compliance with NEPA. c: The proposed action would not have highly controversial environmental effects. Disturbance and degradation of a protected and functional native plant ecosystem under these circumstances is not acceptable to WNPS and is therefore highly controversial whether or not the inventory techniques are a common methodology. Proclamation 8947 “identifies the Monument’s diverse habitats, and the varied wildlife species that depend on them, as values for which the area was designated.” It also notes that grasslands throughout the region are estimated at 9% of pre-Euro-American settlement levels and the majority of this ecosystem within the monument is found at the south end of Lopez Island – Iceberg Point and nearby property. This habitat type was historically maintained by Native Americans who used fire to support camas (Camassia spp.), “an important food source that figured prominently in cultural practices of the native inhabitants” (Analysis). In this case, the cultural value of the site is largely the vegetation itself so as presented the project is not consistent with the purpose of the designation.

C. Compliance with NEPA. d: The proposed action would not have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks. The amount of risk is well beyond the area of active soil disturbance, which at 30 cm per shovel probe at 30 meters apart and walking by 25 students, is already significant. The possibility of shovel probes at 10 meters obviously increases the impact. For a more meaningful measure all the area of the study should be included in the number of acres impacted – 100 acres according to the Categorical Exclusion. Invasive plants, once introduced, are quick to multiply and crowd out established, less aggressive vegetation particularly in areas where soil structure has been compromised.

The proposed action falls within Title (not category) 43 CFR 46.210(e). It would be helpful to include a link to the regulation.

C. Compliance with NEPA. e: The proposed action would not establish a precedent for future actions or represent a decision in principle about future actions with potentially significant environmental effects. Allowing research that degrades or destroys culturally significant native plant habitat on National Monuments and ACEC lands is a precedent with potentially significant environmental effects. The draft Categorical Exclusion states that “results of the investigation would provide additional cultural resources information important for future management of the lands.” WNPS notes that cultural resources that might exist underneath the protective and protected existing vegetation are best protected by limiting anthropogenic impacts to the current ecosystem.

C. Compliance with NEPA. f: - The proposed action would not have a direct relationship to other actions with individually insignificant but cumulatively significant environmental effects. The project has the potential to cause cumulatively significant environmental effects related to the inevitable introduction of non-native species, the destruction of the soil structure, and the added interest in exploring for cultural artifacts that the project is likely to encourage. BLM does not have the staffing to ensure that future unauthorized excavation occurs.

C. Compliance with NEPA. g: The proposed action would not have significant impacts on properties listed, or eligible for listing, on the National Register of Historic Places as determined by the bureau. WNPS appreciates that several stakeholders were consulted regarding impact on properties listed. We note that there does not seem to have been a communication to these agencies that the vegetation itself is of cultural significance. Additionally, we note that the Lummi Nation Tribal Historic Preservation Office and Tulalip Tribes indicate reservations regarding disturbance of the site.

C. Compliance with NEPA. h - The proposed action would not have significant impacts on species listed, or proposed to be listed, on the List of Endangered or Threatened Species, or have significant impacts on designated critical habitat for these species. This ecosystem includes a G2 S1 plant association considered to be globally imperiled and critically imperiled in Washington State. It may include an imperiled grass land association (Rocchio, 2017 – see Appendix). Plants growing here are designated by the state as being rare and of concern. The Area of Critical Environmental Concern (ACEC) designation for Iceberg Point qualifies the site as critical habitat. The ACEC specifies managing visitor use by closing areas to any use that tends to degrade the natural values of the site. Plants growing here are designated by the state as being rare and of concern (WNPS Background, 2017 – see Appendix).

C. Compliance with NEPA. l - The proposed action would not contribute to the introduction, continued existence, or spread of noxious weeds or non-native invasive species known to occur in the area… One of the primary threats to the monument’s grassland is invasive species competition with native plants (Analysis). The draft Categorical Exclusion notes “staging areas would be located in a weed-free area” and “activities would avoid or minimize all types of travel through weed-infested areas, or restrict travel to periods when the spread of seeds or propagules is least likely” both of which are highly suspect. Even if staging areas are located in paved parking areas weed seeds will be present; the activity is scheduled for July – a month that is prime for seeds. WNPS is not convinced that the project leaders have the expertise to identify or recognize the weeds (or for that matter the native plants) of concern.

As stated above, soil sifting is highly disruptive to soil structure, which is critical to vegetation, and will result in mingling of soil profiles. There is no way of rebuilding the existing soil structure. It is common knowledge that archeology, like soil science, is an activity that destroys the study area in its current condition. Re-establishment by “either natural recovery or artificial techniques” is vague and indicates a lack of understanding of the challenges of prairie restoration. What type of “artificial techniques” would be used?

Coastal plants often have extensive root systems that help anchor them in damp, windy coastal environments. For example, sea thrift (Armeria maritima), a small, herbaceous, perennial plant that grows on Lopez Island (WNPS 2008), can have woody roots up to three feet long. Roots cannot be cut without negatively impacting plants; some plants will inevitably die and some species will be affected more than others. To limit damage to Iceberg Point, seed collected from the site, must be available to appropriately restore any areas lacking vegetation after the program. Knowledge of how to store and start seeds is required for restoration. At a minimum this project needs to employ a botanist familiar with the location’s ecosystem. Additionally, WNPS encourages the students and professor to consider training in restoration ecology before deciding whether the costs of this proposed project are worth the benefits.

Appendix - Rocchio

From: Rocchio, Joe (DNR) [mailto:[email protected]] Sent: Friday, May 26, 2017 2:49 PM To: Becky Chaney Cc: ARNETT, JOSEPH (DNR) Subject: RE: WNPS and Iceberg Point

Hi Becky,

Referencing the attached:

The blue polygon immediately to the NE of Iceberg Point (NOT Iceberg Island) is the location of Pseudotsuga menziesii – (Abies grandis, Thuja plicata) / Mahonia nervosa – Gaultheria shallon Forest. It is a G2 S1 plant association, meaning it is considered to be Globally imperiled and critically imperiled in Washington state. In other words, very rare and threatened with extinction. This particular example is noted to be in good/fair condition, however the last observation was 1987.

We don’t have any element occurrence records for native bald/bluff grasslands at Iceberg Point but my recollection (and based on Steve Rust’s 1992 MS Thesis “Plant Ecology of A Coastal Headland Iceberg Point, Lopez Island, Washington”) is that the Festuca rubra – (Camassia leichtlinii, Grindelia stricta var. stricta) Grassland is present within the grassland matrix at Iceberg Point. I’m not certain why we don’t have an EO because this is a G1S1 plant association and we generally consider all examples of very rare types to be element occurrence “quality”. It could be that the occurrence is extremely small or that previous NHP ecologist did not feel the type was present.

Trampling from human activity and physical disturbances to the soil can have negative impacts to the native grassland community, especially when nonnative species are nearby and can quickly colonize disturbed soils. Such activities can also have negative effects on the understory of the forest but these would not have as severe impacts as they would in grasslands.

Joe Rocchio Senior Vegetation Ecologist Washington Dept. of Natural Resources, Natural Heritage Program Olympia, WA 360-902-1041 http://www.dnr.wa.gov/natural-heritage-program

Yes, you can include my comments. Please note that my comment about the G1S1 grassland community is speculative and that we don’t’ have any conclusive evidence of its presence in that location.

Joe Rocchio Senior Vegetation Ecologist Washington Dept. of Natural Resources, Natural Heritage Program Olympia, WA 360-902-1041 http://www.dnr.wa.gov/natural-heritage-program

Appendix – Background and Plant List

WNPS Background Research: Iceberg Point is located within the San Juan Islands National Monument and is administered by the Bureau of Land Management (BLM). Unlike much of BLM land, which is managed for potential resource extraction, this is a designated National Monument with a mandate to “maintain their historical and cultural significance and enhance their unique and varied natural and scientific resources, for the benefit of all Americans.” The designation recognizes the environmental, cultural, and recreational significance of the 75 sites within the monument.

Iceberg Point is on record since 1990 as an Area of Critical Environmental Concern (ACEC) according to the BLM Resource Management Plan and Environmental Impact Statement Analysis of the Management Situation (Analysis). The Analysis notes that a volunteer monitoring program “has consistently provided the BLM with information about the condition of resources and visitation within the lands covered by the ACEC.” The ACEC specifies managing visitor use by closing areas to any use that tends to degrade the natural values of the site.

The Analysis recognizes plant communities at Iceberg Point include Dry Forest (including relatively undisturbed stands of Douglas-fir-white-fir forest), Vancouverian Lowland Grassland and Shrubland made up of the North Pacific Herbaceous Bald and Bluff plant community. The Analysis also notes that the ecotone between the grasslands and Douglas-fir forest at Iceberg Point “has been described as one of the finest examples of this type of habitat in the region”.

Iceberg Point’s prairie landscape provides habitat for rare plants, trees, and grasses as reported on the BLM website (additional plants and habitat are also of concern): Slender Crazyweed (Oxytropis campestris var. gracile) State Listed Columbian white Topped Aster (Seriocarpus rigidus) State Listed, Federal Species of Concern Brittle Prickly Pear (Opuntia fragilis) California Buttercup (Ranunculus californicus) State Listed Showy Jacob’s Ladder (Polemonium pulcherrimum) Locally rare Diverse and rare lichens (Rhoades 2009) 500-600 year old trees Roemer’s Fescue (Festuca idahoensis var. roemeri) Red Fescue (Festuca rubra) California Oatgrass (Danthonia californica).

Nearby state registered archaeological sites indicate 3,000 years of occupation and the monument includes site includes pre-contact Coast Salish camas cultivation sites. It is reasonable to assert that Iceberg Point’s cultural significance is the ecosystem of vegetation and wildlife that has existed through thousands of years of human experience.

Vascular Plant List Lopez Island

Lopez Island, San Juan County, WA. List covers plants found on Lopez Island, one of the larger San Juan Islands. List by Mildred Arnot and Dorothy Naas, April 1995, with a few additions by Mark Turner, June 2008. 168 spp.

These lists represent the work of different WNPS members over the years. Their accuracy has not been verified by the Washington Native Plant Society. We offer these lists to individuals as a tool to enhance the enjoyment and study of native plants.

* - Introduced Scientific Name Common Name Family Name Abies grandis Grand fir Pinaceae Acer glabrum Douglas maple Aceraceae Acer macrophyllum Big-leaf maple Aceraceae Achillea millifolium Yarrow Asteraceae Adenocaulon bicolor Pathfinder Asteraceae Aira caryophyllea* Silver hairgrass Poaceae Aira praecox* Early hairgrass Poaceae Alchemilla occidentalis Western lady's-mantle Rosaceae Allium acuminatum Taper-tip onion Liliaceae Allium cernuum Nodding onion Liliaceae Alnus rubra Red alder Betulaceae Ambrosia chamissonis Silver bursage Asteraceae Amelanchier alnifolia Serviceberry Rosaceae Anaphalis margaritacea Pearly everlasting Asteraceae Arbutus menziesii Pacific madrone Ericaceae Arctium minus* Common burdock Asteraceae Armeria maritima Sea thrift Plumbaginaceae Artemisia suksdorfii Suksdorf's sagewort Asteraceae Athyrium filix-femina Lady fern Polypodiaceae Atriplex patula Spear saltbush Chenopodiaceae Bellis perennis* English daisy Asteraceae Berberis aquifolium Tall Oregongrape Berberidaceae Berberis nervosa Cascade Oregongrape Berberidaceae Brodiaea coronaria Harvest brodiaea Liliaceae Brodiaea hyacinthina Hyacinth brodiaea Liliaceae Bromus tectorum* Cheat grass Poaceae Calypso bulbosa Fairy slipper Orchidaceae Camassia leichtlinii Great camas Liliaceae Campanula rotundifolia Common harebell Campanulaceae Cardamine oligosperma Little Western bittercress Brassicaceae Carex brevicaulis Berm sedge Cyperaceae Carex obnupta Slough sedge Cyperaceae Carex pensylvanica Pennsylvania sedge Cyperaceae Carex sp. Sedge Cyperaceae Castilleja hispida Harsh paintbrush Scrophulariaceae Cerastium arvense Field chickweed Caryophyllaceae Cerastium viscosum* Sticky chickweed Caryophyllaceae Cirsium arvense* Canada thistle Asteraceae

WNPS Native Plant List Lopez Island, San Juan County, 12-08 Page 1 of 4 Cirsium vulgare* Bull thistle Asteraceae Collinsia parviflora Small-flowered blue-eyed Mary Scrophulariaceae Conioselinum pacificum Pacific hemlock-parsley Apiaceae Corallorrhiza maculata Spotted coral-root Orchidaceae Corallorrhiza sp. Coral-root Orchidaceae Crataegus douglasii Black hawthorn Rosaceae Daucus pusillus American carrot Apiaceae Delphinium menziesii Mountain larkspur Ranunculaceae Distichlis spicata Seashore salt grass Poaceae Dodecatheon pulchellum Few-flowered shooting star Primulaceae Equisetum arvense Common horsetail Equisetaceae Eriophyllum lanatum Oregon sunshine Asteraceae Erodium cicutarium* Filaree Geraniaceae Festuca bromoides* Barren fescue Poaceae Fragaria vesca Wild strawberry Rosaceae Fragaria virginiana Woods strawberry Rosaceae Fritillaria lanceolata Chocolate lily Liliaceae Galium aparine Cleavers Rubiaceae Gaultheria shallon Salal Ericaceae Geranium molle* Dovefoot geranium Geraniaceae Goodyera oblongifolia Rattlesnake-plantain Orchidaceae Grindelia integrifolia Coastal gumweed Asteraceae Habenaria sp. Bog-orchid Orchidaceae Heuchera micrantha Small-flowered alumroot Saxifragaceae Hieracium albiflorum White-flowered hawkweed Asteraceae Holodiscus discolor Ocean spray Rosaceae Hypochaeris radicata* Hairy cat's-ear Asteraceae Juncus effusus Soft rush Juncaceae Lactuca muralis* Wall lettuce Asteraceae Lathyrus nevadensis Nuttall's peavine Fabaceae Lepidium virginicum* Tall pepperweed Brassicaceae Linnaea borealis Twinflower Caprifoliaceae Listera cordata Heart-leaved twayblade Orchidaceae Lithophragma parviflorum Small-flowered prairie-star Saxifragaceae Lomatium nudicaule Pestle parsnip Apiaceae Lomatium utriculatum Spring gold Apiaceae Lonicera ciliosa Orange honeysuckle Caprifoliaceae Lonicera hispidula California honeysuckle Caprifoliaceae Lonicera involucrata Black twinberry Caprifoliaceae Lotus micranthus Miniature lotus Fabaceae Lupinus bicolor Two-color lupine Fabaceae Luzula campestris Field woodrush Juncaceae Lysichiton americanus Skunk cabbage Araceae Madia madioides Woodland tarweed Asteraceae Maianthemum dilatatum False lily-of-the-valley Liliaceae Mimulus alsinoides Chickweed monkey-flower Scrophulariaceae Montia linearis Narrow-leaf montia Portulacaceae Montia parvifolia Streambank spring beauty Portulacaceae Montia perfoliata Miner's lettuce Portulacaceae Montia sibirica Candyflower Portulacaceae

WNPS Native Plant List Lopez Island, San Juan County, 12-08 Page 2 of 4 Myosotis discolor* Yellow & blue forget-me-not Boraginaceae Nemophila parviflora Small-flowered nemophila Hydrophyllaceae Oenanthe sarmentosa Water parsley Apiaceae Opuntia fragilis Brittle cactus Cactaceae Orobanche uniflora Naked broom-rape Orobanchaceae Orthocarpus pusillus Dwarf owl-clover Scrophulariaceae Osmorhiza chilensis Mountain sweet-cicely Apiaceae Oxytropis campestris Field locoweed Fabaceae Picea sitchensis Sitka spruce Pinaceae Pinus contorta Lodgepole pine Pinaceae Plantago lanceolata* English plantain Plantaginaceae Plantago major* Common plantain Plantaginaceae Plantago maritima Seaside plantain Plantaginaceae Plectritis congesta Sea blush Valerianaceae Poa pratensis* Kentucky bluegrass Poaceae Polemonium pulcherrimum Showy Jacob's ladder Polemoniaceae Polypodium glycyrrhiza Licorice fern Polypodiaceae Polystichum munitum Sword fern Polypodiaceae Potentilla pacifica Pacific silverweed Rosaceae Prunus avium* Sweet cherry Rosaceae Pseudotsuga menziesii Douglas fir Pinaceae Pteridium aquilinum Bracken Polypodiaceae Pyrus fusca Crabapple Rosaceae Ranunculus californicus California buttercup Ranunculaceae Ranunculus occidentalis Western buttercup Ranunculaceae Ranunculus repens* Creeping buttercup Ranunculaceae Ranunculus sceleratus Celery-leaved buttercup Ranunculaceae Ranunculus uncinatus Little buttercup Ranunculaceae Ribes divaricatum Coast black gooseberry Grossulariaceae Ribes lacustre Prickly currant Grossulariaceae Ribes sanguineum Red-flowered currant Grossulariaceae Rosa gymnocarpa Baldhip rose Rosaceae Rosa nutkana Nootka rose Rosaceae Rubus discolor* Himalayan blackberry Rosaceae Rubus leucodermis Blackcap Rosaceae Rubus parviflorus Thimbleberry Rosaceae Rubus spectabilus Salmonberry Rosaceae Rubus ursinus Wild blackberry Rosaceae Rumex acetosella* Sheep sorrel Polygonaceae Salix hookeriana Hooker's willow Salicaceae Salix scouleriana Scouler willow Salicaceae Salix sp. Willow Salicaceae Sambucus racemosa Red elderberry Caprifoliaceae Sanicula bipinnatifida Purple sanicle Apiaceae Sanicula crassicaulis Pacific sanicle Apiaceae Satureja douglasii Yerba buena Lamiaceae Saxifraga integrifolia Grassland saxifrage Saxifragaceae Sedum lanceolatum Lance-leaved stonecrop Crassulaceae Sedum spathulifolium Broadleaved stonecrop Crassulaceae Selaginella wallacei Wallace's selaginella Selaginellaceae

WNPS Native Plant List Lopez Island, San Juan County, 12-08 Page 3 of 4 Shepherdia canadensis Buffalo berry Elaeagnaceae Sherardia arvensis* Blue field-madder Rubiaceae Sisyrinchium angustifolium Blue-eyed grass Iridaceae Smilacina stellata Star-flowered Solomon's seal Liliaceae Sonchus sp. Sowthistle Asteraceae Spergularia macrotheca Beach sandspurry Caryophyllaceae Stachys cooleyae Cooley's hedge-nettle Lamiaceae Stellaria media* Common chickweed Caryophyllaceae Symphoricarpos albus Common snowberry Caprifoliaceae Taraxacum officinale* Dandelion Asteraceae Taxus brevifolia Western yew Taxaceae Tellima grandiflora Fringecup Saxifragaceae Thuja plicata Western red cedar Cupressaceae Trientalis latifolia Broadleaved starflower Primulaceae Trifolium dubium* Least hop clover Fabaceae Trifolium microcephalum Woolly clover Fabaceae Trifolium microdon Valparaiso clover Fabaceae Trifolium oliganthum Few-flowered clover Fabaceae Trifolium tridentatum Tomcat clover Fabaceae Tsuga heterophylla Western hemlock Pinaceae Urtica dioica Stinging nettle Urticaceae Veronica americana American brooklime Scrophulariaceae Veronica arvensis* Field veronica Scrophulariaceae Veronica serpyllifolia Thyme-leaf speedwell Scrophulariaceae Vicia americana American vetch Fabaceae Vicia gigantea Giant vetch Fabaceae Vicia hirsuta* Tiny vetch Fabaceae Viola howellii Howell's violet Violaceae Viola sempervirens Evergreen violet Violaceae Zigadenus venenosus Meadow death camas Liliaceae

WNPS Native Plant List Lopez Island, San Juan County, 12-08 Page 4 of 4