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